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Economic Principles and Usage Based Billing

Jeffrey Church
Professor, Department of Economics, University of Calgary
and
Director, Berkeley Research Group, LLC.

March 28, 2011

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Contents  

1.   Introduction .............................................................................................................................. 3  
2.   Technology and Costs of Broadband Networks ...................................................................... 5  
2.1.   Implications of the Technology of Broadband Networks for Pricing............................... 7  
2.1.1.   Efficient Pricing, Firm Viability, and NonLinear Pricing ......................................... 7  
2.1.2.   Congestion and Optimal Capacity ............................................................................. 9  
3.   Congestion Management, Fixed Cost Recovery, and UBB ................................................... 13  
3.1.1.   Fixed Cost Recovery ................................................................................................ 13  
3.1.2.   Congestion Management ......................................................................................... 13  
4.   Wholesale UBB ..................................................................................................................... 15  
4.1.   Mandated Wholesale Access of High Speed Internet ..................................................... 15  
4.2.   Regulatory Arbitrage and Its Effects .............................................................................. 16  
5.   Tables and Figures ................................................................................................................. 18  
6.   References .............................................................................................................................. 21  

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1. INTRODUCTION1
1. I am a Full Professor in the Department of Economics at the University of Calgary. I
received a Ph.D. in economics from the University of California, Berkeley in 1989,
and have been continuously employed in the Department of Economics at the
University of Calgary thereafter, teaching courses in industrial organization,
competition policy, regulatory economics, and microeconomics. My published
research includes articles on network economics, intellectual property rights, and
competition policy. I am the coauthor of a book on the regulation of natural gas
pipelines in Canada, a text in industrial organization, and a recent monograph on the
competitive implications of vertical and conglomerate mergers. A complete list of my
publications is included in my curriculum vitae, which is marked and attached hereto
as Exhibit 1. I have acted as an expert on a wide range of regulatory and competition
policy matters. From 1995 to 1996, I held the T.D. MacDonald Chair in Industrial
Economics at the Competition Bureau. As summarized in my curriculum vitae I have
been involved with the development of telecommunications policy in Canada since
1995, providing expert advice and participating in drafting many of the
telecommunications submissions of the Competition Bureau.
2. In this report I address the following issues relevant to the Commission’s proceeding
on billing practices for wholesale residential high-speed access services:
• the implications of the characteristics of the technology of high-speed networks
for pricing;
• the consistency of nonlinear pricing with efficient recovery of sunk network
costs;
• the use of pricing to manage congestion on networks and efficiently resolve the
trade off between the increased production costs and the reduction in
congestion costs from increasing capacity;
• the implications for investment and congestion costs if there is an asymmetric
application of usage based billing between wholesale and retail under
mandatory resale.
3. I reach the following conclusions:
• Broadband networks are characterized by economies of scale and scope and
require significant capital investment that is sunk. As a result short run
marginal cost is not a relevant measure for assessing the inefficient exercise of
market power. Service providers will typically have to mark their services up
above short run marginal cost in order to break even. The use of nonlinear

1
The following report was commissioned by Rogers Communications Partnership. However, the views expressed
are those of the authors and not of Rogers Communications Partnership, as is the responsibility for errors and
omissions.
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pricing—pricing that involves the potential for different prices for different
units of consumption—will more efficiently resolve the trade off between
recovery of sunk costs and efficient use of a network than uniform pricing (all
units priced the same).
• Broadband networks have elements that are often shared by users: total
demand for the services of the element is the aggregate of the demand of all
users. When these elements have a capacity constraint too much demand by all
users can result in congestion and congestion costs. Efficient pricing of
network usage requires that prices signal to users not just the avoidable private
costs of the network operator, but also the costs of congestion. The costs of
congestion are the harm imposed on other users of the network by the use of a
subscriber. If the costs of congestion are greater than the costs of additional
capacity, then it is efficient to expand capacity. If the costs of congestion are
less than the costs of additional capacity, eliminating congestion is not
efficient.
• Congestion pricing that reflects instantaneous network conditions or that
reflects predictable daily variations in demand is only efficient if the costs of
implementation are less than the efficiency gains. If this is not the case then it
may be possible to identify second best proxies that are correlated with
congestion.
• The form of usage based billing instituted by the major telecommunication and
cable networks is consistent with efficient recovery of sunk network costs and
congestion management. It appears not unreasonable that volumes might well
be a second best proxy for congestion.
• Retail usage based billing therefore appears to have benefits associated with
fixed cost recovery and congestion management. A regulatory policy that
prohibited usage based billing for mandatory wholesale high-speed internet
service could easily create profitable opportunities for arbitrage by independent
Internet service providers (ISPs). This regulatory arbitrage would target high
volume subscribers subject to overage charges on the incumbent carriers. If
symmetric usage based billing does not apply at wholesale the high volume
subscriber can avoid overage charges by switching to an independent ISP. The
independent ISP has mandated access at a flat rate for the identical network
service provided by the network owner. The effect of this is to deny the
network carrier revenues that may have been required to cover its sunk
network costs. This is a form of regulatory hold up which will negatively
impact the incentives of network carriers to maintain and upgrade their
networks. Moreover, since the users that switch will no longer have the same
incentives to reduce their use of the network, the effect will be to either push
up network costs if the carrier maintains network quality, increase aggregate
costs of congestion, or provide incentives for the network owners to substitute
more heavy handed measures to control congestion. This will be amplified if in
response to the effects of regulatory arbitrage network carriers no longer use
usage based billing at retail.

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4. The remainder of this report is structured as follows:


• Section 2 identifies relevant characteristics of a broadband network and
discusses the implications of the relevant characteristics for efficient
pricing;
• Section 3 explains why the form of usage based billing practiced in
Canada is consistent with recovery of sunk costs and congestion
management;
• Section 4 considers the incentives created by an asymmetric regulatory
treatment of retail and wholesale usage based billing and the consequences
of the regulatory arbitrage enabled.

2. TECHNOLOGY AND COSTS OF BROADBAND NETWORKS


5. Residential broadband internet service is typically provided either through the network
of the incumbent telephone company (ILEC) or the cable company (Cableco). Each
involves a device that insures the appropriate connection between customer premise
equipment and the compatible portion of the “last-mile” connection. In the case of a
cable network, the cable modem distinguishes between data and other services and the
last mile connection is coaxial cable. The coaxial cable connects the premise to a fibre
node. The fibre node is connected by fibre optic cable to the cable headend. At the
cable headend, the fibre feeds into the cable modem terminating system (CMTS). The
CMTS is connected to other data networks via routers. In the case of the ILEC
telephone network “conditioned” copper loops connect the premise to either a remote
terminal or a central office (local exchange). In either case the loops terminate in a
digital subscriber line access multiplexer (DSLAM). The DSLAM is connected to data
networks via routers.2
6. On both types of networks, data traffic is aggregated and uses shared facilities. On a
cable network virtually all network elements are used by aggregated data (data from
more than one user). Data aggregation occurs at the coaxial feeder cable outside a
premise that runs to the node. On a telecom network data aggregation occurs on the
network side of the DSLAM (either at the the remote terminal or the central office). If
the DSLAM is at the remote, then in some cases aggregation might occur at the remote
terminal itself.
7. The costs of providing broadband service to a premise are two-fold. Costs must be
incurred to connect the premise to the network (“costs of providing access”) and costs
are incurred when data is sent and received over the network from the premise. These
latter costs are usage costs. The incremental costs of providing service depend on the
costs of connection or “access” and the extent of usage. The incremental costs of
providing service at a given level of usage by the premise is the difference between the

2
See the discussion of network components in Spulber and Yoo (2009).
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costs of the network with the premise and its associated level of usage and the costs of
the network without the premise.
8. The direct incremental costs of providing access are associated with facilities that are
not shared, for instance in the case of cable, this is the cost of installing the coaxial
cable from the feeder coaxial cable to the premise or the pair of copper loops for a
telecommunications network. In addition the expected additional usage (data traffic)
may require an expansion of shared facilities. These two sources of cost to bring a
premise on net for a given level of usage involve capital expenditures that are sunk.
That means that these expenditures cannot be recovered by exit, but by earning quasi-
rents from providing broadband service. Quasi-rents are the difference between
revenues and short run avoidable costs associated with usage. 3 The short run avoidable
costs associated with using bandwidth are relatively small assuming capacity is
available, i.e. there is no congestion. When commentators refer to the costs of
transporting an additional GB and suggest that this cost is “pennies per GB”, they are
referring to the short-run costs, not the costs of expanding capacity at the margin.
9. There are two types of costs associated with usage of a broadband network. The first
cost category is the avoidable costs that must be incurred by the provider to deliver the
packets sent by the user. The second cost category arises if the additional traffic on the
network creates congestion. The social marginal cost of additional traffic on an
existing network is the sum of the avoidable costs of the network and the costs of
congestion.
10. Congestion arises because all of the shared network elements have capacity limits.
This includes shared components of the last mile, middle mile networks, and backbone
networks. When an element is congested, the effect is to delay processing of data,
degrading the quality of service provided by the network to all users whose traffic uses
that element. The costs of congestion include delays in information transmission and
degradation in the quality of information. Delays in receiving time-sensitive
information may decay the value of that information or in the extreme render the
content requested useless. An example of degradation in the quality of information
arises in particular with video playback when congestion results in frozen playback
while data is buffered or if some packets are lost (rendering a file damaged). Whether
congestion results in delay or degradation there is typically also the additional time
cost to users of waiting.4
11. The capacity of a broadband network cannot be adjusted up and down to meet
predictable variations in demand. The predictable variations in demand happen before
capacity can be adjusted. For instance, capacity cannot be expanded to meet demand in
the evening and then reduced when demand falls in the early morning hours. This
occurs because installing capacity quickly is very costly and since this capacity is sunk

3
See Church and Ware (2000) at p. 23 for a definition and discussion of quasi-rents. Care should be taken to
distinguish quasi-rents from Ricardian rents and monopoly rents (profits). Ricardian rents arise from ownership
of a superior factor of production that give a firm a cost advantage over its rivals. Monopoly rents from market
power, the ability to profitably raise price above competitive levels. Revenues in excess of long run opportunity
costs indicate monopoly rents.
4
For discussion of the source of congestion in broadband networks see Spulber and Yoo (2009) and Jamison and
Hauge (2009).
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it is not possible to reduce capacity and recover expenditures on investment.


Consequently capacity cannot be increased in peak periods and reduced in off peak
periods as demand varies.
12. Broadband networks are highly capital-intensive, the construction and capital costs are
sunk, and they are characterized by economies of scale and scope. Economies of scale
arise from long run fixed costs associated with construction and indivisibilities
associated with the components of the network (the average cost of capacity of
network components declines as capacity increases). Economies of scope arise
because the network can be used to provide multiple services.

2.1. Implications of the Technology of Broadband Networks for Pricing


13. The specific characteristics of broadband networks have important implications for
pricing and investment. The first is the important advantage of using nonlinear pricing
to recover sunk capital costs. A constant per unit price gives rise to a linear tariff. The
total expenditure by a customer is linear in usage and average expenditure is constant.
If customers face nonlinear pricing, the average price depends on total consumption.
Under a two-part tariff, customers pay an access fee (that is independent of usage) and
a usage charge. Under a three-part tariff, customers pay an access fee, a usage fee for
usage below a maximum threshold in the first block and a different usage fee for usage
above the maximum threshold.
14. The second is the role of pricing in efficiently managing the peak-load problem and
congestion on the network. The peak-load problem arises when service is provided
across a number of time periods and demand over those periods is cyclical but
predictable; output is not storable; and capacity is the same across the time periods. In
these circumstances increasing capacity will reduce congestion costs during peak
periods, but at the cost of having excess capacity in off peak periods. Installing less
capacity lowers capacity costs, but increases the costs of congestion in peak periods.
Managing the trade-off efficiently between the costs of congestion and the costs of
additional capacity requires appropriate pricing. The magnitude and sunk nature of
capital investment ensures that such management is especially important with
broadband networks.

2.1.1. Efficient Pricing, Firm Viability, and NonLinear Pricing


15. Economies of scale and scope typically mean that pricing at marginal cost is not
viable. In the simplest case of a single product firm characterized by economies of
scale, pricing at marginal cost will result in the firm not recovering its costs (including
the opportunity cost of its capital), since economies of scale mean that marginal cost is
less than average cost. A similar problem usually arises for multiproduct firms
characterized by economies of scale and scope.
16. By the very nature of their costs, firms that provide broadband service cannot price at
short run marginal cost as firms in hypothetically perfectly competitive markets
would. Instead they must price at levels in excess of short run marginal cost, thereby
exercising “market power”. However, it would be wrong to expect that pricing above
short run marginal cost is necessarily an indication of the inefficient exercise of market
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power. Firms must be able to price so that they recover at least their average long run
cost of production.
17. Because of economies of scale and scope, it should be expected that broadband service
providers will price well in excess of their short run marginal cost and that they will
have high gross margins. The required difference creates quasi-rents equal to their
sunk network costs.
18. A trade off between viability and efficiency arises when a firm is not viable if its
services are priced at marginal cost. Raising prices above marginal costs increases the
quasi-rents of the firm, but at a cost in allocative efficiency. Raising the price above
costs creates a quantity distortion: the higher price means that consumers reduce
consumption below the efficient or “optimal” level. The cost to society of the quantity
distortion arises because the alternatives consumers substitute towards have a lower
value and the firm loses quasi-rents on units no longer produced (difference between
price and marginal cost). This reduction in aggregate social “surplus” or value is
known as the deadweight loss of the increase in price.
19. An alternative is that firms have an incentive to raise revenues by instead using
nonlinear pricing. As indicated above a common form of nonlinear pricing is a two
part tariff, where consumers pay a fixed access fee and a per unit usage charge (two
parts). The use of a two part tariff is a more efficient means for the firm to recover its
sunk costs and break even. It can leave the usage fee closer to marginal cost, thereby
encouraging consumption, and use the access fee to extract surplus from consumption
of inframarginal units.5
20. A menu of nonlinear pricing options further reduces the social costs of fixed cost
recovery. A continuous nonlinear pricing schedule specifies a price for each increment
of consumption. A user’s total expenditure is the sum of the price for each increment
they purchase. Intuitively an optimal pricing menu sets the mark-up for an increment
of consumption proportional to the inverse of the elasticity of demand for that
increment.
21. Thus the optimal nonlinear pricing schedule follows Ramsey pricing principles. It
recognizes that there are two effects of raising prices above marginal cost: the first is
the creation of profits that contribute to firm viability, the second a reduction in output
that is socially costly. Ramsey pricing trades these two effects off optimally,
recognizing that raising prices for inelastic demands results in a larger contribution to
cover the deficit of the firm at little cost in terms of lost output relative to elastic
demands.6
22. Mark-ups are higher for levels of usage that are price inelastic, whereas for levels of
usage that are price elastic, mark-ups are lower. If increments of usage become
steadily more price inelastic at higher usage rates, then the marginal price rises and
quantity premiums become optimal. If increments of usage become steadily more
price elastic at higher usage rates, then the marginal price falls and quantity discounts

5
See Brown and Sibley (1986) at Section 4.5.
6
See Church and Ware (2000) Chapter 24 for a discussion of Ramsey pricing principles.
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become optimal. In either case the consumers with higher demands make a larger
contribution to covering the costs of the firm.7
23. Under certain conditions the optimal nonlinear pricing schedule can be implemented
with a menu of two part tariffs, with a tariff targeted at each level of usage. It will
feature a trade off between low access fees and high usage charges. This reduces the
extent to which consumers with low valuations for the service opt not to purchase
access, while at the same time reducing the incentives of high valuation consumers to
engage in personal arbitrage by masquerading as low value consumers. The high value
consumers are high value typically because they have a high willingness to pay for
usage, i.e. get lots of benefit from using the broadband network. They will be heavy
users. Charging a high usage fee with low access fees discourages them from avoiding
a higher access fee since it reduces their usage. Hence the firm can charge higher
access fees to them and lower usage fees. The effect of the first assists in recovery of
fixed and sunk costs, the second contributes to expanding usage.
24. Alternatively, the firm instead of discriminating on the basis of quantity could
discriminate on the basis of quality. Higher quality is provided at a higher price, lower
quality for a lower price. Those with a high willingness to pay for quality are induced
to pay the higher price: avoiding the higher price can only be done by opting for lower
quality service and the combination of lower quality service (albeit at a lower price), is
less attractive than higher quality and a higher price for those that value high quality.
25. For example, consider a customer who has a high willingness to pay for internet
services: she is a heavy user who downloads large files and streams lots of video and
audio content and who gets lots of value from doing so. A second consumer has a low
willingness to pay for broadband service: he is a light user who uses access for email
and occasional web surfing and who gets little value from doing so. Suppose that the
internet service provider offers two plans: a low price plan intended for the light user
and a high price plan intended for the heavy user. Any attempt to extract revenue from
the heavy user will be frustrated by her ability to opt for the low price plan. To prevent
this, the broadband service provider should reduce the quality of the low price plan,
thereby reducing its appeal to high value, heavy users. This could be done by reducing
its speed or imposing a lower monthly cap with relatively higher overage charges for
low price plans.
26. One result of using such a price menu is that more of the burden of cost recovery is
likely to fall on high value, heavy users. Besides typically being more efficient than a
uniform price, a price menu is also likely to be viewed by many as more equitable.
Those who benefit from the network pay a greater share of its costs.

2.1.2. Congestion and Optimal Capacity


27. In this section, I discuss two models that support positive usage prices to curtail
congestion. The first is a model of peak load pricing. It recognizes that capacity in the
network is available across all periods, but it abstracts from the issue of viability by

7
See Brown and Sibley (1986) Chapter 5, Tirole (1988) Section 3.5.1.2, and Braeutigam (1989) Section 7.3.
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assuming that long run marginal cost pricing allows the firm to break even. The
second is a model of congestion pricing that assumes only a single period.
28. While many of the capital costs of a network are fixed in the long run, not all are. In
the long run some capacity costs are variable, i.e., as planned output increases, so to
does capacity and capacity costs. In the short run these costs are sunk, but in the long
run they vary with output.
I. A Simple Example Illustrating Peak-Load Pricing
29. To see the role of usage prices in resolving the trade off between congestion costs and
capital costs, it is useful to abstract away from the issue of cost recovery and firm
viability. This can be done by assuming that production is constant returns to scale,
requiring one unit of capacity and one unit of all other inputs. The costs of capacity are
sunk, the cost per unit of all other inputs is constant and equal to c. Since “all other
costs” are variable in the short run, c is short run marginal cost. It is also informative
to simplify the costs of congestion by assuming that once capacity is reached,
consumption benefits of additional units are not reduced, but instead lost completely.
Finally assume that there are two periods of equal length, demand is independent, and
higher in the peak period, lower in the off peak period.8
30. Efficient usage pricing for a fixed level of capacity depends on the demand in the
period when price equals c. If demand during the off-peak period is sufficiently low
then when price equals c demand will be less than capacity, and the optimal price
during the off peak is c. Conversely in the peak period we would expect that demand
exceeds capacity. Hence the price should rise to ration capacity: the efficient price
reduces demand until it just equals capacity in the peak period. Denote this price p * .
31. The price in the peak period will equal the social marginal cost of production. The
private cost to the firm of providing service is c. But there is a second “social” cost,
which is essentially an opportunity cost: the cost of providing service to a subscriber
with a higher willingness to pay than p* is that at the margin a consumer with
willingness to pay of p* is unable to consume. Hence the costs of congestion are the
lost benefits of marginal consumption. This rationing cost is the difference between
the consumer’s willingness to pay and the costs of production: p*-c. The total social
marginal cost is therefore c + p*-c= p*. So as expected the efficient price involves
marginal cost pricing.
32. The social value of increasing capacity is the reduction in congestion costs. At the
margin the costs of congestion are only p*-c, the costs of not having capacity in the
peak period. If this exceeds the cost of having another unit of capacity in both periods,
then capacity should be expanded. The benefit of expanding capacity is the reduction
in congestion costs and that exceeds the per unit costs of capacity. In this case there is
no benefit in having additional capacity in the off peak period, only in the peak period.
Hence users in the peak period bear the burden of paying the costs of capacity for both
periods. Off peak users pay only short run marginal cost.

8
The following is based on Church and Ware (2000) Section 25.3. Independent demands means that the cross-price
elasticity between the two periods is zero.
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33. The efficiency gain from moving from an average uniform price (with capacity that
meets peak demand) to peak-load pricing arises from two effects. The first is a
reduction in peak consumption. Under uniform pricing, peak consumers paid a price
less than the efficient price since off peak consumers also paid a price above c. Since
off peak consumers made some contribution to capacity costs, peak period consumers
have to pay less. But of course this means that peak period consumers paid a price less
than the social marginal cost, while off peak period consumers pay a price greater than
marginal cost. Peak-load pricing eliminates the subsidization of peak period
consumption by off peak consumers. As a result inefficient consumption in the peak
period (where marginal cost was greater than consumption benefits) is reduced and
less peak capacity is required. Second the reduction in the price in the off peak period
leads to more intensive utilization of the network in the off peak period, an increase in
usage and consumer benefit.
34. If off peak period demand at c is greater than capacity, then price in the off peak
period will rise above c in order to ration capacity efficiently. If this price is p**, then
the cost of rationing in the off peak period will be p**-c. At the optimal level of
capacity the reduction in rationing costs in the peak period plus the reduction in
rationing costs in the off peak period will equal the per unit cost of providing capacity
across the two periods. Hence peak and off peak period consumers will make
contributions to cover the costs of capacity.
II. Congestion and Internet Pricing
35. The second example recognizes that when facilities are shared, increased usage might
result in congestion and that the costs of congestion are increasing in usage and
incurred by all users. This arises because capacity is assumed to be shared and as the
ratio of usage to capacity increases, the benefits to all users decreases. This is unlike
the previous example where there were no costs of congestion until the capacity limit
was reached and those who received service did not suffer any congestion costs.
However in this example demand is constant across periods—there is not a peak-load
trade off.9
36. Efficient use of a network with a given capacity requires that each user sets their
marginal benefit of additional usage equal to the marginal private cost of their service
provider plus the marginal congestion cost their additional usage creates. The marginal
congestion cost their additional usage creates is the aggregate value of congestion
costs imposed on all other users. This negative externality is ignored by a user if the
price they face for usage depends only on the private costs of their service provider.
The efficient price equals the short run marginal cost of usage plus the marginal social
cost of usage.
37. Expanding capacity is optimal if the aggregate reduction in congestion costs exceeds
the cost of expanding capacity. If congestion is priced optimally, then capacity
expansion is optimal when the revenues from the congestion charge exceed the costs
of the capacity expansion. The price of congestion plays two roles: it measures the

9
This example is based on the analysis of MacKie-Mason and Varian (1995a).
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costs of congestion from increased usage for a fixed level of capacity and it also
measures the value of a change in capacity.
38. Broadband service providers will have an incentive to internalize the marginal social
cost of usage in the prices they charge their subscribers. Broadband providers will
choose prices and capacity knowing the effect of usage on the quality of service and
how the quality of service affects demand.
III. Metering and Congestion Pricing
39. If demand and supply are uncertain, then the congestion price should vary as
conditions on the network change and for efficiency there should be a price for every
network element. At any instant in time the lowest price to complete a request would
be communicated to each user before they sent or received data. The user would then
compare this price to their benefit they expect from using the network.10 If the benefit
exceeded the price, they would use the network, if not they would defer, reduce, or
cancel their planned network usage.
40. The transaction costs of determining prices and informing users are prohibitive. Even
just providing instantaneous usage information appears to be prohibitively costly given
existing technology. The principles under which the Internet operates appear to
preclude congestion based metering. Data traffic is divided up into packets that are
then sent individually and reassembled at their destination. Different packets may take
different routes and use different network elements.11 The transaction costs of instead
using time of day as a proxy for congestion and billing on that basis also appear to be
prohibitive or sufficiently large that they exceed the benefits of moving to time of day
pricing.
41. On the other hand, as originally suggested by Coase (1974) in the context of
lighthouses, it may be possible to relatively easily measure proxies for user created
congestion and base congestion charges on these proxies. Spulber and Yoo (2009)
have suggested that limits on bandwidth usage are based on similar logic.12 In the next
section I explain that usage based billing in conjunction with different qualities of
service could play a similar role.

10
Mackie-Mason and Varian (1995b) suggest a decentralized mechanism to set the price for congested network
elements. Users would assign bids to packets for processing at each congested element, with those with the
highest willingness to pay awarded priority access. See Gupta, Stahl, and Whinston (2005) for a critical
assessment of implementation difficulties.
11
See Spulber and Yoo (2009) at pp. 420-421.
12
See Spulber and Yoo (2009) at pp. 419-429. Lighthouses are often used as an example of a pure public good. A
pure public good is both non-excludable and non-rivalrous in consumption. Non-excludability means that the
transaction costs of metering and charging for usage (benefits) are prohibitive and suggest that private provision
is not likely. Coase documented the existence of private lighthouses that imposed tolls on access to proximate
ports.
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3. CONGESTION MANAGEMENT, FIXED COST RECOVERY, AND UBB


42. Table 1 shows the broadband plans currently offered by Rogers and Bell. The plans
are differentiated by bandwidth (maximum transfer rates), flat rate, monthly volume
cap, and overage charge. The lower bandwidth plans have lower flat rates, but their
UBB components, are less attractive, i.e., lower aggregate cap and a higher overage
charge.
43. These plans thus are similar to a multipart tariff for a given speed. There is a fixed
access fee equal to the flat rate charge, a marginal price of zero in the first block, and a
positive marginal price in the second block.
44. In the next two sections I suggest that these plans are consistent in form with efficient
cost recovery and congestion management.

3.1.1. Fixed Cost Recovery


45. As expected there is a trade off between speed and the flat fee: higher quality service
is provided at a higher flat fee. Moreover the UBB components operate as theory
would predict. Lower speed plans have more stringent UBB restrictions, making them
even less attractive to high volume/high value users. This means that the total higher
volume/high value users will pay (access fee and total usage charges) can be increased
before the cost of their plan becomes sufficient to tempt them to substitute to a lower
speed plan.
46. Moreover the price of usage is zero in the first block, with most of the tariff made up
of the fixed fee, i.e., the charge for access. Since most of the cost of service (excluding
congestion) are fixed and sunk network costs, it is appropriate to recover most of these
costs through the access fee. Assuming the absence of congestion and if there was a
single quality offered, then there would be a trade off between an access fee and a
usage fee above marginal cost of network usage. The access fee might be reduced and
the usage fee raised above marginal cost of usage if access was price sensitive. This
would encourage low value subscribers to join, even though their usage would be
limited. Instead under the Bell and Rogers plans incentives for low value subscribers
are provided by offering lower price and lower quality options.

3.1.2. Congestion Management


47. Given economies of scale and scope, we might have expected that an efficient (or
profit maximizing) menu of pricing plans would feature decreasing marginal block
pricing. The typical trade off is to lower the marginal price to encourage usage by
raising the fixed fee and/or charging higher prices in initial blocks. The increasing
block price in the broadband plans offered by Bell and Rogers suggest the importance
of managing congestion. Increasing block prices are consistent with increasing social
marginal cost attributable to congestion as usage increases.
48. Congestion arises when the demands for bandwidth at a point in time exceed the
capacity of a network element. Hence as discussed in the previous section, congestion
pricing should be based on the costs of congestion created by a subscriber’s
instantaneous use of the network. It is the bandwidth demand of a subscriber at the

# filed in confidence with the CRTC 13


ABRIDGED

peak times that contributes to congestion and creates congestion costs. Their use at off
peak times is unlikely to contribute much to congestion or create congestion costs. It is
not their total monthly usage, per se, that creates congestion. However, monthly
volume usage might be a reasonable proxy, given the transaction/metering costs
associated with real time congestion pricing.
49. Traffic data for Rogers’ network suggest the traffic peak is for a four hour period
between 20:00-24:00 or 19:00-23:00 on weeknights, though the shoulder period on
weekends indicates substantial use (as a percentage of peak traffic) from 12:00
onwards. Based on this data, it seems reasonable to estimate that between 25% and
30% of total daily usage occurs within the peak hours. This is between 1.5 and 2 times
what might be expected if demand was uniform, i.e. constant per hour.
50. There is evidence that suggests that bandwidth demand by heavy users does contribute
to congestion. High end users generate most of the traffic on the Rogers’ network.
Table 2 shows that the top 1% of Rogers users accounted for #% of total volume
(April 2010), the top 5% of users, #% of all traffic, and the top 10% more than #% of
all traffic. The bottom 75% of users account for only just over #% of total monthly
usage.
51. In April 2010, the average data usage across all Rogers’ high-speed Internet customers
was # GB.13 Table 2 shows that the average user in the top 1% transferred # GB, the
average user in the top 5%, # GB, and the average user in the top 10%, # GB. Further,
the average transfer of the top 12 (i.e., roughly the top 0.01%) subscribers in April
2010 was almost # GB.
52. The sheer dominance of the high volume users in aggregate usage data virtually
ensures that they are also substantial contributors to peak usage.
53. For instance, it must be the case that the top 25% of users are making some
contribution to peak hour usage, which accounts for at least around 25% of total daily
usage. If this were not the case, one would then have to believe that a group (the
bottom 75%) that accounts for just around #% of total monthly usage, manages to
account for all of the usage during the peak period, which is 25% of daily traffic.
54. Of course it is also likely the case, especially given the hours of the peak period that
even light users contribute to peak demand.
55. Hence as an alternative to the “first best” of precise metering and charging users by
measured contribution to peak traffic, it could be “second best” to price congestion on
the basis of total volumes used for all users. Since the overage charge is playing two
roles, encouraging monthly usage by high value/high volume users, but also curbing
congestion, it is difficult to infer much from the fact that the overage charge declines
as the volume cap rises.
56. Table 2 also shows the revenue share of the top 1%, 5%, 10% subscribers from
January 2011. The revenue share for the bottom 90% is #%, its traffic share #%. The

13
Note that this average is skewed upwards by the exceptional usage volumes in the top 10% of users. Median usage
is a mere # GB.
# filed in confidence with the CRTC 14
ABRIDGED

revenue shares are substantially less than the traffic shares.14 This is not consistent
with a conclusion that UBB congestion charges are disproportionately restricting use
by the high volume users.
57. Figure 1 shows the increase in total download traffic volume on the Rogers’ network
from January 2008 to July 2009 and the total number of ports available.15 While total
traffic has grown substantially, the growth in ports is more than # the growth in
traffic (#% versus #%), while the growth in subscribers was only #%. The increase in
traffic is driven by an increase in the average volume per subscriber of almost #%.
58. Rogers is adding capacity to avoid congestion and deterioration in the quality of
service. Capacity is not just there to be utilized, but must be augmented as demand
grows and the increase in capacity is clearly correlated with total traffic volume.
59. The information in Figure 1 and Table 2 suggests that Rogers puts a greater weight on
expanding its network to manage congestion than it does on aggressive
implementation of UBB.

4. WHOLESALE UBB
60. The present proceeding addresses usage based billing in the wholesale provision of
high speed internet access by the incumbent telcos (ILECs) and cable carriers,
collectively the incumbents. The incumbent providers typically utilize usage based
billing for their retail services. The issue is whether there should be symmetry between
the retail and wholesale high speed internet services of the incumbent networks with
respect to usage based billing.

4.1. Mandated Wholesale Access of High Speed Internet


61. In Telecom Decision 2008-17 the Commission determined that aggregated ADSL and
third-party Internet access (TIPA) service were “conditional mandated non-essential”.
These services provide both access to a customer’s premise and transport to a single
point of interface with the network of an ILEC or a single point of interface in a
geographic area with the network of a cable company. Hence they provide both access
and transport, limiting the investment required by entrants to compete in the provision
of broadband service.
62. The Commission found that ADSL access service was “conditional essential”. ADSL
access service provides competitors with a connection between the customer’s premise
and the central office over which it can offer high speed internet services. This access
service was deemed essential but only until functionally equivalent alternatives

14
I acknowledge that the revenue shares and the traffic data are from different months. I have no reason to believe
that the qualitative analysis would be different if the data was for the same month.
15
A port is the interface on the CMTS router than connects the cable network to the IP network. Increasing the
number of these interfaces is typically one of the first steps in dealing with congestion.
# filed in confidence with the CRTC 15
ABRIDGED

available to the competitors were sufficiently available that withdrawal of mandated


access would not substantially lessen competition in the retail high-speed internet
market (hence access is conditional until this occurs).
63. High speed service could be offered by competitors using ADSL access service, self
supplied transport and co-location. So while the Commission found that competitors
could duplicate the transport functionality of aggregated ADSL and TIPA, it also held
that in most cases co-location and self-supplied transport would not be a cost-effective
alternative. Presumably by this it meant self supply of transport while possible would
not provide much of a competitive constraint on the ILECs (and by extension the cable
carriers). Hence the determination that aggregated ADSL and TIPA were not essential
but mandated access was required until wholesale alternatives exist which would
constrain the market power of the ILEC.
64. The Commission confirmed its view of the importance of mandated access to
aggregated high speed access in its matching speed decision (Telecom Decision 2010-
632) released August of 2010. In this decision it imposed a condition on the ILECs
and cable carriers requiring that they must provide at wholesale options that match all
the speeds they provide at retail. The Commission determined that if equivalent
wholesale access was not mandated, the competitive constraint (if any) of the
competitors would erode as the incumbents upgraded the speed of their retail products.
65. In Telecom Decision 2010-255 (May 2010) the Commission approved usage based
billing by the Bell companies for their aggregated ADSL service (GAS). The three
main provisions of the approved UBB were that Internet service providers providing
service using GAS would pay (i) a monthly flat rate up to a usage threshold; (ii) above
the threshold they would pay a per-gigabyte overage charge; and (iii) total overage
charges were capped. The monthly flat rate is cost plus a mark-up, while the overage
charge was 25% less than the market based rate Bell charged its own retail customers.
66. In Telecom Decision 2010-802 (October 2010) the Commission varied 2010-255 and
eliminated the 25% discount off residential UBB rates for wholesale aggregated ADSL
service. It did so to maintain symmetric regulatory treatment with TPIA service
offered by the cable carriers. At the same time the Commission initiated a public
hearing to determine the discount on overage charges for both TPIA and aggregated
ADSL. In Telecom Decision 2011-44 (January 2011) it set the discount at 15%.

4.2. Regulatory Arbitrage and Its Effects


67. In this section I consider the effect of not mandating UBB at wholesale. This would
mean that, at least initially, the incumbent carriers would use UBB at retail, but at
wholesale they would have to provide essentially the same service at a cost plus mark-
up flat rate with unlimited monthly usage.
68. Competitive ISPs have substantial incentives to oppose the introduction of UBB at
wholesale or support UBB at wholesale only if the discount on the overage charge was
50%. Regulation banning wholesale UBB could easily create the opportunity for
independent ISPs to engage in profitable regulatory arbitrage.

# filed in confidence with the CRTC 16


ABRIDGED

69. The average usage level in April 2010 for a Rogers’ subscriber in the top 1% of
subscribers by volume was # GB. If a user with this level of monthly usage were to
select the Rogers’ plan that minimises their overall monthly bill, they would select the
fastest option, the Ultimate plan. Based on Rogers’ current rates their monthly charge
(based on Table 1) would be $# (which includes an overage charge of $# ). If the
flat rate lease is $89.17 (as per Rogers’ proposed tolls),16 the margin an independent
ISP has for its other costs is $#. If it is subject to the same UBB overage rate as a retail
user, however, the margin for its other costs falls to $#.
70. In contrast the average usage level of a subscriber in the bottom 50% of Rogers’
subscribers by volume in April 2010 was # GB. A subscriber with this level of usage
would minimize their expenditures by choosing Rogers’ Ultra-Lite option. Their
monthly charge would be $# (which includes an overage charge of $# ). If the flat
rate lease is $19.42 (as per Rogers’ proposed tolls),17 the margin an independent ISP
has for its other costs is $#. If it is subject to the same UBB overage rate as a retail
user, the margin available to cover its other costs falls to $#.
71. These calculations show the extent to which avoiding the UBB overage rate provides
an extra margin for the independent ISP. That extra margin is much more significant
for the high volume user, providing the independent ISP with considerable incentive to
“cream skim.” Cream skimming refers to the incentive and ability of the independent
ISP to compete away mainly the high value customers from Rogers.
72. When Rogers loses an Ultimate plan customer to an independent ISP, Rogers’ network
costs do not change: the reduction in its revenues from $# to $89.17 are not matched
by a reduction in network costs since Rogers’ still provides the same network
service.18 To the extent they were required for Rogers’ to cover its sunk network costs
the effect is to expropriate Rogers’ network investment by reducing its quasi-rents.
This is a form of regulatory hold up. Regulatory hold up occurs when a firm makes an
investment in sunk assets with the expectation that those expenditures will be
recovered, but a change in regulatory policy reduces their expected revenue below
total costs.19 The effect on the incentives for all network carriers to continue to
maintain their networks, let alone upgrade is counter-productive.
73. In addition, the effect of significant losses to Rogers of its high volume/high value
customers will harm all users because the costs of the Rogers’ network will increase.
The reason is that if the high volume users are no longer subject to a cap on usage,
they will have an incentive to use the Rogers’ network more extensively. This will
either push up Rogers’ network costs if it maintains network quality, increase
aggregate costs of congestion, or provide incentives for Rogers (and other network
owners) to substitute more heavy handed measures to control congestion. These
effects will be amplified if in response to the effects of regulatory arbitrage Rogers
(and the other incumbents) abandon UBB at retail.

16
Rogers Tariff Notice 18, Revised, March 11, 2011.
17
Rogers Tariff Notice 18, Revised March 11, 2011.
18
Off setting this Rogers will save its avoidable retail costs.
19
See Church and Ware (2000) at pp. 768-769.
# filed in confidence with the CRTC 17
ABRIDGED

5. TABLES AND FIGURES


Table 1: Ontario prices and service offerings for Bell and Rogers

             
Additional   Monthly  
Monthly   Usage   Max   Service  Fee  
Max   Max   Bandwidth   Charge  per   Usage   incl.  
Bell  Service     Speed   Speed   Cap     GB     Billing   modem  
    Download     Upload                  
Fibre  25   25  Mbps   7  Mbps   75  GB   $1.00     $60     $74.90    
Fibre  16   16  Mbps   1  Mbps   75  GB   $1.00     $60     $68.90    
Fibre  12   12  Mbps   1  Mbps   50  GB   $1.50     $60     $58.90    
Fibre  6   6  Mbps   1  Mbps   25  GB   $2.00     $60     $48.90    
Performance   6  Mbps   1  Mbps   25  GB   $2.00     $60     $48.90    
Essential  Plus   2  Mbps   800  Kbps   2  GB   $2.50     $60     $38.90    
             
             
Additional   Monthly  
Monthly   Usage   Max   Service  Fee  
Max   Max   Bandwidth   Charge  per   Usage   incl.  
Rogers  Service   Speed   Speed   Cap     GB     Billing   modem  
ON   Download     Upload                  
Ultimate  -­‐  Ontario   50  Mbps       2  Mbps     175  (GB)   $0.50     $50     $103.99    
Extreme  Plus     25  Mbps     1  Mbps   125  (GB)   $1.25     $50     $73.99    
Extreme  -­‐  Ontario   15  Mbps     1  Mbps   80  (GB)   $1.50     $50     $63.99    
Express   10  Mbps     512  Kbps   60  (GB)   $2.00     $50     $50.99    
Lite  -­‐  Ontario   3  Mbps     256  Kbps   15  (GB)   $4.00     $50     $39.99    
Ultra-­‐Lite   500  Kbps   256  Kbps   2  (GB)   $5.00     $50     $31.99    

Notes:  
1.  Bell  plan  details  from    http://www.bell.ca/shopping/PrsShpInt_Access.page  
2.  Rogers  plan  details  from  
htttp://www.rogers.com/web/Rogers.portal?_nfpb=true&windowLabel=...compare&HiSpeed
Browse_1_2productID=WAVE&pageLabel=Inter_HISPEED  
3.  Rogers  offers  discounts  of  5%,  10%,  15%  if  purchased  with  1,2,  or  3  other  services.  
4.  Bell  prices  are  discounted  by  around  25%  for  many  services  if  purchased  with  other  services  
in  a  bundle.  
 
 
 

# filed in confidence with the CRTC 18


ABRIDGED

Table 2: Rogers’ Wireline Internet Usage and Revenue


 
%  of  
Top  %  of   %  of  Total  Wireline   Aggregate   Average  GB  
Internet  Base   Internet  Gross  Revenue   Traffic   per  Month  
1   #   #   #  
5   #   #   #  
10   #   #   #  
 
 
Notes:  
 
1. Revenue  share  data  from  Jan  2011.  Revenues  include  monthly  fees  and  overages.  
2. Usage  data  from  April  2010.  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

# filed in confidence with the CRTC 19


ABRIDGED

Figure 1: Ports and Downstream Volume (TB) on Rogers’ Wireline Internet network

# filed in confidence with the CRTC 20


ABRIDGED

6. REFERENCES
Braeutigam, R. 1989. "Optimal Policies for Natural Monopoly." In R. Schmalensee and R.
Willig, ed., Handbook of Industrial Organization. 2. Amersterdam: North-Holland,
1289-1346.
Brown, S., and D. Sibley. 1986. The Theory of Public Utility Pricing. Cambridge: Cambridge
University Press.
Church, J., and R. Ware. 2000. Industrial Organization: A Strategic Approach. San Francisco:
McGraw-Hill.
Coase, R. 1974. "The Lighthouse in Economics." Journal of Law and Economics 17: 357-376.
Gupta, A., D. Stahl, and A. Whinston. 2005. "Pricing Traffic on Interconnected Networks:
Issues, Approaches, and Solutions." In S. Majumdar, I. Vogelsang and M. Cave, ed.,
Handbook of Telecommunications Economics. Vol. 2. Amsterdam: Elsevier, 413-439.
Jamison, M., and J. Hauge. 2009. "Dumbing Down the Net: A Further Look a the Net
Neutrality Debate." In W. Lehr and J. Pupillo, ed., Internet Policy and Economics.
Second Edition. New York: Springer, 57-72.
MacKie-Mason, J., and H. Varian. 1995a. "Pricing Congestible Resources." IEEE Journal on
Selected Areas in Communications 13: 1141-1149.
MacKie-Mason, J., and H. Varian. 1995b. "Pricing the Internet." In B. Kahin and J. Keller, ed.,
Public Access to the Internet. Englewood Cliffs, N.J.: Princeton University Press,
Spulber, D., and C. Yoo. 2009. Networks in Telecommunications. New York: Cambridge
University Press.
Tirole, J. 1988. The Theory of Industrial Organization. Cambridge, Mass.: MIT Press.

# filed in confidence with the CRTC 21


Jeffrey Robert Church

Exhibit-1
March 2011

_______________________________________
Contact Information

Department of Economics

University of Calgary

2500 University Drive, N.W.

Calgary, Alberta

T2N 1N4

Phone:
(403) 220 6106

Fax:
(403) 282-5262

e-mail:
jrchurch@ucalgary.ca

_______________________________________
Citizenship

Canadian

_______________________________________
Education and Professional Qualifications


•! Ph.D., Economics, University of California, Berkeley 1989, specialization in Industrial
Organization and International Trade. Supervisory Committee Richard Gilbert, Michael
Katz, and Jeffrey Perloff.


B.A. First Class Honours (Economics), University of Calgary 1984.


Qualified as an expert witness before the National Energy Board, the Alberta Energy

Utilities Board, the Canadian Radio-Television and Telecommunications Commission,

the Federal Court of Canada, and Supreme Court of British Columbia.

______________________________________
Positions Held

Academic Appointments


Professor, Department of Economics, University of Calgary (since July 1, 2001).


IAPR Professor, Institute for Advanced Policy Research, University of Calgary,

Coordinator of the Markets, Institutions, and Regulation Working Group (July 1, 2006

to

June 30, 2009).
Jeffrey Church


March 2011
Curriculum Vitae

Page 2 of 17



Associate Professor, Department of Economics, University of Calgary (1994-2001).


Assistant Professor, Department of Economics, University of Calgary (1989-1994).


Other Appointments


Chairperson, Terra Nova Reference Price Committee, Newfoundland (2007 and 2010-).


Fellow, Economics Network for Competition and Regulation (ENCORE), Netherlands,
(since 2007).


Founding Academic Director, Centre for Regulatory Affairs in the Van Horne Institute for
International Transportation and Regulatory Affairs, University of Calgary (1998-2001).


T.D. MacDonald Chair in Industrial Economics, Competition Bureau,



Industry Canada, Hull, Quebec (1995-1996).


President, Church Economic Consultants Ltd. (1992-).


Director, Berkeley Research Group (2010-).

_______________________________________
Academic Awards and Distinctions


Teaching Awards


Faculty of Social Science Distinguished Teacher Award, University of Calgary 1994 and
2004.


Superior Teaching Award, Department of Economics, University of Calgary, 1997, 1999,
2000, 2002, 2003, 2004.


Students' Union Teaching Excellence Award, University of Calgary 1994-95.


Major Academic Distinctions


Faculty of Social Sciences Gold Medal, University of Calgary 1984.


Listed as one of the leading competition economists in the world in the Directory of
Competition Economists in The International Who’s Who of Competition Lawyers and
Economists. London: Global Competition Review 1998 onwards.

_______________________________________
Research Interests



Industrial Organization


Economics of Regulation


Competition Policy
Jeffrey Church


March 2011
Curriculum Vitae

Page 3 of 17

_______________________________________
Publications


Refereed Journal Articles


“Indirect Network Effects and Adoption Externalities.” (with N. Gandal and D. Krause)
Review of Network Economics 7: 325-346, 2008.


“The Church Report’s Analysis of Vertical and Conglomerate Mergers: A Reply to
Cooper, Froeb, O’Brien and Vita.” Journal of Competition Law & Economics 1: 797-802,
2005.


"Specification Issues and Confidence Intervals in Unilateral Price Effects Analysis." (with
O.Capps, Jr. and H.A. Love) Journal of Econometrics 113, 3-31, 2003.


"Systems Competition, Vertical Merger, and Foreclosure." (with Neil Gandal) Journal of
Economics and Management Strategy 9, 25-52, 2000.


"Abuse of Dominance under the 1986 Canadian Competition Act." (with Roger Ware)
Review of Industrial Organization 13, 85-129, 1998.


“Strategic Entry Deterrence: Complementary Products as Installed Base.” (with Neil
Gandal) European Journal of Political Economy 12, 331-354, 1996.


"Delegation, Market Share and the Limit Price in Sequential Entry Models." (with Roger
Ware) International Journal of Industrial Organization 14, 575-609, 1996.


"Complementary Network Externalities and Technological Adoption." (with Neil Gandal)
International Journal of Industrial Organization 11, 239-260, 1993.


"Bilingualism and Network Externalities." (with Ian King) Canadian Journal of
Economics XXVI, 337-345, 1993. Reprinted in Economics of Language. ed. D.
Lamberton. International Series of Critical Writing in Economics, Vol. 150, Northampton,
MA.: Edward Elgar Publishing, 2002.


"Comment on ‘Energy Politics in Canada, 1980-81: Threat Power in a Sequential
Game’." Canadian Journal of Political Science XXVI, 61-64, 1993.


"Integration, Complementary Products and Variety." (with Neil Gandal) Journal of
Economics and Management Strategy 1, 651-675, 1992.


"Network Effects, Software Provision and Standardization." (with Neil Gandal) Journal
of Industrial Economics XL, 85-104, 1992.


Invited Papers


"Trade-Dress and Pharmaceuticals in Canada: Efficiency, Competition and Intellectual
Property Rights," (with Roger Ware) Policy Options 18: 9-12, 1997.
Jeffrey Church


March 2011
Curriculum Vitae

Page 4 of 17


Books and Monographs


The Impact of Vertical and Conglomerate Mergers on Competition Brussels: European
Commission, 2004 at http://europa.eu.int/comm/competition/mergers/others/#study.
Published as European Commission, 2006, The Impact of Vertical and Conglomerate
Mergers on Competition Luxembourg: Office for Official Publications of the European
Communities.


Industrial Organization: A Strategic Approach (with Roger Ware) San Francisco: IRWIN/
McGraw-Hill, 2000. Second edition forthcoming from Cambridge University Press.


Traditional and Incentive Regulation: Applications to Natural Gas Pipelines in Canada
(with Robert Mansell) Calgary: Van Horne Institute, 1995.


Econometric Models and Economic Forecasts: A Computer Handbook Using MicroTsp
New York: McGraw-Hill, 1990.


Chapters in Books


"Conglomerate Mergers." in W.D. Collins ed., Issues in Competition Law and Policy

Volume 2 Chicago: American Bar Association, pp. 1503-1552, 2008.


"Vertical Mergers." in W.D. Collins ed., Issues in Competition Law and Policy Volume 2
Chicago: American Bar Association, pp. 1455-1502, 2008.


"Platform Competition in Telecommunications." (with N. Gandal) in M. Cave, S.
Majumdar, and I. Vogelsang eds., Handbook of Telecommunications Vol. 2 Amsterdam:
North-Holland, pp. 119-155, 2005.


"Mergers and Market Power: Estimating the Effect on Market Power of the Proposed
Acquisition by The Coca-Cola Company of Cadbury-Schweppes’ Carbonated Soft Drinks
in Canada." (with A. Abere, O. Capps, Jr. and H.A. Love) in D. Slottje ed., Economic
Issues in Measuring Market Power, Contributions to Economic Analysis, Vol. 255,
Amsterdam: North-Holland, pp. 233-294, 2002.


"The Economics of Coordinated Effects and Merger Analysis." in D. Houston ed., CBA
Competition Law Conference 2000 Juris Publisher: Yonkers, N.Y., pp. 561-575, 2001.


"Network Industries, Intellectual Property Rights, and Competition Policy." (with Roger
Ware) in N. Gallini and R. Anderson eds., Competition Policy, Intellectual Property
Rights and International Economic Integration Calgary: University of Calgary Press, pp.
227-285, 1998.


Papers and Proceedings


“The Interface Between Competition Law and Intellectual Property in Canada: An
Jeffrey Church


March 2011
Curriculum Vitae

Page 5 of 17

Uneasy Alliance or Holy War?” on CD-ROM, 2005 Annual Fall Conference on


Competition Law. Ottawa: Canadian Bar Association, 2005.


“The Economics of Exclusionary Contracts and Abuse of Dominance in Canada.” on
CD-ROM, 2003 Annual Fall Conference on Competition Law. Ottawa: Canadian Bar
Association, 2003.


"Competition Policy and the Intercity Passenger Transportation System in Canada." in M.
Duncan, ed. Directions: A New Framework for Transportation Calgary: Van Horne
Institute, pp. 21-25, 1993.


"Commodity Price Regulation in Canada: A Survey of the Main Issues." (with Robert
Mansell) Papers and Proceedings of the Fifth Annual Regulatory Educational
Conference, Canadian Association of Members of Public Utility Tribunals, 1991.


Public Reports


Transmission Policy in Alberta and Bill 50 (with William Rosehart and John
MacCormack). School of Public Policy, University of Calgary Research Paper, 2009.


Buyer Power: Background Note. Competition Committee, Directorate for Financial and

Enterprise Affairs, OECD, Paris, 2009, Available at http://www.oecd.org/dataoecd/

38/63/44445750.pdf.


Vertical Mergers: Background Note. Competition Committee, Directorate for Financial
and Enterprise Affairs, OECD, Paris, 2007. Available at http://www.oecd.org/dataoecd/
25/49/39891031.pdf.


An Evaluation of Traditional and Incentive Regulation for Canadian Natural Gas
Pipelines. (with Robert Mansell) Study submitted to, and available from, the National
Energy Board of Canada, 1992.


Methodology for Evaluating Natural Gas Transmission System Reliability Levels and
Alternatives. (with Robert Mansell) Study prepared for, and available from, the Canadian
Petroleum Association, 1991.


Public Regulatory Interventions


Submission of The Director of Investigation and Research to Industry Canada re: Canada
Gazette Notice No. DGTP-008-95 Review of Canadian Overseas Telecommunications
and Specifically Teleglobe Canada's Role October 27, 1995 (with David Smith).


Reply Comments of The Director of Investigation and Research to Industry Canada re:
Canada Gazette Notice No. DGTP-008-95 Review of Canadian Overseas
Telecommunications and Specifically Teleglobe Canada's Role December 11, 1995 (with
David Smith).
Jeffrey Church


March 2011
Curriculum Vitae

Page 6 of 17



Submission of The Director of Investigation and Research to The Canadian Radio-
Television and Telecommunications Commissions re: Telecom Notice CRTC 95-36
Implementation of Regulatory Framework, Local Interconnection and Network
Component Unbundling January 26, 1996 (with Cal Gundy and Patrick Hughes).


Final Argument of The Director of Investigation and Research to The Canadian Radio-
Television and Telecommunications Commissions re: Telecom Notice CRTC 95-36
Implementation of Regulatory Framework, Local Interconnection and Network
Component Unbundling October, 1996 (with Cal Gundy and Patrick Hughes).


Final Oral Argument of The Director of Investigation and Research to The National
Energy Board in PanCanadian Petroleum Limited application dated 26 July 1996 for an
order requiring Interprovincial Pipe Line Inc. to transport natural gas liquids for
PanCanadian Petroleum Limited from Kerrobert, Saskatchewan (MH-4-96) November
1996 (co-author).


Opening Statement to the Alberta Utilities and Energy Board in Federated Pipe Lines Ltd.
Application to Construct and Operate a Crude Oil Pipeline from Valhalla to Doe Creek,
Alberta Energy and Utilities Board March (Decision 98-12) March 1998.


Final Argument of The Director of Investigation and Research to The Canadian Radio-
Television and Telecommunications Commissions re: Telecom Notice CRTC 98-10 Local
Competition Start-Up Proceeding November, 1998 (with Cal Gundy).


Commissioner of Competition Intellectual Property Enforcement Guidelines, Hull,
Quebec: Competition Bureau. External member Commissioner of Competition's Drafting
Team, first draft released in June 1999, second draft released April 2000, final version
released September 2000.


Final Argument of The Commissioner of Competition to The Canadian Radio-Television
and Telecommunications Commissions re: Telecom Notice Public Notice 2001-37 - Price
Cap Review and Related Issues October 2001 (with Cal Gundy).


Comments of The Commissioner of Competition to The Canadian Radio-Television and
Telecommunications Commissions re: Telecom Notice Public Notice 2001-47
Framework for the expansion of local calling areas and related issues November 2001
(with Cal Gundy and Masood Qureshi).


Written Comments of the Competition Bureau to the Alberta Electricity Industry
Structure Review February 2002 (with David Krause and Mark Ronayne).


Final Submission of the Commissioner of Competition to the Ontario Energy Board’s
Natural Gas Forum Consultation on the Ontario Natural Gas Market November 2004
(with Mark Ronayne).
Jeffrey Church


March 2011
Curriculum Vitae

Page 7 of 17



The Commissioner of Competition Evidence, Final, and Reply Argument, The Canadian
Radio-Television and Telecommunications Commissions re: Telecom Notice Public
Notice 2005-2, Forbearance from Regulation of Local Exchange Services June,
September, and October 2005 (part of the Competition Bureau’s drafting team).


Market Power and the Mackenzie Gas Project, Evidence filed before the National Energy
Board, Mackenzie Gas Project, GH-1-2004, June 2005.


The Commissioner of Competition Evidence, Supplementary Material, Final Argument,
and Reply Argument, The Canadian Radio-Television and Telecommunications
Commissions re: Telecom Notice Public Notice 2006-14, Review of Regulatory
Framework for Wholesale Services and Definition of Essential Service 2007 (part of the
Competition Bureau’s drafting team).


Commissioner of Competition, Abuse of Dominance Provisions as applied to the
Telecommunications Industry, Hull, Quebec: Competition Bureau. External member
Commissioner of Competition's Drafting Team, first draft released September 2006, final
version released June 2008.


Foreign Ownership Restrictions of Canadian Telecoms: An Analysis of Industry Canada’s
Proposals (with assistance of BRG) re Industry Canada Consultation on Opening
Canada's Doors to Foreign Investment in Telecommunications: Options for Reform, July
2010. Available online at http://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/Rogers.pdf/$file/
Rogers.pdf.


Spectrum Policy as Competition Policy: A Good Choice for Canada? (with assistance of
BRG) re Industry Canada Consultation on a Policy and Technical Framework for the
700 MHz Band and Aspects Related to Commercial Mobile Spectrum Gazette Notice
SMSE-018-10, February 2011. Available online at http://www.ic.gc.ca/eic/site/smt-
gst.nsf/vwapj/smse-018-10-jeffreychurch-rogers.pdf/$FILE/smse-018-10-jeffreychurch-
rogers.pdf.


Book Reviews


Competition Policy: A Game -Theoretic Perspective (by Louis Phlips) for The Economic
Journal, 107, 1590-1592, 1997.


Websites


Industrial Organization: A Strategic Approach. URL: http://www.econ.ucalgary.ca/
iosa/



Industrial Organization: A Strategic Approach Instructor's Manual. URL: http://
Jeffrey Church


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www.econ.ucalgary.ca/iosa/IM/

_______________________________________
Research In Progress



"Network Externalities, Technological Progress, and Competitive Upgrades." (with
Michael Turner) Mimeo, Department of Economics, University of Calgary 2002.


“Direct and Indirect Strategic Effects: A Taxonomy of Investment Strategies.” (with L.
Moldovan) Mimeo, Department of Economics, University of Calgary 2006.


“Market Power in the Alberta Red Meat Packing Industry.” (with D. Gordon) IAPR
Technical Paper 07-004, Institute for Advanced Policy Studies, University of Calgary
2007.
! •
“Platform Competition with Software Bundling.” (with J. Mathewson) Mimeo,
Department of Economics, University of Calgary 2007.


“Asymmetries, Simulation and the Assessment of Input Foreclosure in Vertical
Mergers.” (with A. Majumdar and M. Baldauf) Mimeo, Department of Economics,
University of Calgary 2010.
! •
“Coase, Hotelling and Capacity Constraints in Discrete Time: A Difference in
Economics” (with L. Vojtassak and J. Boyce) Mimeo, Department of Economics,
University of Calgary 2010.

_______________________________________
Presentations



“Regulatory Governance and the Alberta Integrated Electric System.” 11th Annual
Alberta Power Summit, Calgary, November 2010.


“Asymmetries, Simulation and the Assessment of Input Foreclosure in Vertical Mergers.”
Bates White’s Seventh Annual Antitrust Conference, Washington, D.C., June 2010.


“The Competition Act and the Fair Efficient and Open Competition Regulation.”
Workshop for the Alberta Utilities Commission, Calgary, April 2010 (with Barry
Zalmanowitz).


“Transmission Policy in Alberta and Bill 50.” School of Public Policy Workshop,
Electricity Transmission Policies: Issues and Alternatives, Calgary, October 2009 and the
National Energy Board, Calgary, February 2010.


“Economics of Vertical Mergers.” British Institute for International and Comparative
Law, 7th Annual Merger Conference, London, November 2008.


“Telecommunications in Canada: Market Structure and the State of the Industry.” 2008
Telecommunications Invitational Forum, Landgon Hall, Ontario, April 2008.
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“Cartel Cases Under Section 45: Is Proof of Market Definition the Achilles Heel?”
Panelist, Competition, Crime and Punishment, Canadian Bar Association National
Competition Law Section Spring Conference, Toronto, April 2008.


“Forbearance of Local Telecommunications in Canada: One Back, Two Forward?”
Telecommunications and Broadcasting Current Regulatory Issues and Policy Insight
Communications Conference, Ottawa, April 2007.


“The Economics of Non-Horizontal Merger Guidelines.” ENCORE Workshop on the
Assessment of Non-Horizontal Mergers, The Hague, April 2007.


“Stumbling Around in No Man’s Land is Dangerous: Competition Policy, the CRTC, and
Deregulation of Local Telecom in Canada.” Competition Policy in Regulated Industries:
Principles and Exceptions, C.D. Howe Institute Policy Conference, Toronto, November
2006.


“ Competition in Local Telecommunications in Canada: Grading the CRTC.” Delta
Marsh Annual Conference, Department of Economics, University of Manitoba,
Winnipeg, October 2006.


“Grading the CRTC: Forbearance from the Regulation of Retail Local Exchange Services
Telecom Decision 2006-15.” part of the Panel on Local Competition at the Annual
Meetings of the Canadian Economics Association, Montreal, May 2006.


“The Interface Between Competition Law and Intellectual Property in Canada: An
Uneasy Alliance or Holy War?” Presented at the Canadian Bar Association Annual Fall
Conference on Competition Law, Gatineau, November 2005.


“Game Theory and Industrial Organization: An Introduction.” Competition Tribunal,
Knowlton, Quebec, October 2005.


“The Impact of Vertical and Conglomerate Mergers on Competition: An Overview of the
Survey And Implications for Competition Policy.” DG IV European Commission,
Brussels, July 2004, UK Competition Commission, London, September 2005, British
Institute of International and Comparative Law/Competition Law Forum, Brussels,
September 2005 and Conference on Economics in Competition Policy, Ottawa, April
2006.


“The Economics and Competition Policy of Exclusionary Agreements.” Competition
Bureau, Gatineau, April 24-25, 2005.


“Intellectual Property Issues and Abuse: The IP/Competition Policy Interface in Canada.”
2004 Competition Law and Policy Forum, Langdon Hall, Cambridge, Ontario, April
2004.


“Efficiencies Gained and Paradise Lost? Or the Inverse? Comments on the Propane
Case.” Economics Society of Calgary Seminar Regulation vs. Competition: Different
Jeffrey Church


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Curriculum Vitae

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Shades of Grey, Calgary, October 2003.




“The Economics of Exclusionary Contracts and Abuse of Dominance in Canada”
Presented at the Canadian Bar Association Annual Fall Conference on Competition Law,
Hull, October 2003.


“Network Externalities, Technological Progress, and Competitive Upgrades” Presented at
PIMS-ASRA Alberta Industrial Organization Conference, Calgary, November 2002.


Panelist, The Changing Competition Law Landscape, Osler, Hoskin & Harcourt, Calgary,
June 2002.


Panelist, Efficiencies in Mergers Under the Competition Act, Annual Meeting of the
Canadian Economics Association, Calgary, June 2002.


"Specification Issues and Confidence Intervals in Unilateral Price Effects Analysis"
Presented at the Annual Meeting of the Canadian Economics Association, Calgary, June
2002.


“The Economics and Econometrics of Unilateral Effects Analysis.” Competition Bureau,
Gatineau, January 7th and 8th, 2002 (with Oral Capps, Jr. and H. Alan Love).


“Economics and Antitrust of Network Industries.” Competition Bureau, Gatineau,
January 2001.


"The Economics of Coordinated Effects and Merger Analysis." Presented at the Canadian
Bar Association Annual Fall Conference on Competition Law, Ottawa, September 2000.


"Network Externalities, Technological Progress, and Competitive Upgrades." Presented at
the Annual Meeting of the Canadian Economics Association, Vancouver, June 2000.
• "Competition Policy for Network Industries." Presented at Centre for the Study of
Government and Business New Challenges for Competition Policy Panel, Annual
Meeting of the Canadian Economics Association, Vancouver, June 2000.


"Applying Antitrust Concepts in IT Industries." Presented at Roundtable on Reassessing
the Role of Antitrust in Mega-Mergers and IT Industries Faculty of Law, University of
Toronto, June 2000.


"The Economics of Electricity Restructuring: The Case of Alberta." Canadian Law and
Economics Conference, Toronto, September 1999.


"Refusals to License and the IP Guidelines: Abuse of Dominance and Section 32."
McMillan Binch Symposium on Intellectual Property Rights and Competition Policy,
Toronto, June 1999.


"The Economics of Electricity Restructuring: The Alberta Case." presented at Economic
Society of Calgary conference Alberta's Electricity Market—Moving Towards
Deregulation, Calgary, May 1999.


"Competition in Natural Gas Transmission: Implications for Capacity and Entry."
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March 2011
Curriculum Vitae

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presented at Van Horne Institute conference The New World in Gas Transmission:
Regulatory Reform and Excess Capacity, Calgary, April 1999.


"Bill 27: The Regulatory Framework." presented at Canadian Institute of Resources Law
conference on Restructuring Alberta's Electricity System: How will It Work?, Calgary,
June 1998.


Panelist, Antitrust and Telecommunications, Global Networking '97 Conference, Calgary,
June 1997.


"Network Industries, Intellectual Property Rights, and Competition Policy." presented at
Author's Symposium on Competition Policy, Intellectual Property Rights and International
Economic Integration, Ottawa, May 1996.


Panelist, Symposium on Barriers to Entry, Bureau of Competition Policy, Ottawa, March
1995.


"Branded Ingredient Strategies," presented at the Summer Conference on Industrial
Organization, University of British Columbia, Vancouver, August 1994.


"Equilibrium Foreclosure and Complementary Products," the Annual Meetings of the
European Association for Research in Industrial Economics, Tel-Aviv, September 1993, the
Annual Meeting of the Canadian Economics Association, Ottawa, June 1993 and the Mini-
Conference on Network Economics at Tel Aviv University, July 1992.


"Competition Policy and the Intercity Passenger Transportation System in Canada,"
presented at the Van Horne Institute for International Transportation and Regulatory Affairs
symposium on The Final Report of the Royal Commission on National Passenger
Transportation, The University of Calgary, February 1993.


"Integration, Complementary Products and Variety," presented at the Annual Meeting of the
Canadian Economics Association, Prince Edward Island, June 1992 and
Telecommunications Research Policy Conference, Solomons Island, MA, September 1991.


"The Role of Limit Pricing in Sequential Entry Models," presented at the Twenty-Fifth
Annual Meeting of the Canadian Economics Association, Kingston, June 1991.


"Commodity Price Regulation in Canada: A Survey of the Main Issues," presented at the
Fifth Annual Regulatory Educational Conference, Canadian Association of Members of
Public Utility Tribunals, May 1991.


"Complementary Network Externalities and Technological Adoption," at the Twenty-Fourth
Annual Meeting of the Canadian Economics Association, Victoria, June 1990 and at the
Fifteenth Canadian Economic Theory Conference, Vancouver, June 1990.
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Curriculum Vitae

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_______________________________________
Invited Seminars



Faculty of Commerce and Business Administration, University of British Columbia, April
2002



Department of Economics, University of Toronto, March 2002


School of Business & Economics, Wilfred Laurier University March 2002


Competition Bureau, January 2002


Department of Economics, University of Laval, April 1996


Department of Economics, Carleton University, Ottawa, January 1996


Stern School of Business, New York University, December 1995


Bureau of Competition Policy, Industry Canada, Ottawa, March 1994


Department of Economics, Simon Fraser University, November 1992


Department of Economics, University of Victoria, November 1992


Department of Economics, University of Toronto, October 1991


Department of Economics, Queen's University, Kingston, October 1991


Department of Economics, University of Alberta, February 1990

_______________________________________
Refereeing



American Economic Review, Canadian Journal of Agricultural Economics, Canadian
Journal of Economics, Canadian Journal of Political Science, Canadian Public Policy,
C.D. Howe Institute, Energy Journal, European Economic Review, FCAR, Information
Economics and Policy, International Economics and Economic Policy, International
Economic Review, International Journal of the Economics of Business, International
Journal of Industrial Organization, Journal of Econometrics, Journal of Economic
Behavior and Organization, Journal of Economic Education, Journal of Economic
Psychology, Journal of Economics, Journal of Economics and Business, Journal of
Economics and Management Strategy, Journal of Industrial Economics, Journal of
International Economics, Journal of Law, Economics, & Organization, Management
Science, Marketing Science, National Science Foundation, RAND Journal of Economics,
Journal of Economic Surveys, Review of Industrial Organization, Review of Network
Economics, Routledge , SSHRC, University of Cambridge Press
Jeffrey Church


March 2011
Curriculum Vitae

Page 13 of 17

_______________________________________
Professional Service



Chair Canadian Bar Association National Competition Law Section Economics and Law
Committee, 2005-2007.


Vice-Chair Canadian Bar Association National Competition Law Section Economics and
Law Committee, 2004-2005.


Juror, James M. Bocking Memorial Award, Canadian Bar Association National
Competition Law Section, 2006, 2007, 2008, 2009, 2010.


Co-Editor, Journal of Economics & Management Strategy, 2001-2007.


Editorial Board, Canadian Journal of Economics, 1993-1996.


Theme Head Economics Sessions and Programme Committee, International
Telecommunications Society and the International Council for Computer Education
Global Networking '97 Conference, Calgary, June 1997.


Organizer, Roundtable on Vertical Mergers, Competition Committee, Directorate for
Financial and Enterprise Affairs, OECD, Paris, 2007. See http://www.oecd.org/dataoecd/
25/49/39891031.pdf


Organizer, Roundtable on Buyer Power, Competition Committee, Directorate for
Financial and Enterprise Affairs, OECD, Paris, 2008. See http://www.oecd.org/dataoecd/
38/63/44445750.pdf


External Examiner for E. Croft Ph.D, Policy Programme, Faculty of Commerce and
Business Administration, University of British Columbia, April 1999, B. Isaacs Ph.D,
Department of Economics, Simon Fraser University, May 2000, and J. Landa Ph. D,
Department of Economics Carleton University May 2001


House of Commons Standing Committee on Industry, Science and Technology
Roundtable Participant on Competition Policy, December 2001.


House of Commons Standing Committee on Industry, Science and Technology,
Deregulation of Telecommunications, February 2007.
_______________________________________
Teaching Experience


Graduate


Ph.D. Micro Theory


Industrial Organization


Regulatory Economics
Jeffrey Church


March 2011
Curriculum Vitae

Page 14 of 17

Undergraduate


Regulatory Economics


Competition Policy


Honours Micro Theory


Industrial Organization


Intermediate Microeconomics



Professional


Regulatory economics through the Centre for Regulatory Affairs.


Principles of Microeconomics, Industrial Organization and Competition Policy for the
Competition Bureau.

_______________________________________
Graduate Student Supervision/Examination


Completed


Supervisor, M. Ec. Programme, Mark Larsen, "Calgary Crossfield Sour Gas: A Case
Study in the Costs of Regulation," Department of Economics, University of Calgary,
1993.


Supervisor, M. A. Programme, George Given, "The Dynamics of Industries Characterized
by Complementary Network Externalities," Department of Economics, University of
Calgary, 1994.


Supervisor, M. Ec. Programme, R. Allan Wood, "Subsidies to Municipal Golfers in
Calgary, AB. ," Department of Economics, University of Calgary, 1995.


Supervisor, M. A. Programme, Marcy Cochlan, "Branded Ingredient Strategies,"
Department of Economics, University of Calgary, 1995.


Supervisor, M. Ec. Programme, Shaun Hatch, "Optimal Pricing and the Allocation of
Water Under Uncertainty: A Stochastic Nonlinear Programming Approach," Department
of Economics, University of Calgary, 1995.


Supervisor, M. A. Programme, Denelle Peacey, "Priority Pricing," Department of
Economics, University of Calgary, 1995.


Supervisor, M.A. Programme, Michael Turner, "Analysis of Product Upgrades in
Computer Software," Department of Economics, University of Calgary, 1999.


Supervisor, M.A. Programme, Kurtis Hildebrandt, "Market Dominance and Innovation in
Computer Software Markets," Department of Economics, University of Calgary, 1999.


Supervisor, M.A. Programme, Alex Harris, "Optimal Multiproduct Tolling on an Oil
Pipeline," Department of Economics, University of Calgary, 2000.
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Supervisor, M.A. Programme, Noelle Bacalso, "Conceptual Hazards Associated with
Power Purchase Arrangements," Department of Economics, University of Calgary, 2000.


Supervisor, M.A. Programme, Laura Jolles, “Antitrust Logit Model,” Department of
Economics, University of Calgary, 2005.


Supervisor, M.A. Programme, Mohamed Amery, “The Procurement of Ancillary Services
in Alberta,” Department of Economics, University of Calgary, 2007.


Supervisor, M.A. Programme, Graham Thomson, “Optimal Price Cap Regulation,”
Department of Economics, University of Calgary, 2008


Supervisor, M. A. Programme, Kevin Wipond, “ Market Power in the Alberta Electrical
Industry,” Department of Economics, University of Calgary, 2008.

Supervisor, M.A. Programme, Nicholas Janota, “Introducing Competition into Regulated
Network Industries: From Hierarchies to Markets in Canada’s Railroad Industry,”
Department of Economics, University of Calgary, 2009.


Supervisor, M.A. Programme, Cory Temple, “A Beggars’ Banquet? Copyright,
Compensation Alternatives, and Music in the Digital Economy,” Department of
Economics, University of Calgary, 2010.


Supervisor, Ph.D. Programme, David Krause, "Internalizing Network Externalities,"
Department of Economics, University of Calgary, 2002.


Supervisory Committee, Ph.D. Programme, Lucia Vojtassak, “Equilibrium Concepts in
Exhaustible Resource Economics.” Department of Economics, University of Calgary,
2006.


Examination Committee Member, M. Ec. Programme, Murray Sondergard, "An
Examination of the Efficient Markets Hypothesis for the Toronto Stock Exchange,"
Department of Economics, University of Calgary, 1992.


Examination Committee Member, M.A. Programme, Denise Froese, "Auctioning Private
Use of Public Land," Department of Economics, University of Calgary, 1993.


Examination Committee Member, M.Ec. Programme, Merrill Whitney, " Economic
Espionage as a Form of Strategic Trade Policy" Department of Economics, University of
Calgary, 1994.


Examination Committee Member, M.Ec. Programme, Robert Richardson, "North-South
Disputes Over IPRs" Department of Economics, University of Calgary, 1994.


Examination Committee Member, M. Ec. Programme, Eva Cudmore, "The Viability of
New Entry into the Alberta Electrical Generation Industry," Department of Economics,
University of Calgary, 1997.


Examination Committee Member, M. A.. Programme, Geok (Suzy) Tan, Course Based
M.A, Department of Economics, University of Calgary, 1997.
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Examination Committee Member, M.A. Programme, Kris Aksomitis, "Strategic
Behaviour in the Alberta Electricity Market," Department of Economics, University of
Calgary, 2002.
! Current


Supervisor, M.A. Programme, Susan Baker, Jecielle Alonso, and Michael Ata,
Department of Economics, University of Calgary.

______________________________________
University Service



University Research Grants Committee 1994/95


Dean’s Academic Appointment Committee, Department of Mathematics and Statistics 2001


ISEEE Tier II Chair in Energy and Climate Change Search Committee 2005/06


Faculty of Social Sciences Academic Program Review Committee 2000/01


Faculty of Social Sciences Executive Council 2002/03


Department of Economics, Ad Hoc Outreach Committee 2001/02


Curriculum Fellow, Department of Economics, 2001


Department of Economics Representative on Van Horne Institute Sub-Committee on
Centre for Regulatory Affairs 1997/98


Department of Economics Advisory Committee 1997/98


Department of Economics Undergraduate Curriculum Committee 1993/94, 1994/95,
1996/97, 1997/98, 1999/00, 2000/01, 2001/02, 2010/11


Department of Economics Honours Advisor 1992/93, 1993/94, 1994/95, 2006/07


Department of Economics Hiring Committee 1990/91, 1991/92, 1994/95, 1998/99,
1999/00, 2002/03, 2003/04, 2004/05, and 2005/06


Department of Economics Computer Committee 1992/93, 1993/94, 1996/97, and 1997/98


Department of Economics Ph.D. Ad Hoc Committee 1990/91 and 1992/93


Department of Economics Ad Hoc Committee on the Status of Women 1991/92


Department of Economics Striking Committee 1991/92


Department of Economics Guest Lecturers Committee 1990/91 and 1991/92


Department of Economics Graduate Curriculum Committee 1989/90


Department of Economics Library Coordinator 2006/07


Department of Economics Graduate Studies Committee 2007/08 and 2008/09


Department of Economics Fund Raising Coordinator 2006/07, 2007/08, and 2008/09


University of Calgary Appointment Appeals Committees 2008


Haskayne School of Business, Academic Appointment Review Committee 2007/08,
2008/09
Jeffrey Church


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General Promotions Committee, University of Calgary 2008/2009, 2010/2011

______________________________________
Consulting Experience
President of Church Economic Consultants Ltd., for whom I have written consulting reports and
provided advice on issues in regulatory and antitrust economics for Alberta Beef Producers, Apotex,
Bayer CropScience, BC Ferries, the Canadian Association of Petroleum Producers, the Canadian
Cattlemen’s Association, the Canadian Competition Bureau, The Coca-Cola Company, The
Conference Board of Canada, Enbridge Pipelines, EPCOR, European Commission, Foothills
Pipelines, Google Inc., James Richardson International Limited, Mackenzie Explorers Group, Maple
Leaf Foods, Microcell, Nokia, Nova Gas Transmission, OECD Competition Division, Pacific Gas &
Electric, Pan Alberta Gas, PanCanadian Petroleum, Peace Pipe Line, Perimeter Transportation,
Rogers Communications, Superior Propane, TransAlta, TransCanada Pipelines, Williams Energy,
and eight major motion picture film studios.
______________________________________
Other


3M National Coaching Certification Program Level 1 Softball January 2002


3M National Coaching Certification Program Coach Level Hockey November 2002


3M National Coaching Certification Program Level 1 Baseball September 2003