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Ottawa, 12 August 2013

Our Reference: 8622-Q15-201310508

By email

Mr. Dennis Béland
Vice President, Regulatory Affairs – Telecommunications,
Quebecor Media Inc.
612 St-Jacques St., 15th floor, South tower
Montréal, Quebec H3C 4M8
dennis.beland@quebecor.com

Re: Application by Quebecor to review and vary the Wireless Code

Dear Mr. Béland,

This is in reference to the application by Quebecor Media Inc. (Quebecor), on behalf of itself and its subsidiary Videotron G.P. (Videotron), to review and vary certain elements of Telecom Regulatory Policy 2013-271 (the Wireless Code or the Code).

Commission staff has reviewed Quebecor’s application and determined that additional information is required. Accordingly, Quebecor is to its file responses to the request for additional information attached to this letter by 19 August 2013, copying all parties. In light of this request, Commission staff considers that interveners could benefit from additional time in order to comment on Quebecor’s application. The deadline to submit comments is therefore extended to 26 August 2013. Reply comments will be due no later than 3 September 2013.

As set out in Broadcasting and Telecom Information Bulletin 2010-961, Quebecor may designate certain information as confidential. Quebecor must provide an abridged version of the document involved, accompanied by a detailed rationale to explain why the disclosure of the information is not in the public interest.

All submissions are to be made in accordance with the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, SOR/2010-277.

Yours sincerely,

{original signed by}

Steven Harroun
Acting Director General, Strategic Policy

cc: Neil Barratt, CRTC; distribution list

Distribution List
jlo@piac.ca; jlawford@piac.ca; slambert-racine@uniondesconsommateurs.ca; tisrael@cippic.ca; mac@mediac.ca; bmilligan@mediac.ca; regulatory.matters@corp.eastlink.ca; gary.wong@mobilicity.ca; whitehurst@consumerscouncil.com; bell.regulatory@bell.ca; Bob.Boron@publicmobile.ca; iworkstation@mtsallstream.com; ljackson@windmobile.ca; regulatory.affairs@telus.com; rwi_gr@rci.rogers.com; document.control@sasktel.com;

Appendix – Request for Information

1) As set out in Telecom Regulatory Policy 2013-271, “The Wireless Code will take effect on 2 December 2013, and will apply to all new or amended wireless service contracts from that day forward.” In addition, the Wireless Code will apply to all wireless contracts, regardless of when they are signed, by no later than 3 June 2015.

Identify the costs of implementing the Wireless Code, and estimate Quebecor’s total cost if the Commission:
a) were to approve its application; and
b) were to deny its application.

Provide supporting evidence to justify your response. In your response, clearly indicate those costs that would be incurred under both scenarios (e.g. customers that are expected to renew, amend, or otherwise enter into a new contract within that period of time).

2) Refer to the following transcript from the Commission’s 11 February 2013 public hearing:

10389 COMMISSIONER POIRIER: I was also wondering, for your clients. As I understand it, there is not a contract for the service, but there is a contract for the device.

10390 Did I get that right? You seem to be hesitating – is that not what you’ve been saying?

10391 MR. BÉLAND: Without getting into the legal arguments, in fact, there is a contract for both.

[TRANSLATION]

Please clarify how Quebecor views the relationship between the wireless services and the repayment of the device subsidy. Does this constitute one or two contracts? Please explain.

3) The Code establishes, at paragraph 369, a date upon which all Canadian wireless customers will be covered by the code (3 June 2015). In the absence of this date, Quebecor’s interpretation of indeterminate contracts could mean that some of Videotron’s customers might never be covered by the Code.

In addition, the Code sets out the principle that “it is in the best interest of consumers that the Wireless Code be implemented as soon as practicable”. Please comment on the impact of the requested relief on Videotron’s consumers, with reference to this principle.

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