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ARCHIVED - Telecom Procedural Letter Addressed to Dennis Béland (Québecor Média)

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Ottawa, 1 December 2015

Our reference:  8661-P8-201510199

BY EMAIL

Mr. Dennis Béland
Vice President, Regulatory Affairs, Telecommunications
Québecor Média
612 St-Jacques Street, 15th Floor, South Tower
Montréal, Québec  H3C 4M8
dennis.beland@quebecor.com

Re:  Part I Applications regarding Vidéotron’s practices related to its mobile wireless Unlimited Music service – Requests for Information

Dear Mr Béland:

Attached to this letter are requests for information issued to Québecor Média inc. (QMI) (or Vidéotron s.e.n.c. (Vidéotron)).

Responses to these requests for information are to be filed with the Commission by 16 December 2015.

As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential.  A person designating information as confidential must provide a detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.

Sincerely,

Original signed by

Andrew Falcone
Senior Manager, Strategic Planning and Research
Telecommunications Sector

c.c.: 

Attach (1)

ATTACHMENT

Questions for QMI

  1. What criteria does Vidéotron use to determine whether an online audio streaming provider is eligible for zero-rating under the Unlimited Music service?
  2. Have any online streaming audio services sought to be included in Vidéotron’s Unlimited Music offering, but were not included by Vidéotron?  If so, explain in detail why such services were not included.
  3. What factors did Vidéotron consider in making its business decision not to include radio stations in Unlimited Music service?
  4. Would applications allowing Canadians to stream user-owned audio content for their own use qualify for zero-rating under the Unlimited Music service (e.g. content stored in the cloud and streamed using any audio streaming applications)?  Explain why or why not.
  1. Does Vidéotron currently zero-rate any other applications or services? If so, identify each application or service. Does Vidéotron plan to zero-rate any other applications or services in the future?  If so, provide the details of your plans.
  2. For the purposes of billing, how does Vidéotron distinguish between the data used to stream audio and other data usage associated with audio streaming apps (e.g. browsing websites associated with the apps, downloading album covers, sharing playlists)?
  3. With respect to data usage associated with Unlimited Music service:
    1. Confirm that while data usage for the Unlimited Music service does not count towards a user’s standard monthly data allowance, data usage does count towards the user’s monthly data allowance for music streamed: (a) over a virtual private network (VPN), (b) at a bitrate that exceeds 128Kbps, and (c) via tethering.
    2. If data usage for Unlimited Music is counted as set out above, explain why Vidéotron imposes these conditions on use of Unlimited Music.
    3. Are there any other Fair/Acceptable/Excessive usage policies that apply to Unlimited Music? If so, describe each of these policies.
  4. With respect to technical requirements to participate in Unlimited Music:
    1. Identify and describe all technical criteria and/or requirements that must be met by online streaming music companies that participate in the Unlimited Music service.
    2. For each company participating in the Unlimited Music program, provide the technical document containing the list of Network Flow Parameters referred to in its agreement with Vidéotron.
  5. Confirm that the Unlimited Music service is only available to subscribers of wireless packages with usage caps of 2 GB or more or 1 GB in the case of a subscriber also subscribing to cable Internet service. What factors did Vidéotron consider in requiring that the Unlimited Music service only be available to subscribers to these wireless packages? Explain why Unlimited Music service was not made available to subscribers to plans with lower usage caps.
  6. How many hours of music streaming within the Unlimited Music service does 1 GB represent? Provide the methodology and assumptions made.
  7. Assume that the Unlimited Music service was available as of 1 September 2014. From 1 September 2014 to 1 September 2015, provide on a monthly basis:
    1. The total number of mobile wireless subscribers to a mobile wireless data service.
    2. The percentage of those subscribers who were eligible for the Unlimited Music service.

    Provide the methodology and any assumptions made.

  8. From 1 September 2015 to 30 November 2015 provide, on a monthly basis:
    1. The total number of Vidéotron’s mobile wireless subscribers to a mobile wireless data service.
    2. The percentage of those subscribers that are eligible for the Unlimited Music service.
  9. From 1 December 2015 to 1 December 2016 provide, on a monthly basis, the following forecasted data:
    1. The total number of forecasted mobile wireless subscribers to a Vidéotron mobile wireless data service.
    2. The percentage of those subscribers that are forecasted to be eligible for the Unlimited Music service.

    Provide the methodology and assumptions made for your forecasts.

  10. From 1 September 2015 to 1 December 2015, on a monthly basis, provide the following data:
    1. The number of Vidéotron customers that were eligible for Unlimited Music service that actually used the service (active customers).
    2. Both the average and median of data usage by active customers further broken down by a) data usage under their mobile data package, b) data usage that exceeds their data caps, and c) data usage for Unlimited Music service.
    3. The average usage by the top 5% of the heaviest active customers broken down by a) data usage under their mobile data package, b) data usage that exceeds their data caps, and c) data usage for Unlimited Music Service.

    Provide the methodology and any assumptions made.

  11. From 1 December 2015 to 1 December 2016 provide, on a monthly basis, the following forecasted data:
    1. The number of customers that are forecasted to be active customers of the Unlimited Music service.
    2. The forecasted average and median of data usage by active customers broken down by a) data usage under their mobile data package, b) data usage that exceeds their data caps, and c) data usage for Unlimited Music service.

    Provide the methodology and any assumptions made.

  12. In its submission Vidéotron suggested, in general, that the increase in traffic due to expanded music streaming may be as much as 7.7%, but that this would be manageable in terms of network forecasting and provisioning. It also argued that there is no meaningful risk of service degradation to the broader customer base a result of the Unlimited Music service:
    1. Could a customer’s monthly data usage related to Unlimited Music be greater than the customer’s monthly data allowance included in their wireless plan?  Provide detailed evidence in support of Vidéotron’s view, including actual and forecast usage data related to Unlimited Music.
    2. If consumers’ use of the Unlimited Music service results in total monthly usage that exceeds their monthly data caps, provide a detailed explanation as to why the advantage to these consumers of “free” data usage associated with Unlimited Music is justified under s. 27(2) of the Telecommunications Act.  Is there a level of usage associated with Unlimited Music that would render the advantage “undue”?  Is there a level at which Vidéotron will reconsider its offering?  Provide full rationale in support of the company’s position.
    3. If, as Vidéotron has stated, congestion is manageable and there is no meaningful risk of service degradation as a result of offering Unlimited Music service, explain why Vidéotron did not either increase or eliminate data usage caps for your broader customer base instead of zero-rating certain applications or services.
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