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Ottawa, 20 July 2018

Our reference:  1011-NOC2018-0098

BY EMAIL

Distribution list

RE:  Lower-cost data-only plans for mobile wireless services, Telecom Notice of Consultation 2018-98 – Requests for information

Dear Madam, Sir:

With the issuance of Telecom Notice of Consultation 2018-98 (the Notice) in March of this year,Footnote 1 the Commission initiated a proceeding to make lower-cost data-only plans broadly available in the mobile wireless market. Pursuant to the process set out in the Notice, reply comments from the national wireless carriersFootnote 2 were submitted on 29 June 2018.

Commission staff is of the view that additional information is needed to further develop the record of the proceeding. As such, parties are asked to respond to the requests for information appended to this letter. Parties will also be given an opportunity to comment on the new evidence that will be filed, and reply to those comments if they so choose. The procedural steps and dates for this additional process are set out below.  

These submissions must be received, not merely sent, by these dates.

Parties are reminded that any comments or reply comments that are filed should be limited to the contents and matters raised in the responses to the requests for information, and should not introduce new evidence or directly address evidence that was previously submitted.

For greater clarity, any person required to respond to this letter who has not previously participated in the proceeding will be considered a party to this proceeding going forward.

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.

Yours sincerely,

Original signed by

Philippe Kent
Director, Competition and Emergency Services Policy
Telecommunications Sector

c.c.:     Jeremy Lendvay, CRTC, 819- 997-4946, jeremy.lendvay@crtc.gc.ca
Sylvie Labbé, CRTC, 819-953-4945, sylvie.labbe@crtc.gc.ca

Distribution List
bell.regulatory@bell.ca; regulatory.affairs@telus.com; rwi_gr@rci.rogers.com; regulatory.matters@corp.eastlink.ca; dennis.beland@quebecor.com; regaffairs@quebecor.com; regulatory@sjrb.ca; document.control@sasktel.com; regulatory@icewireless.ca; cj.prudham@corp.xplornet.com; jlawford@piac.ca; execdir@frpc.net; gloria@cacmanitoba.ca; bywil@pilc.mb.ca; tisrael@cippic.ca; regulatory@openmedia.org; lisa@deafwireless.ca; Vicky.Eatrides@canada.ca.

Attachment

Requests for information

Questions for Bell Mobility; Rogers; TELUS; Shaw; Videotron; Eastlink; SaskTel; Ice Wireless; Xplornet; the Competition Bureau; CIPPIC and OpenMedia; the Forum for Research and Policy in Communications; the Manitoba Branch of the Consumers' Association of Canada and the Aboriginal Council of Winnipeg; and PIAC

  1. Bell Mobility, TELUS and Shaw have questioned or contested, among other things, the Commission’s ability under section 24 of the Telecommunications Act (The Act) to mandate the provision of a lower-cost data-only mobile wireless plan or to impose a price ceiling on such plans. Some of these parties suggest that, for the Commission to implement such measures, it must first reverse previous forbearance determinations and resume exercising its powers and duties under at least section 25 and subsection 27(1) of the Act.

    A component of past Commission analyses of whether forbearance under section 34 of the Act is or remains necessary or appropriate for a given service has often been an assessment of market conditions for that service. In this regard, the Competition Bureau submitted that the national wireless carriers enjoy market power in at least some parts of Canada, and that market power is not likely to be limited to customers who purchase only lower-capacity products. The Competition Bureau added that even those who purchase high-capacity wireless plans likely face at least somewhat higher prices than would be delivered in a competitive market.

    One potential method of addressing these and similar concerns raised on the record of the proceeding would be for the Commission to assess the market conditions associated with lower-cost data-only plans as part of this proceeding for the purpose of conducting an analysis under section 34 of the Act, and in particular: whether a segment of the retail mobile wireless market, namely that of lower-cost data-only plans, is subject to sufficient competition to protect the interests of users; whether continued forbearance from price regulation of this segment would be likely to impair unduly the establishment or continuance of a competitive market for such services; or whether continued forbearance would be consistent with the Canadian telecommunications policy objectives.

    In order to permit the Commission to perform such an assessment, should it choose to do so, please respond to the following:

    1. Indicate whether lower-cost data only plans (for example plans that are less than $25 and contain 1GB or less of data) ought to be considered a relevant product market for the purposes of an assessment under section 34. If not, what would the relevant product market be in this context?
    2. In light of the fact that the Commission has found there to be a gap in the market with respect to lower-cost data-only plans, discuss whether competition in this specific market segment is sufficient to protect the interests of users and whether continued forbearance from price regulation of this segment would be likely to impair unduly the establishment or continuance of a competitive market for such services.
    3. If the Commission were to find that competition is not sufficient to protect the interests of users in the market for lower-cost data-only plans, discuss whether it would be appropriate for the Commission to establish a price ceiling and capacity floor for lower cost data only plans using its powers under section 24, subsection 27(1) and subsection 27(5) of the Act. If so, how should the Commission go about determining an appropriate amount for a price ceiling and capacity floor, and what should those amounts be?
    4. Discuss whether, instead of establishing a price ceiling and capacity floor under section 24 and subsection 27(1), it would be more appropriate for the Commission to require the national wireless carriers to file tariffs and cost studies for a mandated lower-cost data only plan pursuant to section 25 of the Act. If so, discuss whether it would be appropriate for the Commission to set interim rates for the national wireless carriers’ mandated lower-cost data only plans and comment on what those amounts should be in terms of price and capacity.

Questions for Bell Mobility, Rogers, and TELUS

  1. On a price per GB basis, the postpaid plans proposed by Bell Mobility and TELUS work out to $60 per GB of data (and $50 per GB for TELUS’ prepaid plan), and the plan offered by Rogers works out to $62.50 per GB of data. Several parties, including many Canadian consumers, submitted that the companies’ proposals represented a high price per GB, especially compared to other mobile wireless plans available in the Canadian marketFootnote 3 and internationally, and proposed alternative plans with higher capacity, a lower price per GB or both. For example:
    • the Forum for Research and Policy in Communications (FRPC) proposed, among other things, a plan at $7 for 1 GB;Footnote 4
    • the Samuelson-Glushko Canadian Internet Policy & Public Interest Clinic (CIPPIC) and OpenMedia proposed plans for about $2 per GB;Footnote 5
    • the Manitoba Branch of the Consumers' Association of Canada and the Aboriginal Council of Winnipeg  supported the “CRTC Flex Plan” proposed by Mr. Benjamin Klass and Dr. Dwayne Winseck, in which a price of $20 for 1 GB is proposed;Footnote 6 and
    • the vast majority of Canadian customers that submitted alternative plans as part of their intervention in this proceeding proposed capacity of at least 1 GB for a lower price per GB than the lowest price of the companies’ proposals (i.e., under $25). 

    As well, the Competition Bureau provided international examples of data-only plans in the USA, the UK and Germany that are significantly less in terms of price per GB than what is being proposed by Bell Mobility, Rogers and TELUS in their plans, even accounting for differences in currencies.

    In light of these comments, as well as the Commission’s original views as to the first lower-cost data only plan proposed,Footnote 7 will your company propose an alternative lower-cost data-only plan (alternative plan) that would address the concerns raised by parties and meet the expectations of Canadians reflected on the record of the proceeding? If not, explain why not.

  2. The Competition Bureau submitted that it supported the establishment of a condition of service requiring national wireless service providers to make lower-cost data-only plans available on a temporary basis, until such time that the Commission can establish longer-term, more robust solutions to competition issues that may exist in this market.

    Should the Commission decide to impose a requirement on the national wireless carriers to make specific lower-cost data only plans available, indicate, with supporting rationale, how long such a requirement should remain in place.

  3. For each of the years 2014 to 2017 as well as forecasts for each of the years 2018 and 2019, provide your company’s (i) total subscribers to your retail mobile wireless services; (ii) average monthly mobile wireless data consumption per subscriber; and (iii) the median amount of monthly mobile wireless data consumption per subscriber. Include separate totals for any other brands your company operates. Include all assumptions used.
  4. For each of the years 2017 and 2018, and for each province/territory, provide a list of all of your company’s mobile wireless plans that were offered for $30 per month and below. Provide a separate list for any other brands your company operates. For each plan, provide:  (i) price; (ii) voice, text, and/or data allotments; (iii) overage rate; and (iv) number of subscribers to the plan (at year end for 2017 and currently for 2018).
  5. For each of the years 2014-2018, and for each province/territory, provide a list of your company’s tablet plans that were offered on a stand-alone basis (i.e. not offered in conjunction with an underlying mobile wireless plan or other services provided by the company). Provide a separate list for any other brands your company operates. For each plan, provide: (i) price; (ii) data allotments; (iii) overage rate; and (iv) number of subscribers to the plan (at year end for 2014-2017 and currently for 2018). Also explain why any tablet plans that were previously offered on a stand-alone basis are no longer offered on such a basis.
  6. Should the Commission decide to accept your company’s proposed or alternative plans, indicate your projections as to the level of uptake for this service, broken down by brand and province/territory, for each of the next three years (2019-2021). Provide your views as to the whether this service offering could improve overall wireless adoption in Canada, by attracting new subscribers to mobile wireless services.
  7. Indicate whether your proposed and/or alternative plans would include or allow subscribers to add voice and/or text services and if so, provide the terms and conditions under which these services would be available.
  8. Should the Commission decide to accept your company’s proposed or alternative plans without any further regulatory intervention, how long does your company intend to make its proposed plans available to consumers with the same price, capacity, terms and conditions?

Questions for Bell Mobility

  1. Indicate, with supporting rationale, what would be an appropriate amount of data for a lower-cost data only plan offered at a monthly rate of (i) $10; (ii) $15; (iii) $20; and (iv) $25. What attributes or restrictions would be associated with such plans?
  2. Indicate how the company intends to meet its obligations associated with the provision of 9-1-1 service for the proposed and/or alternative plans.
  3. With respect to your proposed and/or alternative plan(s), for both the prepaid and postpaid options, indicate, with relevant details, whether
    1. they would be offered under a specific term commitment or on a month-to-month basis; and
    2. they would be offered on a “bring your own device basis” or whether the company would offer the option to obtain subsidized handsets.
  4. In its proposal, Bell Mobility indicated that it planned to launch its proposed plan under its Virgin Mobile brand and provided rationale as to why it believed that offering the plan under this flanker brand was the best way to address the Commission’s objective for such a service.
    1. Provide a list detailing any differences existing between mobile wireless services offered through the Bell Mobility brand and the company’s other brands (e.g. difference in network coverage, major terms and conditions, level of support available to customers, etc.).
    2. Indicate, with supporting rationale, why the company’s proposed and/or alternative plan(s) should not also be offered under the Bell Mobility brand.
  5. In its proposal, Bell Mobility indicated that there was a one-time subscriber identification module (SIM) card fee of $10 for prepaid plans and a one-time connection charge of $30 for postpaid plans.
    1. Indicate whether any other one-time or recurring charges would apply to the proposed and/or alternative plans. If so, provide a description of what those charges would be (e.g. amount of the charge, whether it would be a one-time or recurring charges).
    2. Should the proposed plans be offered through the Bell Mobility brand, provide a list of and describe all one-time and/or recurring charges that could apply to the company’s proposed and/or alternative plan, if different.
    3. Explain, with supporting rationale, why any such charges should not be considered to adversely affect the affordability of the proposed and/or alternative plans?
  6. Indicate whether subscribers to the proposed and/or alternative plan(s) would be allowed to use additional data, and if so what would be the options available (e.g., data overage increments and charges).  Also indicate, with supporting rationale, whether the company intends to offer the same data overage increments and charges that would be offered to the company’s other mobile wireless subscribers. Outline any differences between the plans if offered under the Virgin brand as compared to being offered under the Bell Mobility brand, and explain how any such differences would be consistent with the objective of affordability.
  7. Indicate whether your company intends to impose network usage limitations that would apply to the proposed and/or alternative plans but that do not apply to customers on other plans (e.g. subscribers only being able to use the proposed plans within the company’s network footprint versus being permitted to roam on other carriers’ networks). If so,
    1. describe what these limitations would be, including, but not limited to, the customer’s ability to access 9-1-1;
    2. indicate, with supporting rationale, why the company intends to impose such limitations;
    3. explain what would be the impact on the proposed and/or alternative plans if the company were to offer the plan without these limitations; and

    Also indicate whether there will be other limitations for the customers of your proposed and/or alternative plans compared to customers subscribing to your other plans.

  8. Describe any tools that would be available to the subscribers of the company’s proposed and/or alternative plans to enable them to monitor and manage their data usage (e.g. data usage alert, data usage calculator). Also describe the data monitoring and management tools that would be available to these subscribers should the proposed and/or alternative plans be required to be offered through the Bell Mobility brand.
  9. Bell Mobility indicated that the company would showcase its proposed plan in the rate plan section of the Virgin Mobile website and communicate the launch of the plan through Virgin Mobile's distribution channels.
    1. Indicate whether other promotional and marketing means are generally used to promote the company’s mobile wireless plans. If so, provide a list of these other means and indicate whether the proposed and/or alternative plans would be subject to comparable promotional and marketing efforts. Also indicate to what extent the company’s sales staff would be trained to promote and respond to inquiries regarding these plans.
    2. Provide the current number of mobile wireless services points of sale or retail outlets, broken down by province/territory and for each brand the company operates.
  10. Bell Mobility indicated that its proposed plan would be introduced within 120 days after the Commission’s approval. Explain why a 120-day timeframe would be required to introduce the proposed and/or alternative plans. Also indicate why Bell Mobility now proposes to introduce the plan within 120 days when it indicated, in the process that led to Telecom Decision 2018-97, that it could introduce a similar plan within 90 days.Footnote 8

Questions for Rogers

  1. Indicate, with supporting rationale, what would be an appropriate amount of data for a lower-cost data only plan offered at a monthly rate of (i) $10; (ii) $15; (iii) $20; and (iv) $30. What attributes or restrictions would be associated with such plans?
  2. Indicate whether Rogers’ proposed and/or alternative plan(s) would be available under the Rogers brand or under one of the company’s other brands.
    1. Provide a list detailing any differences existing between mobile wireless services offered through the Rogers brand and the company’s other brands (e.g. difference in network coverage, major terms and conditions, level of support available to customers, etc.).
    2. If Rogers intends to provide the plan under one of its other brands, indicate
      1. under which brand(s) Rogers intends to offer the plans;
      2. why the company considers it appropriate to offer its plans through its other brand(s); and
      3. why the company’s plans should not also be offered under the Rogers brand.
  3. In its proposal, Rogers indicated that subscribers must purchase a subscriber identity module (SIM) card from Rogers if the device they wish to use does not already have one, and that the price of a SIM card would be $10.
    1. Indicate whether any other one-time or recurring charges would apply to the company’s proposed and/or alternative plan(s). If so, provide a description of what those charges would be (e.g. amount of the charge, whether it would be a one-time or recurring charges).
    2. If Rogers intends to provide its proposed or alternative plan(s) under one of its flanker brands, provide a list of and describe all one-time and/or recurring charges that could apply to the company’s plan(s) if they were offered under the Rogers brand instead.
    3. Explain, with supporting rationale, why any such charges should not be considered to adversely affect the affordability of the proposed plans?
  4. In its proposal, Rogers indicated that the company’s proposed plan would be available in Rogers’ mobile wireless LTE network footprint, but that subscribers to this plan would be unable to access extended domestic coverage, nor be eligible for Rogers’ Roam Like Home feature when abroad.
    1. Provide justification explaining why the customers subscribing to the proposed and/or alternative plan should not be able to make use of the same domestic or international roaming services available to subscribers on other plans.
    2. Indicate whether there will be other limitations for the customers of your proposed and alternative plan compared to customers subscribing to your other plans, including, but not limited to, the customer’s ability to access 9-1-1.
  5. In its proposal, Rogers indicated that subscribers to its proposed postpaid plan will receive usage notifications when they surpass 90% and 100% of their monthly data allowance. Rogers also indicated that subscribers to its proposed prepaid plan will receive a similar usage notification at 100% of their data allowance.

    Describe any other tools that would be available to the subscribers of the proposed and/or alternative plans to enable them to monitor and manage their data usage. If Rogers intends to offer its proposed and/or alternative plan through one of its flanker brands, indicate when subscribers would receive data usage notifications and describe the data monitoring and management tools that would be available to these subscribers in that case.

  6. Rogers indicated that the proposed plans would be readily available and visible on the company’s website and that its frontline staff would be trained and to respond to any inquiry from interested customers.
    1. Indicate whether other promotional and marketing means are generally used to promote the company’s mobile wireless plans.  If so, provide a list of these other means and indicate whether the proposed and/or alternative plans would be subject to comparable promotional and marketing efforts. Also indicate to what extent the company’s sales staff, in addition to being trained to respond to inquiries regarding these plans, would be trained to promote them.
    2. Provide the current number of mobile wireless services points of sale or retail outlets, broken down by province/territory and for each brand the company operates.
  7. Rogers indicated that its proposed prepaid and postpaid plans would be introduced within 120 days and 90 days after the decision respectively. Explain why a 90- or a 120-day timeframe would be required to introduce the proposed and/or alternative plans.
  8. In its reply comments, Bell Mobility submitted that it would extend its accessibility add-on to its lower-cost data only plan. Does your company have plans to extend its own accessibility offerings in conjunction with its lower-cost data-only plans? If so, explain how. If not explain why not, with supporting rationale.

Questions for TELUS

  1. Indicate, with supporting rationale, what would be an appropriate amount of data for a lower-cost data only plan offered at a monthly rate of (i) $10; (ii) $15; (iii) $20; and (iv) $25. What attributes or restrictions would be associated with such plans?
  2. Indicate how the company intends to meet its obligations associated with the provision of 9-1-1 service for the proposed and/or alternative plans.
  3. In its proposal, TELUS indicated that it would offer its prepaid and postpaid proposed plans through its Public Mobile and Koodo brands respectively, and provided reasons why the plans should be offered through these brands.
    1. Provide a list detailing any differences existing between mobile wireless services offered through the TELUS Mobility brand and the company’s other brands (e.g. difference in network coverage, major terms and conditions, level of support available to customers, etc.).
    2. Indicate, with supporting rationale, why the company’s proposed and/or alternative plans should not also be offered under the TELUS Mobility brand.
  4. Indicate whether any one-time or recurring charges (e.g. subscriber identification module [SIM] card charge, connection charge) would apply to the company’s proposed and/or alternative plans. If so, provide a description of what those charges would be (e.g. amount of the charge, whether it would be a one-time or recurring charges).  Should the proposed and/or alternative plans be offered through the TELUS Mobility brand, provide a list of and describe all one-time and/or recurring charges that could apply to the company’s plans, if different.  Also explain, with supporting rationale, why any such charges should not be considered to adversely affect the affordability of the proposed plans?
  5. TELUS indicated that prepaid and postpaid subscribers of its proposed plans would have the ability to add data capacity through add-ons, and that postpaid customers would also be able to use additional data on a pay-per-use basis.

    Provide the charges for overage and data add-ons that would apply to the proposed and/or alternative plans. Also indicate, with supporting rationale, whether the company intends to offer the same data overage and add-on charges that would be offered to the company’s other mobile wireless subscribers. Outline any differences between the plans if offered under the Public Mobile or Koodo brand as compared to being offered under the TELUS Mobility brand, and explain how any such differences would be consistent with the objective of affordability.

  6. Indicate whether your company intends to impose network usage limitations that would apply to the proposed and/or alternative plans but that do not apply to customers on other plans (e.g. subscribers only being able to use the proposed plans within the company’s network footprint versus being permitted to roam on other carriers’ networks). If so,
    1. describe what these limitations would be, including, but not limited to, the customer’s ability to access 9-1-1;
    2. indicate, with supporting rationale, why the company intends to impose such limitations;
    3. explain what would be the impact on the proposed and/or alternative plans if the company were to offer the plan without these limitations; and

    Also indicate whether there will be other limitations for the customers of your proposed and/or alternative plans compared to customers subscribing to your other plans.

  7. In its proposal, TELUS indicated that Public Mobile customers are notified when they use 75%, 95% and 100% of their data, and that Koodo customers are notified when they use 50%, 90% percent and 100% of their data.

    Describe any other tools that would be available for subscribers to the proposed and/or alternative plans to enable them to monitor and manage their data usage. Also indicate when subscribers would receive data usage alerts should the proposed and/or alternative plans be required to be offered through the TELUS Mobility brand, and describe the data monitoring and management tools that would be available to these subscribers.

  8. TELUS indicated that the company is promoting its prepaid data-only plans through out-of-home advertising, digital advertising, and on the Public Mobile website. TELUS also indicated that its proposed postpaid plan would be promoted with equal prominence alongside all the other rate plans on the Koodo website and in-store, and that TELUS Mobility customer service team members will be trained to cross-promote both the Public Mobile and the Koodo data-only plans to customers who contact TELUS seeking lower-priced data-only wireless solutions.
    1. Indicate whether other promotional and marketing means are generally used to promote the company’s mobile wireless plans. If so, provide a list of these other means and indicate whether the proposed and/or alternative plans would be subject to comparable promotional and marketing efforts. Also indicate to what extent the company’s sales staff would be trained to promote and respond to inquiries regarding these plans.
    2. Provide the current number of mobile wireless services points of sale or retail outlets, broken down by province/territory and for each brand the company operates.
  9. Indicate, with supporting rationale, when the proposed postpaid and/or alternative plans could be introduced.
  10. In its reply comments, Bell Mobility submitted that it would extend its accessibility add-on to its lower-cost data only plan. Does your company have plans to extend its own accessibility offerings in conjunction with its lower-cost data-only plans? If so, explain how. If not explain why not, with supporting rationale.

Questions for Shaw, Videotron, Eastlink, SaskTel, and Ice Wireless

  1. The Competition Bureau submitted that it supported the establishment of a condition of service requiring national wireless service providers to make lower-cost data-only plans available on a temporary basis, until such time that the Commission can establish longer-term, more robust solutions to competition issues that may exist in this market.

    Should the Commission decide to impose a requirement on the national wireless carriers to make specific lower-cost data only plans available, indicate, with supporting rationale, how long such a requirement should remain in place.

  2. For each of the years 2014 to 2017 as well as forecasts for each of the years 2018 and 2019, provide your company’s (i) total subscribers to your retail mobile wireless services; (ii) average monthly mobile wireless data consumption per subscriber; and (iii) the median amount of monthly mobile wireless data consumption per subscriber. Include all assumptions used.
  3. For each of the years 2017 and 2018, and for each province/territory, provide a list of all of your company’s mobile wireless plans that were offered for $30 per month and below. Provide a separate list for any other brands your company operates. For each plan, provide:  (i) price; (ii) voice, text, and/or data allotments; (iii) overage rate; and (iv) number of subscribers to the plan (at year end for 2017 and currently for 2018).
  4. For each of the years 2014-2018, and for each province/territory, provide a list of your company’s tablet plans that were offered on a stand-alone basis (i.e. not offered in conjunction with an underlying mobile wireless plan or other services provided by the company). Provide a separate list for any other brands your company operates. For each plan, provide: (i) price; (ii) data allotments; (iii) overage rate; and (iv) number of subscribers to the plan (at year end for 2014-2017 and currently for 2018). Also explain why any tablet plans that were previously offered on a stand-alone basis are no longer offered on such a basis.
  5. Indicate whether your company has concrete plans to compete in the lower-cost data-only plan market in response to the introduction of the national wireless carriers’ proposed and/or alternative plans. If so, indicate (i) what would be the price and data allotments of these plans; (ii) key attributes or restrictions; and (iii) within what timeframe these plans would be introduced. 

Questions for CIPPIC and OpenMedia; the Forum for Research and Policy in Communications; the Manitoba Branch of the Consumers' Association of Canada and the Aboriginal Council of Winnipeg; and PIAC

  1. The Competition Bureau submitted that it supported the establishment of a condition of service requiring national wireless service providers to make lower-cost data-only plans available on a temporary basis, until such time that the Commission can establish longer-term, more robust solutions to competition issues that may exist in this market.

    Should the Commission decide to impose a requirement on the national wireless carriers to make specific lower-cost data only plans available, indicate, with supporting rationale, how long such a requirement should remain in place.

  2. Provide your views on whether it is appropriate for the national wireless carriers to offer their lower-cost data-only plans under their flanker brands (e.g. Virgin for Bell Mobility, Fido for Rogers, and Public Mobile and Koodo for TELUS), and not on their main brands.

Question for DWCC et al.

  1. As stated in the Notice, the Commission’s view is that “if more options for lower-cost data-only plans were available in the market, consumers would be further empowered to use innovative applications, including voice and messaging applications, through a combination of Wi-Fi access and cellular networks.” (paragraph 7) (emphasis added). 

    In DWCC’s intervention, it submitted that Deaf, Deaf-Blind and Hard of Hearing Canadians use data for everyday needs such as video communications and that 83% of respondents to its survey used video communications on their smartphones (such as FaceTime, Glide, and Skype).

    Provide your view, with supporting rationale, as to whether a combination of Wi-Fi access and cellular networks would meet the needs of Canadians with disabilities, including those who use video applications to communicate, as well as way-finding and Global Positioning System.

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