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CRTC Exhibit 1 – Review of the Wireless Code – Oral Hearing

Written Undertakings

Questions for Consumer groups, accessibility groups and academics:   

Bill shock due to overage fees:

  1. Some WSPs enable customers to buy additional data (for additional fees) prior to hitting their data cap and paying overage fees. Some WSPs have argued that customers that pay more to increase their data limit should not have their overage fees capped when they hit their limit – can you comment on that proposal? Should the additional purchase price count toward the data overage fees?
  2. Should the Code add and define the term ‘account holder’ in the Code?  In what provisions should the term ‘customer’ be replaced with ‘account holder’?

Critical Information Summary (CIS):

  1. Should the CIS include more info about the trial period, limits on any service purchased as ‘unlimited’, or unlocking fees for all devices (not just subsidized devices, the current requirement of the Code)?

Ensuring customers get permanent copies of contracts:

  1. Should WSPs be required to send the contract to customers who opt for an electronic copy sooner than the current 15 day timeframe?

Implementation:

  1. Should WSPs be required to complete implementation and compliance reports? How frequently should compliance reports be submitted?  Only after the first year of implementation?  Annually thereafter?

Consumer awareness of the Code and their rights:

  1. In terms of in-store promotion of the Code, should WSPs be required to visually display information about consumer rights under the Code or provide a leaflet of the simplified Code along with the contract and CIS?

Questions for Wireless Service Providers (WSPs):

Prepaid services:

  1. According to the CCTS some prepaid plans have contracts up to one year long.  On the other hand the CWTA submitted that no prepaid contracts are on a term, nor are there instances in which the prepaid customer does not actively top up their account at least once every 30 days.  Do you offer any prepaid plans on a fixed-term basis, for example fixed-terms longer than 30 days or 1 month? 

Data overage cap:

  1. Is $50 still a reasonable amount to trigger the suspension of data overage charges requirement, or should the suspension be triggered as soon as the customer’s monthly data allotment is reached (i.e. at $0 in overage fees)?
  2. What would be the cost to implement the suspension of data when the customer’s monthly data allotment is reached, and to notify all users on an account that they have reached 95% or 100% of their data allotment?  When could such a system be put in place for new customers and for all existing customers?

Notification of overages:

  1. For multi-user plans, in instances where your system does not currently allow for the account holder to be notified when the $50 limit is reached and consent is sought, how costly would it be to modify and how long would it take to do so for new customers and for all existing customers?
  2. The Commission understands that some WSPs now offer Canadians the possibility of buying data flex plans, data add-ons or top-ups prior to going into overage.  Do you consider the purchase of a flex plan, data add-on or data top-up to count towards the $50 overage cap?  Should the $50 cap apply to customers who have purchased an add-on or top-up?

Definition of customer and account holder:

  1. Should the Code add and define the term ‘account holder’ in the Code?  In what provisions should the term ‘customer’ be replaced with ‘account holder’?

Data roaming:

  1. Describe the data roaming plans you offer as an add-on for customers travelling outside of Canada.
  2. Can customers incur overage charges under some roaming add-on plans?  Should the purchase of a roaming add-on count towards the $100 data roaming charge cap?

Unlocking:

  1. What are your annual revenues from unlocking fees? What are the costs associated with locking devices to your network and unlocking devices upon request?
  2. How would a prohibition on unlocking fees affect device and service rates?
  3. Comment on the feasibility, cost and resource implications of implementing proposals A and B below, so that it applies to: all new contracts within 6 months of the publication of the modified Code; or all new and existing contracts within 6 months of the publication of the modified Code.
    1. that the Code apply a formula to unlocking fees similar to the formula currently used in the Code for early cancellation fees (ECFs).  Such a formula would require WSPs to reduce the unlocking fee by an equal amount or percentage each month, for the lesser of 24 months or the total number of months in the contract term, such that the fee is reduced to $0 by the end of the period; or
    2. that WSPs be prohibited from charging an unlocking fee for any of the following: unsubsidized devices, devices for which the early cancellation fee has been paid or the contract term has elapsed, or devices customers brought to the contract, such as used devices (i.e. BYOD).

Device subsidies:

  1. What costs would be associated with updating your billing systems to separate the device subsidy amount from the monthly reoccurring service charge on a customer’s monthly bill, or alternatively, to sell two separate contracts – one for the mobile wireless service and one for the device?  How soon could the change be implemented for new customers and for all existing customers?
  2. How would this proposal affect the prices charged for mobile wireless services and devices?
  3. Over the course of a year, what revenues are associated with maintaining the monthly reoccurring service charge at the same level on a customer’s bill after the amount of their device subsidy has been repaid and the customer is no longer subject to an early cancellation fee?

Critical Information Summary:

  1. Should the CIS include more info about the trial period, limits on any service purchased as ‘unlimited’, or unlocking fees for all devices (not just subsidized devices, the current requirement of the Code)?  Can you provide estimates on the cost and resource implications of adding new information to the CIS? Of providing the CIS to prepaid customers on fixed terms longer than one month?  How soon could such changes be implemented?

Ensuring customers get permanent copies of contracts:

  1. Should WSPs be required to send the contract to customers who opt for an electronical copy of their contract sooner than the current 15 day timeframe?

Accessibility requests:

  1. Provide estimate on costs and resources involved with creating and providing ASL and LSQ videos for each of the following: 1) terminologies commonly used in wireless services; 2) promotional materials for wireless services and products and the Wireless Code; and 3) in-store sign-language interpretation or Video Remote Interpretation (VRI), upon request .
  2. Would a requirement that WSPs create such videos by working together, rather than a requirement that each WSP make such videos individually, be more feasible, or less feasible?  Why?

Implementation:

  1. When should the modified Code come into effect, and should it apply to all customers at once or only to new customers at first?  Should it apply to all new contracts within 6 months of the publication of the modified Code? Should it apply to all new and existing contracts within 6 months of the publication of the modified Code?
  2. Should WSPs be required to complete implementation and reports? How frequently should compliance reports be submitted?  Only after the first year of implementation?  Annually?

Consumer awareness of the Code and their rights:

  1. Please provide a detailed cost estimate of, (1) visually displaying information about consumer rights under the Code in-stores and (2) providing a leaflet copy of the simplified Code along with the contract and CIS for agreements signed in-store.

Trial period:

  1. How often have customers returned devices pursuant to the trial period over each of the last three years?
  2. Comment on the requirement that the usage limits during the trial period be based off of a certain percentage of the customer’s monthly usage limits included in the plan that the customer has chosen, e.g. the customers can use no more than 50% of the plan’s voice, text, and data allotments for the month? In your view, what would be the appropriate percentage?  Can you provide estimates on the cost and resource implications of such a change to the Code, and how soon such changes could be implemented for all new and existing contracts?

Additional Questions - Party specific

Deaf Wireless Canada Consultative Committee: 

Accessibility requests:

  1. With respect to your proposal that a sign language video be created explaining common contract terminology in sign language, can you provide a list of terminology commonly used in contracts that you believe should be included in a sign language video?
  2. You have offered to prepare a draft proposed video project budget, if requested as an undertaking. What expertise or experience do you have in this area? Could you provide a draft video budget for both ASL and LSQ for each of the following: 1) terminologies commonly used in wireless services; 2) promotional materials for wireless services and products; and 3) in-store sign-language interpretation or Video Remote Interpretation (VRI), upon request; and 4) an awareness campaign.
  3. Some WSPs offer sign-language interpretation in-store, upon request.  Do you promote this option to your constituency? 

Device software updates and security patches:

  1. Have your constituents ever experienced problems with the accessibility features of their devices after downloading a software update?   If yes, can you provide any details on how the update altered the features on the device?

Media Access Canada: 

Accessibility requests:

  1. Please comment on the DWCC’s request to have sign language videos to explain terminologies commonly used in contracts and in-store sign language interpretation or Video Remote Interpretation (VRI), upon request.  Do you believe this would be helpful for your constituency? If yes, can you provide a list of terminology commonly used in contracts that you believe should be included in a sign language video?
  2. What about requests from persons with disabilities other than those that are deaf or hard of hearing?  Are there any accessibility requests relating to wireless services that you haven’t yet mentioned as part of this proceeding? 

Device software updates and security patches:

  1. Have your constituents ever experienced problems with the accessibility features of their devices after downloading a software update?   If yes, can you provide any details on how the update altered the features on the device?

Commissioner for Complaints for Telecommunications Services (CCTS):

  1. Implementation: Do you have any comments on how any changes to the Code should be implemented?
  2. The CCTS Annual Reports indicate the number of breaches of section F.1 of the Code, but the number of complaints relating to unlocking fees is not clearly indicated.  Can you provide complaints data on mobile device unlocking fees and unlocking more generally for the past three years?
  3. Device software updates and security patches: In your response to requests for further information, you submitted that device software updates and security patches do not fall within your mandate.  Can you elaborate on this?
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