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Rogers Communications Canada Inc.

Response to Requests For Information


September 10, 2018 Rogers(CRTC)20Jul18-201
CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
Page !1 of 7

Q101.
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:

i) 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?

ii) 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.

iii) 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
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-201
CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
Page !2 of 7

the Commission go about determining an appropriate amount for a price


ceiling and capacity floor, and what should those amounts be?

iv) 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.

A.

i)
There is no need for a section 34 assessment under the Telecommunications Act (“the Act”).
The wireless market remains extremely competitive at all segments of the market. There are
four carriers actively pursuing customers in each market in the country by investing in their
networks and promoting their products and services. As a result, Canada has among the most
advanced wireless networks in the world while offering price plans for as low as $10 a month.
Due to this competitive intensity, over five million customers changed wireless providers in 2016
alone.1 The market is clearly working.
Despite how competitive the wireless industry is, the Competition Bureau (“the Bureau”) has
asserted that there is market power in the retail wireless market in Canada.2 However, there is
no evidence supporting this assertion. While the Bureau raised concerns during the
Commission’s 2014 review of wholesale mobile services, it did not detail its position on market
power in the retail market. For example, did the three national wireless service providers have
market power individually or collectively? This was never explored. Further, while the Bureau
also suggested that concentration in Canada was excessive, this was never reconciled against
even higher concentration levels in many peer countries, including Germany, Australia, Japan
and Italy.3 The Bureau’s analysis then rested extensively on its expert evidence, the Brattle
Report, which was strongly contested by other participants for its poor methodology and
inconclusive findings.4 Moreover, despite expressing some reservations, the Bureau has
permitted merger activity to continue in the industry. In 2017, it authorized the merger of Bell
and Manitoba Telecom Services (MTS) reducing the number of operators in Manitoba to three
from four, while allowing for Xplornet Communications Inc. to eventually become a fourth,
smaller competitor. This is because wireless carriers continue to compete aggressively with one

1 CRTC 2017 Communications Monitoring Report, pp. 304.


2See, for example, http://www.competitionbureau.gc.ca/eic/site/cb-bc.nsf/eng/04375.html and
http://www.competitionbureau.gc.ca/eic/site/cb-bc.nsf/eng/03737.html
3 Bank of America Merrill Lynch Global Wireless Matrix, April 9 2018, HHI, Table 1: 4Q17 industry
snapshot by region – developed markets
4 See, for example, https://journalhosting.ucalgary.ca/index.php/sppp/article/view/42473
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-201
CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
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another across Canada. In short, the Commission should not accept claims that the national
wireless carriers enjoy market power as a foregone conclusion, even if limited to the lower-cost
data-only segment.
In fact, the lower-cost data-only market segment demonstrates robust competition. After the
national wireless carriers filed their proposed lower-cost data-only plans earlier this year, Shaw
Communications Inc. (“Shaw”) launched a new mobile wireless plan that directly competes with
them. Rogers expects that other regional and new entrant carriers will do the same in the near
future.
If it is the Commission’s broader intention to ensure that Canadians have ready access to lower-
cost mobile wireless services, no regulatory intervention is necessary. As Rogers detailed in its
reply comments, it already offers a wide array of low-cost offerings.5 As further described in
Rogers’ response to part iv), Rogers is now adding five new low-cost plans to stand alongside
its existing offers.
Simply put, there is no evidence that additional regulatory intervention is required beyond the
Commission asking the national wireless carriers to design these plans as it did in Telecom
Notice of Consultation CRTC 2018-98 (TNC 2018-98). Rogers therefore disagrees with the very
premise that the Commission needs to perform an assessment under section 34 of the Act.
Should the Commission find that it must invoke its powers under the Act and regulate the
national wireless carriers’ lower-cost data-only offerings, it should do so under section 24 rather
than perform a section 34 assessment. Section 24 empowers the Commission to impose any
condition it deems appropriate on the offering and provision of a telecommunications service.

24. The offering and provision of any telecommunications service by a


Canadian carrier are subject to any conditions imposed by the Commission
or included in a tariff approved by the Commission.
This section could be used to impose a condition on the national wireless service providers to
offer a lower-cost data-only plan as a condition of supplying wireless mobile services to the
public. The condition could direct carriers to make available their individual proposed plans to
the public for a period of time to ensure the gap for lower-cost data-only plans identified by the
Commission is closed. In the alternative, the Commission could direct all the carriers to make
available the same specific price and data plan rather than those proposed by the individual
carrier. The former proposal, however, is better as ideally it will provide a variety of different
plans with a variety of different prices and buckets. In turn, the variety will drive other carriers to
match or beat them in order to win the customer. Carriers can always choose to offer better
prices and/or larger buckets, but at a minimum they must offer the directed plan.
Rogers believes that the Commission should limit its intervention in the competitive wireless
data market to the minimum extent necessary to address the perceived market failure. This is
required by section 1(a) of the Direction to the CRTC on Implementing the Canadian
Telecommunications Policy Objectives (the “Policy Direction”):

5 Rogers’ reply comments, table 2.


Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-201
CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
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1(a) the Commission should

(i) rely on market forces to the maximum extent feasible as the


means of achieving the telecommunications policy objectives, and

(ii) when relying on regulation, use measures that are efficient and
proportionate to their purpose and that interfere with the operation
of competitive market forces to the minimum extent necessary to
meet the policy objectives;6
In this case, directing the national wireless carriers to make available their proposed lower-cost
data-only plans, which conform to their brands, networks and capabilities, would address the
gap the Commission identified with the minimum amount of market interference. It will also allow
the proposed plans to drive further competition in the market. As discussed below, evidence of
such additional competition is already apparent with the entry of Shaw into this product market.
Excessive regulatory intervention could have the effect of dampening this competition and
unwittingly hurt consumers of these services. An incremental approach to regulation would be
more consistent with the Policy Direction.
However, should the Commission find that it needs to perform an assessment under section 34,
the relevant product market should be lower-cost data-only plans and the relevant geographic
market should be Canada.
While Rogers disputes that any particular market segment in Canada is suffering from a lack of
competition, there is also no evidence whatsoever that any broader product market is suffering
from a lack of competition. The gap perceived by the Commission in this case is likely the result
of a relatively small product market and not a lack of competition. It may be that the market
segment in question has not always been addressed by carriers due to a lack of demand.
Rogers’ experience has been that most of its customers are constantly requiring more data to
fulfill their needs. This drives the need for increased investment in infrastructure and a pricing
model that recovers this investment. However, the evidence in this proceeding also
demonstrates that there already is a variety of low cost plans in the Canadian wireless market
due in part to the efforts made by companies like Rogers to develop special plans addressed to
people with low household incomes.
The relevant geographic market is Canada-wide given that the three national wireless service
providers offer their services on a Canada-wide basis. Additionally, individuals who desire a
lower-cost data-only plan are spread across the country.
ii)
Consumer demand for lower-cost data-only plans will ensure that wireless service providers
offer them at reasonable rates and with fair terms and conditions. This includes new entrant and
regional wireless service providers who were not asked by the Commission to propose data-
only plans in TNC 2018-98. Taken together with the low cost plans that were already in the

6 SOR/2006-355
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-201
CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
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market, the amount of competition in the lower-cost data-only segment is more than sufficient to
protect the interests of consumers and maintain forbearance.
In fact, competition in this market segment has already materialized. Rogers predicted in its
initial April 23rd proposal letter that “[t]he regional and new entrant service providers may decide
to offer their own lower-cost data-only plans in response to the plans proposed by the national
carriers.”7 Rogers notes that Shaw has since launched two new lower-cost plans. One of these
plans is a data-centric plan with 1 gigabyte (GB) of mobile wireless LTE data for $30 per month,
or $25 if subscribed to pre-authorized payments, on its geographically limited wireless network,
with the option for a 1 GB data add-on on the networks of domestic roaming partners for an
additional $30 to avoid paying a fee of $0.05 per MB of data on these networks 8 , 9 Shaw is
competing with the data-only plans already in the market and the additional data-only plans that
Rogers and Bell will launch as a result of this proceeding. 10
Rogers further expects that other regional and new entrant wireless service providers may also
launch their own lower-cost data-only plans. For example, Quebecor Media wrote in its
intervention that,

L’introduction par les trois fournisseurs pancanadiens de nouveaux forfaits de


données seulement à moindre coût aura assurément un effet d’entraînement
dans le marché. Vidéotron, pour sa part, a l’intention de demeurer
concurrentielle dans ce segment du marché.11
With the three national wireless service providers and at least one new entrant service provider
offering or soon to offer lower-cost data-only plans, subscribers who are not satisfied with their
current data-only plan will have a wide range of alternatives available to them. Rogers expects
that carriers will actively compete for consumers in this market segment.
This market activity also definitively proves that maintaining forbearance from price regulation in
this segment will not impair the continuance of a competitive market for lower-cost data-only
plans. Shaw has no obligation to offer a lower-cost data-only plan and has presumably only
done so to compete with the national wireless carriers for this specific segment of the market.

7 Rogers’ proposal, para. 25.


8This plan also includes unlimited incoming calls and unlimited global text messaging as long as the
customer is in one of Shaw’s ‘home zones.’ The plan costs $30 per month for customers who do not use
preauthorized payments. See https://www.freedommobile.ca/plans-and-devices/plans
9Shaw also launched a $15 plan with 250 MB of LTE mobile wireless data, unlimited incoming calls, 100
minutes of outgoing calls, and unlimited Canadian and USA text messaging as long as the customer is in
one of Shaw’s ‘home zones.’ The plan costs $20 per month for customers who do not setup
preauthorized payments.
10Telus has already launched its proposed lower-cost data-only plans under its Public Mobile and Koodo
brands.

11 Quebecor’s intervention, para. 13.


Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-201
CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
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Because this competition has arisen without any price regulation, such regulation is clearly
unnecessary. As Shaw wrote in its intervention, “Heavy-handed rate regulation or the imposition
of a condition of service would be ineffective, highly disruptive to competitive market forces, and
contrary to the Policy Direction. Shaw remains of the view that designing retail services should
be a function of the market, not the regulator.” 12
As discussed above, a competitive market without cumbersome regulatory intervention has
already given rise to a wide-range of low-cost mobile wireless plans with monthly service fees
as low as $10. The same market can successfully foster the introduction and provide ongoing
support to lower-cost data-only plans without any further regulatory intervention. There is no
evidence that shows otherwise.
In fact, price regulation would likely impair the continuance of a competitive market for lower-
cost data-only plans. Wireless service providers must be free to dynamically adjust their service
offerings in response to changing market conditions and other factors, such as customer needs.
For example, if the Commission requires the national wireless carriers to offer their lower-cost
data-only plans at artificially low rates, subscribers to these plans might not be able to use the
carriers’ Fifth Generation (“5G”) networks once they are deployed. As Rogers wrote in its reply
comments, price regulation would stall investment in network growth and upgrades.13
Lastly, it is worth mentioning that the Commission’s Wireless Code already protects consumers’
interests, including subscribers to lower-cost data-only plans. 14 As a result, between the
competitive market and any direction made by the Commission under section 24 of the Act,
consumer interests are protected and market forces should otherwise be allowed to function
under forbearance.
iii)
Rogers maintains that neither a price ceiling nor a capacity floor is required. The national
wireless service providers have each put forward lower-cost data-only plans that meet all of the
Commission’s criteria as listed in TNC 2018-9815 and furthermore fulfil ISED’s goals as listed in
the Order in Council.16 Natural free market forces will ensure that service providers keep these
plans in the market with appropriate data allowances and at affordable rates.
In fact, an active and rivalrous market for lower-cost data-only plans has already emerged, as
made evident by Shaw’s recent foray into the market segment. This will put additional pressure
on the national wireless carriers’ to keep their offerings in the market with competitive rates and
terms. Such measures would certainly not prevent any sort of undercutting or product

12 Shaw’s intervention, para. 12.


13 Rogers’ reply comments, para. E9.
14 TRP 2013-271 and TRP 2017-200.
15 TNC 2018-98, para. 12.
16 In full, the Order of the Governor in Council P.C. 2017-0557.
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-201
CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
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differentiation in the first place. And neither price floors nor capacity ceilings have been
historically necessary for Canada’s wireless service providers to engage in fierce competition.
Mobile data pricing continues to decline in Canada in the absence of any retail rate regulation.
As Rogers wrote in its reply comments,

Mobile wireless data rates have fallen by approximately 44% over the past
three years, as measured by the cost per megabyte of data. Quebecor
explains that declining prices mean that “tout prix plafond ou seuil de
capacité minimum imposé par le Conseil risque de devenir rapidement
désuet.” With prices declining and data usage growing, hard limits on
pricing and data allowances simply don’t make sense. 17
However, should the Commission find that the carrier’s proposed plans are insufficient and
decides against establishing a single plan for all the carriers, it could impose a price ceiling and
capacity floor through its powers under section 24 of the Act as discussed above in response to
part i).
In the event that the Commission proceeds on this basis, Rogers recommends a price ceiling of
no less than $30 per month. A $30 plan would reflect the cost and value of Canada’s leading
wireless networks, which are recognized as among the very best networks in the world despite
a small population dispersed across an enormous geography. It will allow many low income
Canadians to better access the digital economy.
Rogers additionally recommends a capacity floor of no more than 1 GB. Plans with data
allowances larger than 1 GB are well represented in the market with multiple offerings by every
mobile wireless service provider. A plan with more than 1 GB of mobile wireless data would also
not represent the type of introductory plan that the Commission envisioned in Telecom Decision
CRTC 2018-97 (TD 2018-97). In that decision, the Commission acknowledged that there are
already data-only plans with large allowances in the market. On the other hand, the Commission
raised concerns that the same is not true for data-only options at lower price points:

Competition for high-data users is therefore likely to result in choice of


innovative service plans at increasingly affordable prices. However, the
situation for users of lower amounts of mobile wireless data appears to
be different. While the market and pricing of mobile wireless services is
fluid, the Commission can find few examples of data-only options
available at lower price points, and most entry-level plans include a
combination of voice and text messaging with only limited data or no
data. 18 [Emphasis added.]

A $30 ceiling and 1 GB floor does not impair a carrier from making other combinations available.
Rogers would still be able to market its proposed $15 for 250 MB plan alongside its $25 for 500

17 Rogers’ reply comments, para. 106 with footnotes omitted.


18 TD 2018-97, para. 99.
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-201
CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
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MB plan. As long as at least one plan met both the floor and ceiling, carriers could still offer an
array of plans to customers that meet their needs more closely.
However, imposing a price ceiling of less than $30 per month combined with a capacity floor of
more than 1 GB could jeopardize the national wireless carriers’ ability to reinvest in their
telecommunications infrastructure. Carriers must be able to sell their plans at a reasonable profit
to raise funds for network development and growth.
As noted above, a too-low price ceiling combined with a too-high capacity floor would also pose
a significant challenge to new entrant and regional service providers. They would need to adjust
their own competing plans to undercut the national wireless carriers, putting their own network
investments at risk. Such market activity, instigated by unnecessary regulation, would ultimately
end up harming Canadians and the networks they depend on.
iv)
If the Commission were to regulate the national wireless carriers’ lower-cost data-only plans, it
should do so under its powers granted by section 24 of the Act. The Commission should not
require the national wireless carriers to file tariffs backed by cost studies.
Setting a cost-based rate would entail a lengthy and costly tariff setting proceeding requiring
input from many parties. The mobile wireless marketplace moves quickly in Canada. While the
national wireless carriers have all proposed lower-cost data-only plans that are responsive to
current needs, the plans may be outdated by the time a costing exercise concludes.
However, if the Commission were to decide that the lower-cost data-only plans should be
backed by tariffs, it should not set interim rates while the tariffs and costing studies are
completed. The Commission should allow the national wireless carriers to offer their proposed
plans until it sets final rates. This would reduce uncertainty for subscribers and carriers alike.
Should the final rate differ from the interim rate, carriers would either need to collect or credit
funds to their subscribers. This would be a burdensome undertaking that would likely confuse
customers. It would also be nearly impossible to administrate, especially for prepaid accounts
where limited customer information is collected.
In the alternative, if the Commission decides that an interim rate is necessary, this rate should
be set no lower than the effective per megabyte rate calculated from each carrier’s proposed
lower-cost data-only plans. For Rogers, this rate would be $0.0293 per MB. The national
wireless carriers have devised plans with prices that allow them to recoup their costs and allow
for some reasonable profit margin to be used for network reinvestment. An interim rate lower
than the carriers’ proposed effective rates would, at worst, not recover costs and, at best, still
result in reduced investment. Neither outcome is good public policy.
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-201
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Q201.

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 market 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;
• the Samuelson-Glushko Canadian Internet Policy & Public Interest Clinic
(CIPPIC) and OpenMedia proposed plans for about $2 per GB;
• 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; 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, 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.

A.

In its April 23 proposal letter, Rogers put forward a lower-cost data-only plan (for both prepaid
and postpaid) that was completely responsive to the Commission’s and Innovation, Science and
Economic Development Canada’s (ISED’s) intentions and requirements as described in this
proceeding’s Notice of Consultation and the Order in Council, respectively. However, Rogers
has taken the opportunity to further study the plans currently being offered and developed five
new proposals that better address the gap identified by the Commission and provide even
greater value to our customers. The breadth of this approach recognizes that within the lower-
cost data-only segment itself, customers have different needs. Together, these plans will fulfil
both the Commission’s and ISED’s intentions and requirements. Rogers’ proposed new plans
are shown in the following table.
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-201
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Brand Monthly Data allowance Voice and text Type of plan


service allowance
fee
Lower-cost Fido $15 250 MB LTE Unlimited text and Prepaid and
data-only picture messaging postpaid
plan
Lower-cost Fido $25 500 MB LTE Unlimited text and Prepaid and
data-only picture messaging postpaid
plan
Lower-cost Fido $30 1 GB LTE Unlimited text and Prepaid and
data-only picture messaging postpaid
plan
Lower-cost chatr $15 250 MB at 3G 100 outgoing Prepaid
talk, text, and speeds Canada-wide voice
data plan calling minutes,
unlimited incoming
calls, unlimited
Canada-wide text
and picture
messaging
Lower-cost chatr $25 1 GB at 3G Unlimited incoming Prepaid
talk, text, and speeds voice calls,
data plan unlimited Canada-
wide text and
picture messaging
Table 1: Summary of Rogers’ proposed lower-cost data-only plans.

To begin with, Rogers will introduce an even more affordable option for consumers. For $15 per
month, subscribers will have access to 250 megabytes (MB) of Long-Term Evolution (LTE)
mobile wireless data and unlimited text and picture messaging.19 This amount of data allows for
approximately 750 minutes of voice calling, 100 minutes of FaceTime calling, 2,500 emails,
1,250 webpages, or some combination thereof.20 While the data allowance is smaller than
Rogers’ original proposal, the price will allow entry to even more customers. Subscribers’ data
allowances will also go further because text and picture messages will no longer consume any
portion of a subscriber’s data bucket. Moreover, when subscribers are connected to free and
ubiquitous Wi-Fi, they will effectively have unlimited communications capabilities. Rogers’
proposed $15 plans therefore offer Canadians a considerable amount of connectivity at a very
economical rate.

19 Short message service and multimedia message service.


20 Using the sample conversions from Sugar Mobile. See https://sugarmobile.ca/
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September 10, 2018 Rogers(CRTC)20Jul18-201
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In addition, Rogers will continue to offer a $25 plan, now with 500 MB of LTE mobile wireless
data and unlimited text and picture messaging. This provides 25% more data than originally
offered at this price point and double the data for only $10 more than the $15 plan. It also now
includes unlimited text and picture messaging making the data allowance go further as
explained above. This again will deliver a terrific balance of price and usage to many
Canadians, providing an important mid-point in the market.
For customers with more advanced needs, Rogers is also proposing a lower-cost data-only plan
that will provide customers with 1 GB of LTE data and unlimited text and picture messaging for
$30 per month. This provides double the data of our $25 plan for only $5 more. One gigabyte of
data allows for 2,500 minutes (over 40 hours) of voice calling, 400 minutes of FaceTime video
calling, 10,000 emails, 5,000 webpages, or some combination thereof. Subscribers can also use
unlimited text and picture messaging without using any of their data allotment.
Along with these three plans offered over the Rogers 4G LTE network through the Fido brand,
Rogers will also make available two plans over Rogers’ 3G network through the chatr mobile
(chatr) brand. While these offers do not meet the technical requirement set forth by the
Commission to provide service over LTE networks, Rogers feels these plans will provide a very
worthwhile additional complement to the three plans described above.
To begin with, Rogers will launch a plan that will offer 500 MB of mobile wireless data at 3G
speeds and unlimited Canada-wide text and picture messaging for $25 per month.21
Subscribers who enrol in chatr’s pre-authorized payment plan will receive an extra 500 MB of
mobile wireless data at 3G speeds for no additional charge. This effectively provides for 1 GB of
mobile wireless data for $25 per month.
Rogers will also launch a $15 per month plan that provide customers with 100 Canada-wide
outgoing voice calling minutes, unlimited incoming voice calling minutes, unlimited Canada-wide
picture and text messaging. 22 Subscribers who enrol in chatr’s pre-authorized payment plan will
receive 250 MB of mobile wireless data at 3G speeds.
Rogers will make these chatr plans available to anyone within its operating footprint. chatr does
not perform credit checks. Subscribers to these plans who surpass their data allowance will also
not pay any data overages, as their data connection speed will be reduced until the start of their
next billing cycle. Customers will have the option to purchase a data top-up for $5 if they desire
additional mobile wireless data. Subscribers can also use ubiquitous Wi-Fi hotspots to provide
wireless data connectivity at no extra cost.
Rogers expects that its new proposed lower-cost data-only plans will help to cut mobile wireless
spending in households with low incomes. Rogers also expects that its plans will attract new
subscribers to the mobile wireless market.
Unlike some of the prices and rates proposed by interveners in this proceeding, the new plans
proposed are both affordable and reasonable. Rogers has carefully examined the alternative

21 Plus applicable taxes.


22 Short messaging service and multimedia messaging service.
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-201
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plans proposed by some interveners. As Rogers explained in its reply comments, these
alternative plans are based on faulty premises. For example, both the FRPC and the Bureau
have compared the national wireless carriers’ proposed lower-cost data-only plans with plans
available in other OECD countries. However, comparisons between Rogers’ proposed lower-
cost data-only plans and foreign carriers’ plans are apples-to-oranges, particularly when plans
have not been adjusted for currency exchange rates. It is difficult to compare pricing on a
standalone basis between carriers in different jurisdictions as there are numerous factors to
consider, something the Bureau has not done despite noting that various important factors “can
result in significant price differences across jurisdictions.”23 As a result, the superficial analyses
of the FRPC and Bureau are clearly inadequate.
For example, a fair comparison would consider network quality and coverage. Not only have
Canadian mobile wireless service providers made enormous investments in building LTE
networks that cover almost the entirety of Canada’s sparse population, but they invest far more
in network upgrades and improvements than their peers in other countries. As Rogers noted in
its reply comments,

In 2016, mobile data traffic grew by 41% in Canada.24 To meet this demand,
Canadian wireless service providers continue to invest in their networks to
increase capacity and improve service levels. Canada ranked fourth among
the 22 OECD countries in capital expenditures per capita in 2011-2013,25
and first among the G-7 countries in 2016 wireless capital expenditures. 26
This trend continued in 2017 with Canadian mobile wireless service
providers having the highest capital expenditure per subscriber compared
to peer nations. Canadian service providers spent $105.52 USD per
subscriber while Australian operators spent $87.82 USD per subscriber and
American operators spent $68.44 USD per subscriber.27 All together,
Canadian mobile wireless service providers have made a sustained
investment of almost $45 billion over the past 30 years.28
The FRPC has also based the pricing of its proposed plan on a distorted look at retail data
pricing in the Province of Manitoba. The FRPC states that “$10 would obtain 2.5 GB”29 in

23 The Bureau’s intervention, para. 30.


24 Cisco VNI Mobile Forecast Highlights, 2016-2021.
25OECD, OECD Digital Economy Outlook 2015, Table 2.31.
http://www.oecd.org/internet/oecd-digital-economy-outlook-2015-9789264232440-en.htm
26 Bank of America Merrill Lynch Q1 2017 Global Wireless Matrix.
27 Bank of America Merrill Lynch Q1 2018 Global Wireless Matrix.
28Canadian Wireless Telecommunications Association, Facts & Figures – Wireless phone subscribers in
Canada. Available: https://www.cwta.ca/facts-figures/
29 The FRPC’s intervention, para. 88.
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September 10, 2018 Rogers(CRTC)20Jul18-201
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Manitoba, but this is highly misleading. Rogers explained in its reply comments that Bell only
sells 2.5 GB of data for $10 as an add-on to talk and text plans that cost at least $35 per month.
It is impossible to calculate a meaningful retail price for mobile wireless data based on the price
of a data add-on that is not sold on a standalone basis.
CIPPIC – OpenMedia’s proposed plans are based on the very similar faulty premise that they
can isolate an accurate retail cost for mobile wireless data by subtracting the price of one plan
from another. As Rogers explained in its reply comments, this approach does not work, and
demonstrates a complete failure to understand fundamental wireless pricing economics, making
CIPPIC – OpenMedia’s proposed plans completely infeasible:

The base retail cost of a plan must recoup the costs associated with
designing, building, running, and maintaining a nationwide mobile wireless
network (a massive and extremely costly exercise), plus spectrum licences,
rent on office space and retail storefronts, employee costs, provisioning,
marketing, customer care, insurance, and much more, while also allowing
for some reasonable profit margin.

CIPPIC – OpenMedia attempts to determine the ‘true retail cost’ of mobile


wireless data by subtracting the retail cost of the voice calling and text
messaging components from a talk, text, and data plan with a 10 GB
allowance. Such an approach is flawed because, as explained in the
paragraph above, it does not properly consider the cost of providing the 10
GB of data to the customer. Some of that cost is borne by the portion of the
plan that CIPPIC – OpenMedia removed. 30
If Rogers were to sell a data-only plan at the far-fetched rates proposed by some interveners, its
ability to invest in its mobile wireless network would be severely compromised. Some of these
rates would simply result in Rogers losing money on each sale. They would certainly impair any
future investment and jeopardize our ability to provide a world-class network experience for our
customers. Not only must Rogers continually increase network capacity to support the explosive
growth in mobile wireless data usage, as described above, Rogers and other Canadian mobile
wireless service providers are already making early investments in Fifth Generation (“5G”)
mobile wireless technology. Canada’s nascent 5G networks would be jeopardized by any kind of
below-cost plan that would lead to a large decline in industry revenues. As Rogers explained in
its reply comments, the data-only plans proposed by some interveners could cause this exact
problem:

55. … PIAC, for example, proposes a mandated $11.62 per month plan that
includes 1 GB of data. In paragraph 100 of its intervention, PIAC projects,
based on its survey, that 10 million consumers would subscribe to a $15 plan
that includes 1 GB of data and contrasts that take-up with the estimated
two million consumers who take-up a $30 plan that includes 500 MB (Bell’s

30 Rogers’ reply comments, paras. 31 and 32.


Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-201
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and Telus’ post-paid proposals). Consider the difference in impact on the


carriers: a massive reduction of $1.75 billion dollars annually while also
having to provision for twice the amount of traffic for these consumers (1
GB vs 500 MB). Obviously this would have a significant harmful impact on
carriers’ ability to invest in networks to meet demand, much to the
detriment of Canadian consumers and businesses, let alone to invest in new
5G networks. This analysis significantly underestimates the harm that will
be done to network investment and the wireless services Canadians use as it
simply shows the estimated impact of dropping the price and increasing the
data allowance of the $30 for 500 MB low-cost data-only proposal.

56. Now consider the impact relative to the actual market. The average
wireless consumer in 2016 had a monthly bill of $64. With 10 million
consumers attracted to an $11.62 monthly price point for 1 GB of data, the
impact on the industry in reality would be a reduction of $6.29 billion per
annum as the price falls from $64 to $11.62 per month, a 25% reduction in
total industry revenue, again with a greater traffic load. EBITDA would be
reduced by 60% from $10.6 billion to $4.3 billion based on the revenue
impact alone. Mobile wireless service providers would be left with an
insufficient margin to fund needed capital expenditures and pay debt
charges, and no profits. Wireless networks would not be upgraded to meet
traffic demands and new 5G networks would be very slow in coming. This
would devastate wireless services for Canadian consumers and businesses
and the future of Canada in a digital world.31
The impact of the proposed, farfetched plans listed in this question would be even greater on
the new entrant and regional wireless carriers than on the national wireless carriers. Nationwide
plans costing only a few dollars would drastically undercut the new entrants’ pricing, likely
leading to a significant loss of their otherwise growing market share. As Bell wrote in its reply
comments, “Adoption of these types of plans would disrupt the competitive marketplace, reduce
investment in networks, and in particular undermine new entrant facilities-based competitors like
Shaw, Videotron and Eastlink.” 32
Rogers’ proposed plans are priced fairly for the value they will deliver to Canadians. They
balance consumers’ needs with Rogers’ continued need to invest in and maintain its world-class
mobile wireless network.
Shaw’s new data-centric plan, which provides 1 GB of mobile wireless data for $30 per month,
$25 with pre-authorized payments, is designed as a “home plan.”33 This means that customers
pay $25 per month only if they use the service exclusively on Shaw’s geographically limited
mobile wireless network. If a customer uses any part of the service on one of Shaw’s domestic

31 Rogers’ reply comments, paras. 55 and 56.


32 Bell’s reply comments, para. E7.
33See Shaw’s Home Plans, available: https://www.freedommobile.ca/plans-and-devices/
plans#category=basics
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-201
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roaming partners’ networks, they pay an additional fee of $0.05 per MB of data. While some
customers would likely be able to restrict their use to Shaw’s network, many customers would
find themselves paying more for usage of Shaw’s domestic roaming partners’ networks. To
reduce the ‘bill shock’ that might arise from such unexpected charges, Shaw sells a data add-on
with 1 GB of mobile wireless data on its partners’ networks for an additional $30 per month.
The pricing of Shaw’s data add-on helps to demonstrate the relative value of Rogers’ proposed
plans. Shaw operates a relatively small mobile wireless network that only serves urban and
semi-urban areas. Shaw has only recently started to deploy LTE technology. On the other hand,
Rogers operates a world-class, nationwide network that provides significant urban and rural
coverage. Rogers was the first Canadian service provider to offer commercial LTE service as far
back as 2011. Rogers has since continued to invest in and upgrade its network every year. By
pricing its data add-on of 1 GB of data on its partner networks for $5 more per month than 1 GB
of data on its own network, Shaw validates that service over Rogers’ larger and better network
is more valuable than over its own.
Ultimately, consumers should have free choice over which mobile wireless plan best fits their
needs. Some consumers will choose Shaw’s data-centric plan and some will choose Rogers’
data-only plans. This level of competition is exactly what the Commission and ISED envisioned
when designing their policies favouring facilities-based competition backed with wholesale, but
not retail, regulation. Any changes to this approach threaten the future of Canada’s
telecommunications marketplace.
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-202
Abridged CRTC File No: 1011-NOC2018-0098
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Q202.

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.


A.

Rogers is filing part of its response to this question in confidence. Rogers’ response
includes detailed commercial information concerning its wireless networks that Rogers
holds in confidence. Therefore, Rogers requests that the Commission treat this
information as confidential, pursuant to subsection 20(1)(b) of the Access to Information
Act, and sections 38 and 39 of the Act. For competitive reasons, Rogers would never
publicly disclose the information contained in this answer other than to the Commission.
Rogers submits that any possible public interest in disclosure of the information in this
answer is greatly outweighed by the specific direct harm that would flow to Rogers and
to the listed service providers.
The Commission does not need to impose a condition of service on the national wireless
carriers to make specific lower-cost data-only plans available to the Canadian market. As
Rogers noted above in its answer to part i) of Rogers(CRTC)20Jul18-101, the Bureau’s
assumption that the mobile wireless marketplace in Canada is not competitive is wrong. Rogers
additionally wrote in a recent proceeding that,

22. The market shares of Canadian wireless carriers have undergone


significant changes over the past decade with the three national carriers
and the regional carrier in each market jockeying for position. This is not
just a case of new entrants taking market share from incumbents. The
incumbents are taking market share from each other with significant shifts
in market share occurring, in some regions up to 20%.

23. Rivalry in this market continues to be intense with hundreds of price


changes occurring on an annual basis. Churn remains high with
approximately 14% (3.3 million) of the subscriber base changing carriers
each year. In addition, those customers who remain with a carrier are
often changing their plans to upgrade or move to a plan that better suits
their needs. Advertised prices in this market have declined significantly and
continue to do so. “Under the counter” pricing offers are another sign of
the competitive intensity in the market and are even more aggressive than
posted offers. Data rates alone have fallen by approximately 44% over the
past three years, measured as the cost per MB of data. Canada was recently
ranked first among 75 countries in affordability of Internet access services
including wireless data.

# Filed in Confidence with the Commission


Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-202
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187. In the first quarter of 2017 alone, there were 95 overt pricing actions,
roughly one a day of which 75 were by competitors of Rogers. Rogers and its
brands either responded or initiated the remaining 20 pricing actions. This
rate of pricing change is even more intense than when Rogers last reviewed
it in 2014, three years ago. At that time (Jan 7th to March 7th) Rogers
counted 32 overt pricing actions by competitors across the country, or 1
roughly every 2 days.34
The activity described in these paragraphs is strongly indicative of a competitive market. Rogers
expects that similar activity will directly apply to the national wireless carriers’ proposed lower-
cost data-only plans as well as competing data-only plans offered by new entrant and regional
wireless service providers.
The Bureau’s view that the national wireless carriers’ proposed lower-cost data-only will only
represent a “temporary fix” 35 for an “uncompetitive market” is based on the faulty premise that
the plans will be “difficult for consumers to access, not vigorously promoted, or not seen as a
real option for consumers (perhaps because of high prices or low data limits).”36 This will not be
the case.
Rogers has committed to making its lower-cost data-only plans easily accessible.37 Interested
Canadians will be able to learn more about Rogers’ proposed plans by calling Fido’s contact
centre, visiting Fido’s website, engaging with the company through social media, or by visiting a
store. Rogers will promote its lower-cost data-only plans with the same intensity it promotes
comparable plans.
Rogers’ proposed plans will be a useful and cost-effective option for many Canadians. Rogers’
proposed $15 plan will provide 250 MB of LTE mobile wireless data and unlimited Canada-wide
text and picture messaging. This amount of data enables approximately 750 minutes of voice
calling, 100 minutes of FaceTime calling, 2,500 emails, 1,250 webpage visits, or some
combination thereof.38 This is a significant amount of service, especially considering that
subscribers will supplement the mobile wireless component of these plans with freely available
and ubiquitous Wi-Fi. Over Wi-Fi, subscribers will effectively have unlimited connectivity. This
amount of communications capability will be more than sufficient for many users.
Rogers will improve its initially proposed lower-cost data-only plan by increasing the data
allowance by 25% to 500 MB of LTE data and by adding unlimited Canada-wide text and picture
messaging without changing the price from $25. This will enable 1,500 minutes of voice calling,

34 Rogers’ intervention to TNC 2017-259, paras. 22, 23, 187 with footnotes omitted.
35 The Bureau’s intervention, para. 35.
36 The Bureau’s intervention, para. 33.
37 Rogers’ proposal, para 16.
38 Rogers’ reply comments, para. 10.

# Filed in Confidence with the Commission


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200 minutes of FaceTime video calling, 5,000 emails, visits to 2,500 webpages or some
combination thereof.
Consumers with advanced needs would likely benefit more from Rogers’ proposed 1 GB data-
only plan. For only $30 per month, customers can make four times the amount of calls, video
calls, or web page visits as a subscriber to Rogers’ 250 MB plan over mobile wireless networks
alone. This plan will also include nation-wide text and picture messaging, further increasing its
value to customers.
As further detailed in Rogers’ answer to Rogers(CRTC)20Jul18-206, Rogers expects that its
proposed lower-cost data-only plans will attract more than # # subscribers over a three-
year period. Contrary to the Bureau’s claims, this estimate is not indicative of plans that are
difficult for consumers to access or not seen as a real option. Rogers expects that Bell’s and
Telus’ plans, and competing plans offered by other service providers, will be similarly successful.
Because the Canadian mobile wireless market is already subject to very active competition,
there is no need for the Commission to impose any sort of temporary requirement on the
national wireless service providers to offer a lower-cost data-only plan while it otherwise
examines the market.
However, should the Commission ultimately decide to impose a condition of service requiring
the national wireless carriers to make specific lower-cost data-only plans available on a
temporary basis, the condition should only apply until the Commission finishes its broader
review of industry competitiveness. Specifically, the Commission could impose a condition of
service that expires when it concludes its upcoming review of the wholesale wireless
framework.39
Rogers expects that the future proceeding will encompass a broad range of topics, including a
comprehensive review of the competitiveness of the Canadian mobile wireless market. Once
this proceeding concludes, the Commission may either remove or extend the condition of
service, as appropriate based on its findings.

39 CRTC TD 2018-97, para. 119.

# Filed in Confidence with the Commission


Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-203
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Q203.

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.

A.

Rogers is filing its response to this question as an appendix in confidence. Rogers’


response includes detailed commercial information concerning its wireless networks
that Rogers holds in confidence. Therefore, Rogers requests that the Commission treat
this information as confidential, pursuant to subsection 20(1)(b) of the Access to
Information Act, and sections 38 and 39 of the Telecommunications Act. For competitive
reasons, Rogers would never publicly disclose the information contained in this answer
other than to the Commission. Rogers submits that any possible public interest in
disclosure of the information in this answer is greatly outweighed by the specific direct
harm that would flow to Rogers.
Rogers is including an abridged version of its answer for the public record below.
See Appendix A.

2017 2016 2015 2014


Postpaid subscribers 8,703,603 8,556,718 8,271,361 8,165,560
– all brands
Prepaid subscribers – 1,777,625 1,716,537 1,605,889 1,376,845
all brands
Total subscribers – 10,481,228 10,273,255 9,877,250 9,542,405
all brands

Table 2: Number of postpaid and prepaid subscribers across all Rogers brands for 2014 - 2017.
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-204
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Q204.

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).

A.

Rogers is filing its response to this question as an appendix in confidence. Rogers’


response includes detailed commercial information concerning its wireless networks
that Rogers holds in confidence. Therefore, Rogers requests that the Commission treat
this information as confidential, pursuant to subsection 20(1)(b) of the Access to
Information Act, and sections 38 and 39 of the Telecommunications Act. For competitive
reasons, Rogers would never publicly disclose the information contained in this answer
other than to the Commission. Rogers submits that any possible public interest in
disclosure of the information in this answer is greatly outweighed by the specific direct
harm that would flow to Rogers.
Rogers is including an abridged version of its answer for the public record.
Given the Commission’s and ISED’s intentions, Rogers’ answer focuses solely on consumer
plans. Rogers has also excluded plans that were not widely available (e.g., retentions offers),
not truly mobile wireless plans (e.g., rocket hub plans), or did not include any Canadian usage
(e.g., ‘snowbird’ plans on Zoomer Wireless).
See Appendix A.
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-205
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Q205.

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.

A.

Rogers is filing its response to this question as an appendix in confidence. Rogers’


response includes detailed commercial information concerning its wireless networks
that Rogers holds in confidence. Therefore, Rogers requests that the Commission treat
this information as confidential, pursuant to subsection 20(1)(b) of the Access to
Information Act, and sections 38 and 39 of the Telecommunications Act. For competitive
reasons, Rogers would never publicly disclose the information contained in this answer
other than to the Commission. Rogers submits that any possible public interest in
disclosure of the information in this answer is greatly outweighed by the specific direct
harm that would flow to Rogers.
Rogers is including an abridged version of its answer for the public record. Given the
Commission’s and ISED’s intentions, Rogers’ answer focuses solely on consumer plans.
Rogers has also excluded tablet plans that were not widely available (e.g., retention offers).
See Appendix A.
The number of subscriptions to smartphone-based mobile wireless plans has risen dramatically
over the last few years. In fact, the number of Canadians with a smartphone increased by over
50% from 2012 to 2017.40 Smartphones are much more useful primary devices than tablets due
to their smaller form factor and wider variety of features. On the other hand, the tablet market is
steadily declining.41 Customers tend to see tablets as secondary devices to their smartphones
that are best used for watching movies or other applications where a much larger screen is
helpful.
As a result, Rogers has changed how it offers its tablet plans to match this consumer behaviour.
Rogers’ tablet plan prices are designed to reflect that tablets are supplements to the primary
smartphone account. This allows Rogers to sell them at a lower price than if they were
marketed as a primary device. This is because much of the incremental cost of providing the
additional service is recouped through the customer’s primary smartphone plan. For example,
Rogers’ tablet-plan pricing is based on the premise that much of the cost of performing account

40 CRTC 2017 Communications Monitoring Report, Figure 5.5.8.


41IDC: Tablet shipments decline for 15th straight quarter, https://venturebeat.com/2018/08/02/idc-
tablet-shipments-decline-for-15th-straight-quarter/
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September 10, 2018 Rogers(CRTC)20Jul18-205
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management activities will be recouped through customers’ primary smartphone plans. #

#
Customers also have access to enhanced data usage monitoring, especially by combining their
tablet and smartphone plans together in a Rogers Share Everything plan.
#

#
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-206
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Q206.

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.

A.

Rogers is filing part of its response to this question in confidence. Rogers’ response
includes detailed commercial information concerning its wireless networks that Rogers
holds in confidence. Therefore, Rogers requests that the Commission treat this
information as confidential, pursuant to subsection 20(1)(b) of the Access to Information
Act, and sections 38 and 39 of the Telecommunications Act. For competitive reasons,
Rogers would never publicly disclose the information contained in this answer other
than to the Commission. Rogers submits that any possible public interest in disclosure
of the information in this answer is greatly outweighed by the specific direct harm that
would flow to Rogers.
Rogers is including an abridged version of its answer for the public record.
The following tables show the estimated number of new incremental subscribers in each
of the next three years to Rogers’ proposed lower-cost data-only plans.
#
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-206
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# # # #

# # # #
# # # #
# # # #
# # # #
# # # #
# # # #
# # # #
# # # #
# # # #
# # # #
# # # #
#

# # # #

# # # #
# # # #
# # # #
# # # #
# # # #
# # # #
# # # #
# # # #
# # # #
# # # #
# # # #
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-206
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# # # #

# # # #
# # # #
# # # #
# # # #
# # # #
# # # #
# # # #
# # # #
# # # #
# # # #
# # # #
#

At the end of 2021, Rogers estimates that its three lower-cost data-only plans will have attracted
a total of # # new subscriptions.
Rogers expects that its proposed lower-cost data-only plans will improve wireless adoption in
Canada. Rogers’ proposed plans will increase the diversity of economical mobile wireless
service offerings available in the market. They will provide an attractive option for Canadians
who have not yet signed up for a mobile wireless subscription because they are not looking for,
nor do they need, voice calling capabilities.
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-207
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Page !1 of 2

Q207.

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.

A.

Rogers designed its proposed lower-cost data-only plans in keeping with the Commission’s
directions from TNC 2018-98, which asked for a data-only plan.42 ISED’s Order in Council
similarly envisioned “innovative business models and technological solutions [that] can result in
more meaningful choices for Canadian consumers.”43 Rogers will accordingly not provide voice
calling capabilities with its lower-cost data-only plans. However, Rogers has decided to increase
the plans’ value to customers by including Canada-wide text and picture messaging service.
Subscribers to Rogers’ proposed $15, $25, and $30 prepaid and postpaid plans on its Fido
brand will receive this extremely useful addition at no extra cost.
Subscribers to Rogers’ proposed plans who desire voice calling service can easily add them by
installing a free, third-party application through the Apple App Store or the Google Play Store.
Rogers wrote in its reply comments that,

There are a large number of such applications available to Canadians. The


best known ones are Skype, Google Hangouts, WhatsApp, Viber, Fongo, and
Facebook Messenger, though Rogers notes that many more are available for
both the Android and iPhone smartphone platforms. These applications are
typically free to use for basic voice and messaging capabilities. For
example, Fongo provides customers with a new phone number, voice calling
to 85% of the country, voice mail, call forwarding, and caller ID for
absolutely free. 44,45
Rogers reiterates that these applications will provide Canadians with full-featured voice calling
and text messaging services that they can use over either Rogers’ mobile wireless network or
free and ubiquitous Wi-Fi hotspots.
Consumers with low household incomes who need built-in voice calling service would be well
served by some of Rogers’ other low-cost service plans. Rogers has provided a list of these
plans in its reply comments.46 These plans retail for as low as $10 per month. In addition to
these plans, Rogers will offer a new plan through its chatr brand with 100 Canada-wide outgoing

42 TNC 2018-98, para. 14.


43 The Order in Council
44 Fongo Features, available: https://www.fongo.com/features/
45 Rogers’ reply comments, para. 80.
46 Rogers’ reply comments, table 2.
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-207
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voice minutes, unlimited incoming voice minutes, unlimited picture and text messaging for only
$15 per month. Subscribers who enrol in chatr’s pre-authorized payment plan will receive 250
MB of mobile wireless data at 3G speeds.
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-208
CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
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Q208.

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?

A.

Rogers intends to make its proposed lower-cost data-only plans available at the same price and
with the same capacity and terms for at least two years following the Commission’s decision in
this proceeding. After two years, Rogers will make the plans available on an ongoing basis with
the intent of making changes no more than once per year to adjust for changing technological
and economic conditions. However, a low-cost data-only plan that is responsive to the
Commission’s intentions as listed in TNC 2018-98 and ISED’s Order in Council will remain in the
market.
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-301
CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
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Q301.

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?

A.

Rogers has increased the range of its proposed lower-cost data-only plans by introducing two
new plans and by enhancing its initial offering. Taken together, Rogers’ proposed plans cover a
range of affordable price points and offer a wide variety of data allowances to better meet
consumer needs.
The following table shows the various plans that Rogers would provide at the Commission’s
specified price points. Three of these rates now align with Rogers’ proposed plans.

Price Data Bucket Rationale


$10 0 Not economically viable.
$15 250 MB ✓ Proposed plan.
At $15, Rogers can begin to offer a meaningful mobile wireless
plan that will allow it to recover its costs while still providing
customers with an ample amount of communications service.
$20 300 MB This would not provide a distinct service offering between
Rogers’ proposed 250 MB and 500 MB plans. Customers would
be significantly better off subscribing to the $25 plan, which
would provide 200 MB of additional LTE data for only $5.
$25 500 MB ✓ Proposed plan.

$30 1 GB ✓ Proposed plan.


Through the benefit of volume discounting, Rogers is able to
double the mobile wireless data allotment from its $25 plan for
only $5 more.

These price and data plans mostly reflect Rogers’ proposals. Rogers, however, has not provided
a data bucket for the $10 price point as there is no economically feasible way to provide a data-
only service offering that meets the Commission’s specifications at $10. Such a plan would
never recover the cost of providing the service, let alone provide any funds for network
investment.
Rogers’ newly proposed $15 and $30 plans will have the same attributes and restrictions as its
originally proposed $25 plan. The three plans will each offer their respective amounts of LTE
mobile wireless data and unlimited Canada-wide text and picture messaging.
Rogers’ proposed 250 MB plan will provide for approximately 750 minutes of voice calling, 100
minutes of FaceTime calling, 2,500 emails, 1,250 webpages, or some combination thereof.
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-301
CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
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Rogers has improved its initially proposed lower-cost data-only plan by increasing its mobile
wireless data allotment from 400 MB to 500 MB. With this increase, customers can make up to
1,500 minutes of voice calling, 200 minutes of FaceTime calling, send 5,000 emails, visit 2,500
webpages, or some combination of these services.
Finally, Rogers’ $30 plan will provide subscribers with 1 GB of mobile wireless data per month.
Subscribers to this plan could make up to 3,000 minutes of voice calling, 400 minutes of
FaceTime calling, send 10,000 emails, visit 5,000 webpages, or some combination of these
services.
With these $15, $25, and $30 price points in the market, Rogers submits that offering a $20 plan
would not provide for any meaningful additional value. Rogers proposed plans already cover
both lower and higher price points and offer a wide range of data allowances. If Rogers were to
offer a lower-cost data-only plan for $20 per month, the plan’s data allowance would be 300 MB
per month. Customers who need around 300 MB of mobile wireless data per month would be
better served by paying only $5 more for an additional 200 MB of mobile wireless data.
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-302
CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
Page !1 of 3

Q302.

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.
i) 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.).
ii) If Rogers intends to provide the plan under one of its other brands, indicate
a. under which brand(s) Rogers intends to offer the plans;
b. why the company considers it appropriate to offer its plans through its other
brand(s); and
c. why the company’s plans should not also be offered under the Rogers brand.

A.

i)

Cityfone, 

Primus Wireless,
Rogers Fido chatr SimplyConnect,
Zoomer Wireless

Nationwide
covering 97% of
Canadians.
Some of chatr’s
plans are zone-
based, meaning
that subscribers
Nationwide Nationwide pay additional fees Nationwide
Network covering 97% of covering 97% of if they use their covering 97% of
Coverage Canadians Canadians plan outside of Canadians
their home zone,
however chatr
subscribers’
phones will
function across the
entire Rogers
footprint

Network Speed LTE LTE 3G LTE


Phones, tablets,
Mobile Wireless Phones, tablets,
mobile hotspots, Phones Phones, tablets
Products mobile hotspots
rocket sticks
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-302
CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
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Cityfone, 

Primus Wireless,
Rogers Fido chatr SimplyConnect,
Zoomer Wireless
Postpaid: no-term,
bring your own Postpaid: no-term, Postpaid: no-term,
device (BYOD) or BYOD or buy a BYOD or buy a
buy a phone phone outright; phone outright;
outright; subsidized Prepaid: pay as subsidized
subsidized handsets on 2- you go with no handsets on 2-
Types of plans handsets on 2- year terms. credit checks. year terms.
year terms. Prepaid: pay as BYOD or buy a Prepaid: pay as
Prepaid: pay as you go with no phone outright. you go with no
you go with no credit checks. credit checks.
credit checks. BYOD or buy a BYOD or buy a
BYOD or buy a phone outright. phone outright.
phone outright.
Consumers, small
businesses,
Type of enterprise, Consumers, small
Consumers Consumers
customers government, businesses
machine-to-
machine
Online (chat, Online (chat,
Level of support social media, social media, Online (social
Chat, email, call
available to website), email, website), email, media), email, call
center, mail
customers call center, stores, call center, stores, center, stores, mail
mail mail

Carrier Wi-Fi
Yes (select Yes (select
calling and No No
devices) devices)
VoLTE capability
Targeted at
families and
individuals who
Entry level zone-
need sophisticated
based plans
wireless services
enable customers
and features like
Targeted at value- to use their plan Targeted to older
premium device
Other notable seeking shoppers features inside the adults, entry level
protection,
differences who are looking for limit of a specific phones, simple
premium device
affordable deals. geographic zone plans.
selection,
and incur pay per
exclusive access
use charges when
to VIP experiences
used out of zone.
like Rogers
GamesPlus and
much more.

ii)
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-302
CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
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Rogers intends to offer its lower-cost data-only plans under its Fido brand. As the table above
indicates, there are no functional differences between the Rogers brand and the Fido brand with
the exception of the types of customer each targets. Fido tends to attract value-oriented
consumers, making it a natural fit for plans designed for first-time subscribers and Canadians
with lower household incomes. Fido’s nation-wide distribution ensures all Canadians living in
Rogers’ footprint will be able to access the lower-cost data-only plans through the widest
possible variety of sales channels.
Given the Rogers brand’s focus on shared family plans and a premium experience, the
proposed lower-cost data-only plans would not resonate as effectively with Rogers’ target
market as they would with Fido’s.
Rogers’ other brands only offer postpaid service or prepaid service but not both. Rogers would
therefore be unable to offer both of its lower-cost data-only plans under the same brand if it
used its chatr or other brands. These brands also have more limited distribution points and
sales channels than the Fido brand. However, Rogers intends to offer two new plans through its
chatr brand that Canadians with low household incomes might find very attractive. Both plans
will be nation-wide plans. The first plan will include 100 Canada-wide outgoing voice minutes,
unlimited incoming voice minutes, unlimited picture and text messaging for only $15 per month.
Subscribers who enrol in chatr’s pre-authorized payment plan will receive 250 MB of mobile
wireless data at 3G speeds. The other plan will provide customers with 1 GB of mobile wireless
data at 3G speeds47, unlimited incoming calls, and unlimited text and picture messaging for $25
per month.

47The plan will provide 500 MB of mobile wireless data. Customers who enrol in chatr’s auto-pay plan
will receive an additional 500 MB of mobile wireless data.
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-303
CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
Page !1 of 2

Q303.

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.
i) 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).
ii) 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.
iii) Explain, with supporting rationale, why any such charges should not be
considered to adversely affect the affordability of the proposed plans?

A.

i), ii)
Beyond a one-time $10 purchase of a SIM card, the following list describes fees that could
apply to subscribers to Rogers’ proposed lower-cost data-only plans. These fees are identical
on the Rogers and Fido brands.
Note that Rogers will waive its standard $30 connection fee for subscribers to its proposed
lower-cost data-only plans.
1. Late Payment Charge: a fee charged when a customer does not pay an invoice by the
due date. The Late Payment Charge is charged daily at a monthly interest rate of 2%
2. Non Sufficient Funds: a $25 fee charged when funds are not available to cover the
amount needed (cheque, credit card)
3. Restoral Fee/Suspension Fee: a $35 fee charged when an account is restored from
involuntary suspension
4. Transfer of Responsibility Fee: a $35 fee charged when a telephone number or account
is transferred to a new owner
5. Invoice reprint: a $15 fee charged for requesting that Rogers reprints an invoice
6. 9-1-1 Fee: up to $1.50 per month depending on where the customer lives. This
government-set fee is included in the monthly service fee of all in-market postpaid plans.
7. Telephone Number Change Fee: a $35 fee charged when a customer changes their
telephone number. Rogers waives this fee for customers who change their number using
online self-serve.
8. Early Cancellation Fee: a fee levied to pay for the balance on a subsidized handset if a
customer cancels their service before their commitment period ends. The fee varies
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-303
CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
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depending on the amount owing but will be calculated in accordance with the Wireless
Code
These charges are not necessarily one-time charges or recurring charges. In fact, many
customers will never have to pay any of them. Some of the charges are associated with unusual
events such as account suspensions and transfers.
None of the above fees would apply to subscribers to the prepaid lower-cost data-only plan with
the exception of the 9-1-1 fee.
iii)
At $15, $25 and $30 per month, Rogers proposed lower-cost data-only plans will be attractive
new service offerings for Canadians with low household incomes.
In order to further improve affordability, Rogers has opted to waive its standard $30 connection
fee for subscribers to its proposed lower-cost data-only plans.
Rogers’ prepaid plans, including its prepaid lower-cost data-only plan, might be the best option
for Canadians with low household incomes. Rogers does not perform credit checks on new
subscribers to its prepaid plans. As noted in part i) above, most of the fees listed would not
apply to prepaid customers. It’s also worth noting that prepaid customers who use their full
balance would still be able to use their device over free and ubiquitous Wi-Fi hotspots. Prepaid
customers with no balance will also be able to make 9-1-1 emergency calls free of charge.
Otherwise, many customers would never pay any of the charges listed above in part i). Prepaid
customers will be subject to only the 9-1-1 fee. Rogers does not expect that the charges would
adversely affect the affordability of Rogers’ proposed plans.
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-304
CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
Page !1 of 2

Q304.

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.
i) 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.
ii) 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.

A.

i)
Rogers designed its lower-cost data-only plans to be as cost-effective for customers as
possible. By excluding domestic roaming service, Rogers is able to offer the plans at lower
rates. Rogers incurs incremental usage fees while its customers roam on its domestic roaming
partners’ networks. By not including domestic roaming service with its proposed lower-cost data-
only plans, Rogers avoids paying these fees. This allows Rogers to offer the proposed lower-
cost data-only plans.
Rogers’ extensive mobile wireless network covers 97% of the Canadian population. Rogers
does not expect that its customers will be inconvenienced by not having domestic roaming
service available.
Subscribers to Rogers’ proposed postpaid lower-cost data-only plan will not have access to Fido
Roam (the Fido brand equivalent of Rogers’ Rome Like Home feature). Rogers has designed its
lower-cost plans to be responsive to the needs of Canadians with low household incomes. By
excluding Fido Roam, Rogers expects that its customers will avoid incurring incremental
charges. Instead, Rogers expects that its customers will turn to free and ubiquitous Wi-Fi
hotspots when travelling internationally. This will allow customers to ‘roam’ without increasing
their monthly bill.
Otherwise, subscribers who are travelling outside of Canada will still be able to stay connected
cost effectively by using local SIM cards, or, if necessary, pay per use roaming. Prepaid
customers can buy Roaming Wireless Internet Passes to use data service while abroad.
ii)
Rogers will naturally block voice calling service on its proposed lower-cost data-only plans as
directed by the OIC and CRTC. Customers who desire voice service can add it through third-
party software applications. However, this will not impact a customer’s ability to dial 9-1-1. Even
without voice service, customers will be able to use their handset’s native dialer to call 9-1-1.
Prepaid customers without a balance will also be able to make 9-1-1 calls.
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-304
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Lower-cost Data-only Plans for Mobile Wireless Services
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Subscribers to Rogers’ postpaid lower-cost data-only plans will not be eligible to buy data top-
ups. This does not mean that subscribers will have to pay overage rates. Customers can track
their usage in real-time using Fido’s My Account App. Rogers will also notify customers when
they use their entire data allowance. At that point, subscribers can disable mobile wireless data
and not pay any extra fees. They can also continue to access wireless data over Wi-Fi
connections until the end of their billing cycle for no extra cost. If a customer uses a third-party
voice calling and text messaging service, they would have full use of these services when
connected to Wi-Fi.
Rogers will also require subscribers to its proposed lower-cost data-only plans to sign up for
Fido’s pre-authorized payment program. Subscribers will have their flexibility to make their
payments through either a preauthorized credit card or through their bank account. Rogers will
additionally not mail paper bills to subscribers to its lower-cost data-only plans. Customers can
view their bills at any time on Fido’s website or through Fido’s My Account smartphone
application. Again, this allows Rogers to avoid additional costs enabling it to offer the proposed
plans. As customers subscribing to a data-only plan have access to the Internet, this should not
be an inconvenience for them. Rogers notes that account management inquiries do not count
against a customer’s data allotment.

Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-305
CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
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Q305.

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.

A.

Rogers will offer its proposed lower-cost data-only plans on its Fido brand. Through a
combination of automatic data warning notifications and account self-management tools,
customers will be able to carefully monitor their data usage. If a customer on either the postpaid
or prepaid version of the data-only plans approaches their data allowance for the month, they
can turn to free and ubiquitous Wi-Fi to bridge the gap until the end of the month and allow for
continuous connectivity.
Subscribers to the postpaid lower-cost data-only plan will first receive a text message
notification when they use 90% of their monthly data allowance. They will then receive an
additional text message notification when they use their full data allowance. Customers will also
be able to monitor their data usage in real-time through Fido’s My Account App. Figure 1 shows
a screenshot of Fido’s My Account App.
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-305
CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
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!
Figure 1: Representative screenshot of Fido's My Account App. Customers can track their data usage in real-time
to prevent overage charges.

Through real-time monitoring of data usage through Fido’s My Account application, combined
with automatic text messages, subscribers to Rogers’ postpaid lower-cost data-only plan can
avoid paying any overage charges.
Customers on Rogers’ proposed prepaid plan will receive a notification when they have used
100% of their data allowance. Rogers will then suspend their data service unless they deposit
additional funds into their account. At that point, if they continue to use the service, Rogers will
deduct overage fees at the prevailing prepaid data overage rate until the end of the monthly
billing cycle. Prepaid customers can also continue to use their device without paying any more
than $15, $25 or $30 per month by relying on Wi-Fi hotspots.
Rogers will also offer two new low-cost plans on through its chatr brand. Subscribers to these
plans will similarly receive notifications when they have reached both 75% and 100% of their
data allotment. If a subscriber uses their full data allowance, their mobile wireless data
connection speed will be reduced until the start of their next billing cycle. This way there are no
overage charges. Customers would still be able to use wireless data over any Wi-Fi connection.
Customers could also purchase Data Plus, which gives a customer an additional 200 MB of
mobile wireless data for $5.
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-306
Abridged CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
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Q306.

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.
i) 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.
ii) 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.

A.

Rogers is filing part of its response to this question in confidence. Rogers’ response
includes detailed commercial information concerning its commercial operations that
Rogers holds in confidence. Therefore, Rogers requests that the Commission treat this
information as confidential, pursuant to subsection 20(1)(b) of the Access to Information
Act, and sections 38 and 39 of the Telecommunications Act. For competitive reasons,
Rogers would never publicly disclose the information contained in this answer other
than to the Commission. Rogers submits that any possible public interest in disclosure
of the information in this answer is greatly outweighed by the specific direct harm that
would flow to Rogers.
i)
Consistent with the way that it promotes other plans, Rogers will use internal sales bulletins to
announce the lower-cost data-only plans to its sales agents. The bulletins will inform agents
about the plans’ features and how to position them alongside Fido’s other mobile wireless plans.
In its stores, Rogers will update its digital brochures to include the new lower-cost data-only
plans. Rogers reserves its advertising displays (e.g., printed displays in store windows) for
limited-time promotions.
On its website, Rogers will show its lower-cost data-only plans with equal prominence to
comparable service offerings. For example, Fido’s prepaid and postpaid webpages already
show all of the brand’s plans with equal prominence. Rogers will add its lower-cost data-only
plans to those Fido webpages, again displaying them as it shows its other plans.
Both in its stores and online, agents will promote Rogers’ lower-cost data-only plans to
customers who do not need traditional voice calling service, as part of our needs-based
approach to selling, grounded in understanding the needs of our customers and share options
to meet their needs and budget.
ii)

# Filed in Confidence with the Commission


Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-306
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# # # # # # # # # # # #
# # # # # # # # # # # #
#
# # # # # # # # # # # #

# # # # # # # # # # # #
#
# # # # # # # # # # # #

# # # # # # # # # # # #
#
# # # # # # # # # # # #

# # # # # # # # # # # #
#
# # # # # # # # # # # #

# Filed in Confidence with the Commission


Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-307
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Q307.

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.

A.

Rogers is filing part of its response to this question in confidence. Rogers’ response
includes detailed commercial information concerning its commercial operations that
Rogers holds in confidence. Therefore, Rogers requests that the Commission treat this
information as confidential, pursuant to subsection 20(1)(b) of the Access to Information
Act, and sections 38 and 39 of the Telecommunications Act. For competitive reasons,
Rogers would never publicly disclose the information contained in this answer other
than to the Commission. Rogers submits that any possible public interest in disclosure
of the information in this answer is greatly outweighed by the specific direct harm that
would flow to Rogers.
Rogers will require longer than usual development times to build, test, and launch its postpaid
and prepaid lower-cost data-only plans due to the plans’ unique features. Rogers has not
previously built the capability to deliver a smartphone plan that does not provide voice service.
However, by taking advantage of planning over the past few weeks, Rogers now estimates that
it could introduce the prepaid lower-cost data-only plans 100 days after the Commission’s
decision. Developing the prepaid plan will require the following work:
• #

#
• #

#
• #

#
• #

#
• #
Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-307
Abridged CRTC File No: 1011-NOC2018-0098
Lower-cost Data-only Plans for Mobile Wireless Services
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#
#

#
#

# Rogers now estimates that it could launch its postpaid lower-cost data-only plans 70 days
after the Commission’s decision.
Outside of its systems development work, Rogers plans to invest in additional training for its
sales agents. Rogers wants to ensure that its agents fully understand the features and
limitations of its proposed data-only plans.
For example, some customers might expect that all smartphone plans include voice calling
service. Sales agents must be able to explain to customers these the data-only plans do not
include voice service ‘out of the box’ but customers can add it through third-party software. This
additional training will ensure Rogers is able to provide the best possible customer service to its
current and potential subscribers. Rogers will engage in this training while it is building its
proposed plans.
Launching these plans will also require more development work on Fido’s website than usual.
Fido’s website is designed to display plans including talk, text, and data allowances. Rogers will
need to list data-only plans alongside these plans while clearly showing that the plans do not
include any voice calling capabilities. 

Rogers Communications Canada Inc.Response to Requests For Information
September 10, 2018 Rogers(CRTC)20Jul18-308
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Q308

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.

A.

Rogers will extend Fido’s existing Disability Organization Membership Discount program to its
proposed postpaid lower-cost data-only plans.48 People with disabilities will receive a $10
discount every month on the cost of the plan.
Rogers expects that some Canadians with disabilities will find its data-only plans to be very
useful. A 1 GB mobile wireless data allowance allows for 400 minutes of Facetime video calling
or approximately 18 hours of low-quality Skype video calling.49 Importantly, Rogers provides its
subscribers with disabilities with free, unlimited access to SRV Canada VRS without consuming
any portion of their mobile wireless data allowance. The DWCC et al.’s intervention shows that
SRV Canada VRS is one of the most popular video messaging services used by the hard-of-
hearing community.50 Subscribers will have effectively unlimited use of any video messaging
application over free and ubiquitous Wi-Fi connections.
Rogers also expects that the plan’s unlimited text messaging feature will appeal to Canadians
with disabilities who do not use voice calling service.
By discounting its postpaid lower-cost data-only plans by $10, Rogers is lowering the price
below retail market value. This discount does not mean that Rogers can profitably offer its
proposed plans for $5, $15, or $20 per month. Rogers only offers its accessibility discount to
Canadians with membership in a disability organization. Rogers could not extend the offer at
this low price to all Canadians without jeopardizing its ability to afford future investments in its
mobile wireless network.

*** END OF DOCUMENT ***

48Rogers and other wireless service providers provide their accessibility discounts to postpaid plans
only. See https://www.fido.ca/consumer/accessibility/plans for mode detail.
49Assuming the video call operates at Skype’s minimum speed of 128 kbps. See https://
support.skype.com/en/faq/FA1417/how-much-bandwidth-does-skype-need
50 DWCC et al.’s intervention, pp. 67.

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