You are on page 1of 5

TELUS Communications Inc.

ABRIDGED TNC 208-98


September 10, 2018 Response to Request for
Information
TELUS(CRTC)20July18-201
Page 1 of 5

201. 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 market1 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;2

 the Samuelson-Glushko Canadian Internet Policy & Public Interest Clinic (CIPPIC) and
OpenMedia proposed plans for about $2 per GB;3

 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;4 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,5 will your company propose an alternative lowercost 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.

1
For example, many interveners submitted that the companies’ tablet plans and mobile wireless plans with
greater data allotments were providing a significantly lower price per GB, that the proposed plans are more
expensive than the companies’ prepaid data add-ons for the same volume of data, and that some data plans in
some geographic markets provide more value to consumers than the companies’ proposed plans (e.g. SaskTel’s
Sharemore Data Only plan at $15 for 1 GB, $20 for 5 GB, and $30 for 10 GB).
2
The FRPC also proposed a plan of 2 GB for $10 per month.
3
The CIPPIC and OpenMedia proposed plans of 10 GB for $20 per month or, in the alternative, 6 GB for $14
per month.
4
This report proposed the following plans: 250MB for $5; 500MB for $10; 750MB for $15; 1 GB for $20; 1
GB for $25; 2 GB for $30; and 5 GB for $45.
5
In Telecom Decision CRTC 2018-97, Reconsideration of Telecom Decision 2017-56 regarding final terms and
conditions for wholesale mobile wireless roaming service, 22 March 2018 (Telecom Decision 2018-97), the
Commission was not persuaded that Bell Mobility’s proposed plan, as structured, would meet the needs of
consumers looking for a reliable lower-cost data-only plan. Later, in the Notice, the Commission provided a
non-exhaustive list of criteria in a lower-cost data only plan that it considered important to address its concerns,
while also indicating that it did not have a view at the time as the appropriate price or capacity threshold for
such plans.
TELUS Communications Inc. ABRIDGED TNC 208-98
September 10, 2018 Response to Request for
Information
TELUS(CRTC)20July18-201
Page 2 of 5

ANSWER

TELUS files certain information in this response in confidence with the Commission pursuant to
section 39(1) of the Telecommunications Act6 and Rule 32 of the CRTC Rules of Practice and
Procedure.7 Specifically, the number of Wi-Fi hotspots, number of monthly hotspot users and
monthly average hotspot data usage is commercially sensitive information and is consistently
treated as such by TELUS. Were this information to be shared with competitors, it would allow
them to understand the details of TELUS’ public Wi-Fi network deployment, including number of
locations and capacity. Competitors could use this information to better determine how they should
develop and deploy their own Wi-Fi networks and could also develop targeted marketing
campaigns based on a comparison of TELUS Wi-Fi networks versus those of the competitor. This
would prejudice TELUS’ competitive position and result in material financial loss. Accordingly,
TELUS asks that this information not be disclosed on the public record of this proceeding. An
abridged version is provided for the public record.

TELUS proposes two alternative monthly low-cost data-only plans as follows:

● $30 postpaid data-only wireless offering through its Koodo brand that will provide 1GB of
data at 4G speeds and

● $30 prepaid data-only wireless offering through its Public Mobile brand that will provide
1GB of data at 4G speeds.

The plans are responsive to all of the attributes set out by the Commission in the Notice: 8 (1) they
are affordable; (2) they are available on the latest mobile wireless technology over TELUS’ 4G
LTE network (though 3G plans remain available and at lower cost); (3) they will be available to
anyone in Canada; and (4) they will be available on both a prepaid basis (through Public Mobile)
and postpaid basis (through Koodo).

The chart below sets out the attributes of the alternative data-only plans and the associated Public
Mobile and Koodo brands.

6
Telecommunications Act, SC 1993, c 38, s. 39(1).
7
Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure,
SOR/2010-277 at s.32.
8
Telecom Notice of Consultation CRTC 2018-98, Lower-cost data-only plans for mobile wireless services,
22 March 2018 (the “Notice”) at para 12.
TELUS Communications Inc. ABRIDGED TNC 208-98
September 10, 2018 Response to Request for
Information
TELUS(CRTC)20July18-201
Page 3 of 5

Public Mobile and Koodo Lower-Cost Data-Only Plan Attributes

Public Mobile Prepaid Plans Koodo Postpaid Plan


1GB
Public Mobile offers other data-only plans
1 GB
Data Allowance of varying sizes at both 3G and 4G LTE
speeds. 3G plans start at 250MB and 4G
plans start at 600MB.
4G LTE TELUS national network
covering 99% of Canada’s population; 4G LTE TELUS national network
Network speed
Public Mobile also offers a choice of other covering 99% of Canada’s population
3G or 4G data-only plans.
75%, 95% and 100% of data allotment 50%, 90% and 100% of data allotment
Data usage alerts
used used
Add-ons - no expiry until they are used as Pay per use (PPU) or Add-ons. Add-ons
Additional data long as there is an active account, or 90 expire at the end of the customer’s
days after the account becomes inactive. billing cycle.
Add-ons for cellular voice. Customers can PPU voice and text. Customers can use
Voice & text
use their preferred over-the-top their preferred over-the-top application
options application for voice & text for voice & text
Wi-Fi based data,
Unlimited Unlimited
talk & text
No restrictions - customers can use their No restrictions - customers can use their
Tethering data to tether other smart devices such as data to tether other smart devices such
laptops, smartphones and tablets as laptops, smartphones and tablets
Device Subsidy No subsidy - Bring Your Own Device No subsidy - Bring Your Own Device
Business Model Prepaid - no credit check required. Postpaid
Online or at over hundreds of
Online or at over 1,000 distribution points, distribution points, including in-store
Availability including Walmart and WOW! nationally, (Koodo stores & kiosks nationally),
and local and regional retailers Walmart, London Drugs and a national
network of dealers and resellers
$30/month, equivalent to $0.99/day.
3G plans starting as low as $20/month,
equivalent to $0.66/day.
Rate $30/month, equivalent to $0.99/day
Public Mobile customers have the ability
to reduce the cost of their plans to as low
as $0 through reward activities.
TELUS Communications Inc. ABRIDGED TNC 208-98
September 10, 2018 Response to Request for
Information
TELUS(CRTC)20July18-201
Page 4 of 5

The purpose of the current proceeding is to ensure “that lower-cost data-only plans are widely
available to Canadians.”9 The Commission seeks data-only plans that are intended to empower
consumers “to use innovative applications, including voice and messaging applications, through a
combination of Wi-Fi and cellular networks”10 (emphasis added). The cellular data allotment of
1GB that TELUS now proposes far exceeds what would reasonably be necessary as a complement
to primary Wi-Fi use, and will enable customers to meaningfully participate in the digital
economy.11

In addition to providing attractive lower-cost data-only plans, TELUS offers other lower-cost
wireless plans on its Public Mobile brand with various usage attributes, including: a $20 plan with
250MB of 3G data; a $20 plan with unlimited talk; a $25 plan with unlimited talk and text and a
$30 plan with 500MB of 3G data and unlimited talk and text.

Wireless plans are only as good as the networks over which they run. TELUS has spent billions of
dollars building and operating world-class national networks12 including a 4G LTE network that
covers 99% of Canada’s population at December 31, 2017.13 The TELUS wireless network has
won every recent major mobile network award. OpenSignal ranked TELUS number one in overall
wireless download speeds nationally in its latest State of the Mobile Networks report.14 J.D. Power
ranked TELUS number one for overall wireless network quality in Ontario15 and Ookla awarded
TELUS the fastest network award for mobile network speed in Canada.16 PC Mag also recently
named TELUS’ wireless network Canada’s fastest mobile network.17

9
The Notice at para 8.
10
The Notice at para 7.
11
As set out at paragraph 41 of TELUS’ initial submission, Enabling participation in the digital economy is
also consistent with recent telecom policy decisions. See Modern Telecommunications Services: the path
forward for Canada’s digital economy, Telecom Regulatory Policy CRTC 2016-496, 23 December 2016 at
para. 18: “The Commission’s decisions in recent years have been made with the goals of shaping Canada’s
communication system and enabling Canadians to be active participants in the digital economy for years to
come.”
12
In 2017, TELUS’ capital expenditures were $3.09B, excluding wireless spectrum licenses. Between 2012
and 2017, TELUS spent over $18.5B on capital expenditures and spectrum license payments. Source:
TELUS 2017 Annual Report, p 34, online:
<https://assets.ctfassets.net/rz9m1rynx8pv/30cPueYwwUSuysoSSeE6oe/4bc06c10c67a516f4ff77e2ef72bb
0d7/TELUS_2017_annual_report-for_online.pdf> (“TELUS 2017 Annual Report”).
13
TELUS 2017 Annual Report, p 49.
14
“Open Signal Mobile Networks Update: Canada (August 2018),” online:
<https://opensignal.com/reports/2018/08/canada/mobile-networks-update>.
15
“J.D. Power 2018 Wireless Network Quality Study,” online: <http://canada.jdpower.com/press-releases/jd-
power-2018-canada-wireless-network-quality-study>.
16
“Ookla Speedtest awards Canada Q1-Q2 2018,” online:
<http://www.speedtest.net/awards/canada/2018/?award_type=carrier&time_period=q1-q2>.
17
“PC Mag: Fastest Mobile Networks Canada 2017,” online: <https://www.pcmag.com/article/348825/fastest-
mobile-networks-canada-2017>.
TELUS Communications Inc. ABRIDGED TNC 208-98
September 10, 2018 Response to Request for
Information
TELUS(CRTC)20July18-201
Page 5 of 5

TELUS’ 4G network speeds are well ahead those of the other G8 countries and are 2X as fast as
the leading national provider in the US and 1.75X as fast as the leading UK national provider.18
The average LTE download speed on the TELUS network is 51.05 Mbps compared to 21.57 Mbps
on national leader T-Mobile’s network in the US and 29.02 Mbps on the EE network (a division
of BT Group) in the UK.19 TELUS also compares favourably on latency metrics, providing an
average of 40.38ms compared to 54.05ms on top-ranked AT&T in the US and virtually tied with
EE at 40.35ms in the UK.20

All of TELUS’ wireless brands use the award-winning TELUS network. There are no differences
in network coverage, throughput, quality, etc. as a result of a customer being on one TELUS brand
versus another. Major terms and conditions are all similar across TELUS brands (with the
exception that Public Mobile offers only prepaid services and associated terms).

In addition to mobile wireless networks, TELUS has invested heavily in providing free public Wi-
Fi hotspots throughout the country in areas with high public traffic. Since initiating its public
access Wi-Fi program in # #, TELUS has deployed over # # hotspots across Canada.
Each month, these Wi-Fi networks have an average of # # total users and carry an average
of # # of data. In this way, TELUS furthers the national goal of maximizing participation in
the digital economy.

TELUS combines its leading networks with industry-leading customer service built on a culture
of Customers First. Despite being one of Canada’s largest telecom providers, TELUS accounted
for just 7.5 percent of industry complaints in the 2017- 2018 CCTS mid-year report.21 TELUS also
has significantly lower churn rates than its major competitors – in Q2/2018, TELUS’ wireless
postpaid churn rates were only 0.83%.22

All TELUS customers, including lower-cost data-only customers benefit from the value of award-
winning networks and industry-leading customer service.

* * * End of document * * *

18
“OpenSignal Reports,” online by country: < https://opensignal.com/reports/> (“OpenSignal Reports”).
19
OpenSignal Reports.
20
OpenSignal Reports. OpenSignal describes latency as: measured in milliseconds, the delay data experiences
as it makes a round trip through the network. A lower score in this metric is a sign of a more responsive
network.
21
“CCTS Mid-Year Report August 1, 2017 – January 31, 2018,” p 2, online:<https://www.ccts-cprst.ca/wp-
content/uploads/2018/04/CCTS-Mid-Year-Report-2017-2018.pdf>.
22
“TELUS reports strong results for second quarter 2018,” online:
<https://assets.ctfassets.net/rz9m1rynx8pv/2y1bJEmmFOe68gaWkc4EaO/9652934e154298e4b4b5396fac2
16e8a/TELUS_Q2_2018_earnings_news_release__EN.pdf>. In comparison, BCE’s churn rate was 1.10%
and Rogers had a churn rate of 1.01% for the same time period. Sources: “BCE 2018 Q2 Shareholder Report”,
p. 13, online:<http://www.bce.ca/investors/financial-reporting/2018-Q2/2018-q2-shareholder-report.pdf >
and “Rogers Communications Reports Second Quarter 2018 Results”, p.1, online:
<https://investors.rogers.com/fiscal_year/2018/rogers-q2-2018-press-release/>.

You might also like