Bell Mobility Inc.

Response to Request
10 September 2018 Bell Mobility(CRTC)20Jul18-201 TNC 2018-98
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Q. 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.

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.
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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 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. Yes, below we set out an alternative proposal that we believe addresses concerns raised
by parties and meets the expectations of Canadians, while attempting to balance the
continued development of a highly competitive marketplace that includes the emergence
of facilities-based entrants such as Shaw, Videotron, and Eastlink.

In Decision 2018-976 , the Commission concluded that "entry-level wireless plans with
lower price points are widely available from several wireless service providers".7 The
Commission also concluded that "[c]ompetition for high-data users is … likely to result in
choice of innovative service plans at increasingly affordable prices".8 In other words,
competition is already addressing any perceived market need for lower-priced plans
generally, and for plans that provide a large amount of data usage. On this basis, the
Commission found that there is a gap in the market for lower-cost data-only plans9,
which are plans with a lower amount of data usage.

It would not be reasonable to conclude that there is a "gap" in the market because some
believe there is an insufficient number of high quality/high volume service offerings being
made available at discounted prices (which would normally be associated with lower

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.

6 Telecom Decision CRTC 2018-97, Reconsideration of Telecom Decision 2017-56 regarding final terms and
conditions for wholesale mobile wireless roaming service.
7 Decision 2018-97, paragraph 98.

8 Decision 2018-97, paragraph 99.

9 We continue to believe that the most likely reason for having relatively few lower-cost data-only plans available in
the marketplace is that there is low consumer demand for plans of this nature and there are more compelling
lower-cost plans that also include voice and text usage in the monthly price.
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quality/lower volume offerings). The Commission has, for good reason, declined to
reach such a conclusion.

Instead, following its conclusions in Decision 2018-9710, the Commission directed the
national wireless carriers to submit proposals for lower-cost, [lower usage] data-only
plans11. Neither "lower-cost" nor "[lower usage]" were defined. The conditions that the
new offerings were expected to satisfy were set out in paragraph 12 of TNC 2018-98:
"available on the latest mobile wireless network technology (i.e., not limited to the third-
generation [3G] network)"; "available to all consumers (i.e., not limited to a means-tested
subset of low-income households)"; and "available on both a prepaid and postpaid
basis". The national wireless carriers proposed plans that satisfied all of these
conditions. The data allotments included in the proposed plans were consistent with,
and in some cases exceeded, the amount of data included in the WiFi-First plan offered
by Sugar Mobile that was the subject of an application to the Commission by Sugar
Mobile seeking access to other carriers' networks.12

Following receipt of these proposals, in ___(CRTC)20Jul18-201, the Commission has

identified a number of comments in this proceeding that proposed plans with 1 GB of
usage.

In consideration of the above developments, we are making an alternative proposal

comprised of three lower-cost data-only plans:13

Plan 1 Plan 2 Plan 3

Brand Virgin Mobile Lucky Mobile
Pre-/Post-Paid Post-paid Pre-paid Pre-paid
Price/month $28 $15
Data included 1 GB 500 MB

10 Decision 2018-97, paragraph 101.

11 TNC 2018-98, paragraph 14.

12 The Sugar Mobile plan in question offered unlimited talk and text and 400 MB of data (originally the plan
provided 200 MB of data) at 3G speeds for $19/month plus a $29 start-up fee.

13 These plans replace the plans we previously proposed.

Bell Mobility Inc. Response to Request
10 September 2018 Bell Mobility(CRTC)20Jul18-201 TNC 2018-98
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Network speed LTE 3G

Wi-Fi data included Unlimited Unlimited Unlimited

These plans would be available on the same basic terms and conditions as are
applicable at the applicable time to other pre-paid and post-paid plans, respectively, on
the same brand on which each is offered. See Bell Mobility(CRTC)20Jul18-207,
Bell Mobility(CRTC)20Jul18-303, Bell Mobility(CRTC)20Jul18-305, and Bell
Mobility(CRTC)20Jul18-306.

As discussed below, these plans will meet the expectations of Canadians with respect to
lower-cost data-only plans.

Plans 1 (post-paid) and 2 (pre-paid) provide twice as much data as the plans in our
original proposal at less than half the price per GB of the original plans. Both are
provided at LTE network speeds and meet all of the criteria set out by the Commission in
TNC 2018-98. As they increase the data allotment to 1 GB per month and reduce the
price, we believe that Plans 1 and 2 are completely consistent with the Commission's
guidance to the national wireless carriers and responsive to the proposals of interveners.

Plan 3 adds an additional lower-cost data-only alternative for consumers, available from
Lucky Mobile. Lucky Mobile is our new pre-paid service brand which was launched in
Ontario, Alberta and British Columbia in December 2017. Availability of the brand was
then expanded into Manitoba and Saskatchewan in March 2018. In July 2018, we
announced that Lucky Mobile was entering Quebec and the Atlantic provinces, which
means that its services are now available in all 10 Canadian provinces.14 The
geographic expansion of Lucky Mobile is a testament to the competitiveness of the retail
wireless market in Canada – if the market was not competitive, we would have no
reason to invest in Lucky Mobile's expansion across the country.

All Lucky Mobile plans are only available on a pre-paid basis and at 3G network speeds.
As a result, the Lucky Mobile offering included in our proposal is also available only on a
pre-paid basis at 3G network speeds. This allows us to offer the same amount of data

14 Lucky Mobile lower-cost wireless arrives in Quebec and Atlantic Canada, 23 July 2018, available at: https://
www.newswire.ca/news-releases/lucky-mobile-low-cost-wireless-arrives-in-quebec-and-atlantic-
canada-688869241.html.
Bell Mobility Inc. Response to Request
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as in our previous proposal, but at half the price. Like some interveners, we expect that
some customers will prefer the lower speed/price point combination of this alternative.
As PIAC noted in its comments:

This suggests that while there are many consumers who are willing to
pay for 4G LTE speeds, there are also many consumer[s] willing to make-
do with 3G speeds for the level of discounts likely to be offered for that
slower service.15

The price and data allotment in Plan 3 are superior to the "WiFi-first" plan offered by
Sugar Mobile, which was also pre-paid and available at 3G speeds. In this regard, our
proposal exceeds the expectation of the Competition Bureau that the lower-cost data-
only plans "can act as a step in the right direction, providing at least some of the
consumer advantages and general economic benefits that Sugar Mobile promised."16 In
fact, our proposal provides more data at a lower price than the Sugar Mobile plan. More
importantly, it provides the widely acknowledged greater benefits to consumers and the
economy generally of facilities-based competition, compared to the Sugar Mobile
offering that was based on an inappropriate use of a tariff to access another carriers'
network.

Because Lucky Mobile only offers pre-paid plans, Plan 3 is not available on a post-paid
basis. This does not reduce its attractiveness, however, particularly for price-sensitive
Canadians who may not want to undergo the credit check required for a post-paid plan.
All Lucky Mobile subscribers, including those who would subscribe to Plan 3, can take
advantage of our automatic monthly top-up capabilities which offer the best features of a
pre-paid service with the convenience of automatic monthly billing of the kind provided
by a post-paid service. 17 We believe that Plan 3 is an attractive complement to Plans 1
and 2 and adds to the lower-cost data-only options available nationally – the
Commission's primary objective in this proceeding.

Together, our proposed plans meet the various needs and expectations of Canadians
expressed on the record of this proceeding.

15 PIAC Intervention, 13 June 2018, paragraph 127.

16 Competition Bureau Intervention, 13 June 2018, paragraph 18.

17 See an explanation of the available top-up mechanisms at https://www.luckymobile.ca/support/balance-top-up/

how-to-top-up.
Bell Mobility Inc. Response to Request
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