st

December 1 , 2015
Our reference: 8661-P8-201510199

BY EMAIL

Mr. Dennis Bland

Vice President, Regulatory Affairs, Telecommunications
Qubecor Mdia
th
612 St-Jacques Street, 15 Floor, South Tower
Montral, Qubec H3C 4M8
dennis.beland@quebecor.com

Re: Part I Applications regarding Vidotrons practices related to its mobile wireless Unlimited Music service
Requests for Information

Dear Mr Bland:
Attached to this letter are requests for information issued to Qubecor Mdia inc. (QMI) (or Vidotron s.e.n.c.
(Vidotron)).
Responses to these requests for information are to be filed with the Commission by 16 December 2015.
As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC
2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings,
persons may designate certain information as confidential. A person designating information as confidential must
provide a detailed explanation on why the designated information is confidential and why its disclosure would not
be in the public interest, including why the specific direct harm that would be likely to result from the disclosure
would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential
must either file an abridged version of the document omitting only the information designated as confidential or
provide reasons why an abridged version cannot be filed.
Sincerely,

Original signed by

Andrew Falcone
Senior Manager, Strategic Planning and Research
Telecommunications Sector

Questions for QMI

1.

What criteria does Vidotron use to determine whether an online audio streaming provider is eligible for
zero-rating under the Unlimited Music service?

2.

Have any online streaming audio services sought to be included in Vidotrons Unlimited Music offering,
but were not included by Vidotron? If so, explain in detail why such services were not included.

3.

What factors did Vidotron consider in making its business decision not to include radio stations in
Unlimited Music service?

4.

Would applications allowing Canadians to stream user-owned audio content for their own use qualify for
zero-rating under the Unlimited Music service (e.g. content stored in the cloud and streamed using any
audio streaming applications)? Explain why or why not.

5.

Does Vidotron currently zero-rate any other applications or services? If so, identify each application or
service. Does Vidotron plan to zero-rate any other applications or services in the future? If so, provide
the details of your plans.

6.

For the purposes of billing, how does Vidotron distinguish between the data used to stream audio and
other data usage associated with audio streaming apps (e.g. browsing websites associated with the apps,
downloading album covers, sharing playlists)?

7.

With respect to data usage associated with Unlimited Music service:

8.

9.

a.

Confirm that while data usage for the Unlimited Music service does not count towards a users
standard monthly data allowance, data usage does count towards the users monthly data
allowance for music streamed: (a) over a virtual private network (VPN), (b) at a bitrate that
exceeds 128Kbps, and (c) via tethering.

b.

If data usage for Unlimited Music is counted as set out above, explain why Vidotron imposes
these conditions on use of Unlimited Music.

c.

Are there any other Fair/Acceptable/Excessive usage policies that apply to Unlimited Music? If
so, describe each of these policies.

With respect to technical requirements to participate in Unlimited Music:

a.

Identify and describe all technical criteria and/or requirements that must be met by online
streaming music companies that participate in the Unlimited Music service.

b.

For each company participating in the Unlimited Music program, provide the technical document
containing the list of Network Flow Parameters referred to in its agreement with Vidotron.

Confirm that the Unlimited Music service is only available to subscribers of wireless packages with usage
caps of 2 GB or more or 1 GB in the case of a subscriber also subscribing to cable Internet service. What
factors did Vidotron consider in requiring that the Unlimited Music service only be available to
subscribers to these wireless packages? Explain why Unlimited Music service was not made available to
subscribers to plans with lower usage caps.

10. How many hours of music streaming within the Unlimited Music service does 1 GB represent? Provide the
methodology and assumptions made.
11. Assume that the Unlimited Music service was available as of 1 September 2014. From 1 September 2014
to 1 September 2015, provide on a monthly basis:
a.

The total number of mobile wireless subscribers to a mobile wireless data service.

b.

The percentage of those subscribers who were eligible for the Unlimited Music service.

Provide the methodology and any assumptions made.

12. From 1 September 2015 to 30 November 2015 provide, on a monthly basis:
a.

The total number of Vidotrons mobile wireless subscribers to a mobile wireless data service.

ATTACHMENT
b.

The percentage of those subscribers that are eligible for the Unlimited Music service.

13. From 1 December 2015 to 1 December 2016 provide, on a monthly basis, the following forecasted data:
a.

The total number of forecasted mobile wireless subscribers to a Vidotron mobile wireless data
service.

b.

The percentage of those subscribers that are forecasted to be eligible for the Unlimited Music
service.

Provide the methodology and assumptions made for your forecasts.

14. From 1 September 2015 to 1 December 2015, on a monthly basis, provide the following data:
a.

The number of Vidotron customers that were eligible for Unlimited Music service that actually
used the service (active customers).

b.

Both the average and median of data usage by active customers further broken down by a) data
usage under their mobile data package, b) data usage that exceeds their data caps, and c) data
usage for Unlimited Music service.

c.

The average usage by the top 5% of the heaviest active customers broken down by a) data usage
under their mobile data package, b) data usage that exceeds their data caps, and c) data usage
for Unlimited Music Service.

Provide the methodology and any assumptions made.

15. From 1 December 2015 to 1 December 2016 provide, on a monthly basis, the following forecasted data:
a.

The number of customers that are forecasted to be active customers of the Unlimited Music
service.

b.

The forecasted average and median of data usage by active customers broken down by a) data
usage under their mobile data package, b) data usage that exceeds their data caps, and c) data
usage for Unlimited Music service.

Provide the methodology and any assumptions made.

16. In its submission Vidotron suggested, in general, that the increase in traffic due to expanded music
streaming may be as much as 7.7%, but that this would be manageable in terms of network forecasting
and provisioning. It also argued that there is no meaningful risk of service degradation to the broader
customer base a result of the Unlimited Music service:
a.

Could a customers monthly data usage related to Unlimited Music be greater than the
customers monthly data allowance included in their wireless plan? Provide detailed evidence in
support of Vidotrons view, including actual and forecast usage data related to Unlimited Music.

b.

If consumers use of the Unlimited Music service results in total monthly usage that exceeds their
monthly data caps, provide a detailed explanation as to why the advantage to these consumers
of free data usage associated with Unlimited Music is justified under s. 27(2) of the
Telecommunications Act. Is there a level of usage associated with Unlimited Music that would
render the advantage undue? Is there a level at which Vidotron will reconsider its offering?
Provide full rationale in support of the companys position.

c.

If, as Vidotron has stated, congestion is manageable and there is no meaningful risk of service
degradation as a result of offering Unlimited Music service, explain why Vidotron did not either
increase or eliminate data usage caps for your broader customer base instead of zero-rating
certain applications or services.