Well to me this is a Non issue. We have unlimited and the way we upgrade our phones is simple....
We pay 10 dollars extra a month to have a 3rd line. On this line we upgrade it every 2 years and get a new phone. We simply move the phone over to which ever line we want and then presto Upgraded phone through the back door. Also We wait till the phone is free. That way we are paying 240 for the upgrade. Like last time I updated to the Galaxy S4 on Black Friday of last year. It was free. However that means between me and my wife we only get an upgrade every 4 years. She is still on the Droid 4. So hopefully in 2015 she will get the Samsung Galaxy S 5 or 6.
Ironically this is exactly how I upgraded one of my unlimited lines using the Edge program, and the other was a CLNR. It's fairly easy to get them to give a newer CLNR model to replace a non-performing older model.
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