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Telecom - Staff Letter addressed to the Distribution list

Gatineau, 4 September 2025

Reference(s): 8640-J92-202501551

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Distribution list

Subject: Part 1 Application Seeking Forbearance of Residential and Business Local Exchange Services in the Incumbent Exchanges of Independent Telecommunications Providers Association Member Companies, Request for information – 4 September 2025

The Commission is currently considering the above referenced Part 1 Application from the Independent Telecommunications Providers Association (ITPA) seeking forbearance of residential and business local exchange services in the incumbent exchanges of ITPA member companies.

Pursuant to section 37 of the Telecommunications Act, the Commission may require any person to submit information that is necessary for the administration of the Act.To help develop a fulsome record and assist the Commission in its assessment of the Part 1 Application, parties are to file responses to the questions directed towards all parties and the ITPA included in the appendix below by 22 September 2025. Mobile wireless service providers are to then file responses to the question directed towards them by 13 October 2025.

The ITPA will then have an opportunity to file a reply by 17 October 2025.

Confidential information

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, parties may designate certain information as confidential.

A party designating information as confidential must provide a detailed explanation of 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 party 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.

A copy of this letter will be placed on the public record of this proceeding.

Yours sincerely,

Original signed by

Lisanne Legros
Director, Telecommunications Networks Policy
Telecommunications Sector

c.c.:     Simon Wozny, CRTC, simon.wozny@crtc.gc.ca
Jordan Wegner, CRTC, jordan.wegner@crtc.gc.ca

Distribution List:

Independent Telecommunications Providers Association: regulatory@itpa.ca
Mark Nanni: mn_crtc@proton.me;
SaskTel: document.control@sasktel.com;
Bell Canada: bell.regulatory@bell.ca;
TELUS Communications Inc.: regulatory.affairs@telus.com;
Québecor Media Inc.: regaffairs@quebecor.com;
Bragg Communications Inc.: regulatory.matters@corp.eastlink.ca;

Appendix: Questions

To all parties

  1. The ITPA submitted in its application (at para. 23):

    The requirement in TRP 2009-379 to show entry by at least one other wireline CLEC has had the unintended consequence of preventing successful applications for local forbearance by SILECs, with the result that it is no longer an effective regulatory mechanism that can deliver the needed pricing flexibility for SILECs in the face of growing competition by an ever-present wave of far larger competitors.

    In Telecom Regulatory Policy CRTC 2009-379 | CRTC, para. 20, the Commission indicated that for SILECs, where the 75 percent competitor presence threshold is unlikely to ever be achieved, the Commission will consider that the competitor presence test has been met if the following circumstances exist in the relevant market:

    For residential local exchange services, there must be, in addition to the SILEC, at least two independent facilities-based telecommunications service providers, including providers of mobile wireless services, each of which offers local exchange services in the market and is capable of serving at least 50 percent of the number of residential local exchange service lines that the SILEC is capable of serving, and at least one of which, in addition to the SILEC, is a facilities-based, fixed-line telecommunications service provider;

    or

    For business local exchange services, there must be, in addition to the SILEC, at least one other independent facilities-based, fixed-line telecommunications service provider that offers local exchange services in the market and is capable of serving at least 50 percent of the number of business local exchange service lines that the SILEC is capable of serving.”

    If the Commission were to grant the ITPA’s request for forbearance in exchanges without a  wireline (or fixed-line) competitor and place greater emphasis on the presence of mobile wireless services and/or the percentage of premises served with broadband sufficient to support local Voice over Internet Protocol (VoIP) in assessing whether it is appropriate to forbear from residential and business local exchange services, how should the criteria above be modified? In your response, please address both the criteria for residential and business services. In particular, provide your views on the following:

    1. What would be an appropriate minimum number of wireless service providers operating in an exchange for the market to be considered sufficiently competitive, and why?
    2. What minimum percentage of wireless coverage within an exchange should be considered sufficient to demonstrate competitive presence for the purposes of forbearance, and why?
    3. To what extent should the percentage of premises served with broadband sufficient to support local VoIP be a factor in determining whether it is appropriate to forbear?

To the ITPA

  1. In Telecom Regulatory Policy CRTC 2009-379 | CRTC, para. 37, the Commission determined that all SILEC local forbearance applications must include the information required in Appendix 1 to that decision. For each exchange identified in the ITPA’s application, provide the required information per Appendix 1, including a list of the relevant tariff items and numbers for which forbearance is requested.

To mobile wireless service providers named in the ITPA’s application (Bell, Bell Mobility, Brooke Telecom, Chatr, Eastlink, Execulink, Fido, Fizz, Freedom, Koodo, Lucky, No Name, PC Mobile, Public Mobile, Rogers, TELUS, Vidéotron, Virgin)

  1. In Telecom Regulatory Policy CRTC 2009-379 | CRTC, wireless service providers are required to provide the information at Appendix 4 to support a SILEC’s forbearance request in an exchange. For each exchange where the ITPA has indicated you provide mobile services,Footnote 1 please provide the information required under Appendix 4.
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