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Telecom - Staff Letter addressed to the Distribution List

Gatineau, 3 October 2025

Our Reference: 1011-NOC2025-0010

BY EMAIL

Distribution List

Subject: Implementing a retail Internet service subsidy in the Far North, Notice of Consultation CRTC 2025-10, Request for information-4 – 3 October 2025

This letter sets out a request for information (RFI) related to the proceeding initiated by Telecom Notice of Consultation CRTC 2025-10, to implement a retail Internet service subsidy in the Far North.

In response to questions issued in RFI-2 on 17 June 2025, SSi Micro Ltd. (SSi) noted that the Commission’s definition of retail InternetFootnote 1 explicitly excludes mobile wireless data services and submitted that:

“If this were interpreted to exclude nomadic internet services, it would also exclude the services offered by many of the existing and potential ISPs in the Far North, given the use of wireless technologies in Far Northern areas, such as Nunavut. This would in turn limit the benefits of choice, innovation, service, and price that come with competition.”

Commission staff notes that Telecom Notice of Consultation CRTC 2022-147 explicitly excluded mobile wireless services from its scope and defined these services as:

“Mobile wireless voice and data (including text) services. Mobile wireless data services include, but are not limited to, data plans for smartphones and tablets as well as mobile Internet plans used with Internet hubs, sticks, keys, and MiFi or similar devices. The Wireless Code applies to contracts for mobile wireless services.”

As such, any determination made in the resulting Telecommunications Regulatory Policy 2025-9, in which the Commission determined it would introduce a subsidy for retail Internet in the Far North, would apply only to Internet access services and exclude mobile wireless data services.

However, Commission staff notes SSi’s concerns that this would exclude some services currently offered by SSi in Nunavut. Commission staff notes, as indicated by the Commission in Telecom Regulatory Policy 2025-9, “… to improve affordability [the subsidy] should be available in all communities and to all ISPs operating in the Far North. This will help ensure that it does not act as a barrier to competition and consumer choice, and that customers can benefit regardless of where they live or who their ISP is.”

SSi’s submission raises the possibility that there may be some customers who use mobile wireless data services as a functional equivalent for retail Internet services where other options are not available.

The following questions seek to better understand if there are specific circumstances under which some mobile wireless data services should be considered eligible for the subsidy.

Request for information

  1. In TRP 2025-9, the Commission introduced a retail Internet service subsidy to improve the affordability of Internet services in all households in the Far North. However, as indicated by SSi, some households in the Far North may subscribe to mobile wireless data services to access the Internet within their household.

    1. Are there specific circumstances where some mobile wireless data services should be eligible for the subsidy? Explain what these circumstances may be (for example: there are limited or no terrestrial retail Internet services available; there is limited competition in the area, the mobile wireless data service is the only Internet service in the household, the end user does not use mobile wireless data outside their household, etc.).
    2. What plan, network, subscriber equipment (i.e. a wireless modem), features, or technical characteristics that can differentiate between mobile wireless data services being used by households to access the Internet and an individual’s mobile wireless plan?
    3. Is the eligibility of some mobile wireless data services to the subsidy necessary to ensure that the affordability of Internet access is improved for all households in the Far North?
    4. Should all TSPs offering mobile wireless data service plans to households as their primary method to access the Internet in the Far North, coupled with the circumstances identified in response to 1a), be eligible to receive the subsidy for those plans? Explain why and how they can be identified.
    5. What proof would be necessary in order to establish that a household meets the criteria set out in response to question d.

    Respondents: All parties

  1. Should the same approach to mobile wireless data services apply throughout the Far North or are there specific areas where more flexibility in service eligibility is required, such as Nunavut?

    1. Explain how the Commission could identify the areas where an exception to the service eligible for the subsidy should be considered.

    Respondents: All parties

  1. In response to RFI-2, SSi stated that nomadicity is a key feature of its QINIQ broadband offerings, as it allows its subscribers to move their premises equipment within and beyond the Far North, thereby enabling them to use Internet services outside of their household. Further, SSi stated:

    “to use customer premises equipment to access internet services outside of SSi’s network area in the Far North, the customer must purchase out-of-region roaming data, which is billed and tracked separately from the in-region plans.”

    In reply comments to RFI-2, Bell and Northwestel Inc. (Bell and Northwestel) addressed SSi’s proposal to make nomadic Internet services eligible for the subsidy by submitting:

    “The subsidy was specifically designed to address affordability challenges faced by "households in the Far North." Nomadic services, by definition, can be used anywhere, including outside of the Far North, which would defeat the targeted focus of the subsidy and potentially divert funds to services used elsewhere in Canada or internationally.”

    With the above in mind, provide responses to the following questions:

    1. Clarify what your network area is and whether it extends beyond the Far North as defined in the proceeding. If so, comment on whether it is possible to distinguish between subscribers using mobile wireless data services within or outside of the Far North?
    2. Using 2023 and 2024 data, provide the number of subscribers that have roamed outside of your serving territory, including what percentage of overall data consumption this represents.

    Respondents: SSi

    1. The Commission created the subsidy for the Far North. How can the Commission ensure that the subsidy is only available for services subscribed to and used within the Far North if it deems some mobile wireless data services, in specific circumstances as identified above, eligible to receive the subsidy? How can ISPs ensure that these services are only accessed by subscribers in the Far North?

    Respondents: All parties

  1. Does your company offer access to the Internet to households via mobile wireless data services within the Far North? If so, identify what these services are, where you are offering them and whether they should be eligible.

    Respondents: All TSPs

  1. In Telecom Notice of Consultation CRTC 2025-10, the Commission indicated its intent to balance improvements to affordability with the impact on the National Contribution Fund. To inform the Commission’s considerations on this matter, provide your total number of mobile wireless data services subscribers in 2024, and projections for 2025 and 2026. Identify which of these subscribers could be eligible based on the specific circumstances identified above. Separate these subscribers by “data only plans” and “voice and data plans”, as well as by the device used by the subscriber (such as smartphones or tablets and Internet hubs, sticks, keys, and MiFi or similar devices). Include the prices of these plans. Further, identify in which community and territory or province these subscribers are located.

    Respondents: TSPs providing mobile wireless data services in the Far North, including SSi

  1. In response to RFI-2, Starlink indicated that it does not provide subscriber data separated by community and indicated that this level of detail is not available, as users self-install the service at a location of their choosing, which may span multiple census subdivisions, particularly in remote or rural areas. However, Starlink noted that the subscribers listed for Alberta and British Columbia were only those located in the Far North.

    1. Confirm whether you can identify the community in which subscribers are accessing your services.
    2. Would you be able to ensure that the subsidy is only available for services subscribed to and used only within the Far North?
    3. Are subscribers to Starlink Residential plans required to update their service address if they wish to move their premise equipment and use the service from a different location?
    4. What happens if Starlink Residential subscribers move to a new location but do not update their service address? Will they still be able to use the service in this case?

    Respondents: Starlink

    1. If it were a condition of eligibility for the subsidy program, would your organization be able to provide the numbers of subscribers by community for fixed Internet services and mobile wireless data services?

    Respondents: All parties, including Starlink

  1. Referring to the definition of “fixed wireless services” in Telecom Notice of Consultation CRTC 2022-147,Footnote 2 what differentiates equipment providing fixed wireless services from equipment providing mobile wireless services such as hubs, sticks, keys, and MiFi or similar devices? Furthermore, explain what modifications could be done to hubs, sticks, keys, and MiFi or similar devices for the services used by them to be considered as fixed wireless services?
  2. Respondents: All parties, including SSi
  1. How are SIM cards used in mobile devices different from those used in hubs, sticks, keys, and MiFi or similar devices (e.g., SIM cards providing data and voice services versus data-only)? Furthermore, how does this differ from SIM cards used by equipment to provide fixed wireless services (e.g., SIM cards providing access to service to a specific location only)?
  2. Respondents: All parties
  1. From a network perspective, would you provide fixed wireless services differently from mobile wireless services (e.g., using specific cell sites/frequency bands to provide fixed wireless services)?
  2. Respondents: All parties

Parties are asked to file responses to the questions included in this letter by 17 October 2025.

Parties may file replies providing comments on responses to this request for information with the Commission no later than 24 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.

If you have any questions, please do not hesitate to contact me (Lisanne.Legros@crtc.gc.ca), or the Commission's Indigenous Relations Team at era-irt@crtc.gc.ca.

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.: Josiane Lord, CRTC, josiane.lord@crtc.gc.ca
Sarah McMaster, CRTC, Sarah.McMaster@crtc.gc.ca
Hayley Meulenbroeks, CRTC, Hayley.Meulenbroeks@crtc.gc.ca
Loïc Yves Abena Fouda, CRTC, loicyves.abenafouda@crtc.gc.ca

Distribution list:

Central Fund Administrator: knadeau@cfawelchllp.com
Canadian Telecommunications Contribution Consortium Inc.: jkennedy@fasken.com
Government of British Columbia: rachel.greenspan@gov.bc.ca
Union of British Columbia Municipalities: rtagami@ubcm.ca
Government of the Northwest Territories: dave_heffernan@gov.nt.ca
Kativik Regional Government: dpellerin@krg.ca
Regional District of Kitimat Stikine: drockle@icloud.com
Peace River Regional District: trevor.ouellette@prrd.bc.ca
Taku River Tlingit First Nation: wcd.cherishclarke@gov.trtfn.com, geoff@batstonelaw.com
Mount Lorne Local Advisory Council: lac@mtlorne.ca
Tagish Community Centre: brycebekar@gmail.com
Public Interest Advocacy Centre: tdawood@piac.ca
Canada Deaf Grassroots Movement: canadadeafgrassrootsmovement@gmail.com
Bell Canada and Northwestel Inc.: regulatoryaffairs@nwtel.ca
Iristel Inc.: regulatory@iristel.com
Quebecor Media Inc: regaffairs@quebecor.com
Rogers Communications Canada Inc.: regulatory@rci.rogers.com
SpaceX Canada Corp.: Shea.Boyd@spacex.com
SSi Canada: regulatory@ssicanada.com
TELUS Communications Inc.: Kim.Miller@telus.com
Paulhus Communications Inc.: paulhuscommunications@gmail.com
Nicole Corrado: ntcorrado@rogers.com
Marc Coulombe: mc470903@gmail.com
Jeremy Freeman: jeremyfreemanbiol@gmail.com
Ron Knowling: ronknowling@gmail.com
Virginia Labelle: virginia_labelle@hotmail.com
Cyril Melin: vetemelin@gmail.com
Yuri Podmoroff: yuri_podmoroff@hotmail.com
Richard Schlosser: rickrschlosser@gmail.com
Jennifer Tregidgo: Jtregclav@gmail.com
Douglas Tutty: douglas.tutty@hushmail.com
Warren Mulvey: mulveyw@live.com
Frances Woodcock: Franwoodcock@gmail.com

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