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Telecom - Staff Letter addressed to the Distribution list

Gatineau, 21 January 2026

Reference(s): 1011-NOC2023-0056, 8740-A53-202302256, 8740-M59-202302264

BY EMAIL

Distribution list

Subject: Follow-up to Telecom Notice of Consultation CRTC 2023-56 – Review of the wholesale high-speed access service framework – Supplemental Requests for Information

As part of the proceeding initiated by Telecom Notice of Consultation CRTC 2023-56, Review of the wholesale high-speed access service framework, 8 March 2023 (NoC 2023-56), the Commission directed incumbent carriers to file proposed tariffs and associated cost studies, prepared in accordance with the Phase II costing methodology and supported by rationale, for fibre-to-the-premises (FTTP) facilities over aggregated wholesale high-speed access (HSA) services. The Commission also directed incumbent carriers to file new Phase II cost studies to establish rates for aggregated wholesale HSA services.

The Commission subsequently received tariff applications, along with the required supporting information, from the incumbent carriers in accordance with its directions in NoC 2023-56.

As a follow up to the cost study submissions from Bell Aliant and Bell MTS dated 15 May 2025Footnote 1, Commission staff requests supplementary information to further the review of these companies’ cost studies for fibre-to-the-premises (FTTP) facilities over aggregated wholesale HSA services. Staff may issue additional requests for information (RFIs) in due course.

Bell Aliant and Bell MTS are to submit responses to the attached requests for information no later than 11 February 2026.

All documents filed and served must be received, not merely sent, by the date provided. Parties are to send an electronic copy of all documents to Commission staff copied on this letter.

As set out in section 39 of the Telecommunications ActFootnote 2 and in Broadcasting and Telecom Information Bulletin CRTC 2010-961Footnote 3, 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.

Parties and interested persons may request the public disclosure of information that has been designated confidential in responses to the attached RFIs, setting out in each case the reasons for disclosure. These disclosure requests must be filed with the Commission and served on the entities to whom they are addressed by 18 February 2026. Responses to those disclosure requests may then be filed with the Commission no later than 4 March 2026.

Sincerely,

Original signed by

Chris Noonan
Director, Competitor Services & Costing Implementation
Telecommunications Sector

c.c.: Abderrahman El Fatihi, CRTC 819-953-3662 AbderRahman.ElFatihi@crtc.gc.ca
Stais Armstrong, CRTC 819-775-0401, Stacey.Armstrong@crtc.gc.ca

Attach. (3)

  1. Distribution List – Attachment 1
  2. Request for Information (RFI) Questions – Attachment 2
  3. Attachment 3 (Attachments upon request only)

Distribution List - Attachment 1

Bell Canada; 7664, 7664/A, 7664/B, 7664/C; 8740-B2-202302248; Philippe Gauvin; bell.regulatory@bell.ca ;
Bell Aliant Regional Communications, Limited Partnership; 569, 569/A, 569/B, 569/C, 569/D; 8740-A53-202302256; Philippe Gauvin; bell.regulatory@bell.ca ;
Bell MTS Inc.; 852, 852/A, 852/B, 852/C, 852/D; 8740-M59-202302264; Philippe Gauvin; bell.regulatory@bell.ca ;
TELUS Communications Inc.; 583, 583/A; 583/B, 583/C, 601, 657, 657/A, 657/B, 657/C, 672; 8740-T66-202303494, 8740-T69-202303502; Carol Ho; regulatory.affairs@telus.com ;
Saskatchewan Telecommunications; 378, 378/A, 378/B, 378/C, 378/D; 8740-S22-202302230; Kevin Spelay; document.control@sasktel.com ;
Cogeco; telecom.regulatory@cogeco.com ;
Eastlink; regulatory.matters@corp.eastlink.ca ;
Rogers Communications Canada Inc.; regulatory@rci.rogers.com ;
Shaw Communications; Regulatory@sjrb.ca ;
Videotron; regaffairs@quebecor.com ;
CNOC, regulatory@cnoc.ca ;
Community Fibre, ben@communityfibre.ca ;
Comwave, legal@comwave.net ;
Public Interest Advocacy Centre, jlawford@piac.ca ;
TekSavvy, regulatory@teksavvy.ca ;
Vaxination Informatique, jfmezei@vaxination.ca ;
John Roman, johnphiliproman@gmail.com ;
WaveDirect Telecommunications Limited, ryan@wavedirect.org ;
Vaxxine Computer Systems Inc., president@vaxxine.com ;
Truespeed Internet Services Inc., adam@truespeed.ca ;
SkyChoice Communications, serge@skychoice.ca ;
Securenet, info@securenet.net ;
Secure by Design, kirk@secure-by-design.com ;
OpenMedia, erin@openmedia.org ;
Netrevolution inc., drouleau@gtvr.com ;
National Capital FreeNet, execdir@ncf.ca ;
IGS Hawkesbury Inc., jbogue@hawkmail.ca ;
First Mile Connectivity Consortium, info@firstmile.ca ;
Devtel Communications Inc., devin@devtelcommunications.ca ;
CPC, campbell@campbellpatterson.com ;
Canadian Anti-Monopoly Project (CAMP), keldon@antimonopoly.ca ;
Beanfield, todd@beanfield.com ;
Marc Nanni, mn_crtc@proton.me ;
Competition Bureau, Conor.Parson@cb-bc.gc.ca ;
Competition Bureau, crtc2023-56@cb-bc.gc.ca ;
Coextro, skhandor@coextro.com ;
Carry Telecom, frankw@carrytel.ca ;
Execulink, regulatory@execulinktelecom.ca ;
Frontier Networks, cgooey@frontiernetworks.ca ;
Citywide, david@yourcitywide.com ;
CIK Telecom, jordan.d@ciktel.com ;
British Columbia Broadband Association (BCBA), admin@bcba.ca ;

Requests for Information (RFI) – Attachment 2

  1. Refer to Bell Aliant’s response to RFIs in relation to Telecom Notice of Consultation 2013-551 (TNC 2013-551), where the actual fibre to the premise (FTTP) capital expenditures and associated homes passed by year were provided.Footnote 4

    1. Complete the Excel worksheets in Attachment 3 for each company separately (i.e., Bell Aliant and Bell MTS) by year with the requested data which is identified by cells highlighted in green as follows:

      1. Total FTTP capital expenditure
      2. Total FTTP locations built to-date
      3. Total FTTP locations built in-year
      4. Total FTTP capital expenditure identified in item 1)a)i) above distributed to each capital asset class
    2. If the Actual FTTP locations built to date and the Actual Total FTTP Capital Expenditures differ from the pre-populated information included in the Attachment, for the years identified in Attachment 3, provide a fulsome explanation, including all supporting rationale, that explains the differences.
    3. Comment, in detail, with supporting rationale, on the appropriateness of distributing the actual FTTP capital expenditures by company, identified in the worksheets in both this RFI and prior staff RFI, to capital asset categories.

    4. The detailed historical FTTP cost breakdown provided by each company did not satisfy previous requests for information issued in the context of the relevant proceeding. For Bell Aliant in particular, the detailed historical cost breakdown the companies have provided in prior rounds of RFI related to Notice of Consultation 2023-56, which amounts to the years 2018 to 2023, represent roughly 25% of the locations built by the company. In Bell Aliant’s intervention submitted in the context of TNC 2013-551 – Review of wholesale services and associated policies, the company there stated that:

      “The current phase of Bell Aliant's FTTP deployment has targeted the most dense and most populated areas (and hence the relatively lowest cost) that present the most promising business case. One cannot over-emphasize however that the FTTP business case will only get increasingly more challenging as future deployments push further into lower density areas, as well as regions served by buried infrastructure.” (emphasis added)

      Given the above, explain, with supporting rationale, why these lowest cost locations should be excluded from the detailed historical cost breakdown. Further, provide the companies’ views on the appropriateness of using the Bell Canada rates as a proxy for Bell Aliant and Bell MTS, on a final basis, if the companies maintain that they are unable to provide the actual historical cost breakdown in question 1) a).

  2. Refer to the 2014Footnote 5 and 2016Footnote 6 Bell Canada Enterprises (BCE) Inc. Annual Reports where the company states:

    2014 BCE Inc. Annual Report:

    Page 17: “To compete at our best, the Bell team knows we need to work as efficiently as possible. In 2014, we realized significant cost savings across the business through tight management of spending and capital costs, increased efficiency in our customer operations, and synergies resulting from the integration of companies like Astral Media and Bell Aliant.” (emphasis added)

    Page 17: “…the privatization of Atlantic Canada affiliate Bell Aliant, completed in Q4 2014, is producing capital and operational cost savings while maintaining the strong Bell Aliant brand in Atlantic Canada. With an aligned broadband network strategy, integration of IT and other corporate operations, and elimination of duplicate public company costs as with Astral, Bell will realize substantial Bell Aliant synergies in both the wireline and wireless segments in 2015.” (emphasis added)

    Page 40: “Completed the Privatization of Bell Aliant and began its integration into Bell’s operations, simplifying BCE’s corporate structure and increasing overall operating and capital investment efficiencies, including wholesale cost savings, as we move Atlantic branches of major business customers onto the national Bell network” (emphasis added)

    2016 BCE Inc. Annual Report:

    Page 44: “Realize operating cost savings from workforce attrition and retirements, lower contracted rates from our suppliers, reduction in traffic that is not on our wireline network, broader deployment of FTTP, customer service improvements, and operating cost synergies from the planned integration of MTS into our Bell Wireline and Bell Wireless operating segments following the completion of the acquisition by BCE” (emphasis added)

    Page 56: “Capture operating cost and capital expenditure synergies from the integration of MTS following the completion of the acquisition by BCE” (emphasis added)

    1. Refer to the “Upfront Development Costs to Introduce FTTP Services” described in Bell AliantFootnote 7 and Bell MTS’Footnote 8 FTTP access cost study reports where it states:

      “The systems and operational processes to offer a Wholesale aggregated FTTP service do not exist in any portions of our serving territory today. The build required to offer such services will be significant as we have three separate and unique regions and each have unique network architectures, and their own IS/IT systems and processes. Effectively we would have to do three unique "builds" (i.e., Central (Ontario and Quebec), Atlantic and Manitoba) to be able to offer such services across those regions.” (emphasis added)

      1. Refer to the worksheet titled “IS IT Development Costs” in each of the Bell Canada, Bell Aliant and Bell MTS “Fibre To The Premises (FTTP) Access – Monthly Rate” IVA cost models. For each task identified under the headings “FTTP Development on existing IS/IT systems” and “Development on future IS/IT Systems and migration”, explain in detail, with supporting rationale, why these same current and future tasks have not been standardized across all companies and have not been subsequently integrated into a single system and set of processes, taking into consideration the above references from the 2014 and 2016 Annual Reports that state that numerous systems began integration many years prior.
      2. Having regard to the above noted activities undertaken by Bell Canada Enterprises, justify the appropriateness of setting rates based on costs for three distinct systems and processes versus on the basis of one integrated and uniform IS/IT system(s) and process(es).

    2. Refer to the “Expenses Causal to Demand” described in Bell AliantFootnote 9 and Bell MTS’Footnote 10 FTTP access cost study reports where it is stated:

      “the expense unit costs used for years 1, 2, and 3 represent the expense unit costs associated with offering FTTP access within the current IS/IT systems in our [Atlantic and Manitoba] serving [territories] whereas the expense unit costs used for years 4 and 5 represent the expense unit costs that reflect the efficiency gains that we expect to realize within the new IS/IT systems which will be introduced under Phase II… [by] years 4 and 5, we will have a common system across all regions with more automation. Therefore, for years 4 and 5, we have used the expense unit costs used in the GAS-FTTP cost study for Ontario and Quebec as a proxy where applicable since we assume that by that time we would have achieved a similar level of automation that we will have in Ontario and Quebec.”

      Further, refer to the worksheet named “Expense Details (years 1-3)” in each of Bell Aliant and Bell MTS’ IVA cost models as follows:

      • Bell Aliant “Fibre To The Premises (FTTP) Access – Monthly Rate”
      • Bell MTS “Fibre To The Premises (FTTP) Access – Monthly Rate”
      • Bell Aliant “Fibre To The Premises (FTTP) Access – Installation Service Charge with Visit”
      • Bell MTS “Fibre To The Premises (FTTP) Access – Installation Service Charge with Visit”
      • Bell Aliant “Fibre To The Premises (FTTP) Access – Installation Service Charge with No Visit”
      • Bell MTS “Fibre To The Premises (FTTP) Access – Installation Service Charge with No Visit”
      1. Explain in detail, with supporting rationale, why the above-referenced tasks for years 1 through 3 across all companies have not been standardized and subsequently integrated into one IS/IT system and set of processes, taking into consideration the above references from the 2014 and 2016 Annual Reports that state that numerous systems began integration many years prior.
      2. Explain in detail, with supporting rationale, the extent Bell Aliant and Bell MTS are able to leverage the resources, expertise, and business processes of Bell Canada in order to integrate their activities, and state why it anticipates to incur the above-referenced “Expense Details (years 1-3)” tasks, taking into consideration Bell Aliant and Bell MTS’ response to question 2)b)i) above.

  3. Refer to the expense items identified in the following:

    • “PROPOSED - Bell Aliant TN 569C - ATT 2 - APP 2 - FTTP SC with Visit - REVISED_ABR” (“Bell Aliant Installation Charge Model With Visit”), worksheet “Table 6a – Expenses”, expense items “Inward Sales Management No Access Bell” (item number 14) and “Inward Sales Management No Access Contractor” (item number 15)
    • “PROPOSED - Bell MTS TN 852C - ATT 2 - APP 2 - FTTP SC with Visit_ABR” (“Bell MTS Installation Charge Model with Visit”), worksheet “Table 6a – Expenses”, expense items “Inward Sales Management No Access Bell” (item number 14) and “Inward Sales Management No Access Contractor” (item number 15)
    1. Explain in detail, with supporting rationale, why the occurrence rates for “Inward Sales Management No Access Bell” and “Inward Sales Management No Access Contractor” in Bell Aliant and Bell MTS’ serving territory differ from that of Bell Canada’s serving territory.
    2. Provide supporting evidence in the form of, for example, service visit logs that validate the occurrence rate for “Inward Sales Management No Access Bell” and “Inward Sales Management No Access Contractor” in each of Bell Aliant and Bell MTS’ serving territories for the years 2019 to 2023.
    3. Explain in detail, with supporting rationale, what factors result in the occurrence rate for “Inward Sales Management No Access Bell” and “Inward Sales Management No Access Contractor” being similar between the serving territories of Bell MTS and Bell Aliant, but different from the serving territory of Bell Canada.
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