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Telecom - Staff Letter addressed to the Distribution List

Ottawa–Gatineau, 26 January 2026

Reference: 8638-J64-202505157

BY EMAIL

Distribution List

Subject: Request for Information: Iristel’s application regarding authorization of funding from the National Contribution Fund in order to meet its Wireless Public Alerting requirements

Dear recipients:

This letter sets out the questions related to the application filed by Iristel Inc. and its affiliate Ice Wireless (Iristel), seeking, in the first instance, funding from the National Contribution Fund (NCF) in order to meet its Wireless Public Alerting (WPA) requirements set out in Implementation of the National Public Alerting System by wireless service providers to protect Canadians, Telecom Regulatory Policy CRTC 2017-91, 6 April 2017.

In response to Iristel’s request, telecommunications service providers (parties) have intervened and raised concerns. Commission staff has reviewed the application record and, based on its review, staff has concluded that further investigation is necessary. As per the Telecommunications Act (the Act) and the CRTC Rules of Practice and Procedure, the Commission may require the submission of information as necessary for the administration of the Act.

Accordingly, staff requests the parties to respond to this request for information (RFI) to assist the Commission in evaluating Iristel’s application.

Request for Information

The following questions are intended to build on parties’ submissions and to gather further information.

For Iristel

  1. Please list all steps that remain for Iristel to implement wireless public alerting (WPA) on its long-term evolution (LTE) or newer networks. For each step:

    1. Please indicate the associated upfront, non-recurring costs and, if applicable, the recurring annual costs. Please provide costs individually and in aggregate. Prospective costs are to be provided for, amongst all other significant costs, the following equipment and services:

      1. costs for the equipment and software necessary to implement WPA,
      2. costs for engineering or consulting services necessary to implement WPA,
      3. costs directly associated with connecting to the National Alert Aggregation and Dissemination system (i.e. establishing a connection between Iristel and Pelmorex),
      4. Any potential annual costs including those related to equipment, software, or other services.
    2. For any services or costs necessary to implement WPA listed in the first part of this question, please provide supporting quotes from vendors and/or manufacturers.
    3. For any costs that do not necessitate third party equipment or services, please provide supporting evidence and methodology for the cost estimates provided.

  2. Iristel submitted that when it (Iristel) began negotiating with vendors in 2017 and contacting other small wireless carriers, it became apparent that it would not be possible for wireless carriers with a small number of subscribers to implement WPA without incurring significant capital and operating costs:

    1. Specify what type of entity Iristel is referring to as “vendor” in this context (e.g., mobile device vendor, equipment vendor, etc.)?
    2. Indicate what impediments other than financial, if any, were faced by Iristel that are attributed to the vendor(s) in question with respect to implementing WPA.
    3. Specify the issues that other small carriers were facing with respect to implementing WPA on their networks.
    4. Explain why Iristel cannot overcome the stated financial barriers and other impediments identified earlier in this question to implement WPA and how it determined this.

  3. As an alternative solution to receiving funding from the NCF to implement WPA, Iristel requested an exemption from the requirement to provide WPA over relevant networks until such a time as it has enrolled 50,000 wireless subscribers. In support of this chosen threshold, Iristel provided the up front and annual per subscriber cost of implementing and operating WPA at this subscription threshold.

    1. Please elaborate on the rationale behind the proposed minimum threshold of 50,000 subscribers and why the public alerting system cannot be implemented on network with subscribers below this threshold. In preparing your answer to this question, note the fact that WSPs with significantly less than 50,000 subscribers have successfully implemented WPA on their applicable networks.
    2. Provide your methodology, calculations, and all assumptions used in support of your claimed costs. Ensure calculations incorporate all Iristel and Ice Wireless mobile subscriber totals from pre-LTE and LTE or newer networks.

  4. In its response to Bell’s intervention, Iristel submitted that Iristel and its affiliates operate as a “…bring-your-own-device…” carrier to comply with TRP 2017-91. Staff notes that in TRP 2017-91, the Commission directed wireless service providers (WSPs):

    1. to ensure all mobile devices sold are WPA-compatible and in conformance to the ATIS standard (0700021),
    2. to implement wireless public alerting capability on their LTE and newer networks, and
    3. to notify their subscribers with non-LTE-compatible handsets that they will be unable to receive emergency alert messages on their mobile devices.

    In light of these facts:

    Please comment on the Commission potentially imposing a condition of service requiring that Iristel disclose to its customers that they will be unable to receive alerts while operating on Iristel’s LTE or newer networks in the following ways:

    • Customer point of sale,
    • Posted visibly on the website,
    • Through direct communication with existing customers,
    • In the terms of service,
    • Other methods that may be deemed appropriate.
  5. CRTC staff notes that nearly all wireless service providers, including those with a relatively small number of subscribers, have implemented WPA on their applicable networks without a funding source such as the NCF. Please comment on the appropriateness of supporting Iristel’s implementation of broadly applied regulatory obligations with funding through the NCF, having regard for the above.

For Canadian Telecommunications Contribution Consortium Inc (CTCC).

In the event that the Commission grants Iristel’s request to fund set up costs and operating costs related to wireless public alerting, please indicate, with justification, the necessary updates and the timeline to distribute these funds. The response should include:

  1. A list of all updates required, including but not limited to agreements between the Central Fund Administrator (CFA) and eligible recipients and the roles and procedures of the NCF, to allow the collection and distribution of funds. Please specify the approval process required for each update.
  2. The information that the CTCC and the CFA would need from the Commission to make the updates listed above.
  3. The timeline to complete these updates and to submit to the Commission for approval, where needed.

For SSi Micro

Staff notes that SSi Micro (SSi) has recently implemented the National Public Alerting System (NPAS) per its reply to the 6 November 2025 staff letter. Considering this, please provide the following information, and provide any other comments or relevant information:

  1. What technical steps were required for SSi to implement WPA?

  2. Please indicate all the upfront, non-recurring costs and, if applicable, the anticipated recurring annual costs associated with SSi’s implementation of WPA. Include but do not limit your submitted costs to the following equipment and services:

    1. costs for the equipment and software necessary to implement WPA,
    2. costs for engineering or consulting services necessary to implement WPA,
    3. costs directly associated with connecting to the National Alert Aggregation and Dissemination system (i.e. between SSi Micro and Pelmorex),
    4. Any potential annual costs including those related to equipment, software, or other services.

  3. Indicate what impediments, other than financial, if any, were faced by SSi with respect to implementing WPA and how SSi overcame these impediments/barriers.

    1. Specifically, did SSi face any impediments related to vendors due to SSi’s small subscriber base? How did SSi overcome these impediments?

For All Interested Parties

  1. If the Commission grants Iristel’s request to subsidize, whether in whole or in part, the costs to set up and operate wireless public alerting (WPA), should the Central Fund Administrator (CFA) be the third-party administrator of this subsidy? The CFA’s role would include accounting functions such as collecting and disbursing funds to eligible Internet service providers based on a schedule provided by the Commission. If not, please suggest an alternative and provide rationale.
  2. The National Contribution Fund was established using Telecommunications Act (1993) 46.5(1), therefore any monies going to such a fund can only be used for the purpose of supporting “continuing access by Canadians to basic telecommunications services.” Please provide your views, along with supporting rationale and justification, as to whether a subsidy related to defraying the set-up and operating costs associated with WPA satisfies the statutory requirement.

Parties and other identified entities are requested to respond to every specific question that is directed to them, including questions that are directed to all parties and other identified entities, by 9 February 2026. Parties and other identified entities may then submit comments on those responses by no later than 23 February 2026. Finally, the applicant may provide a final submission by no later than 2 March 2026. All documents filed must be received, not merely sent, by the date provided.

As set out in section 39 of the Act and in Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Broadcasting and Telecom Information Bulletin CRTC 2010-961, 23 December 2010, persons may designate certain information submitted as confidential. A detailed explanation of why the designated information is confidential and why its disclosure would not be in the public interest must be provided, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in its disclosure.

If you file a document containing confidential information, an abridged version of the document omitting only the confidential information must also be filed with the Commission. Alternatively, reasons why an abridged version cannot be filed must be provided. Only the abridged version of the document will become part of the public record and will be posted on the CRTC website.

A copy of this letter and all related correspondence will be added to this application’s public record.

If you have any questions, please contact Thomas Forsey: (819) 997-4956 – Thomas.Forsey@crtc.gc.ca.

Sincerely,

Michael Crupi
Manager, Network Technology
Canadian Radio-television and Telecommunications Commission

c.c.: Jean-François Dumoulin regulatory@iristel.com
Julia Kennedy jkennedy@fasken.com
Kim Nadeau knadeau@welchllp.com
Dean Proctor regulatory@ssimicro.com
Marc Nanni: mn_crtc@proton.me
Bell Canada (Bell): bell.regulatory@bell.ca
Rogers Communications Canada Inc. (Rogers): regulatory@rci.rogers.com
Quebecor Media inc. (Quebecor): regaffairs@quebecor.com
TELUS Communications Inc. (TELUS): pamdheri@telus.com

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