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Telecom - Staff Letter addressed to the Distribution List

Gatineau, 27 January 2026

Our Reference: 8663-B2-202501700

BY EMAIL

Distribution List

Subject: Bell Canada Part 1 Application – Adapting the Regulatory Framework for Mobile Primary Exchange Service

This letter sets out a request for information (RFI) related to the above-mentioned Bell Canada (Bell) Part 1 Application.

To help develop a fulsome record and assist the Commission in its assessment of the application, parties are asked to file responses to the questions included in the appendix below with the Commission, serving a copy on all parties to the proceeding by 20 February 2026.

Parties may file replies with the Commission no later than 6 March 2026 limited to comments on responses to this RFI.

Confidential information

As set out in section 39 of the Telecommunications 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, 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.

Sincerely,

Original signed by

Lisanne Legros
Director, Telecommunications Networks Policy
Telecommunications Sector

c.c.: Josiane Lord, CRTC, Josiane.Lord@crtc.gc.ca;
Cameron Warriner, CRTC, Cameron.Warriner@crtc.gc.ca;
Loïc Yves Abena Fouda, CRTC,LoicYves.AbenaFouda@crtc.gc.ca;
Bradley Gaudet, CRTC, Bradley.Gaudet@crtc.gc.ca;
Antica Corner, CRTC, Antica.Corner@crtc.gc.ca

Attach. (2): Distribution List
Appendix

Distribution list

Bell Canada: bell.regulatory@bell.ca;
Vaxination Informatique: jfmezei@vaxination.ca;
TELUS Communications Inc.: regulatory.affairs@telus.com;
Rogers Communications Inc.: regulatory@rci.rogers.com;
Saskatchewan Telecommunications Inc. (SaskTel): document.control@sasktel.com;
Eastlink: regulatory.Matters@corp.eastlink.ca;
Quebecor Media Inc.: regaffairs@quebecor.com;
Canadian Deaf Grassroots Movement (CDGM): canadadeafgrassrootsmovement@gmail.com;
Deaf Wireless Canada Consultative Committee (DWCC): regulatory@deafwireless.ca;
Newfoundland and Labrador Association of the Deaf (NLAD): myles.murphy@nf.sympatico.ca;
Eeyou Communications Network: c.melancon@eeyou.ca;
Deaf and Hard of Hearing Coalition (DHH Coalition): dprong@deafontario.ca; richmanelliott@gmail.com; dprong@deafontario.ca;
Canadian Association of the Deaf – Association des Sourds du Canada (CAD-ASC): info@cad-asc.ca;
Deafness Advocacy Association Nova Scotia (DAANS): daansregs@gmail.com; dans@ns.sympatico.ca;
Ontario Association of the Deaf (OAD): dprong@deafontario.ca; richmanelliott@gmail.com;
Canadian National Society of the Deaf-Blind (CNSDB): mchugh.mm@gmail.com;
Deaf-Blind Planning Committee (DBPC): dpbc2.0@gmail.com;
Audition Quebec: presidence@auditionquebec.org;
Canadian Hard of Hearing Association - BC Chapter (chha-bc.org)
president@chha-bc.org;
Fondation des Sourds du Québec: information@fondationdessourd.net;
Canadian Hard of Hearing Association: info@chha.ca; gmosher@chha.ca;
Canadian Hearing Services: info@chs.ca

Appendix

Questions to Bell

In Bell Canada’s (Bell) Part 1 Application, Bell requested confirmation that it can meet its obligation to provide stand-alone Primary Exchange Service (PES) in forborne exchanges via a mobile wireless service that provides Message Relay Service (MRS) in a “mobile wireless-compatible way.” Specifically, Bell proposes to satisfy its MRS obligation through the provision of Internet Protocol (IP) relay only as part of its mobile PES offering and is asking for confirmation that it is not required to also provide teletypewriter (TTY) relay service – or to otherwise be relieved of any such obligation – for its mobile PES offering in those exchanges.

As set out in Review of the regulatory framework for text-based message relay services, Telecom Regulatory Policy CRTC 2018-466, 14 December 2018 (the 2018 MRS policy), wireline service providers, including incumbent local exchange carrier (ILECs), competitive local exchange carriers (CLECs), and wireless CLECs, are required to provide two forms of MRS – TTY relay service and IP relay service. However, in that policy, the Commission indicated that a telecommunications service provider (TSP) seeking relief from the requirement to provide TTY relay service must provide its plans for phasing out the service, including consultation with accessibility groups. The Commission added that a TSP must demonstrate that its IP relay service is, at minimum, functionally equivalent to its existing TTY relay service and meets the minimum requirements set out in the appendix to the policy.

  1. Has Bell consulted with accessibility groups, or persons who rely on TTY-based MRS, regarding its proposal to satisfy its MRS obligation through the provision of IP relay only when seeking to meet its obligation to provide stand-alone PES in forborne exchanges using mobile wireless?

    1. If so, please provide details including who was consulted and any evidence that the proposed approach adequately addresses users’ needs.
  2. How would Bell identify TTY relay service users in any areas where it plans to replace wireline PES with mobile PES, and ensure they are all aware of the upcoming change?

Questions to all parties

In Obligation to serve and other matters, Telecom Regulatory Policy 2011-291, 3 May 2011, the Commission found that mobile wireless voice services are substitutes for wireline voice services in forborne exchanges and gave ILECs the flexibility to meet their obligation to provide stand-alone PES in those exchanges using mobile wireless services. However, details of how this would be implemented or communicated to customers were not discussed.

  1. How should Bell notify its customers that wireline phone services will no longer be available to them?
  2. How long before the transition should Bell inform its customers of the coming change?
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