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Telecom - Staff Letter addressed to the Distribution list

Gatineau, 4 March 2026

Reference(s): 8633-V3-202505587

BY EMAIL

Distribution list

Subject: Part 1 Application by Quebecor Media Inc. – Clarification of certain aspects of Telecom Regulatory Policy CRTC 2023-31 and other related decisions and orders

This letter presents a request for information (RFI) related to the above-mentioned Part 1 application filed by Quebecor Media Inc. (Quebecor).

To help build a complete record and assist the Commission in assessing the application, the parties must file responses to the questions included in the appendix below no later than 26 March 2026.

Parties may file replies with the Commission no later than 2 April 2026, limited to comments on the responses to this request for information.

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, 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.

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

Sincerely,

Original signed by

Lisanne Legros
Director, Telecommunications Networks Policy
Telecommunications

c. c. Josiane Lord, CRTC, josiane.lord@crtc.gc.ca;
Loïc Yves Abena Fouda, CRTC, LoicYves.AbenaFouda@crtc.gc.ca 

Attachments (1) Appendix

Distribution list

Quebecor Media Inc.: regaffairs@quebecor.com
Bell Canada: bell.regulatory@bell.ca
TELUS Communications Inc.: regulatory.affairs@telus.com
Rogers Communications Inc.: regulatory@rci.rogers.com
Regional County Municipality of D’Autray: fdeschenes@mrcautray.qc.ca
Regional County Municipality of Argenteuil: fjones@argenteuil.qc.ca
Regional County Municipality of Matawinie: mchebert@matawinie.org

APPENDIX

All incumbent local exchange carriers (ILECs) that own or control support structures are required to provide competitive access to these structures in accordance with a tariff and terms and conditions approved by the Commission. Bell’s support structure tariff can be found in item 901 of its National Services Tariff. Item 901.3(a) states that a support structure license agreement (SSA) must be reached, but that the tariff shall prevail in all cases where it conflicts directly with the SSA.

In Telecom Regulatory Policy 2023-31, the Commission determined that new parties seeking access to poles are not responsible for the costs associated with corrective works, to the extent that the poles or third-party equipment were out of compliance with construction standards prior to the receipt of the new attachment request.

Questions for Bell 

  1. Please indicate whether the SSA currently in effect between Bell and Quebecor contains provisions pertaining to corrective works, particularly with regard to the allocation of costs when corrective work is carried out on a support structure.
    1. If applicable, please identify the relevant clauses and explain how they relate to the terms and conditions of the support structure tariff.
    2. Please submit a complete copy of the current version of the SSA.
  2. Item 901.3(p) of the support structure tariff states that whenever emergency work is required to be performed on the licensee’s facilities, Bell will immediately advise the licensee to take necessary action or, if it does not have time to notify the licensee, will perform the necessary emergency work at the licensee’s expense.
    1. How does Bell define emergency work?
    2. Does it consider corrective work to be emergency work?
  3. On 16 October 2023, Bell filed a Tariff Notice application with the Commission stating that the wholesale support structure tariff did not reflect the cost of work to bring a structure into compliance with construction standards. A new tariff was approved in order 2025-275.
    1. Confirm that the intent of the application was for Bell to recover its costs for corrective work resulting from a license application under the approved tariff.
    2. What different factors were considered in assessing the cost of this corrective work resulting from a license application?
    3. Have costs related to the relocation of third-party facilities not involved in an access request been considered?

Questions for all parties

  1. Please describe, on the basis of your recent experience, how costs related to the relocation or reinstallation of an attaching company’s facilities are generally handled when corrective work is required to address a structural non-compliance and not as a result of a request from that company. Explain the assumptions underlying this approach.
  2. Support structure tariffs generally indicate that attached third-party facilities must be relocated at their expense when the ILEC is forced to relocate a support structure by its owner that is not the ILEC.
    1. Are there other cases where attached third parties should be required to relocate their facilities at their own expense?
    2. If yes, please specify them and the associated item or obligation.
  3. Support structure service is defined as access to support structures owned or controlled by an ILEC, enabling a Canadian cable or telecommunications company to install its facilities.
    1. Is it reasonable to consider that the support structures on which the cable or telecommunications company installs its facilities should comply with the applicable construction standards for a support structure and its attachments? Please provide explanations to support your response.
    2. Is the maintenance of support structure compliance one of the costs covered by the tariff paid by the attaching company?
    3. Is it reasonable for the company subscribing to this service to incur additional costs for relocating its facilities if this is in connection with non-compliance of the structures on which it has installed its facilities? Please provide explanations to support your response.
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