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Telecom - Staff Letter addressed to the Distribution List

Gatineau, 11 March 2026

Our Reference: 8662-B2-202505066, 8662-T3-202505975

BY EMAIL

Distribution List

Subject: Part 1 Applications for the Review and Variance of Telecom Decision CRTC 2025-225, Mandatory Notification and Reporting of Major Telecommunications Service Outages

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

To help develop a fulsome record and to assist the Commission in its assessment of the applications, parties, as specified, are asked to respond to the questions included in the appendix to this letter.

Parties responding to the questions appended to this letter must file responses with the Commission and provide a copy to all parties to the proceeding no later than 10 April 2026.

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.

Yours sincerely,

Original signed by

Aysha Omar
Director, Broadband and Network Engineering
Telecommunications Sector

c.c.: James Ndirangu, CRTC, james.ndirangu@crtc.gc.ca;
Vish Iyer, CRTC, vish.iyer@crtc.gc.ca;
Julian Brainerd, CRTC, julian.brainerd@crtc.gc.ca

Distribution List

Philippe Gauvin, Assistant General Counsel, Bell Canada, Philippe.Gauvin@bell.ca
Marielle Wilson, Vice President, Regulatory, Bragg Communications Inc., Marielle.Wilson@corp.eastlink.ca
Paul Beaudry, Vice President, Regulatory and Corporate Affairs, Cogeco Communications Inc., Paul.Beaudry@cogeco.com
Mélanie Cardin, Director, Regulatory Affairs Telecommunications, Quebecor Media Inc., Melanie.Cardin@quebecor.com
Howard Slawner, Vice President, Regulatory, Telecom, Rogers Communications Canada Inc., Regulatory@rci.rogers.com
Kevin Spelay, Director, Regulatory Affairs, Saskatchewan Telecommunications, Kevin.Spelay@sasktel.com
Stephen Schmidt, Vice-President, Telecom Policy & Chief Regulatory Legal Counsel, TELUS Communications Inc., Stephen.Schmidt@telus.com
Jonathan Holmes, Executive Director, Independent Telecommunications Providers Association, Jonathan.Holmes@itpa.ca
John P. Roman, Director Legal & Regulatory Affairs, Canadian Communications Systems Alliance, Jroman@ccsaonline.ca
Andy Kaplan-Myrth, VP, Regulatory & Carrier Affairs, TekSavvy Solutions Inc., Akaplanmyrth@teksavvy.ca
Bill Payne, Director, Information Technology, Halton Regional Police Service, Bill.Payne@haltonpolice.ca
Samer Bishay, CEO, Iristel Inc., Regulatory@iristel.com
Joe Power, President, Calabogie Peaks ULC, Fibernetics Corporation, Purple Cow Internet Inc. and 4141903 CANADA INC. o/a Storm Internet Services, Regulatory@purplecowinternet.com
Marc Nanni, Mn_crtc@proton.me
Cindy Wallace, Regulatory Counsel, Xplore Inc., Legal@xplore.ca
Laura Foulds, Regulatory Analyst, Tbaytel, Laura.Foulds@gmail.com
Jean-Francois Mezei, Consultant, Vaxination Informatique, Jfmezei@vaxination.ca
Tahira Dawood, Staff Lawyer, Public Interest Advocacy Centre, Tdawood@piac.ca
Kimberly Wood, Founder/Chair, Canada Deaf Grassroots Movement, Canadadeafgrassrootsmovement@gmail.com
Elisabeth Neasmith, Senior Director, ITU and Regulatory, Telesat, Eneasmith@telesat.com
Dennis Béland, Vice President, Regulatory Affairs, Terrestar, reglementaire-regulatory@terrestar.ca

Attach. (1) Appendix

APPENDIX

In Telecom Decision 2025-225 (the Decision), the Commission defined the mandatory notification and reporting requirements for major service outages and established timelines to implement these requirements.

On 7 October 2025, Bell Canada; Bragg Communications Inc (operating as Eastlink); Cogeco Communications Inc., on behalf of Cogeco Connexion Inc.; Québecor Media Inc., on behalf of Videotron Ltd and Freedom Mobile Inc.; Rogers Communications Canada Inc.; Saskatchewan Telecommunications; and TELUS Communications Inc. (the Applicants) filed a Part 1 Application for the Review and Variance of Telecom Decision 2025-225.

Separately, on 3 December 2025, Telesat filed a Part 1 Application to Review and Vary Telecom Decision 2025-225.

The Commission considered both Part 1 Applications and issued its decision to combine the two on 13 February 2026.

In the questions below, the term “Applicants” refers only to the parties that filed the 7 October 2025 Part 1 application. Where questions are directed at specific companies, including Telesat, this is specified below.

Questions for each Applicant

  1. The Applicants estimate that, if the outage threshold set out in the Decision is implemented, the Commission would receive over 1,000 reported outages from them. In the Decision, a major primary service outage is one that lasts for more than 30 minutes and affects at least 600,000 user-minutes or results in a community isolation event. The Applicants also indicated that they could provide carrier-specific estimates if the Commission requested them.

    1. Provide your company’s estimated number of outages that were included in the Applicants’ estimate of over 1,000 outages that would have met the major primary service outage threshold established in the Decision, along with the following details:

      1. The period (i.e., start and end date in day/month/year) during which these outages occurred.
      2. Number of end-users affected as defined in the Decision.
      3. Total duration of each outage.

    2. Provide the number of outages your company experienced in 2024 and 2025 that meet the major primary service outage threshold in the Decision. For each outage, provide the following information:

      1. Number of end-users affected as defined in the Decision.
      2. Total duration of each outage.

    3. The Applicants submitted that the 600,000 user-minute threshold represents a significant administrative burden and recommend changing the threshold to 50,000 users over one hour. Alternatively, if the Commission decides to use “user-minutes,” it should start with a threshold of 1.8 million user-minutes. For outages that occurred in 2025, please fill out the following table to provide information under each of the proposed major primary service outage thresholds:

      Thresholds
      User-minutes, for outages over 30 minutes User count, for outages over 60 minutes
      600,000 900,000 1.2 million 1.5 million 1.8 million 50,000
      Total number of outages            
      Combined end-users affected from all outages, as defined in the Decision            
      Combined duration of all outages, as defined in the Decision            
    4. Using the major primary service outage threshold in the Decision, do you estimate that the number of such outages your company will experience each year over the next 5 years (to the end of 2030) will increase or decrease compared to 2025, and by what percentage? Explain why, with supporting rationale and assumptions.

  2. The Applicants proposed that once the applicable thresholds are confirmed, they would require nine months to implement automation and/or process changes for outage notifications. Respond to the questions below under the scenario that your company will submit notifications to the Commission using the existing outage email, as directed in the Decision:

    1. What number of outage notifications per year would trigger you to automate your outage notification process instead of manually emailing notifications to the Commission?

    2. If your company intends to automate its notification process:

      1. Describe your planned automated process to submit outage notifications to the Commission by email. Identify and explain in detail each step in the process.
      2. Identify and explain any steps that will still be manual.
      3. What part of the automated submission process had been completed by the 4 November deadline set out in the Decision? What has been completed to date?
      4. Explain the benefits and efficiencies that your company hopes to realize through automation of the notification process. Explain whether and how automation would help reduce the burden of increased notification and reporting.
    3. If your company has not or does not intend to automate the process to submit notifications based on the Decision, describe with supporting rationale what modifications, if any, are required to the manual notification process you have been using for the interim outage notification requirements in effect since 2023.
    4. If your company has already automated the notification process, describe with supporting rationale what modifications, if any, need to be made based on the Decision. Also, explain why you require additional time to implement notification, given that you already have the systems and infrastructure in place for automation.

  3. The Applicants submitted that they cannot implement the new thresholds within the stipulated two-month period in the Decision. Respond to the questions below under the scenario that your company will submit notifications to the Commission using the existing outage email, as directed in the Decision:

    1. Identify with rationale the number of calendar days your company would require to implement your outage notification process under each of the major primary service outage thresholds in the table below. For each threshold, identify if your company will:

      1. manually submit outage notifications to the CRTC’s outage email; or
      2. automate submission of outage notifications to the CRTC’s outage email.
      Thresholds
      User-minutes, for outages over 30 minutes User count, for outages over 60 minutes
      600,000 900,000 1.2 million 1.5 million 1.8 million 50,000
      Calendar days required to implement outage notification process, if your company will: Manually submit outage notifications to CRTC's outage email            
      Automate submission of outage notifications to CRTC's outage email            

    2. Explain how you could temporarily implement a manual process to submit your outage notifications until you have implemented an automated process, for each threshold identified in the above table:

      1. Describe, with supporting rationale, what modifications, if any, are required to the manual notification process you are using for the interim outage notification requirements in effect since 2023.
      2. Explain how many calendar days you would need to implement this temporary manual notification process until you can implement the automated process.

  4. Do you use services provided by satellite operators?

    1. If so, list the satellite services used by you, along with the names of the satellite operator that provides each service.

Questions for each Applicant, Telesat, and Terrestar

  1. In a scenario where a satellite transport provider is unable to estimate the number of affected end-users of their TSP during an outage, they could potentially approximate the number of end-users using a formula that divides the unavailable satellite transport throughput capacity by the bandwidth of the lowest tier retail internet plan download speed in areas served by satellite transport, and multiplying it by a typical internet access network oversubscription ratio,Footnote 1 i.e.,

    Approximate number of end-users affected = (satellite transport throughput capacity unavailable due to the outage /lowest tier retail internet plan download speed) * typical internet access network oversubscription ratio.

    1. Which of the following is the most accurate and readily available satellite transport capacity metric to use to identify “satellite transportthroughput capacity unavailable due to the outage” in the above formula for each of the various types of satellites that you use currently and in the future, including GEO, GEO-HTS and LEO Satellites? Also, indicate whether it should apply per satellite, per beam, per spot beam, per transponder, or per service cell.

      1. Net usable forward link physical layer throughput capacity,
      2. provisioned throughput capacity,
      3. typical peak daily throughput, or
      4. typical average daily throughput?
    2. If the above metrics are not the most accurate representation of transport capacity or are not readily available to satellite transport providers, explain whether any other metric is more appropriate to identify satellite transport throughput capacity unavailable due to the outage.

    3. What retail internet plan speed should be used in the above formula to represent the lowest-tier speed during busy hours for areas served by satellite transport, for each of the various types of satellites that you use currently and in the future, including GEO, GEO-HTS and LEO Satellites?

      1. If you rely on satellite transport to provide internet access, what is the lowest-tier internet access speed you provide to your retail internet customers?

    4. What oversubscription ratio should be used as the typical retail internet access networkoversubscription during busy hours to avoid underestimating the number of retail internet access end-users served by a TSP that relies on satellite transport leased bandwidth for each of the various types of satellites that you use currently and in the future, including GEO, GEO-HTS and LEO Satellites?

      1. If you rely on satellite transport to provide retail internet access, what oversubscription ratio do you use in your network?
    5. Provide the average Mbps per-subscriber for retail internet service at peak hour in your access network that relies on satellite transport.

    6. Comment, with supporting rationale, if the above formula is an appropriate method of approximating end-users of downstream TSPs.

      1. If not, propose an alternative formula that a satellite transport provider could use to approximate the number of end-users of downstream TSPs. Include how the above formula should take into account: i) the typical retail services that rely on satellite transport (e.g., telephone service or internet access), ii) accurately identifying end-users, iii) the transport capacity information available to the satellite transport provider, iv) variances in retail internet plans, and v) variability in oversubscription ratio.

  2. The FCC has specific outage reporting requirementsFootnote 2 for satellite operators. All satellite communications providers must submit electronically a notification to the FCC within 120 minutes of discovering that they have experienced on any facilities that they own, operate, lease, or otherwise utilize, an outage of at least 30 minutes duration that manifests itself as:

    • A failure of any of the following key system elements: One or more satellite transponders, satellite beams, inter-satellite links, or entire satellites.
    • A loss of complete accessibility to at least one satellite or transponder;
    • A loss of a satellite communications link that potentially affects at least 900,000 user-minutes (as defined in § 4.7(d) of the FCC requirements) of either telephony service or paging service; or
    • Potentially affecting a 911 special facility (as defined in § 4.5(e) of the FCC requirements) or potentially affecting a 988 special facility (as defined in § 4.5(f) of the FCC requirements), in which case the affected facility shall be notified in the manner described in paragraph (h) or (i) of this section of the FCC requirements, respectively.

    1. Explain, with supporting rationale, whether the FCC’s criteria and thresholds for identifying a major satellite outage should be used as an alternative way to identify an outage resulting in a major primary service outage when satellite network providers are unable to identify the number of end users based on the threshold for a major primary service outage in the Decision? If not, explain why and provide supporting rationale.

      1. Should the failure of one or more satellite transponders, satellite beams, inter-satellite links, or entire satellites be the threshold for a satellite outage that results in a major primary service outage? If not, explain why and provide supporting rationale.
      2. Should a loss of complete accessibility to at least one satellite or transponder be the threshold for a major primary service outage for satellite operators? If not, provide an alternative trigger to capture outages due to a loss of complete accessibility to at least one satellite or transponder.
      3. Should the loss of a satellite communications link that potentially affects either telephony service or paging service be the threshold for a major primary service outage for satellite operators? If so, explain with supporting rationale and evidence for each, whether the appropriate threshold for a major primary service outage in Canada is 600,000 user-minutes, 900,000 user-minutes, or more?
      4. Should potentially affecting a 911 special facility (as defined in § 4.5(e) of the FCC requirements) or potentially affecting a 988 special facility (as defined in § 4.5(f) of the FCC requirements) be the threshold for a satellite outage that results in a major primary service outage? If not, explain why and provide supporting rationale.
  3. Do you have alternative criteria and thresholds to those established by both the FCC and the Commission in its Decision to identify a major primary service outage resulting from a satellite network outage? Explain with supporting rationale what the alternative criteria and thresholds are and how they would fulfill the Commission's policy objectives in the Decision?

Questions for Telesat and Terrestar

  1. Does your company provide satellite services in the USA? If so, list the satellite services provided.
  2. Has your company reported outages to the FCC based on their requirements above for satellite outages? If so, provide the number of outage notifications your company submitted to the FCC in 2024 and 2025. Specify the FCC threshold criteria that triggered the notification of these outages and the number of outages for each criterion.

Question for Terrestar

  1. The FCC has specific outage reporting requirementsFootnote 3 that all Mobile-Satellite Service (“MSS”) satellite operators shall submit electronically a notification to the Commission within 120 minutes of discovering that they have experienced on any facilities that they own, operate, lease, or otherwise utilize, of an outage of at least 30 minutes duration that manifests itself as a failure of any gateway earth station, except in the case where other earth stations at the gateway location are used to continue gateway operations within 30 minutes of the onset of the failure.

    1. Should the failure of any gateway earth station resulting in a MSS outage be the threshold for a major primary service outage for satellite operators? If not, explain why and provide supporting rationale.

Questions for Telesat

  1. Provide the list of satellite transport services you offer to your TSP, enterprise, and government customers. For each:

    1. Indicate each service plan or tier offer and the transport service busy hour capacity you offer for both a per-customer basis and a per-earth station basis, where applicable.
    2. Indicate the most common transport service plans or tier you offer, including bandwidths.
    3. Which of the following transport capacity information is available to Telesat during normal operations: i) the usable busy-hour transport capacity, ii) the usable peak information rate (PIR), ii) sustained throughput capacity, or iv) committed information rate (CIR)? Indicate which of these is available on a per-customer, per-earth station, per-transponder, or per-satellite basis.

  2. Telesat, in its intervention, submitted that satellite outages are almost always due to weather events or third-party power outages to earth station facilities, and that a requirement to report these kinds of satellite outages with a minimum duration of 30 minutes will, effectively, result in nuisance reporting. This will result in a large number of reports that do not advance understanding of network resilience and reliability, or means to improve this. A more appropriate minimum duration for reporting of satellite service outages due to weather and third-party power outages would, in Telesat’s view, be 24 hours. In all other circumstances, the 30-minute duration threshold would continue to apply.

    1. Provide a list of outages experienced by Telesat in 2025 with a duration of 30 minutes or more:

      1. Identify the outages caused by weather events and third-party power outages to earth stations, and the duration of each of these outages.
      2. Identify the causes of the outages that were not due to weather events or third-party power outages to earth stations, and the duration of each of these outages.
      3. Of the outages experienced in 2025 with a duration of 30 minutes or more, provide the percentage of these that were caused by weather events and separately, the percentage of these outages caused by third-party power outages to earth stations.

Questions for each Applicant, Telesat, and any other interested party

  1. The Applicants stated that the information the Commission determined could be publicly disclosed would compromise national security, particularly in an era where the aggregation and processing of large amounts of data is facilitated by artificial intelligence.

    1. Explain how, under section 39 of the Telecommunications Act, national security can inform the set criterion to determine the appropriateness of a confidentiality designation. Refer to the particular criterion from section 39 in your explanation, as well as the public interest in non-disclosure.

    2. The Commission determined that the information in the outage notification form, as identified in paragraphs 122 (a) to (g) of the Decision, was non-confidential. Explain why, under Section 39 of the Act, each of them should be treated as confidential, either under the national security grounds you stated or otherwise, and provide specific examples:

      1. the name of the TSP reporting the service outage;
      2. the services affected, such as voice, text, Internet, 9-1-1, wireless public alerting, TTY relay, IP relay, or 9-8-8;
      3. the service areas affected, including the provinces or territories, municipalities, and regions;
      4. the service outage start date and time;
      5. the expected service restoration date and time;
      6. the criteria the service outage met to require reporting;
      7. a brief description of communications with end-users and stakeholders, including a link to the TSP’s communication web page or channel used to inform end-users about service outages;
    3. Explain why the disclosure of information determined under section 39 to be public would cause harm to a TSP and provide detailed examples of specific harm resulting from publication of the information, in aggregate, identified in paragraphs 122 (a) to (g) of the Decision if they were non-confidential.
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