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Telecom - Staff Letter addressed to the Distribution List

Gatineau, 7 May 2025

Our references: 8740-B2-202404987, 8640-B2-202406066

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Distribution List

Subject: Bell Canada, Part 1 Application to request forbearance from the regulation of Bell Canada’s Digital Exchange Access Service, Requests for information – 7 May 2025

On 25 November 2024, the Commission received a Part 1 application from Bell Canada (Bell) requesting regulatory forbearance from Bell Canada’s General Tariff, CRTC 6716, Item 5300 – Digital Exchange Access (DEA) Service. Commission staff is presently considering this Part 1 application, which can be accessed at the link to the reference number above.

This letter sets out questions (also called requests for information or RFIs) related to Bell’s Part 1 application. Paragraph 28(1) (a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure provides that the Commission may require parties to file information or documents where needed.

Appendix 1 sets out questions for Bell.

Appendix 2 sets out questions specifically for Hydro-Québec.

Appendix 3 sets out questions for impacted customers. These questions will be sent to those customers after Bell provides the necessary contact information by the deadline set out below. While Commission staff would appreciate input from impacted customers, responses to these questions are not mandatory.

With the exception of Bell's response to question 1 in Appendix 1, which is due May 12, 2025, responses to the questions in this letter are due by June 6, 2025.

Bell will then have an opportunity to file a reply by 16 June 2025.

Filing Instructions

In your responses, if specific information is not available, provide estimates and assumptions.

The Commission requires the response or other documents to be submitted electronically by using the secured service “My CRTC Account” (Partner Log In or GCKey) and filling the “Telecom Cover Page” located on this webpage.

Privacy Statement

Note that you cannot submit your response anonymously. The personal information you will be asked to provide is required by the Commission to identify participants and manage this public process. It will be posted on our website:

If you search for your personal information using any search engine, they will not show up in the results. However, anyone will still be able to read your personal information and comment if they visit the web pages specific to this process.

Your information is collected as required by section 26 of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, as authorised by sections 16 and 21 of the Broadcasting Act and sections 55 and 67(1)(b) of the Telecommunications Act, and in compliance with section 4 of the Privacy Act. Personal information will be protected under the provisions of the Privacy Act and as described for the CRTC’s Master Address Database personal information bank, CRTC PPU 065.

Your comments and personal information will be available on the public file, as per the retention and disposition period specified for the process for which your information was collected (i.e. duration of a licence) or archival if deemed historical as per the Library and Archives of Canada Act.

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, 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.

Accessible formats for people with disabilities

The CRTC requires regulated entities and encourages all parties to file submissions in accessible formats (for example, text-based file formats that enable text to be enlarged, modified, or read by screen readers) for this proceeding.

To provide assistance in this regard, the CRTC has posted on its website guidelines for preparing documents in accessible formats.

In the event where submitted documents have not been filed in accessible formats, parties may contact the Public Hearings group to request that CRTC staff obtain those documents in accessible formats from the party who originally submitted the documents in question in an inaccessible format.

A copy of this letter, as well as the responses to the requests for information, will also be placed on the public record of the proceeding initiated by Bell Canada’s Tariff Notice 7702 proposing to withdraw DEA Service.

Sincerely,

Original signed by

Lisanne Legros
Director, Telecommunications Networks Policy
Telecommunications Sector

c.c.: Simon Wozny, CRTC, simon.wozny@crtc.gc.ca
Jordan Wegner, CRTC, jordan.wegner@crtc.gc.ca
Jean-François Leblanc-Poirier, CRTC, jean-francois.leblanc-poirier@crtc.gc.ca

Attachment (2) Appendix 1-3 & Distribution list.

Appendix 1: Questions for Bell

  1. In Bell’s response to RFIs issued by Commission staff on 14 January 2025 concerning Bell’s TN 7702 application to withdraw DEA Service, Bell provided a list of customers that currently subscribe to that service. Please provide contact information for these customers, including an email address and phone number, by 12 May 2025.

  2. In its Part 1 application, Bell indicated that it may be prepared to continue to provide DEA Service after the service is withdrawn if the Commission were to forbear from its regulation:

    For the period after 23 December 2025, we are proposing in this Part 1 Application that the Commission grant forbearance to our DEA Service so that in the event that DEA Service should still be required by any customer, we may respond to a request to extend the availability of DEA Service beyond 23 December 2025, through a commercial arrangement.Footnote 1

    In Bell’s reply to its TN 7702 withdrawal application, Bell indicated that there may be concerns with respect to the reliability of DEA Service if it were offered beyond 23 December 2025: Footnote 2

    It would not be prudent for us to maintain DEA Service beyond 23 December 2025, since if our customers were to receive and rely on DEA Service, which has already reached the end of its service life, that service could fail at any time. It must be recognized that the risk of a critical failure increases the longer that DEA Service remains operational.
    1. How does the DEA Service that Bell proposes to provide following its withdrawal of the tariffed service differ, if at all, from the existing tariffed service? Who does Bell propose to provide the service to, and on what terms?
    2. Why does Bell require forbearance to provide this service following withdrawal? Would Bell instead be willing to provide the service via a Special Facilities Tariff (SFT)? Why or why not?
    3. Comment further on the possibility of the risk of a critical failure increasing the longer that DEA Service remains operational. What causes of critical failure are anticipated, and could preventative maintenance be performed to avoid this? Identify and explain the possible risks, and any limitations of the service that customers may experience.
  3. If all impacted customers, including Hydro Quebec, clarify through RFIs that they no longer need access to DEA Service beyond the proposed 23 December 2025 withdrawal date, and the Commission approves Bell’s withdrawal application, would Bell still be seeking forbearance with respect to DEA Service? Why or why not?

Appendix 2: Questions for Hydro-Québec

  1. In Hydro-Quebec’s response to Bell’s TN7702 application to withdraw its DEA Service, Hydro Quebec indicated that:Footnote 3

    Hydro-Québec is obliged to anticipate safety measures, since the service is connected to an electrical installation with high potential rise thresholds. Bell's proposal to withdraw its DEA Service therefore has a major impact on Hydro-Québec. Delays and costs on the order of $200,000 are anticipated to ensure the safety of personnel and the protection of electrical equipment in Kuujjuaq.

    Hydro-Québec is asking the Canadian Radio-television and Telecommunications Commission (CRTC) for an additional 12 months to complete the necessary studies, engineering and installation of protective equipment. This extension takes into account the particular climatic conditions and the complexity of the work to be carried out in this region of Quebec. In addition, Hydro-Québec is requesting that supplier Bell propose a range of modern fiber-optic solutions to avoid significant costs.

    1. Please provide an explanation of the impact that withdrawal of DEA Service will have on Hydro-Québec. Please provide details regarding the $200,000 in costs that are anticipated, and how these are necessary to ensure the safety of personnel and the protection of electrical equipment.
    2. Please provide an update on the status of the necessary studies, engineering, and installation of protective equipment referenced above. If possible, include any documentation produced in relation to the studies referenced.
    3. Do you anticipate that you will require DEA Service beyond 23 December 2025, when Bell proposes to withdraw the service? Why or why not?
    4. Describe the fiber-optic solutions that Hydro-Québec is seeking. Explain how they could help avoid significant costs and include estimates of these saved costs. If fiber-optic infrastructure were available, would Hydro-Québec still need Bell to provide a solution?
    5. The Kativik Regional Government intends to complete a fiber network build from Kawawachikamach, Quebec to Kuujjuaq, Quebec by July of 2026.Footnote 4 Comment on whether this would meet your need for fiber-based solutions, and whether the timing for completion of the project is a concern.

Appendix 3: Questions for all impacted customers

  1. Comment on Bell’s Part 1 application requesting that the Commission forbear from regulating DEA Service following its proposed withdrawal of DEA Service on 23 December 2025. Forbearance would mean that, among other things, the Commission would no longer regulate service terms and conditions, rates, or require tariffs to be filed for approval that set out the manner in which the service would be provided.

    In particular, you may wish to reply to the following questions:

    1. Do you anticipate that you will require DEA Service beyond 23 December 2025? Why or why not?
    2. Bell has indicated that MegalinkFootnote 5 and SIP Trunking ServiceFootnote 6 may be adequate alternatives to DEA Service. Could these services meet your needs? Do you anticipate transitioning to Bell’s Megalink, SIP Trunking Service, a similar service from another provider, or none of the above? Are there any limitations that may prevent you from transitioning to another service? Please explain.

    3. Describe what impact, if any, Bell’s withdrawal and/or forbearance of DEA Service will have on you. For example:

      1. Will it impact your ability to provide services to your end-users?
      2. Will the rates your customers are charged for your services be impacted?
      3. Will it impact the operations of your organization?
      4. Will you be required to incur costs to switch to an alternative service, or for some other reason? Estimate and explain the costs you will incur.
      5. Estimate the amount you expect to pay per month for the alternative service you plan to transition to. Compare this to the amount per month you are currently paying for DEA Service.
    4. Are there any requests you would make of Bell that would help ease your transition away from relying on DEA Service?

Distribution List:

Bell: bell.regulatory@bell.ca
Hydro-Québec: ibrahim.hassan@hydroquebec.com
Bell’s existing DEA customers.

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