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Telecom - Staff Letter addressed to the Distribution List

Gatineau, 3 July 2025

Reference: 1011-NOC2024-0318

BY E-MAIL

Distribution List

Subject: Telecom Notice of Consultation CRTC 2024-318 – Requests for information

Dear recipients,

As mentioned at the 10-13 June 2025 Making it easier for consumers to shop for Internet servicesFootnote 1 (the Notice) hearing, this letter contains the requests for information deemed necessary to complete the record and enable the Commission to make determinations on the matters addressed in the Notice.

As noted in the 17 June 2025 amendment to the Notice,Footnote 2 parties must submit responses to requests for information no later than 30 July 2025. Please repeat the questions before answering them and use the secure service My CRTC Account (Partner Log In or GCKey) for filing the information. Parties who do not have an account and are not submitting confidential information may submit via the Intervention web form for this RFI.

Final submissions are due on 20 August 2025 and may address any relevant part of the public record.

The appendices to this letter set out the requests for information for different parties:

Given the timelines of this hearing, staff asks that parties maximally disclose the requested information on the public record and limit confidential designations. As a reminder, staff intends to follow the Confidentiality Process for any information filed as confidential that, in its estimation, would greatly benefit the public interest, outweighing the potential specific and direct harms to the party who filed this information.

Confidentiality Process

Pursuant to section 39(4)(a) of the Telecommunications Act (the Act), the Commission may disclose information designated as confidential or require its disclosure if it determines, after considering any representations from interested persons, that disclosure is in the public interest.

To ensure confidentiality matters are dealt with expeditiously and Commission resources are expended efficiently, the Commission has adopted a two-step process. The first step is that Commission staff reviews the parties’ confidentiality submissions and issues a non-binding determination on what information should be refiled on the public record or remain confidential. Most disclosure requests are completed at this step.

If a party does not agree with Commission staff’s determination or a party that is requested to disclose information does not do so in accordance with Commission staff’s instructions, that party or any other interested person may engage the second step and request a binding Commission determination on the same confidentiality record. The Commission makes this determination through a Commission letter signed by the Secretary General. As with any Commission determination, such a determination is enforceable or reviewable pursuant to the Act.

Accessible formats for people with disabilities

The Commission 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 or modified or read by screen readers) for this hearing.

To provide assistance in this regard, the Commission 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 Commission staff obtain those documents in accessible formats from the party who originally submitted the documents in question in an inaccessible format.

Yours sincerely,

Nanao Kachi
Director, Social and Consumer Policy

Distribution list

Access Communications Co-operative: documents@myaccess.coop
Bell Canada: bell.regulatory@bell.ca
Bravo Telecom: legal@bravotelecom.com
Catherine Middleton: catherine.middleton@torontomu.ca
CCTS: regulatory@ccts-cprst.ca
CDGM: canadadeafgrassrootsmovement@gmail.com
Cheetah Networks: mccallen@cheetahnetworks.com
CIRA: georgia.evans@cira.ca
Cogeco: leonard.eichel@cogeco.com
Competition Bureau: benjamin.klass@cb-bc.gc.ca
CTA: esmith@canadatelecoms.ca
Dan Mazier: dan.mazier@parl.gc.ca
DHH Coalition: richmanelliott@gmail.com, myles.murphy@nf.sympatico.ca, dprong@deafontario.ca
DWCC: chair@deafwireless.ca
Eastlink: regulatory.matters@corp.eastlink.ca
Fenwick McKelvey: fenwick.mckelvey@concordia.ca
Fibernetics Corporation: regulatory@fibernetics.ca
ITPA: jonathan.holmes@itpa.ca
The Manitoba Coalition: cacmb@mts.net, chkla@legalaid.mb.ca, kadil@legalaid.mb.ca
Marina Pavlovic: marina.pavlovic@uottawa.ca
OpenMedia and CIPPIC: matt.malone@uottawa.ca
Option consommateurs: aplourde@option-consommateurs.org
PIAC: gwhite@piac.ca
Québecor: peggy.tabet@quebecor.com
Rogers: regulatory@rci.rogers.com
Sam Hudson: samhudsonmusic3@gmail.com
Saskatchewan Telecommunications: document.control@sasktel.com
SSi Canada: regulatory@ssicanada.com
TekSavvy: regulatory@teksavvy.ca
TELUS: regulatory.affairs@telus.com, david.peaker@telus.com, molly.samuelson@telus.com, karen.cheung@telus.com
Union des consommateurs: jatack@uniondesconsommateurs.ca
Xplore: legal@xplore.ca

Appendix 1: Questions to all parties

Question 1: Peak periods

Many parties have taken the view that a 7pm to 11pm window (local time) constitutes an adequate and simple definition for the residential (consumer) peak period.

  1. Do you agree with this definition? Explain your rationale.
  2. If setting a specific time window is not the most meaningful way to present this information to consumers, is there a cost-effective way to produce localized peak period-related measurements (for example, the continuous 4-hour period when the most residential Internet traffic is observed on an ISP’s network)?

Question 2: Typical download and upload speeds

Many parties consider “typical download and upload speeds” to approximately mean the end-to-end download and upload speeds subscribers should experience most of the time when using the Internet. Commission staff proposes that “typical download and upload speeds during peak periods” could be more clearly defined as the download and upload speed a subscriber will receive during the peak period discussed above when deploying a speed test to an off-net test server in the closest tier one city, at least 95% of the time.

  1. Would you agree with the elements of this proposed definition? Please explain your rationale.
  2. Should the CRTC instead define typical download and upload speeds as being the average download and upload speeds subscribers should expect to receive, as opposed to 95% of the time? Are there any limitations or problems with this proposed definition?
  3. If you have a definition for “typical download and upload speeds” that differs significantly from the two presented above, please propose it and explain the rationale behind this alternative definition.
  4. If a more flexible definition is chosen, how should ISPs be held to account if subscriber experience differs from reported typical download and upload speeds?
  5. Parties have mentioned that the various technical elements of this hearing (such as landing on a definition for typical download and upload speeds and determining a measurement methodology) should be referred to the CRTC Interconnection Steering Committee (CISC). What are the potential benefits and risks of this approach?

Question 3: Right amount of information to be provided to consumers

On the record of this hearing, different parties have argued for different information to be made available to consumers.

Please indicate which of the following types of information should be provided to consumers by sorting them into the provided table and add any additional information that you think should be included. Furthermore, please do not add more rows to the provided table.

Types of information should be provided to consumers
Most relevant Somewhat relevant Less relevant
     
     
     
     
     
     

Question 4: Iconographic representations

Some parties have suggested that, should a broadband label were to be required, some form of contextualizing information be included. Others were concerned that too much information would clutter a “consumer broadband label” and take away from the clarity of the information it is trying to convey. One way this concern may be addressed is to use icons to represent activities, like gaming, schoolwork, work, streaming music, and streaming audio-visual content.

  1. Would this be beneficial to consumers? Explain your rationale.
  2. Is there a standard set of icons that could be used to represent different activities?
  3. If there isn’t a standard set of icons, would it be a viable solution for the Canadian Telecommunications Association (CTA) to coordinate industry efforts in this regard so that there no duplication of efforts and an industry standard set of icons?

Question 5: Critical information summary (CIS)

The possibility of making the CIS required by the Internet Code more persistently and readily available, such as through the consumer portal of the ISP, was raised at the hearing by multiple parties.

  1. Please comment on this proposal, oncluding cost and feasibility, and elaborate on your position. For ISPs without a consumer portal, is an equivalent obligation (such as emailing the CIS within 24 hours of a request) feasible?
  2. Similarly, if the Commission were to impose a “consumer broadband label”, should it be persistently and readily available in a similar manner? Should it be included in the CIS? Please elaborate on your positions.
  3. Finally, if a “consumer broadband label” were to be required, there may be challenges for consumers to keep track of the information found in a “consumer broadband label” versus what is already provided in a CIS. How would you suggest that the Commission address this situation?

Question 6: Application to smaller ISPs

The application of or exemption from any new rules to small providers and wholesale-based competitors was a topic of discussion during the hearing.

  1. As an alternative to outright exemption, should smaller players still be subject to providing standardized network metrics (such as latency, jitter, packet loss, etc.), but given more flexibility as to how they measure to obtain these metrics and, if so, what form of flexibility would be appropriate?
  2. With respect to typical download and upload speeds, should smaller players still be subject to providing measurements on typical download and upload speeds but given more flexibility as to how they measure typical download and upload speeds and, if so, what form of flexibility would be appropriate?
  3. How should they be held accountable for reported performance metrics where flexibility has been given in how they have been measured?

Question 7: Wholesale

Wholesale ISPs have expressed concern over their ability to provide consumers with, or be held accountable for, network metrics that, in substantial part, only their upstream service suppliers have the ability to control.

  1. If you are a wholesale ISP, do you find yourself in this situation? If so, would the inability for you to perform passive network measurements on your upstream service suppliers be a hinderance in light of the proposed definition of typical download and upload speeds above?
  2. How would existing arrangements and procedures between wholesale ISPs and their upstream providers be impacted by the introduction of the labelling requirement and any related accountability requirements? Will complaint mechanisms need to be revamped?
  3. Are there any implications on existing Commission policies or requirements with regard to wholesale services?

Question 8: Improving on the Federal Communications Commission (FCC) labels

On line 520 of the hearing transcript, Cogeco Connexion Inc. (Cogeco) mentioned during their appearance at the hearing that only 2% of their American online consumers navigated to the FCC-required labels Cogeco provides on their website, as a proxy for the usefulness of the FCC-required label.

Assuming that this measurement is an accurate proxy for the labels’ usefulness, is there any way to make them more useful or otherwise improve on their consumer adoption?

Appendix 2: Questions to all Internet Service Providers (ISPs)

Question 9: Active measurement – typical download and upload speeds

Please propose methodologies that would generate adequate data to provide consumers with regionally accurate typical download and upload speeds. In other words, what level and type of measurements are needed to provide consumers with speeds that you could be held accountable for delivering. Should you be required to do this, please provide the following details:

  1. What technical standard or standards would be helpful in your implementation. For example, Rogers Communications Canada Inc.’s intervention noted Broadband Forum TR-143 (Enabling Network Throughput Performance Tests and Statistical Monitoring), the International Telecommunications Union Y.1564 (Ethernet Service Activation Test), and the Internet Engineering Task Force RFC 2544). Do any of these serve a useful purpose? If so, please explain how.
  2. What kind of sampling is required to generate this type of data for new residential broadband service offerings?
  3. What kind of sampling is required to keep this type of data current and up to date (e.g. rolling averages, updated snapshots in time, etc.)?
  4. What level of granularity (for example, neighborhood-level, access-node level, community-level, etc.) is appropriate to generate meaningful information? Please be specific?
  5. What are the key cost elements and resulting estimated costs associated with carrying out the measurement regime you described above?

Question 10: Active measurement – latency, packet loss, and jitter

The CRTC defines quality of service thresholds for latency and packet loss in Telecom Decision CRTC 2018-241 and jitter in Telecom Regulatory Policy CRTC 2019-42. Furthermore, Telecom Decision CRTC 2018-241 cites a CRTC Interconnection Steering Committee (CISC) report (NTRE061) which sets out testing methodologies for those metrics.

  1. Would these testing methodologies serve as a good starting point for ISPs to measure for latency, packet loss, and jitter should the Commission decide on requiring those metrics to be reported as a result of this hearing?
  2. What would be the estimated costs associated with carrying out this measurement regime?

Question 11: Active measurement methodology – FCC Measuring Broadband America program

From 2011 to 2024, as part of the Measuring Broadband America (MBA) program, the FCC in partnership with SamKnows, measured typical download and upload speeds, latency, and packet loss across the United-Sates. The MBA program tested the suitability of broadband services for various tasks (e.g. web browsing, video streaming, and VOIP). Their measurement methodology was updated throughout the lifetime of the project. Given the above, please answer the following questions:

  1. Understanding there are slight differences in desired outcomes (the FCC looked for typical download and upload speeds in general, not just during peak hours, and measured accordingly), would the SamKnows methodologies and definitions used in the MBA program be a reasonable starting point for the purposes of this hearing?
  2. Since the methodology differs slightly over the years, would it be appropriate to use as a starting point the most recent methodology (found in the thirteenth report of the MBA program)? Are there methodological elements from earlier reports that would be more suitable for the Commission’s purposes?
  3. To what extent do these methodologies complement or differ from those set out in Telecom Decision CRTC 2018-241 and Telecom Regulatory Policy CRTC 2019-42? Where they differ, which approach is to be preferred?
  4. What would be the costs of implementing a measurement regime based on the MBA program after making the necessary adjustments to better fit the context of this hearing (e.g. only taking measurements during the peak period and not throughout the whole day, etc.)

Question 12: Passive measurement tools

To provide the Commission with a better understanding of what is currently achieved through passive monitoring, please provide the following information:

  1. What passive monitoring or measurement tools do you currently use to monitor layer-three Internet user experience and end-to-end network performance that relate at least in part to residential (consumer) users? For example, do you use tools provided with a router OS; third-party tools, including software and hardware (middlebox) solutions; third-party monitoring services; etc.?
  2. Please produce some screenshots of the information available through your passive monitoring systems.

Question 13: Passive measurements in general

Parties at the hearing have argued that a passive-only measurement approach may not be adequate to fully satisfy the requirements of section 24.2 of the Telecommunications Act.

  1. What are the technical limitations and misinterpretations that could result from relying on passive monitoring and measurement tools to describe typical end-user experience of end-to-end Internet performance? What kind of end-user experience can be reasonably inferred from passive monitoring inside your network – for example, could such tools show what a minimum experience is, but not the typical experience attainable on demand?
  2. Do the passive measurement and monitoring tools with which your relevant network management teams are familiar provide a different quality of information with respect to speeds than with respect to latency or jitter?
  3. To what extent do passive measurement and monitoring tools deliver information about end-to-end user experience; on-net experience only; or both? Please explain.

Question 14: Cost to differentiate between different technology types

Various parties have raised on the record that providing consumer with information on the type of technology over which an Internet service offering is delivered would offer more insight into the expected performance of that service than categorizing services based on geography.

What would be the estimated cost to differentiate your various Internet service offerings based on their technology type?

Question 15: Costs of making data available

The previous questions delved into the costs of measuring and collecting data on various network metrics (i.e. typical download and upload speeds, latency, packet loss, jitter, and technology type). Please provide the cost estimates to make that data available in the following ways:

  1. To be included as part of the CIS.
  2. To be made available in a machine-readable format (in the context of allowing third parties to compile information on available offers and create their own “labels”; the FCC’s specifications for machine readability is provided for your reference).
  3. To be placed into a standardized label.

Question 16: Comparing costs of different labels

To support a better understanding of the costs of implementation, please explain the costs involved in the two scenarios below. Since the costs to collect the data used to populate these consumer broadband labels has already been explored in an earlier question, please do not include any measurement or data collection costs in your cost estimates here.

  1. The Commission requires ISPs to provide consumers with a consumer broadband label with six (6) key pieces of information:

    1. All-in prices, before or after promotional discounts
    2. Typical download speed
    3. Typical upload speed
    4. Latency
    5. Technology type
    6. A QR code for additional information

  2. The Commission requires ISPs to provide consumers with a consumer broadband label with ten (10) key pieces of information:

    1. All-in prices, before or after promotional discounts
    2. Typical download speed
    3. Typical upload speed
    4. Maximum download and upload speed as advertised
    5. Technology type
    6. Latency
    7. Jitter
    8. Packet loss
    9. A line referencing the CCTS
    10. A QR code for additional information

Appendix 3: Questions to specific parties

Canada Deaf Grassroots Movement (CDGM)

Question 17: Key information in sign language labels

On line 242 of the hearing transcript, Commissioner Desmond asked the following question to CDGM:

“And if providers were to be required to [provide labels in sign language], what would be kind of the key piece of information that would need to be disclosed for your members? What would be essential in terms of information that would need to be available so that, if [Internet Service Providers] wanted agility and they needed short timelines, if there was something most critical, what would that be?”

The CDGM committed to providing a response after the appearing phase of the hearing. The CDGM is now being asked to provide its response.

Cogeco

Question 18: FCC Broadband Consumer labels implementation insights

On line 520 of the hearing transcript, Cogeco mentioned that only 2% of its American online consumers navigated to the FCC-required labels it provides on its website as a proxy to the usefulness of the FCC-required label.

  1. Could you confirm the accuracy and source of this number?
  2. Some intervenors speculated at the hearing that the click rate might be low because the labels may be behind multiple clicks; only made available at checkout. Likewise, the labels may be displayed in combination with other information in a way that does not require navigation to a dedicated page. Do you believe any of these are factors affecting the click rate? In your view, are other factors likely in play?
  3. Is there any way to improve the consumer adoption of these labels?

CCTS

Question 19: Complaints related to latency or jitter

At the hearing, the CCTS noted that it had never dealt with a complaint about latency or jitter.

  1. Could you please confirm that the CCTS has never received a complaint identifying latency or jitter as an issue to be resolved?
  2. Has the CCTS received complaints related to user experiences that were likely the result of poor jitter or latency performance?
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