Telecom - Staff Letter addressed to the Distribution List

Gatineau, 19 September 2025

Our reference: 8640-J92-202501551

BY EMAIL

Distribution List

Subject: Part 1 Application seeking forbearance of residential and business local exchange services in the incumbent exchanges of Independent Telecommunications Providers Association (ITPA) member companies, Request for information – 4 September 2025 – Response to the ITPA’s Procedural Request

On 4 September 2025, Commission staff sent a request for information (RFI) in relation to a Part 1 application from the Independent Telecommunications Providers Association (ITPA) requesting forbearance of residential and business local exchange services in the incumbent exchanges of ITPA member companies. Questions were sent to the ITPA, other parties, and mobile wireless service providers. The ITPA and other parties were to file responses by 22 September 2025. Mobile wireless service providers were to then file responses to the question directed towards them by 13 October 2025.

On 12 September 2025, the ITPA filed a procedural request with the Commission to extend the deadline for it to file its response by 120 days from the date an extension is granted. The ITPA submitted that it requires this extension to compile the information requested in Commission staff’s RFI for each of its member companies.

Later on 12 September 2025, Marc Nanni requested that the ITPA’s extension request be denied, and the ITPA’s Part 1 Application be dismissed without prejudice.

On 17 September 2025, Telus requested that the Commission deny the ITPA’s extension request. Telus indicated that instead, the Commission should stay the ITPA’s Part 1 application pending the launch and resolution of a separate Notice of Consultation designed to address the broader policy issues raised by parties about the local forbearance framework. Telus submitted that the current RFI process raises significant procedural fairness concerns and is inefficient. Telus also noted that the RFI process does not provide any mechanism for parties to respond to or comment on the submissions of other participants, creating a gap in procedural fairness.

On 18 September 2025, Québecor Media Inc. supported Telus’s position.

On 19 September 2025, Bell Canada proposed an alternative solution. It proposed that the Commission render a decision on the broader policy issue raised by the ITPA’s application (whether forbearance with respect to residential and business local exchange services is appropriate given the market power of ITPA members with respect to these services) without waiting for the ITPA’s RFI responses. Then, further information from the ITPA could be used for a follow-up proceeding.

Commission staff considers that it would be appropriate to consult further regarding these matters. Therefore, Commission staff suspends the deadlines for filing RFI responses.

Commission staff establishes the following procedure:

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

Yours 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

Distribution List:

Independent Telecommunications Providers Association: regulatory@itpa.ca;
Mark Nanni: mn_crtc@proton.me;
SaskTel: document.control@sasktel.com;
Bell Canada: bell.regulatory@bell.ca;
TELUS Communications Inc.: regulatory.affairs@telus.com;
Québecor Media Inc.: regaffairs@quebecor.com;
Bragg Communications Inc.: regulatory.matters@corp.eastlink.ca;
Brooke Telecom Co-operative Ltd.: geoff@brooketel.coop;
Chatr: regulatory@rci.rogers.com;
Execulink Telecom Inc.: andrea.atkinson@execulinktelecom.ca;
Eastlink: regulatory.Matters@corp.eastlink.ca ;
Fido: regulatory@rci.rogers.com;
Fizz: regaffairs@quebecor.com;
Freedom: regaffairs@quebecor.com;
Koodo: regulatory.affairs@telus.com;
Lucky: bell.regulatory@bell.ca;
No Name: bell.regulatory@bell.ca;
PC Mobile: bell.regulatory@bell.ca;
Public Mobile: regulatory.affairs@telus.com;
Rogers Communications Inc.: regulatory@rci.rogers.com;
Videotron: regaffairs@quebecor.com;
Virgin: justin@hyperlinkinc.com;

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