Telecom - Staff Letter addressed to Various Parties

Gatineau, 26 September 2025

Reference: 8698-J64-202500975

BY EMAIL

Jean-François Dumoulin
Vice President Regulatory and Government AffairsIristel Inc.
403-16766 TransCanada Hwy
Kirkland QC H9H 4M7
regulatory@sugarmobile.ca

Philippe Gauvin
Assistant General Counsel
Bell Canada
19th Floor 160 Elgin Street
Ottawa, ON K2P 2C4
bell.regulatory@bell.ca

Stephen Schmidt
Vice-President – Telecom Policy & Chief Regulatory Legal Counsel
Telecom Policy & Regulatory Affairs
Telus Communications Inc.
Floor 5, 215 Slater St.
Ottawa, ON K1P 0A6
regulatory.affairs@telus.com

Subject: Application regarding delays by Bell Canada when routing new central office codes obtained by Iristel – Request for Information

On 10 April 2025, Iristel Inc. (Iristel) filed a Part 1 application alleging that Bell Canada (Bell) had caused unreasonable delays in routing new central office (CO) codes obtained by Iristel. In support of its application, Iristel included, at Appendix 1, a list of 42 CO codes that failed reachability testing using a mobile device subscribed to the Bell Canada network, on or after the scheduled activation date set by Iristel. Iristel indicated that it had provided Bell with an unredacted copy of this list. Of the 42 CO codes identified, 28 were located within the incumbent local exchange carrier (ILEC) territory of TELUS Communications Inc. (TELUS) in Western Canada.

Having reviewed the responses and replies to Commission staff’s 19 June 2025 request for information (RFI) on the record of the Part 1 proceeding, staff requires additional information.

Question for Bell and TELUS

In its 10 July 2025 response to the RFI, TELUS indicated that there are two possibilities for why Iristel’s reachability tests might fail when attempting to complete calls to Western Canada-based CO codes using a mobile device subscribed to the Bell Canada network:

• The first would be an error on TELUS’ part. TELUS is currently undergoing a multi-year network transformation initiative to simplify and optimize its legacy networks. This transformation has required its NPA-NXX activation automation logic to be updated to reflect new network architecture. TELUS is aware of isolated instances where that automation logic was not updated in a timely manner to reflect the architectural changes resulting in automation failure for the NPA-NXX activation.
• The second potential cause of failure of reachability tests might be that the Bell Canada traffic is being directed to an entry point into the TELUS network that is not configured to receive Iristel traffic. A network the size of TELUS’ has multiple entry points and traffic must be directed to one of the entry points that is configured to direct traffic to Iristel’s customers. Those properly configured entry points have been identified to all carriers, including Bell Canada. Based on previous troubleshooting on similar interconnection issues with Bell Canada, Bell Canada, when transiting Iristel traffic may have utilized incorrect entry points to TELUS’ network. This is not unusual and happens to carriers on occasion. In those previous instances, the issues have been identified and resolved through joint trouble shooting between Bell Canada and TELUS.

1. Q1. For each of the 28 CO codes located in TELUS’ ILEC territory that failed reachability testing, as listed in Iristel’s Appendix 1, Bell and TELUS are to indicate whether the failure was due to TELUS’ NPA-NXX activation automation logic, Bell directing traffic to an entry point not configured to receive Iristel traffic, or another cause. In all cases, Bell and TELUS are to provide a clear explanation of the cause of the failure and corrective measures taken or planned.

Procedure

To ensure the information provided to staff is as accurate and aligned to the maximum extent feasible, Bell and TELUS are to file their response jointly, by 10 October 2025.

Iristel may file a reply to Bell and TELUS’ response by 17 October 2025. In doing so, Iristel is to limit its comments to only the new information provided by Bell and TELUS.

Further, staff expects all parties to disclose as much information as possible on the public record to ensure a definitive understanding of the matter.

This letter and any subsequent correspondence will be placed on the Commission’s website. 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, though it 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, should parties designate information as confidential, it 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.

Sincerely,

Original signed by

Suneil Kanjeekal
Director, Dispute Resolution & Regulatory Implementations
Telecommunications

c.c.: Etienne Robelin, CRTC, etienne.robelin@crtc.gc.ca

Attach.: List of CO codes within TELUS’ ILEC territory that failed reachability testing using a mobile device subscribed to the Bell Canada network

Attachment 1 to Request for Information

Date modified:

2025-09-26