Telecom - Staff Letter addressed to the Distribution List
Gatineau, 7 November 2025
Reference(s): 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 Procedural Requests
On 12 September 2025, the Independent Telecommunications Providers Association (ITPA) requested that the Commission extend the deadline for it to file its response to Commission staff’s request for information (RFI) by 120 days from the date an extension is granted. The ITPA submitted that it requires this extension to compile the information requested in the RFI for each of its member companies.
On 19 September 2025, Commission staff published a letter to establish process for considering procedural requests related to this Part 1 application and an RFI issued by Commission staff on 4 September 2025.
Procedural requests and/or related comments were received from the ITPA, Marc Nanni, Telus, Québecor Media Inc. (Québecor), Bell Canada (Bell), Rogers, and SaskTel.
Marc Nanni, Telus, Québecor, and Rogers generally requested that the Commission deny the ITPA’s extension request and stay or dismiss the ITPA’s Part 1 application pending the launch and resolution of a broader consultation regarding the local forbearance framework.
- Marc Nanni submitted that the Commission should deny the ITPA’s application in its entirety due to its procedural and substantive deficiencies, and should deny all requests for extensions, stays, and an immediate policy ruling, as the ITPA’s application defects are incurable by more time.
- Telus submitted that the ITPA’s application should be stayed as the current 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. Telus also noted that a comprehensive consultation would be a far more efficient way to address the matter at hand than responding to staff’s RFIs.
- Québecor submitted that granting the ITPA's 120-day extension request would compromise procedural fairness, regulatory transparency, and the administrative efficiency of the ongoing process as this Part 1 proceeding is inadequate to address the substantive issues raised by the ITPA, including the review of the local forbearance framework.
- Rogers submitted that the ITPA’s application should be dismissed entirely since the ITPA’s request should not be dealt with in a Part 1 Application proceeding, but rather in a full notice of consultation. Rogers also noted that it would be highly impractical and time-consuming to provide the information requested by Commission staff in the RFIs.
SaskTel proposed that the Commission should not rule on the ITPA Application without launching an overall review of the wireline forbearance environment, but that the ITPA’s request for an extension should be granted. SaskTel submitted that the modernization of forbearance rules should be done for all local exchange carriers, not just ITPA members.
Bell proposed a different approach. It submitted that the Commission should:
- Issue a timely decision granting the ITPA’s requested forbearance in principle without waiting for responses by the ITPA to the RFIs;
- Initiate a short follow-up process to finalize lists of affected services/exchanges, any required consumer notices consistent with precedent, and any necessary show-cause on competitor presence under an updated, technology-neutral lens; and,
- To the extent it recognizes wireless, satellite and broadband enabled VoIP as competitors under an updated and technologically-neutral test for SILECS, initiate a follow-up proceeding for ILECs which should be short and efficient based on the outcome of the present proceeding.
Bell submitted that:
- Granting the ITPA relief now and moving to a focused follow-up proceeding will advance competition, affordability, and regulatory efficiency, whereas a dismissal or stay would do the opposite.
- The record already supports a determination that traditional wireline local exchange services are subject to sufficient competitive discipline from wireless services to warrant relief consistent with sections 34(1) and 34(2) of the Telecommunications Act.
- Deciding the application now and launching a follow-up proceeding, if necessary, would be efficient, proportionate, transparent, predictable, and coherent as required by the 2023 Policy Direction, and would conserve resources for all parties.
In reply, the ITPA submitted that Commission staff’s initial RFIs do not introduce major public policy issues and do not require the initiation of a larger process, as they are simply designed to confirm whether sufficient competition exists to protect the interests of users as is required by all existing forbearance tests. Therefore, the ITPA requested that:
- Submissions to stay or to expand the ITPA’s application be denied;
- The ITPA’s RFI deadline be extended to 120 days from the date an extension is granted;
- Wireless service providers be required to respond to RFI questions directed at them within 21 days of the ITPA’s new deadline; and,
- All parties have the opportunity to file reply comments within 10 days following the submission deadline for wireless service providers to alleviate procedural fairness concerns.
Commission staff notes the detailed submissions of the parties regarding the extent to which the Commission should engage with the substance of ITPA’s application and therefore the need for these RFIs. These submissions form part of the record and will be considered by the Commission in due course. However, the RFIs issued by Commission staff on 4 September 2025 are intended to gather information that may be necessary to inform the Commission’s decision-making relative to the specific exchanges where the ITPA seeks forbearance. The Commission will then make its decisions on this file, with a complete record that speaks to all proposed options.
Commission staff also considers that it is reasonable to grant all parties an opportunity to file a reply to all information filed in response to the RFIs. Some parties submitted that the default RFI process does not allow participants to comment on each other’s submissions, which creates a gap in procedural fairness. Providing a reply phase for all parties to comment on the submissions of other participants will address these concerns.
Further, in staff’s view, the amount of additional time requested by the ITPA is reasonable given the limited resources of ITPA members. Therefore, Commission staff considers that it is reasonable for the requested extension to be granted to the ITPA, as well as to other RFI respondents.
Accordingly, Commission staff confirms that the deadline to file responses to the questions set out in its letter of 4 September 2025 is extended until 9 March 2026 for the questions directed towards the ITPA and other parties, and until 30 March 2026 for questions directed towards mobile wireless service providers. Parties that already filed a response to the RFIs will have the opportunity to modify or add to their RFI responses until the new deadline. All parties will then have an opportunity to file a reply to RFI responses by 20 April 2026.
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
Attach. (1) Distribution List
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;
- Date modified: