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Telecom Order CRTC 2025-228

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Gatineau, 5 September 2025

Public record: Tariff Notice 674

TELUS Communications Inc. – Withdrawal of Internet Voice Access Service

Summary

The Commission received an application from TELUS Communications Inc. (TELUS) proposing to withdraw its Internet Voice Access Service (IVAS) under Item 4.02 of its Access Services Tariff.

IVAS is a legacy interconnection service that no longer aligns with industry practices or current technology. There have been no active customers for at least three years, and no future demand is expected. Accordingly, the Commission approves TELUS’s application.

A concurring opinion by Commissioner Bram Abramson is attached to this order.

Application

  1. On 20 June 2025, the Commission received an application from TELUS Communications Inc. (TELUS) proposing to withdraw its Internet Voice Access Service (IVAS) under Item 4.02 of its Access Services Tariff.
  2. IVAS is offered in TELUS’s incumbent operating territory in Quebec and provides Internet service providers with line-side or trunk-side access to TELUS’s public switched telephone network (PSTN).
  3. TELUS submitted that IVAS has had no active customers for at least three years and that no future demand is expected. TELUS emphasized that alternative interconnection solutions are now available in the market and that IVAS has become redundant from both a technical and commercial standpoint.
  4. TELUS requested an effective date of 19 August 2025.
  5. The Commission did not receive any interventions with regard to the application.

Commission’s analysis

  1. The Commission is of the view that IVAS is a legacy interconnection service that no longer aligns with industry practices or current technology. The absence of active customers for at least three years is a strong indicator that the demand for the service has ceased. TELUS submitted that all current interconnection needs are now met through alternative arrangements, such as Internet Protocol-based or wholesale voice over Internet Protocol solutions, which do not require line-side or trunk-side PSTN access.
  2. Furthermore, TELUS argued that IVAS no longer satisfies the input component of the Essentiality Test set out in Telecom Regulatory Policy 2015-326. A service cannot be considered essential if it is not required by competitors to provide downstream retail services, which is a criterion that IVAS no longer meets given the availability of modern alternatives. Accordingly, the Commission considers TELUS’s assessment to be reasonable.
  3. Similarly, in Telecom Order 2023-13, the Commission approved Bell Canada’s application to withdraw IVAS on the basis of there being an absence of active customers and no foreseeable demand for the service. TELUS’s application mirrors those conditions, therefore the Commission considers that approving its withdrawal of IVAS would be appropriate.
  4. The Commission is of the view that a customer transition plan or targeted communications to advise customers of the service withdrawal are not required in this situation given the absence of active customers.
  5. The Commission considers that TELUS’s request is reasonable and that it serves the public interest.

Conclusion

  1. In light of all of the above, the Commission approves, by majority decision, TELUS’s application.
  2. Revised tariff pages are to be issued within 10 calendar days of the date of this order. Revised tariff pages can be submitted to the Commission without a description page or a request for approval; a tariff application is not required.

Secretary General

Related documents

Concurring opinion of Commissioner Bram Abramson

  1. In 2023 Bell Canada applied to withdraw its Internet Voice Access Service (IVAS). It included the brief submission, though not directly responsive to the withdrawal test, that IVAS “would not satisfy any of the prongs of the essentiality test”, as alternatives likely existed.Footnote 1
  2. TELUS Communications Canada Inc.’s (TELUS) submissions likewise throw in the idea that its IVAS “no longer satisfies the input component of the Essentiality Test set out in Telecom Regulatory Policy 2015-326”. The Telecommunications Committee’s majorityFootnote 2 accepts that framing, “consider[ing] TELUS’s assessment [as to the Essentiality Test] to be reasonable”.Footnote 3
  3. But forbearance and withdrawal are different regimes:
    • The Essentiality Test is part of the forbearance framework. It asks whether there is a substantial lessening of competition that warrants tariffing, whether continued or anew.Footnote 4
    • The withdrawal framework is more cursory. It formalizes a carrier’s ceasing to offer a tariffed service. It does not address the status of competition.
  4. This concurring opinion discusses what the muddle means, why it matters, and what to do about it.Footnote 5

If ad hoc, then mindfully

  1. Telecommunications tariffs are standing offers. They must set out all of the essential terms and conditions of service.Footnote 6
  2. Most services are no longer tariffed: the Commission found either sufficient competition, or policy reasons, to de-tariff them.Footnote 7 Some big-ticket items, like broadband and mobile, are hybrids: the Commission may de-tariff retail services but require wholesale supply, or de-tariff only partially by limiting tariffed terms to those needed to foster competition.Footnote 8
  3. But the remainder still numbers in the hundreds, especially for the historic phone monopolies known as incumbent local exchange carriers (ILECs). Wholesale tariffs were last reviewed comprehensively in 2006–2008;Footnote 9 retail tariffs, in more piecemeal plans, between 2007 and 2011.Footnote 10 Meanwhile, markets have shifted from a public switched telephone network (PSTN) to an Internet-Protocol-centric environment. Without systematic review of the tariff system, we have found ourselves managing PSTN turn-down and copper de-commissioning by ad hoc apply-and-respond cycles. This contrasts sharply with the more mindful approach of many of Canada’s trading partners.Footnote 11 It does not, in my respectful view, honour our commitment to recentre regulation on broadband.Footnote 12
  4. Conceptual clarity is crucial in navigating ad-hoc-ery. To wit: withdrawal retires a service that is obsolete or unnecessary. Forbearance, on the other hand, means competition has eroded market power, so that tariffing is likely no longer needed. Using withdrawal as a shortcut to skip market assessment undermines regulatory coherence and accountability, and leaves competition in limbo.

Applying today’s framework

  1. Until 2005, destandardizationFootnote 13 and withdrawalFootnote 14 were just tariff amendments. Telecom Circular 2005-7 responded to technological change with a dedicated framework, requiring a substitute, a transition plan, and notice to customers.Footnote 15
  2. That framework fit the early Internet Protocol transition: clearing out legacy services no one used, without requiring a competition test. Importantly, withdrawal obliges a carrier to stop selling the service. It does not let it sell the service outside a tariff. Only forbearance allows that.
  3. Destandardization and withdrawal are right where services are obsolete. Forbearance is right where services are still relevant but competitive, or need not be fully tariffed for other public-interest reasons. The two should not be conflated. The Telecommunications Act (the Act) makes forbearance in competitive markets mandatory: we cannot use a broader power to fashion a shortcut to the same end.Footnote 16

From two prongs to three

  1. Carriers understandably find destandardization and withdrawal easier than forbearance. But the Act requires that, when competition warrants, we forbear.
  2. Fortunately, the dilemma is of our own making. We invented, in 2005, a streamlined destandardization and withdrawal process. We could also create a parallel streamlined forbearance process, adding a third prong to what are now two:
    • Give notice to customers, with a chance to participate.
    • Require evidence of competition, in place of evidencing substitutes.
    • Permit carriers to consolidate similar services into the same proceeding before opening things up to interventions.
  3. Without evidence of competition, withdrawal should remain a tool for retiring obsolete services. Where there is competition, forbearance is both the better policy, and a statutory obligation. If we muddle withdrawal and forbearance, we erode our own accountability and leave regulated what need not be. If we refine them, making forbearance as procedurally accessible as withdrawal, then carriers gain clarity, consumers keep safeguards, and our work aligns more clearly with the law.
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