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Telecom - Staff Letter addressed to the Distribution List

Gatineau, 27 June 2025

Our references: 8740-B2-202404987, 8640-B2-202406066

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Distribution list

Subject: Bell Canada, Part 1 Application to request forbearance from the regulation of Bell Canada’s Digital Exchange Access Service, Requests for information – Supplemental Requests for Information

On 25 November 2024, the Commission received a Part 1 application from Bell Canada (Bell) requesting regulatory forbearance from Bell Canada’s General Tariff, CRTC 6716, Item 5300 – Digital Exchange Access (DEA) Service. Commission staff is presently considering this Part 1 application, which can be accessed at the link to the reference number above.

On 7 May 2025, Commission staff issued Requests for information (RFIs) in relation to this proceeding. Recipients filed their responses to the RFIs by 23 June 2025.

This letter sets out follow-up questions for Bell and Hydro-Québec to their RFI responses related to Bell’s Part 1 application. Paragraph 28(1) (a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure provides that the Commission may require parties to file information or documents where needed.

Appendix 1 sets out questions for Hydro-Québec.

Appendix 2 sets out questions for Bell.

Responses to the questions in this letter are due by 9 July 2025. Bell will then have an opportunity to submit a reply by 14 July 2025.

Filing Instructions

In your responses, if specific information is not available, provide estimates and assumptions.

The Commission requires the response or other documents to be submitted electronically by using the secured service “My CRTC Account” (Partner Log In or GCKey) and filing the “Telecom Cover Page” located on this webpage.

Privacy Statement

Note that you cannot submit your response anonymously. The personal information you will be asked to provide is required by the Commission to identify participants and manage this public process. It will be posted on our website:

If you search for your personal information using any search engine, they will not show up in the results. However, anyone will still be able to read your personal information and comment if they visit the web pages specific to this process.

Your information is collected as required by section 26 of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, as authorised by sections 16 and 21 of the Broadcasting Act and sections 55 and 67(1)(b) of the Telecommunications Act, and in compliance with section 4 of the Privacy Act. Personal information will be protected under the provisions of the Privacy Act and as described for the CRTC’s Master Address Database personal information bank, CRTC PPU 065.

Your comments and personal information will be available on the public file, as per the retention and disposition period specified for the process for which your information was collected (i.e. duration of a licence) or archival if deemed historical as per the Library and Archives of Canada Act.

Confidential information

As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, parties may designate certain information as confidential.

A party designating information as confidential must provide a detailed explanation of 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, a party designating information as confidential 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.

Accessible formats for people with disabilities

The CRTC 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, modified, or read by screen readers) for this proceeding.

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

A copy of this letter, as well as the responses to the requests for information, will also be placed on the public record of the proceeding initiated by Bell Canada’s Tariff Notice 7702 proposing to withdraw DEA Service.

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
Jean-François Leblanc-Poirier, CRTC, jean-francois.leblanc-poirier@crtc.gc.ca

Attachment (3) Appendix 1-2 & Distribution list.

Appendix 1: Questions for Hydro-Québec

  1. In response to RFIs sent by Commission staff on 7 May 2025 (staff RFIs), Hydro-Québec indicated that it would need Digital Exchange Access (DEA) service beyond 23 December 2025, which is the date that Bell proposes to withdraw the service.

    1. Please explain what progress Hydro-Québec has made on migrating to the 1 Flat Line (1 FL) analog solution proposed by Bell since the tariff withdrawal application was filed on 17 October 2024.
    2. In November 2024, Hydro-Québec requested an additional 12 months for the work required to migrate off DEA service. Why does it now require more time?
    3. Is Hydro-Québec able to commit to a date where it will have fully migrated to the 1FL solution and will no longer require DEA service? If so, please indicate the date. If not, please provide an estimate, including an explanation of any assumptions, projections, and unknown factors that inform the estimate.

  2. In response to staff RFIs, Hydro-Québec submitted that it needs DEA service to support voice communication between staff at the Kuujjuaq power plant, residential and commercial customers, and emergency services. It also indicated that no other provider in its region could offer local telephone services compatible with the telephone system at Hydro-Québec’s Kuujjuaq headquarters.

    1. Please explain why DEA service and/or 1FL service are the only possible solutions to fulfill Hydro-Québec’s needs.

      1. Could mobile services available in the region meet Hydro-Québec’s needs? Why or why not?
      2. Could satellite services such as Starlink Business meet Hydro-Québec’s needs? Why or why not?
      3. Since 1FL service also relies on legacy infrastructure, how sustainable is this solution?

  3. In response to staff RFIs, Hydro-Québec submitted that:

    Upon request, Hydro-Québec will be able to provide documents describing the standard specifications required for [migration from DEA Service to 1 Flat Line (1FL) service], as well as the Earth Potential Elevation Study (EPT).
    1. Please provide the referenced documentation, and any other reports that indicate why the project is necessary, what options were considered to address the issue, and what work is required.
    2. Please provide further justification for the cost table provided in Hydro-Québec’s response to Q1 of the RFIs, including any related cost studies. Were costs managed by modifying existing equipment to function on 1FL service? Are all the costs indicated strictly required to migrate to 1FL service?

Appendix 2: Questions for Bell

  1. In response to RFIs sent by Commission staff on 7 May 2025 (staff RFIs), Hydro-Québec stated that:

    Although Bell's correspondence to [Digital Exchange Access] (DEA) customers suggests switching to other voice services such as Megalink or SIP trunking, Bell offers Hydro-Québec only 1 FL analog line service over copper cable; their Megalink and SIP trunking voice services are not available in this region of Quebec.
    1. Please provide a technical comparison of 1 Flat Line (1FL) service with DEA service, and explain how it will meet the needs of Hydro-Québec. Provide a link to the 1FL service tariff, and a reference to the tariff item.

    2. If DEA service, 1FL service, and Megalink service are all provided over copper infrastructure:

      1. Why isn’t Megalink service available to Hydro-Québec?
      2. Does reliance on 1FL service raise similar concerns in terms of the cost of providing a service that relies on aging infrastructure and parts? Does Bell anticipate being able to provide this service in the long-term?

Distribution List:

Bell: bell.regulatory@bell.ca
Hydro-Québec: ibrahim.hassan@hydroquebec.com

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