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Telecom - Staff Letter addressed to Julia Kennedy (Canadian Telecommunications Contribution Consortium Inc.)

Gatineau, 3 December 2025

Our Reference: 8695-R28-202503094

BY E-MAIL

Julia Kennedy
Secretary
Canadian Telecommunications Contribution Consortium Inc.
1300-55 Metcalfe Street
Ottawa, Ontario K1P 6L5
jkennedy@fasken.com

Subject: Application regarding TSP’s contributions to the National Contribution Fund with respect to the Broadband Fund, Request for Information

Dear Julia Kennedy,

Commission staff have reviewed the RFI response and reply comments and concluded that further inquiry is necessary. As per the Telecommunications Act (the Act) and the CRTC Rules of Practice and Procedure), the Commission may require the submission of information as necessary for the administration of the Act.

Accordingly, staff is seeking further input from the Canadian Telecommunications Contribution Consortium Inc. (CTCC) and Central Fund Administrator (CFA).

We request the following information:

  1. Is it feasible to require that all contributions be paid to the CFA annually, instead of being recorded as uncalled liabilities? If so, could the CFA collect the funds and manage the entire amount in an account at a financial institution?

    1. If not, what alternative approaches could be considered should the CFA be required to collect all the uncalled contributions and collect the entire amount of the BBF collection each month on a going forward basis?

    2. If the CFA is unable to do so, could the CTCC hold the funds on behalf of the CFA?

      1. What risks or barriers might the CTCC face to managing the funds?
      2. Are there ways to overcome any barriers that the CTCC might face in managing such a fund?
    3. Please provide views as to the process that would need to be undertaken to facilitate the holding of all uncalled contributions by the CTCC. Would the NCF procedures need to be amended? Would the NCF Administration Agreement need to be amended? Are there any other procedures that would have be revisited or considered?

  2. Would it be operationally feasible to release BBF funds on an ad hoc basis, in future years? For example, if in 2026, $100M of the $150M collected were committed, the CRTC might contemplate instructing that the remaining $50M be returned to contributors via the annual percentage rate charge decision.

    1. Are there any operational or administrative barriers to releasing uncalled funds on an ad hoc basis?
    2. If the CFA or the CTCC were required to manage a fund containing all contributions, would refunding some contributions in-year in this same manner be feasible?

Please provide your responses to this request for information by 10 December 2025 or advise the Commission in writing beforehand if there is a valid reason this information cannot be provided by that time.

Interested persons and parties may submit interventions on the responses to the request for information to the Commission, copying those in the distribution list, by 16 December 2025. The applicant may submit its reply to the new interventions to the Commission, copying those in the distribution list by 19 December 2025.

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, persons may designate certain information as confidential. A detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest must be provided, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. In addition to the confidential version, an abridged version of the document omitting only the confidential information must be filed or reasons why an abridged version cannot be filed must be provided.

Please let me know if you require clarification on any of the above requests.

Yours sincerely,

Original signed by

Michael Bergeron
Senior Manager, Broadband Fund
Telecommunications

c.c.: Howard Slawner, Rogers Communications Inc., regulatory@rci.rogers.com
Jonathan Homes, Independent Telecommunications Providers Association, regulatory@itpa.ca
Dennis Béland, Terrestar Solutions Inc., dennis.beland@terrestar.ca
Karen Cheung, TELUS Communications Inc., regulatory.affairs@telus.com
Tahira Dawood, The Public Interest Advocacy Centre (PIAC), joined by Samuelson-Glushko Canadian Internet Policy and Public Interest Clinic (CIPPIC), tdawood@piac.ca
Philippe Gauvin, Bell Canada, bell.regulatory@bell.ca
Marielle Wilson, Bragg Communications Inc., regulatory.matters@corp.eastlink.ca
Patrick Desy, Quebecor Media Inc., regaffairs@quebecor.com

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