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Telecom - Staff Letter addressed to Howard Slawner (Rogers Communication Canada Inc.)

Gatineau, 3 December 2025

Our Reference: 8695-R28-202503094

BY E-MAIL

Howard Slawner
Vice President – Regulatory, Telecom
Rogers Communication Canada Inc.
One Mount Pleasant Road
Ontario M4Y 2Y5
regulatory@rci.rogers.com

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

Dear Howard Slawner,

Commission staff has reviewed the application and the record of the proceeding. Based on this review staff has 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, in this request for information (RFI), staff requires Rogers to clarify the specific nature of the harm referenced in its application and to obtain comments on the potential option of releasing of uncalled funds.

  1. Rogers’ application indicates that the amount of uncalled contributions is causing “direct and specific harm” in that it results in some measure of uncertainty on its balance sheets. Rather than recording the uncalled contribution amounts as an uncalled liability, please comment as to whether requiring contributions to be immediately paid to an account outside Rogers’ control on a monthly or annual basis would be preferable. Please indicate whether Rogers would support this proposal and provide the rationale for its position.

  2. To date, the BBF has $825M available for distribution and has awarded funding to projects totalling over $752M; this leaves approximately $73M of contributions that have not yet been awarded to a project. Commission staff anticipates that the entire $73M will be needed for both future funding awards, as well as additional funding requests from already approved projects. Accordingly, 91% of the amount available for distribution to the BBF have been committed to project

    1. Given that 91% of the amount available for distribution have been awarded to projects, and that this funding will be required to be distributed in accordance with the funding recipients' project budgets, explain how Rogers’ proposal could accord with the Broadband Fund’s eligible expense claim reimbursement process?
    2. Would additional reporting from the Commission and the CFA on the amount awarded and committed by the Commission for approved projects as well as collected, uncalled and distributed contribution amounts on a per contributor basis on the monthly invoices address Rogers’ concerns? If so, please describe the frequency and content of the reports.

  3. Comment on the possibility that the Commission could provide relief in future years in deciding to return some amounts of funding in future years if these funds are not awarded by the end of the year. This relief could be considered annually by the Commission during its review of the annual revenue percent charge decision.

    This proposal would not impact the current uncalled liabilities but would impact future years. For example, if in 2026, $100M of the $150M collected were committed, the remaining $50M could potentially be released to contributors in the end of year percentage rate charge decision.

    1. Would this proposal address the alleged harm outlined in the application
    2. To what extent would the potential release of uncalled funds, on an ad hoc basis, address the concerns raised in this application?
    3. How would this type of approach work if the Commission were to receive unplanned funding requests such as those related to change requests from ongoing or approved projects?
    4. Would this approach constrain future calls for funding and if so, how should this be mitigated.

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 have any questions or require clarification on any of the above request.

Yours sincerely,

Original signed by

Michael Bergeron
Senior Manager, Broadband Fund
Telecommunications

c.c.: Julia Kennedy, Canadian Telecommunications Contribution Consortium Inc., jkennedy@fasken.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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