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Telecom - Staff Letter addressed to the Distribution List

Gatineau, 12 May 2026

Reference:  1011-NOC2025-0226

BY EMAIL

Distribution List

Subject: Request for information - Development of a regulatory policy on measures to improve the resiliency of telecommunications networks and the reliability of telecommunications services (Telecom Notice of Consultation 2025-226)

This letter sets out a request for information (RFI) related to Telecom Notice of Consultation 2025-226. This information will help develop a fulsome record and assist the Commission in its assessment of interventions.  

The questions are included in the appendix to this letter. Parties identified in the appendix must file their responses by 09 July 2026. All parties to the proceeding will have the opportunity to comment on the RFI responses and interventions during the reply period. The dates for the reply period will be communicated by letter at a later date.

Confidential information

Your responses will become part of the public record and will be posted on the CRTC website. Section 39 of the Telecommunications Act and Broadcasting and Telecom Information Bulletin CRTC 2010-961 allows you to designate as confidential certain information you submit to the Commission. You 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 its disclosure.

If you file a document containing confidential information, you must also file with the Commission an abridged version of the document omitting only the confidential information; alternatively, you must provide reasons why you cannot file an abridged version. Only the abridged version of the document will be part of the public record and posted on the CRTC website.

A copy of this letter will be placed on the public record of this proceeding.

Yours sincerely,

Original signed by

Aysha Omar
Director, Broadband and Network Engineering
Telecommunications Sector

Attach. (1) Appendix

Distribution List:

Access Communications Co-operative Limited,  documents@myaccess.coop
Alberta Rural Connectivity Coalition, mmcnally@ualberta.ca
Amazon Kuiper Systems Canada ULC, zab@amazon.com
Bell Canada, bell.regulatory@bell.ca
Bragg Communications Inc., regulatory.matters@corp.eastlink.ca
Build Nova Scotia, david.finlayson@novascotia.ca
Canada Deaf Grassroots Movement, canadadeafgrassrootsmovement@gmail.com
Canadian Telecommunications Association, esmith@canadatelecoms.ca
Canadian Internet Registration Authority, noah.flumerfelt@cira.ca
Canadian NG9-1-1 Coalition, andrew.renfree@gmail.com
Canadian Telecommunications Workers Alliance (SCFP), nblais@scfp.ca
Comité 9-1-1 du SCFP-Québec, nblais@scfp.ca, ibeaudoin@sfmm429.qc.ca  
Commission for Complaints for Telecom-Television Services (CCTS), regulatory@ccts-cprst.ca
Cogeco Communications Inc., nathan.jarrett@cogeco.com
Daniel Sokolov, daniel@falco.ca 
Debra Miskiw, dmiskiw@hotmail.com
Deaf Wireless Canada Committee, jbby@mac.com
Eastern Ontario Regional Network (EORN), jst-pierre@eorn.ca
Eeyou Communications Network, regulatory@eeyou.ca
E-Comm 9-1-1, tony.gilligan@ecomm911.ca
First Mile Connectivity Consortium, info@firstmile.ca
Government of British Columbia, ivan.rincon@gov.bc.ca
Halton Regional Police Service, bill.payne@haltonpolice.ca, regulatory@tacitlaw.com
Iristel Inc., regulatory@iristel.com
Independent Telecommunications Providers Association, jonathan.holmes@itpa.ca
Mathieu Dupuis, mathd@live.ca
Marc Nanni, mn_crtc@proton.me
Municipalité du village de Sainte-Madeleine, administration@stemadeleine.quebec
National Capital FreeNet, execdir@ncf.ca
National Indigenous Economic Development Board (NIEDB), cndeaniedbsecretariat@sac-isc.gc.ca
NC-CIPSeR, tyson.macaulay@alumni.carleton.ca
Ontario Library Association, spimentel@accessola.com
Pelmorex Weather Networks, keby@pelmorex.com
Quebecor Media Inc., regaffairs@quebecor.com
Rogers Communications Canada Inc., regulatory@rci.rogers.com
Saskatchewan Telecommunications (SaskTel), document.control@sasktel.com,
SSi Canada, regulatory@ssicanada.com
Telesat, eneasmith@telesat.com
TELUS, regulatory.affairs@telus.com
Terrestar Solutions Inc., reglementaire-regulatory@terrestar.ca
Xplore Inc., legal@xplore.ca

APPENDIX

In Telecom Notice of Consultation CRTC 2025-226 (the Notice), the Commission sought comments on developing a regulatory policy on measures that TSPs should take to help improve the resiliency of telecommunications networks and the reliability of telecommunications services.

In the questions below, the term “parties” refers only to the entities that filed interventions in response to the Notice. The following questions are directed to specific parties as indicated below and are organized into sections for Telecommunications Service Providers (TSPs), 9-1-1 Network Providers, and Wireless Service Providers (WSPs)/Pelmorex.

Questions for TSPs

TSP Compliance Framework:

  1. Some partiesFootnote1 have suggested that mandatory resiliency measures should be principles-based and applied in a proportionate, risk-based manner, reflecting a TSP’s size, operational capacity, or systemic importanceFootnote2 to Canadians’ access to reliable telecommunications services. Under this approach, the Commission could use one or more objective thresholds to determine which TSPs must comply with specific mandatory measures, while encouraging other TSPs to adopt them where feasible. 
    1. Should the Commission establish a threshold or thresholds to determine which TSPs are systemically important and therefore must comply with mandatory resiliency measures? Please explain.
    2. If yes, what criteria should the Commission use to establish these thresholds, and what should the threshold value(s) be? Please provide justification. Examples of possible criteria include:
      • number of subscribers;
      • annual telecommunications service revenues;
      • the proportion of households served by the TSP nationally or regionally; and/or
      • regional or market-specific factors (e.g., the TSP is the sole service provider in a given area, the TSP is operating critical transport infrastructure for downstream TSPs, etc.).
    3. If no, what alternative approach should the Commission use to identify which TSPs must comply?

Resiliency Principles:

  1. Some partiesFootnote3 proposed that the Commission establish a resiliency principle that promotes collaboration.
    1. Should the Commission adopt a resiliency principle that TSPs should “promote coordination with stakeholders to reduce the likelihood, scope, and duration of service outages”?
    2. What measures can TSPs take to improve coordination with stakeholders, e.g. joint emergency planning, pre-event coordination with local emergency management organizations, etc.?
    3. Should the Commission require TSPs to implement these coordination measures? If not, provide reasons why not and explain whether this should instead be considered a best practice.
  2. Some partiesFootnote4 proposed that the Commission establish resiliency principles to support the continuity and timely restoration of designated critical telecommunications services. This could include, for example, TSPs prioritizing certain services for traffic management during congestion, establishing a prioritized service restoration sequence during outages, and enhancing resiliency in network design for these services. The proposed priority services include 9-1-1, wireless public alerting, and specialized services (e.g., teletypewriter relay, Internet Protocol relay services, or 9-8-8). 
    1. Should the Commission adopt a resiliency principle that TSPs “support the continuity and timely restoration of designated critical telecommunications services during network disruptions”? Please explain.
    2. What services should such a principle cover, and why?
    3. What measures could TSPs implement to support this principle, and what benefits would those measures provide? Examples of possible measures include:
      1. prioritizing the traffic for critical services;
      2. prioritizing the restoration of critical services; or
      3. implementing additional resiliency measures in network design and operations
    4. Should the Commission require TSPs to implement these measures? If not, provide reasons why and explain whether this should instead be a best practice.
  3. Some partiesFootnote5 identified resiliency risks to Canadian telecommunications networks and services when TSPs use boomerang routingFootnote6 or host data in foreign countries. They proposed that the Commission could establish resiliency principles and measures to reduce those resiliency risks.
    1. Should the Commission adopt resiliency principles that encourage TSPs to do the following:
      • Prioritize using networks that are located within Canada, including when routing traffic and when hosting telecommunications data.
      • Deploy networks and systems that have network security safeguards and encryption appropriate to the sensitivity and criticality of the network elements and network data.
    2. Describe the network resiliency and service reliability risks associated with boomerang routing and hosting data outside of Canada, how you assess those risks, and the measures you take to mitigate them. Please explain, including what other measures the Commission could take to meet subsections 7 (e) and (i) of the Telecommunications Act Footnote7 to address the concerns and risks associated with boomerang routing and hosting data outside Canada.
    3. Do you implement data encryption to secure information that is being routed and/or hosted outside Canada? If so, describe the type of encryption you use and which type of data you encrypt. If not, explain why not.
    4. What measures, such as data encryption, could TSPs implement to support these principles, and what benefits would those measures provide?
    5. Should the Commission require TSPs to implement these measures? If not, provide reasons why and explain whether this should instead be a best practice.

Network Design

  1. Multiple TSPsFootnote8have stated that they adhere to industry standards when designing, constructing and operating telecommunications infrastructure.
    1. Identify the specific industry standards (e.g., construction, electrical, environmental, safety, etc.) that your organization follows for:
      • The installation of cabling and ducting (e.g., fibre, copper, and other media).
      • The design and installation of indoor and outdoor facilities used to support or house telecommunications equipment (e.g., towers, shelters, central offices, head-ends, etc.).
    2. Do these standards ensure sufficient protection of telecommunications infrastructure from location-specific hazards such as wildfires, flooding, ice storms, or other extreme events? Please explain.
    3. Should adherence to ISO 22372 (Infrastructure resilience), ISO 22301 (Business Continuity), ISO 27001 (Information Security), ISO 20000 (IT service management), ISO 22336 (Organizational Resilience Policy and Strategy), and ISO 22320 (Emergency Management and Incident Response) standards be established as a requirement or a best practice for TSPs network design, operation and management? Please explain for each ISO standard.
  2. Halton Regional Police Service and Peel Regional Police (HRPS-PRP) submitted that TSPs should have a network resiliency plan that covers all the resiliency measures listed in Appendices 1 and 2 of Telecom Notice of Consultation CRTC 2025-226.
    1. Does your company have and maintain a network resiliency plan or equivalent? If so, either provide a copy of the plan or describe in detail what is included in it, including the key resiliency areas and topics it covers.
    2. Should the Commission require TSPs to develop and implement a network resiliency plan? Please explain. If you do not think this should be a requirement, explain what other method(s) TSPs could use to identify and internally communicate resiliency measures. 
    3. What are the minimum details that a network resiliency plan should include, and what is an appropriate review or update cycle?
    4. How long would it take to develop and implement a network resiliency plan?
  3. Some parties Footnote9 have emphasized that maintaining local inventories of critical spare parts is essential for network resiliency.
    1. Describe your network equipment sparing strategy. In your response, include your approach to inventory management for critical components and depot positioning, and the factors you use to determine where to place spare parts, such as component failure history, criticality, or travel time.
    2. Describe your current practices for staging spare parts in remote regions. In your response, explain how you select staging locations, describe your planned and typical inventory levels, and describe the impact your practices have had on mean time to repair (MTTR).
    3. Should the Commission require TSPs to have a network equipment sparing strategy to maintain local inventories of critical network spare parts? If not, should it be considered a best practice? Please explain.

Supply of Uninterrupted Power

  1. Some partiesFootnote10 have proposed that the Commission should require TSPs to implement a minimum duration for backup power at network sites.
    1. Describe your current strategy for backup power at network sites. Include in your response:
      • The criteria you use to select the sites or categories of sites where you maintain backup power.
      • The duration of power backup you design for each site or site category, and why you chose that duration.
      • The technologies you use to provide power backup, and why you choose one technology over another.
      • Typical costs required to develop and establish backup power for each site or site category.
      • The time required to develop and establish backup power for each site or site category.
    2. If the Commission were to mandate that TSPs implement backup power requirements for critical network sites:
      • How should a critical network site or site category be defined?
      • What minimum backup power requirements, including minimum duration, should apply and why? Provide any evidence (e.g., power outage history, restoration times, environmental and access conditions) you have that supports your recommendation.
      • Should the requirements differ based on the type of network site (e.g., core, transport, access) or location (e.g., remote, rural, urban)? If so, propose categories and the minimum backup power requirements for each. If not, then explain why not.

Incorporating Satellite Services

  1. Describe your plans to use satellite services to support network resiliency. In your response:
    1. Explain how the satellite services will be used. For example, for emergency services (e.g., emergency text and call continuity), backhaul, temporary replacement of damaged terrestrial links, direct-to-device connectivity, out-of-band network management and troubleshooting, or other purposes);
    2. Identify the technical, operational, economic, and regulatory challenges limiting broader use of satellite services to improve network resiliency; and
    3. If you do not currently use satellite services and have no intention of doing so in the future, explain why not and identify the conditions under which this position may change.

Network Operations

  1. Some partiesFootnote11 have mentioned that they have implemented the Information Technology Infrastructure Library (ITIL) framework for change management. The Government of British Columbia has recommended that TSPs should align their change management and incident management processes with the ITIL framework.
    1. Do you follow the ITIL framework for your change management and incident management processes? If not, then what industry standards do you follow for your change management and incident management processes?
    2. What other standards could TSPs adopt for change management and incident management?
    3. Should the Commission require TSPs to implement industry standards such as the ITIL framework, as a minimum requirement for their change management and incident management processes or should it instead be a best practice? Please explain. If you think this should be a requirement, explain which standards the Commission should require TSPs to implement.
  1. Some partiesFootnote12 mentioned that they conduct incident response exercises to better prepare for network incidents such as service outages and system failures.
    1. Does your organization conduct incident response exercises? If so, describe how you conduct those exercises. Include information on:
      • the frequency of your incident response exercises;
      • the scenarios you practice;
      • how you coordinate with other stakeholders;
      • what partner organizations, such as vendors or various levels of government, you include in those exercises;
      • how you track the network deficiencies you discover during the exercises; and
      • how you ensure you have implemented measures to address those deficiencies
    2. Do you have an incident response centre or equivalent function to coordinate incident response efforts within your organization? If so, how is your network operations centre interfaced or integrated with it?
    3. Should TSPs be required to conduct incident response exercises, and should they be required to establish an incident response centre? If not, should these be considered best practices? Please explain.
  2. TSPs can protect their networks by insuring against various risks and damages, such as network outages caused by vandalism or natural disasters.
    1. Do you have network insurance? Please explain why or why not. If you have network insurance, provide details on what it covers, including:
      • the risks you are insured against;
      • the parts of the network that are insured;
      • whether the insurance covers network operations; and
      • how much the insurance premiums cost.
    2. Describe in what ways insurance influences resiliency outcomes. For example, does it improve service restoration times?
    3. Should the Commission require TSPs to have a minimum level of network insurance, or should this instead be a best practice? Please explain. If you think this should be a requirement, explain what the minimum required coverage should be.
  3. Third-party incidents are one of the leading causes of service outages. The categories of third-party incidents are theft, vandalism, damage during construction or other activities, and failures by third-party vendors. Implementing robust resiliency measures can help reduce the occurrence and severity of network outages caused by these types of incidents.
    1. For each of the categories above, describe the types of network components that have been most often impacted, how they were damaged or failed, and the geographic areas where these incidents have occurred most frequently.
    2. What measures can TSPs take to reduce the number of incidents in each of the categories above? In your explanation, describe the measures you have implemented to reduce such incidents, and identify which measures should be mandatory and which should be considered best practices.
    3. What actions could the Commission take within its jurisdiction under the Telecommunications Act to reduce outages caused by theft and vandalism?
  4. Properly trained staff are the most reliable resource for ensuring resiliency and early network restoration. Some partiesFootnote13 have indicated they provide such training to their employees.
    1. Describe any employee training plans you have in place that are specifically designed to improve network resiliency and outage restoration times.
    2. What measures do you have in place to incentivize your employees to improve network resiliency and service reliability?
    3. Should the Commission consider employee training plans and employee incentive measures aimed at improving network resiliency to be a requirement or a best practice for TSPs?  Please explain.
  5. Some parties Footnote14 have identified preventive and/or predictive maintenance as an important network resiliency tool.
    1. Do you have a formal maintenance program for your network infrastructure? Please explain. If you have such a program, describe it and respond to the following:
      • Is the program preventive (scheduled, rule‑based), predictive (data‑driven, analytics‑based), or a hybrid of both?
      • Which parts of the network does it cover (e.g. the core, transport or backhaul, access or last mile, or other network support infrastructure [power systems, HVAC, shelters, poles, towers])?
      • How do you prioritize maintenance activities within the program (e.g. based on asset criticality, failure history or failure rates, customer impact, geographic or environmental risk, accessibility for repair, etc.)?
    2. Should the Commission require all TSPs to prepare and implement a maintenance program? If not, provide reasons why and explain whether this should instead be a best practice.
      • What should a maintenance program include?
  6. Many Canadians live in rural and remote areas, where repair times for access, transport and core network can be much longer than in urban areas.
    1. What tools and strategies, such as local support, do you use to detect, monitor, and diagnose network faults in rural and remote areas? How can these tools assist in the early restoration of network faults in remote communities?
    2. How do you estimate service restoration times for rural and remote areas?
    3. Describe the specialized tools and strategies that TSPs should implement to monitor, detect and repair network faults in rural and remote communities, including in transport networks.
  7. Some parties Footnote15 have proposed that artificial intelligence (AI) supported predictive analytics and network monitoring could help improve network resiliency by enabling early detection and correction of network faults.
    1. What types of AI-supported tools do you currently use for predictive analytics and network monitoring?
    2. How can AI-supported tools help improve the resiliency of telecommunications networks and the reliability of services? For example:
      • Can they help detect failures in critical systems or networks, such as in the 9-1-1 network?
      • Can they help optimize preventive maintenance schedules?
      • Can they provide real-time monitoring and alerts when a network experiences a failure or service degradation?
    3. What are the best practices TSPs should follow when using AI-supported predictive analytics and network monitoring?
  8. The First Mile Connectivity Consortium submitted that the Commission should place transport-level monitoring requirements on carriers that operate regional transport infrastructure because local TSPs cannot monitor or diagnose failures.
    1. Do regional transport providers conduct transport-level monitoring? If so, explain that monitoring. If you are such a provider and do not conduct transport-level monitoring, explain why not.
    2. Do regional transport providers notify their TSP customers about network failures or events (e.g., an unplanned outage) that affect the downstream TSPs' customers? If so, what information do they provide, and under what conditions do they provide such notification?
    3. What outage reporting requirements do regional transport providers have through contractual obligations with their TSP customers?
    4. Should the Commission require carriers that operate regional transport infrastructure to implement transport‑level monitoring? In your response, address whether such a requirement is necessary to enable downstream TSPs to detect, diagnose, or respond to network failures. If you do not support it as a requirement, explain why and indicate whether transport-level monitoring should instead be a best practice.

Power Outages at Customer Premises

  1. The risk of power outages varies significantly by region due to a combination of extreme weather patterns, geography, and infrastructure age. For example, some areas are more prone to electrical power disruptions. In addition, some customers are reluctant to use fibre-based or coax-based home phone services because of their vulnerability to power outages at customer premises.
    1. Do you advise your customers to purchase or rent battery backup equipment to ensure that your services continue to function during a power outage, for instance, in cases where customers are transitioning from twisted-pair copper to fibre-based services? Please explain.
    2. What are the typical costs to customers (purchase or rental) for battery backup solutions? This could be either external battery backup equipment or home routers/modems with integrated battery backup capable of providing at least four (4) hours of backup power under typical residential use. Please provide estimated cost ranges and indicate whether the costs relate to purchase or rental arrangements.
    3. Is there any other advice you provide to your customers to ensure the continuity of the services you provide during a power outage affecting their home?

TSPs Emergency Response Plans

  1. Halton Regional Police Service and Peel Regional Police (HRPS-PRP) submitted that TSPs should be required to have an emergency response plan in place to handle situations such as wildfires, floods, and extreme weather events. It proposed that the plan include risk assessments, key contact information, clearly defined roles and responsibilities, and procedures for coordinating with local emergency management organizations.
    1. Does your company have and maintain an emergency response plan or equivalent? If so, either provide a copy of the plan or describe in detail what is included in it.
    2. Should the Commission require TSPs to develop and implement an emergency response plan, or should it be a best practice? Please explain. 
    3. What are the minimum details that an emergency response plan should include, and what is an appropriate review or update cycle?
    4. How long would it take to develop and implement an emergency response plan?

TSP Mutual Assistance

  1. Smaller TSPs are not included in the Memorandum of Understanding on Telecommunications Reliability.
    1. How could larger TSPs support smaller TSPs during outages to help restore services, such as by providing personnel, equipment, facilities, technical expertise, and information sharing?
    2. Does an existing business relationship (e.g. mutual assistance agreement) need to exist prior to providing this support?
    3. If larger TSPs can support continuity of services to the customers of smaller TSPs during outages, what capabilities or level of service could they provide specifically in comparison to the affected voice, text and data services?

Improving the Reliability of Accessibility Services

  1. Rogers stated that they maintain Service Level Agreements (SLAs) and service level targets with third-party providers for accessibility services.Footnote16
    1. Do you maintain SLAs with third-party providers of accessibility services? If so, provide details of the SLAs and key performance indicators (KPIs) and provide details on the costs associated with implementing these SLAs and KPIs.
    2. What SLAs and KPIs should TSPs require of third-party accessibility service providers? Please explain.
  2. Rogers suggested that network stress testing should include load simulation of accessibility services. This would help TSPs evaluate the resiliency of accessibility services under conditions that mimic real-world scenarios.
    1. Do you include accessibility services in your load simulations for network stress testing exercises? Please explain.
    2. In what other ways do you evaluate the resiliency of accessibility services?

Accessing Telecommunications Services During an Emergency

  1. The Ontario Library Association has suggested recognizing public libraries and non-profit community media centres as trusted local hubs and digital access points for emergency communications. It proposed prioritizing these institutions for backup power and redundant connectivity, which would enable them to function as community anchor institutions during telecommunications disruptions.
    1. What are your views on this proposal, including its benefits for improving community connectivity during service disruptions or to distribute information to Canadians about how to stay connected during emergencies?
    2. What other institutions could be considered as trusted local hubs and digital access points for emergency communications?
    3. What are the operational or technical considerations for implementing this proposal?
    4. How could redundant connectivity and backup power for such hubs be funded?
    5. What role can such hubs, particularly public libraries or community media centres, play in distributing TSPs’ emergency communications materials in Indigenous languages and in accessible formats?
  2. Bragg noted in its intervention that it is common for Internet Service Providers to provide information to customers on how to prepare for and stay connected during emergencies.
    1. Do you provide information to customers on how they can proactively prepare for and stay connected during emergencies? If so, provide details on those communications, including how often they are sent. Include details of the medium of communications used, for example, through bill inserts, text messages, or email notifications.   
  3. The Deaf Wireless Canada Committee proposed in its intervention that TSPs provide emergency-preparedness information in the following formats: ASL/LSQ video, captioned plain-language text, and accessible print and Deaf Blind tactile formats.
    1. What material do you provide in these formats?
    2. Should the Commission require TSPs to provide emergency-preparedness information in these formats, or should it be a best practice? Please explain.   

Enforcing the Resiliency Regulatory Policy

  1. Telecommunication services and their supporting resilient networks play a critical role in ensuring public safety and a functioning economy. Therefore, certain regulatory and administrative requirements for TSPs may be necessary to protect the public interest.
    1. If the Commission imposes mandatory resiliency measures on TSPs and requires confirmation of implementation, how (e.g. attestation, compliance report, etc.) and how often should TSPs be required to review their implementation of those measures and provide confirmation to the Commission?  

Questions for 9-1-1 Network Providers

Reliability of 9-1-1 Services

  1. Cogeco stated in its intervention that 9-1-1 networks and services should adhere to the highest standards of redundancy, diversity, and reliability. What resiliency-related performance targets or metrics should apply to 9-1-1 networks or 9-1-1 service-specific parts of the networks? In your response:
    1. Identify relevant quantitative and/or qualitative performance targets or metrics related to 9-1-1 network resiliency (e.g., availability, redundancy, restoration, power, or failover performance).
    2. Indicate whether the metrics you described in a. are currently used within your operations; and
    3. Explain how the metrics you described in a. support reliable delivery of 9-1-1 services.

Questions for WSPs and Pelmorex

Reliability of Wireless Public Alerting Services

  1. Pelmorex noted in its intervention that the National Alert Aggregation and Dissemination (NAAD) System currently operates with two redundant data centres. It proposed adding a third redundant WPA alert gateway to further guard against broad cloud service outages and improve alert delivery reliability.
    1. Should the Commission mandate a third redundant gateway? Please explain.
    2. How much time would it take and what would be the cost for:
      • Pelmorex to implement a third redundant gateway; and
      • WSPs to establish connections to the new gateway?
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