Summary

  • The CRTC wants agreement dates, Tier 4 service areas, MVNO retail customers, new RAN sites, capital investment and planned construction through 9 May 2030.
  • The request creates a useful implementation record, but the information sought cannot by itself establish that wholesale access caused investment or improved service.

A framework reaches its midpoint

On 13 October, CRTC staff asked four national carriers to list their wholesale mobile virtual network operator agreements with regional carriers, attach the agreements and give their start and expiry dates. Four regional groups—Cogeco, Eastlink, Iristel and Quebecor, on behalf of Videotron and Freedom—were asked for the matching agreements and a more granular account of use and expansion.

For each Tier 4 spectrum area where a regional carrier uses wholesale access, the staff letter seeks the latest available retail-customer count, new radio access network (RAN) sites deployed since access began, and associated capital investment. It asks for actual spending where readily available, otherwise the carrier’s best estimate. A final item asks how many additional sites each carrier plans to deploy between its response and 9 May 2030. The letter explicitly includes RAN equipment on shared towers.

Responses must reach the Commission by 13 November 2026. The seven-year access framework, set out in Telecom Regulatory Policy 2021-130, runs through 9 May 2030. Staff describes the request as a consolidated snapshot as the framework enters its second half. It is separate from routine reporting already required under that policy.

Four stages, not one outcome

The questions trace a plausible chain: an agreement makes access available; a carrier uses that access to sell retail service in an area; the carrier may add radio infrastructure; capital is committed to expansion. Putting these elements side by side is more informative than a list of contracts or a national site total. The Tier 4 geography may help distinguish an area where wholesale access is actually used from one where it is merely available.

But sequence is not causation. The CRTC has requested a current customer count, sites added since wholesale use began and an investment figure. It has not requested a matched pre-access baseline in the letter. Without that baseline—or a clear explanation of how each carrier attributes a site or expense—readers cannot tell whether a new site followed access, was already planned, serves another business purpose, or would have been built anyway. Nor does a customer count show whether service quality, affordability or coverage changed.

The requested measures also mix different kinds of evidence. An agreement with dates is a contractual fact. A current customer count is a snapshot. A deployed RAN site is a physical addition, including equipment placed on a shared tower. Capital may be an audited amount or an estimate. Future sites are plans. These are all relevant, but they should not be presented as if they were equally complete or directly comparable.

That distinction matters for the policy question. The framework’s stated purpose is to let eligible regional carriers serve new areas while building networks of their own. The record could therefore reveal both commercial use of wholesale access and a path toward facilities-based presence. It cannot decide whether one is a substitute for the other or whether the intended transition is occurring unless definitions, dates and evidence status travel with every number.

Two processes are moving at once

A separate CRTC proceeding, Telecom Notice of Consultation 2026-259, asks whether to end existing reporting requirements for regional carriers. That is a consultation, not a decision. The 13 October letter says its request is separate and intended to provide a consolidated view. Keeping the two records distinct prevents the new data call from being misread as either an announced sunset of reporting or a finding that the framework is succeeding or failing.

The staff letter requires public abridgements of responses and says confidentiality claims need reasons under the Commission’s rules. Publication will matter as much as collection. If parties use different definitions for a “new” site, investment period or service area, public totals could look precise while resisting comparison. Where estimates or future plans appear, they need to stay labelled as such.

The letter reports no response data. It establishes no agreement count, customer total, investment amount, construction result or compliance concern. Those facts will only become available after the parties file and the Commission processes the record. For now, the useful signal is the design of the question: access, use and expansion are being asked about in the same geography and time horizon.

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