Telecom Procedural Letter addressed to Chris Amendola (President, Beanfield Technologies Inc.) and Deborah A. Howden (Counsel, Shibley Righton LLP)

Ottawa, March 4 2016

Our reference: 8622-B75-201513945

BY EMAIL

Mr. Chris Amendola
President, Beanfield Technologies Inc.
418-77 Mowat Avenue
Toronto, Ontario  M6K 3E3
chris@beanfield.com

Ms. Deborah A. Howden
Counsel, Shibley Righton LLP
700-250 University Avenue
Toronto, Ontario  M5H 3E5
deborah.howden@shibleyrighton.com

RE:  Interrogatories with respect to the request from Beanfield Technologies Inc. for access to multiple dwelling units located at 65, 75 and 85 East Liberty Street, Toronto

Dear Madam, Sir,

On 21 December 2015, Beanfield Technologies Inc. (Beanfield) filed an application requesting an order whereas Toronto Standard Condominium Corporation No. 2322 (the Corporation) would be granting Beanfield access to the multi-dwelling unit (MDU) building located at 65, 75 and 85 East Liberty Street, in Toronto, Ontario.

Commission staff considers that additional information is required in regard to Beanfield’s application. Beanfield and the Corporation are therefore required to provide comprehensive answers, including any supporting information, to the attached interrogatories.

Pursuant to subsection 37(2) of the Telecommunications Act, the Commission may require a person other than a Canadian carrier that is in possession of information that the Commission considers necessary for the administration of the Act, to submit the information to the Commission.

As set out in Procedures for filing confidential information and requesting its disclosure in Commission proceedings Broadcasting and Telecom Information Bulletin 2010-961, 23 December 2010, parties may designate certain information as confidential. Parties must provide an abridged version of the document involved, accompanied by a note explaining how the information removed is confidential.

The Corporation is to file with the Commission, and serve on all other parties, its responses to Questions 2 and 4 by 11 March 2016.

Responses by both parties to the rest of the interrogatories are to be filed with the Commission, and served on all other parties by 24 March 2016.

Written arguments may be filed with the Commission with respect to the responses to these interrogatories, serving copies to all parties by 1 April 2016.

Sincerely,

Original signed by Valerie Plaskacz for

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications sector

c.c:  Marisa Coggin, Owens Wright, mcoggin@owenswright.com
Bell Canada, bell.regulatory@bell.ca
Rogers Communications, rci.regulatory@rci.rogers.com
Coextro, skhandor@coextro.com
Alysia Lau, Public Interest Advocacy Group, alau@piac.ca
Danny Moreau, CRTC, danny.moreau@crtc.gc.ca

Attach. (2)


INTERROGATORIES

Interrogatories to be answered by the Corporation

  1. Considering Section A paragraphs 8 – 32 of Beanfield’s application, provide an account of the timeline of events and actions of the Corporation beginning from when the Corporation was first contacted by Beanfield regarding access to the MDUs and the filing of the application by Beanfield.
  2. Indicate the number of Main Terminal Rooms (MTRs) present in each of the buildings located at 65, 75 and 85 East Liberty Street that are used to support the MDU’s communications infrastructure.
  3. For each of the MTRs identified in Question 2:
    1. Indicate the total number of vertical conduits extending from the MTR to each of the floor closets that are used to support the MDU’s communications infrastructure.
    2. Indicate the diameter for each of these vertical conduits.
    3. Indicate the vacant area in each of these vertical conduits (units2).
  4. Indicate the number of telecommunications closets present in each of the buildings located at 65, 75 and 85 East Liberty Street that are used to support the MDU’s communications infrastructure.
    1. Indicate on which floor each of these closets are located.
  5. For each of the communications closets identified in Question 4:
    1. Indicate the total number of horizontal conduits extending from each closet to individual units that are used to support the MDU’s communications infrastructure.
    2. Indicate the diameter for each of these horizontal conduits.
    3. Indicate the vacant area in each of these horizontal conduits (units2).
  6. Provide appropriate photos to support the answers to the above questions.

INTERROGATORIES

Interrogatories to be answered by Beanfield

  1. Indicate the size of the wires Beanfield would be using to provide its communications services to the MDU located at 65, 75 and 85 East Liberty Street. 
    1. Indicate the number of wires that would have to be installed from the MTRs to each communications closet in order to provide its communications services.
    2. Indicate the number of wires that would have to be installed from each communications closet to individual units in order to provide its communications services.
  2. At paragraph 14 of its final reply dated 16 February 2016, Beanfield indicated that it had “obtained and reviewed pictures of some of the telecommunications closets which are attached as Schedule 1.”
    1. For each of these pictures, identify the specific closets it represents (i.e. the address of the MDU where the closet is located and the floor on which each closet is located).
  3. At paragraph 23 of its final reply dated 16 February 2016, Beanfield indicated that utilization of existing infrastructure on a leased basis would be impossible both technically and physically.  Elaborate on that claim considering that one of the service providers currently present in the MDU, namely Coextro, also provides its services using fibre optic.
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