Telecom Procedural Letter Addressed to Mr. Lawry Trevor-Deutsch (TNW Wireless Inc.)
Ottawa, 13 July 2018
Our reference: 8620-R63-201705675
Mr. Lawry Trevor-Deutsch
TNW Wireless Inc.
468 Pleasant Park Road
Ottawa, ON K1H 5N1
Re:Part 1 application by TNW Wireless Inc. relating to wholesale roaming agreements required under Telecom Regulatory Policy 2015-177) Footnote1 – Requests for information
Dear Mr. Trevor-Deutsch:
Attached are requests for information to TNW Wireless Inc. (TNW Wireless) associated with the above-noted proceeding. Responses to these requests for information are to be filed with the Commission, and served on all parties to this proceeding, by 27 July 2018, in accordance with the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure.
Parties may file supplementary comments on the responses, serving a copy on all parties, by 10 August 2018. TNW Wireless may file supplementary reply comments, serving a copy on all parties, by 17 August 2018.
Documents to be filed or served by a specific date must be actually received, not merely sent, by that date.
Original signed by C. Brock for/
Director, Policy Framework
c.c.: Julie Boisvert, CRTC, (819) 953-2421, firstname.lastname@example.org
Christine Brock, CRTC, (819) 997-4557, email@example.com
Chris Copeland, firstname.lastname@example.org
Bell Mobility Inc., email@example.com
Rogers Communications Canada Inc., firstname.lastname@example.org
TELUS Communications Company, email@example.com
Ice Wireless Inc., firstname.lastname@example.org
Shaw Communications Inc., Regulatory@sjrb.ca
Québecor Média inc. email@example.com
Public Interest Advocacy Centre (PIAC), firstname.lastname@example.org
Requests for information addressed to TNW Wireless
- Provide an organizational chart, and supporting documents, which reflects the current corporate structure of TNW Wireless Inc., including:
- the corporations or legal entities which form part of the control chain and all corporations or legal entities holding directly or indirectly voting interest; and
- affiliates (including) subsidiaries of TNW Wireless Inc.
- Indicate who is the natural person(s) and/or the legal person(s) who controls (as that term is defined in the Telecommunications Act) TNW Wireless Inc. and by what means.
- Provide a description of TNW Wireless Inc.'s ownership history.
- Provide a description of the relationship (recent past and/or present) between TNW Wireless Inc. (or any of the corporations/persons in its corporate structure), and the entities listed below (unless the relationship is established in the previous question):
- TNW Networks Corp
- Investel Captial Corp.
- United American Corp.
- 8640025 Canada Inc.
- Navigata Communications Ltd.
- Teliphone Data Centers Inc.
- Teliphone Canada Corp.
- Teliphone Navigata-Westel Communications
- Fiducie Residence JAAM
- Information Technology and Telecommunications Canada
- Distributel Communications Limited
- Navigata Communications, 2009 Inc.
On May 11, 2017 Bell responded to the TNW proposal by refusing TNW’s request citing amongst other things, that TNW did not provide any details on how it intended to ensure that its customers only used Bell services on an incidental basis and not a permanent basis. The response also requested answers to approximately 30 questions and noted that upon receipt of these answers, Bell “will consider such information and provide a further reply”. On June 14, 2017 TNW provided detailed responses to all Bell’s questions including technical specifications and complete support for TNW compliance with the incidental roaming provisions of CRTC 2017-56.
Also, at paragraph 13, TNW Wireless stated the following:
On January 30, 2017 Telus responded to the TNW letter with a request to provide answers to a questionnaire of some 25 items covering technical aspects, managerial structure, ownership structure, and customer profile. On February 1, 2017 TNW provided Telus with detailed responses to all its questions.
Provide a copy of 1) Bell’s questions, 2) TELUS’ questionnaire, and 3) TNW Wireless’ responses.
- Explain what this “deemed transfer” refers to, and confirm whether the transfer process is now completed.
- If the transfer is completed, provide supporting documentation.
- If the transfer is not completed, provide any documents that can support the statement (e.g. copies of emails) that the transfer has been requested and is “in the queue”. Also, indicate if there is a formal or informal timeline for the processing of the transfer and, if any, provide details of or a copy of that timeline.
- Specify which spectrum licences TNW Wireless holds.
- Provide supporting documentation that the spectrum licenses mentioned in a) are held by TNW Wireless.
- Provide supporting documentation that the renewed spectrum licenses identified in a) were provided by ISED.
- Confirm whether the spectrum licences currently held by TNW Wireless are currently being used by TNW to provide telecommunications services to the public for compensation.
- Identify any cellular towers and/or sites that are owned by TNW wireless.
- Identify any cellular towers and/or sites that are operated by TNW wireless.
- Identify which of these cellular towers and/or sites are operational and currently being used to provide telecommunications services to the public for compensation.
- Identify any cellular towers and/or sites that are not owned or operated by TNW but are used by TNW Wireless to provide telecommunications services to the public for compensation.
- Explain the rationale for connecting to your core network via BTS and licensed spectrum rather than via direct IP connectivity to your core.
- Provide details on the benefits of this approach. For example, are there services that can only be provided using the company’s approach?
- Explain in detail how the traffic from remote customers is retransmitted over TNW Wireless’ RAN. How does this affect the capacity on the company’s RAN when multiple remote users are connected?
- Explain whether remote customers connect to the same cellular network used by TNW Wireless cellular subscribers in TNW Wireless Home Network footprint or whether they are connected at specific towers.
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