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Telecom - Commission Letter addressed to the Distribution List

Ottawa, 29 June 2021

Our reference:  8621-C17-202002856

BY EMAIL

Distribution List

RE:  Part 1 Application filed by City Wide Communications requesting an Order directing Bragg Communications Inc. operating as Eastlink to move its TPIA POI from Pennant Point to the core of Halifax – Additional Requests for Information

As a result of information obtained in response to the revised requests for information dated 12th of May 2021 and subsequent submissions, and in order to assist the Commission in its analysis, staff requires additional information attached to this letter from Bragg Communications Inc. and City Wide Communications to complete the record.

The following process is established in relation to the requested additional information:

Where a document is to be filed or served by a specific date, the document must be actually received, not merely sent, by that date.

Please contact Marc Pilon (marc.pilon@crtc.gc.ca) at 819-997-4535 or myself (chris.noonan@crtc.gc.ca) at (873) 354-0359 should you have any questions in regards to this letter and requests for information.

Sincerely,

Original signed by

Chris Noonan
Director, Competitor Services & Costing Implementation
Telecommunication sector

c.c:    Marc Pilon, marc.pilon@crtc.gc.ca
Abderrahman El Fatihi, Abderrahman.elfaatihi@crtc.gc.ca

Attach (1)

Distribution List:

David Pothier, david@yourcitywide.com
Marielle Wilson, regulatory.matters@corp.eastlink.ca
Howard Slawner, regulatory@rci.rogers.com
Jeff Brownlee, regulatory@cnoc.ca
Andy Kaplan-Myrth, regulatory@teksavvy.ca

Request for Information

Eastlink

  1. In its revised Bragg (CRTC) 11September 2020-5 response, Eastlink submitted that one of the two locations in the core of Halifax identified by City Wide Communications as a potential TPIA POI is being used as an interim data center until migration to a new facility currently under construction. Further, it stated that there will be two major data centers in the Halifax Regional Municipality (Pennant Point and the new site under construction), which will allow them to migrate away from the existing aging and constrained facilities. For the new date center, provide the following information:
    1. The civic address of the new site in the Halifax Regional MunicipalityFootnote1 .
    2. The distance between this new site and downtown Halifax (e.g. Spring Garden road and Barrington street intersection).
    3. Could this new site in the Halifax Regional Municipality support a competitor interface (i.e. POI) allowing competitors to connect to provide wholesale HSA service?  If yes, how would the company proceed to implement a POI at that location should such implantation take place?
    4. What would be a reasonable timeline for the company to implement and to operationalize a POI at this new site should the Commission require that a TPIA POI be implemented at this location?
    5. What would be a reasonable timeline for the company to conduct an efficient migration of all end-users of City Wide from existing Pennant Point POI to this new site should the Commission require that a TPIA POI be implemented at this location?
    6. In the 16 October 2020 reply comments, Eastlink indicated that, should City Wide choose to re-locate to a new POI, it did not intend to charge City Wide for costs associated with the implementation of a TPIA POI, excluding those charges under the tariff.  Should a TPIA POI be established at a new data centre, what costs would Eastlink be prepared to assume and what costs would it charge to an entity requesting migration from Pennant Point to that location?
  2. In its 14th of October 2020 letter, Eastlink indicated that it had engaged in ongoing discussions to resolve the issues between the parties that let to this dispute. As part of these discussions, Eastlink offered to move its POI to a location in the core of Halifax as requested by City Wide. In another letter dated 16 October 2020, Eastlink submitted that it cannot guarantee that it will be able to maintain the POI in this downtown location for the long term.
    1. Did Eastlink propose the new site under construction in the Halifax Regional Municipality as an alternative POI location, even if it would have to be done at a later date? If not, explain why not?  If yes, explain when was the proposal made and what specifics were provided.
  3. In paragraph 14 of its 25 June 2020 answer, Eastlink submitted that retail Internet traffic routinely traverses the Pennant Point data centre. For the period between the end of 2015 and early 2016:
    1. Specify what proportion of Eastlink’s total Nova Scotia retail Internet traffic was routed through Pennant Point.
    2. Did Pennant Point have any CMTS/CCAP equipment that was used to serve Eastlink’s retail Internet service end customers during that period? If yes, what percentage of Eastlink’s retail customers were served by such equipment?
  4. When was the plan to migrate equipment and customers from the core of Halifax to a new data center in the Halifax Regional Municipality initiated or first discussed internally? Have this new site been discussed with City Wide during the proceeding? If yes, provide details of what was revealed.

City Wide

  1. In its revised Bragg (CRTC) 11September 2020-5 response, Eastlink submitted that one of the two locations in the core of Halifax identified by City Wide Communications as a potential TPIA POI is being used as an interim data center until migration to a new facility currently under construction. Further, it stated that there will be two major data centers in the Halifax Regional Municipality (Pennant Point and the new site under construction), which will allow them to migrate away from the existing aging and constrained facilities.
    1. Under which conditions (such as distance from a City Wide point of presence, current transport alternatives and existing transport contract commitments, etc.) would the new facility being built in the Halifax Regional Municipality be a suitable location for the POI? The response should provide details and supporting rationale.
    2. In the event that the new data center would be located in an area generally closer to the core of Halifax and more closely aligned in the direction of  Halifax-Toronto and Halifax-Montreal  than is the current location at Pennant Point, what impact would this have on your response to question (a)?
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