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Telecom - Commission Letter addressed to Stan Thompson (Northwestel Inc. (Northwestel))

Ottawa, 10 May 2022

Our reference: 8646-N1-202108175

BY EMAIL

Stan Thompson
Chief Financial Officer & Vice-President
Northwestel Inc. (Northwestel)
3rd Floor,301 Lambert Street
Whitehorse, Yukon - Y1A 4Y4
regulatoryaffairs@nwtel.ca

Subject: Part 1 application filed by Northwestel Inc. dated 6 December 2021

Dear Stan Thompson:

Pursuant to section 37 of the Telecommunications Act,attached is a request for information (RFI) regarding the above-noted Part 1 application.

As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation as to 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 disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.

Responses to this request must be filed with the Commission by 19 May 2022. Parties may file comments strictly limited to the information provided in response to this RFI by 24 May 2022, and Northwestel may then file their reply to the comments by 30 May 2022.

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

Sincerely,

Original signed by

Lisanne Legros
Director, Telecommunications Networks Policy
Telecommunication Sector

c.c.: Nicolas Gatto, CRTC, nicolas.gatto@crtc.gc.ca
Simon Wozny, CRTC, simon.wozny@crtc.gc.ca
Salahuddin Rafiquddin, salahuddin.rafiquddin@crtc.gc.ca
Distribution List: chief@liidliikue.com ; cdo@watsonlake.ca ; mayor@hayriver.com ; mayor@yellowknife.ca ; Susan.Laramee@gwichintribal.ca ; office@ibew1574.ca ; admin@michaelconwaysolutions.ca ; daniel@falco.ca ; tosh@irpotential.com ; bill.kendrick@cityofdawson.ca ; Susan_Martin@gov.nt.ca ; regulatory@ssimicro.com ; john.mackenzie@telus.com ; jlawford@piac.ca ; nils.clarke@yukon.ca

Attach, (1)

Request for Information – Northwestel

  1. On the record of this proceeding, some parties expressed concern regarding the impact of the relief requested by NorthwestelFootnote1 in its application on existing and prospective competitors in the Far NorthFootnote2 other than Starlink. Parties have also noted that Northwestel has not proposed any measures to mitigate the impact on competition of its proposed relief. Comment on what measures Northwestel may be willing to take to facilitate existing and prospective competition in the Far North, or that may otherwise be appropriate, if the relief it has requested is granted. Parties commenting on Northwestel’s response may also propose any measures they consider appropriate. In particular, comment on:
    1. Would Northwestel be prepared to provide a flat discount to the tariffed rates for Wholesale Connect for as long as the temporary relief requested by Northwestel for retail internet services is in place? What would be an appropriate discount that would allow wholesale-based competitors to decrease their retail rates by an amount that is similar to the average retail rate reduction that Northwestel plans to introduce across all of its service offerings, over the period of time that the temporary relief is granted? Would a discount of 20% from the existing tariffed rates for Wholesale Connect be appropriate?
    2. On the record of this proceeding, the Government of Northwest Territories suggested “lowering the price floor to that of competitors in Northwestel’s serving area.” In reply, Northwestel indicated that even if it could set a price floor based on the retail rate for Starlink’s 150 Mbps service offering, there are no other service offerings to act as a price floor reference for the remainder of Northwestel’s terrestrial Internet portfolio.
      Could a price floor based on a suitable proxy for costing information in the assessment of retail tariff rates proposed by Northwestel help mitigate against concerns that those  retail rates could be predatory with respect to competitors other than Starlink? Propose a method for calculating a proxy price floor with justification or, if no method would be appropriate, justify your response.
    3. Provide any other relevant proposals that you consider could help mitigate the impact of Northwestel’s requested relief on existing and prospective competition in the Far North other than Starlink.
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