Telecom - Commission Letter addressed to Imran Khan (Northwestel Inc. (Northwestel))
Ottawa, 9 September 2022
Our reference: 8000-N1-202204923
BY EMAIL
Imran Khan
Chief Financial Officer & Vice-President
Northwestel Inc. (Northwestel)
3rd Floor, 301 Lambert Street
Whitehorse, Yukon - Y1A 4Y4
regulatoryaffairs@nwtel.ca
Subject: Further Request for Information – Telesat Anik F2 Matters
Imran Khan:
This letter sets out further requests for information (RFIs) directed towards Northwestel in regards to its responses to RFIs that were issued by Commission staff on 22 July 2022, as filed with the Commission on 29 July 2022, and then re-filed on 19 August 2022. At this time, these questions are being asked for the general purpose of administration of the Telecommunications Act. A copy of this letter and any subsequent correspondence will be added to the public record: TEL 8000-C12-202204923.
This letter and any subsequent correspondence may also be added to the public record of other proceedings in the future should it be determined that the information is relevant to the Commission’s determinations. If that occurs, parties to any relevant proceeding would be notified of the addition and given the opportunity to comment on the responses.
Your response to this request is due 23 September 2022.
Confidential information
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, parties may designate certain information as confidential. A party designating information as confidential must provide a detailed explanation on 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 party 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.
Sincerely,
Original signed by Ian Baggley for
Fiona Gilfillan
Executive Director, Telecommunications Sector
APPENDIX 1
Context
Commission staff issued RFIs to Northwestel on 22 July 2022.
Responses to those RFIs were filed by Northwestel in confidence on 29 July 2022, and then re-filed on 19 August 2022 to the public record referenced in this letter.
Further questions for Northwestel
- In response to Question 7 of Commission staff’s RFIs of 22 July 2022, Northwestel indicated that “We are not able to provide at this time a detailed timeline or costing information as the technical solutions have not been finalized.”Footnote1
Provide an update on Northwestel’s risk mitigation strategy to ensure continued connectivity for customers (retail, wholesale, and enterprise) that it serves in affected regions. Specifically address the following, along with any other information that Northwestel deems relevant:
- Discuss whether a technical solution or technical solutions have been finalized;
- Provide a timeline for implementing any technical solutions that Northwestel may be pursuing; and,
- Provide an estimate of the costs associated with any of the technical solutions being pursued.
- In response to Question 4 of Commission staff’s RFIs of 22 July 2022, Northwestel indicated:Footnote2
The net effect of all this [the satellite moving outside of its intended stationary spot] is short duration outages starting as early as February 2023 and growing to several hours per day in March of 2023.
and
The 11 communities in the western Arctic (Northwest Territories, Old Crow and British Columbia) are most at risk of a significant impact because the Anik F2 satellite is used for all telecommunications services to those communities (except local voice). If Anik F2 failed tomorrow, a Northwest Territories community such as Ulukhaktok would lose all (except local) telecommunications services including long distance, 911, DSL, enterprise data, connection to the RCMP, the local health center and school.
Discuss whether the timelines for implementing the technical solution or technical solutions being pursued will entirely prevent the outages noted in Northwestel’s response, or whether its customers should still anticipate such outages.
- In response to Question 7 of Commission staff’s RFIs of 22 July 2022, Northwestel indicated:Footnote3, Footnote4
We plan to migrate all long distance traffic in all 25 Nunavut communities from Anik F2 to a different Telesat satellite, the Telstar 19 Vantage (T19V). We # # already have dishes in all 25 Nunavut communities that point to the T19V. All of Bell Mobility's traffic and Northwestel's DSL traffic is already carried on T19V. It is within Northwestel's control to redirect the long distance voice traffic for these 25 communities from Anik F2 to T19V (i.e., does not require any actions from Telesat even though it is their satellite). Although there are some areas where there is already congestion on T19V, we anticipate that the addition of voice traffic will not materially alter the amount of bandwidth we offer consumers in those impacted communities and we will ensure that long distance traffic is prioritized.
and
We are prepared to work with both our enterprise retail and wholesale customers to determine alternatives. T19V may be a viable alternative in some cases but requires IP-based solutions – which at least in the case of our own retail customers they are currently not using. To avoid relying on Anik F2, we will encourage the impacted customers to upgrade to IP solutions that can be provided over T19V.
Specifically address the following, along with any other information that Northwestel deems relevant:
- Provide information on whether any traffic congestion studies have been conducted to understand the extent of the impact on existing T19V traffic (specifically Northwestel DSL traffic and Bell Mobility traffic) due to the addition of long distance and enterprise traffic from Anik F2;
- Specify how prioritizing Northwestel’s long distance traffic will affect Bell Mobility voice traffic on T19V, and whether any analysis has been done in this regard; and
- Discuss whether a determination has been made on the alternative(s) to Anik F2 for Northwestel’s enterprise retail and wholesale customers, and, if so, provide information on the alternative(s).
End of questions
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