Search

Telecom - Commission Letter addressed to Imran Khan (Northwestel Inc.)

Ottawa, 14 November 2022

Our references: 1011-NOC2022-0147, 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

RE: Request for information – Update on the Anik F2 satellite and Northwestel’s satellite-dependent services in the Far North

Imran Khan:

The purpose of this letter is to support the development of a complete and timely record on the Anik F2 satellite issue and its impact on Northwestel’s services in the Far North for the proceeding initiated by Telecom Notice of Consultation 2022-147, Telecommunications in the Far North, Phase II (TEL 1011-NOC2022-0147 ).

Context

Northwestel uses Telesat’s Anik F2 satellite to provide telecommunications services in satellite-dependent communities (SDCs) in the Far North.

On 13 July 2022, Commission staff became aware of a technical issue that Telesat satellite Anik F2 is experiencing that may affect communications and will shorten the service life of the satellite.

To obtain additional information on the impact on Northwestel of the Anik F2 technical issue, Commission staff issued requests for information (RFI) to Northwestel on 22 July 2022. Given that the Anik F2 situation had not yet been disclosed to the public, Commission staff issued those RFIs under confidential cover letter. Subsequently, on 29 July 2022, Northwestel responded to Commission staff’s RFIs. Given that the Anik F2 technical issue had not yet been disclosed to the public, Northwestel submitted its responses in confidence.

On 5 August 2022, Telesat disclosed to the public, via conference call during which it reported financial results, the technical issues affecting its Anik F2 satellite. On 10 August 2022, following Telesat’s public disclosure of the Anik F2 technical issues, Commission staff issued a letter to Northwestel, indicating that it considered that the information obtained via the confidential RFIs issued on 22 July 2022 should form part of a public record related to the Anik F2 satellite.

On 19 August 2022, Northwestel’s responses to the confidential RFIs issued on 22 July 2022 were added to the public record (i.e. TEL 8000-N1-202204923) noted in Commission staff’s letter of 10 August 2022. On 9 September 2022, Commission staff issued further RFIs to Northwestel. The  responses to those RFIs were submitted by Northwestel on 23 September 2022. 

As set out in a letter dated 29 September 2022, the Commission stated that to ensure a complete and timely record on the Anik F2 issue for the Telecom Notice of Consultation 2022-147 proceeding, relevant information on the issue will be requested from parties in an upcoming request for information.

Request for information

Northwestel is to review the questions in Appendix 1 to this letter, which Northwestel previously answered in August and September 2022 on the record of TEL 8000-N1-202204923.

Commission staff requests that:

  1. Northwestel provide an update to its response to the questions in Appendix 1, where applicable, by 1 December 2022; and,
  2. In order to ensure a complete and timely record on the Anik F2 issue, Northwestel provide ongoing monthly updates due on the first day of each month on the Anik F2 issue, and how it is impacting Northwestel’s short, medium, and long-term satellite solutions. Northwestel is also to inform the Commission when a replacement satellite has been positioned in the orbital slot currently occupied by Anik F2 and Northwestel’s services have been successfully migrated to the replacement satellite. Commission staff will determine when monthly updates are no longer necessary.

Additional information

In regards to request 1) above, Northwestel should clearly indicate the specific questions for which it is providing updates to its responses, if any.

Further, where Northwestel is not updating a response, Northwestel is not required to resubmit information that it has already provided. In cases where Northwestel is not providing an update to a response that it has already provided, the most current response that was provided on the record of TEL 8000-N1-202204923 will be added to the record of Telecom Notice of Consultation 2022-147.

Parties to Telecom Notice of Consultation 2022-147 are invited to address Northwestel’s responses to the Anik F2 issue in their further comments, which are due by 10 February 2023.

A copy of this letter will be placed on the two public records referenced above. Subsequent correspondence from Northwestel in relation to this letter will only be added to the record of Telecom Notice of Consultation 2022-147. All parties are encouraged to monitor the record of Telecom Notice of Consultation 2022-147 for further updates on this matter as it relates to Northwestel.

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

Lisanne Legros
Director, Telecommunications Networks Policy

c.c:
Nicolas Gatto, CRTC, nicolas.gatto@crtc.gc.ca
Celia Millay, CRTC, celia.millay@crtc.gc.ca

Distribution List:

Canadian Internet Registration Authority: Georgia.Evans@cira.ca
Competitive Network Operators of Canada: regulatory@cnoc.ca; regulatory@tacitlaw.com
Council of Yukon First Nations: Peter.Turner@cyfn.net
Daniel Sokolov: daniel@falco.ca
Dominion Gold Resources: dean@dominiongold.ca
Eeyou Communications Network and James Bay Cree Communications Society: c.melancon@eeyou.ca
First Mile Connectivity Consortium: info@firstmile.ca
First Nation of Na-Cho Nyak Dun: lisa@badenhorst.ca; adrienne.hill@nndfn.com
G & V Global Developments: gvdevnt@gmail.com
Government of the Northwest Territories: telecom_reg@gov.nt.ca; bram@32M.io;
Government of Yukon: sean.mcleish@yukon.ca
Hamlet of Resolute Bay: cedo@resolute.ca
Iristel Inc.: regulatory@iristel.com; regulatory@tacitlaw.com
IRP Consulting: tosh@irpotential.com
Kluane First Nation: lisa@badenhorst.ca
Kwanlin Dün First Nation: David.Burke@kdfn.net
Lorraine Rousseau: RousseLo@psac-afpc.com
National Indigenous Economic Development Board: daniel.hughes@sac-isc.gc.ca
Northern Rockies Regional Municipality: mgilbert@northernrockies.ca
Northwestel Inc.: regulatoryaffairs@nwtel.ca
Nukik Corporation: aaudouin@nukik.ca
Public Interest Advocacy Centre: jlawford@piac.ca
Rob Hopkins: media@openbroadcaster.com
Shadhäla Äshèyi yè Kwädän (Champagne and Aishihik First Nations): tbuzzell@cafn.ca
SSi Canada: regulatory@ssicanada.com
TELUS Communications Inc.: regulatory.affairs@telus.com
Tr'ondëk Hwëch'in Government: aaron.woroniuk@trondek.ca
Yukon Utilities Consumers' Group: rrondeau@northwestel.net

APPENDIX

Context

Commission staff has assessed the request for information (RFI) questions issued on 22 July 2022 and 9 September 2022, and considers that the questions in this appendix are relevant to issues in scope of Telecom Notice of Consultation 2022-147.

For the purposes of this RFI, the question numbers are the same as they originally appeared in the RFI letter of 22 July 2022 and in the RFI letter of 9 September 2022.

RFI Questions from Letter of 22 July 2022

Impact on Northwestel’s services and customers

Identifying who is at risk of adverse impacts
  1. List the communities that you serve using the Anik F2 satellite, and identify those that are at risk of being adversely impacted by the degradation of the Anik F2 satellite. Provide the following information for each community:
    • community name
    • province or territory
    • services you offer
    • # of subscribers
  1. List the wholesale customers that you serve using the Anik F2 satellite, and identify those that are at risk of being adversely impacted by the degradation of the Anik F2 satellite. Provide the following information for each customer:
    • customer name
    • location(s)
    • affected wholesale services
Identifying services or customers more at risk of adverse impacts
  1. Are certain communities or customers that you serve more at risk of
    • experiencing adverse impacts sooner than others?
    • experiencing more significant adverse impacts? If so, explain which and why.
  2. Are certain of the telecom services that you provide more at risk of
    • experiencing adverse impacts sooner than others?
    • experiencing more significant adverse impacts? If so, explain which and why.
Risk mitigation
  1. Describe any technical challenges that Northwestel may face in adapting its network, including, but not limited to its satellite ground stations, to ensure continued connectivity for retail telecom customers.
  2. Provide an overview of 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 Northwestel deems relevant:
    • Detailed timeline for overall risk mitigation strategy
    • All technical solutions under consideration (including associated costs and timelines)
    • Notification to customers
    • Whether Northwestel is collaborating with (a) Bell Canada or other Bell companies and/or (b) non-Bell companies (TSPs or otherwise) on risk mitigation and/or to ensure service continuity for impacted services or customer.
  3. Explain how your new risk mitigation strategy is different from previous plans to ensure network resiliency. If applicable, provide an overview of your previous plans to ensure continued connectivity.

RFI Questions from Letter of 9 September 2022

  1. 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:

  1. 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.

  1. 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:

Date modified: