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Telecom - Commission Letter addressed to the Distribution List

Ottawa, 22 November 2022

Our reference: 1011-NOC2022-0147

BY EMAIL

Distribution List

Subject: Telecommunications in the Far North, Phase II, NoC 2022-147, Requests for information – 22 November 2022

This letter sets out questions (also called requests for information or RFIs) related to
the proceeding initiated by Telecommunications in the Far North, Phase II, Telecom Notice of Consultation CRTC 2022-147 (the Phase II Notice).

Specifically, this letter sets out questions for the following companies to obtain further clarification on responses to RFIs issued on 15 June 2022 and parties’ formal interventions, as well as to collect information to understand the wholesale services that may be available in the Far North from existing service providers:

Your responses to the questions in this letter are due by 12 December 2022.If you anticipate being unable to respond by the deadline, please advise us by 5 December 2022.

Context

On 8 June 2022, the Commission published the Phase II Notice.

In the Schedule and Procedure section of the Phase II Notice, the Commission indicated that:

Filing Instructions

Appendix 1 sets out RFIs for the following companies:

Questions for Ice Wireless & Iristel

Questions for Northwestel

Questions for SpaceX

In your responses to the questions set out in Appendix 1:

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.

Accessible formats for people with disabilities

The CRTC requires regulated entities and encourages all parties to file submissions in accessible formats (for example, text-based file formats that enable text to be enlarged or modified, or read by screen readers) for this proceeding.

To provide assistance in this regard, the CRTC has posted on its website guidelines for preparing documents in accessible formats.

In the event where submitted documents have not been filed in accessible formats, parties may contact the Public Hearings group to request that CRTC staff obtain those documents in accessible formats from the party who originally submitted the documents in question in an inaccessible format.

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

Yours sincerely,

Original signed by

Lisanne Legros
Director, Telecommunications Networks Policy
Telecommunications Sector

c.c.:
Nicolas Gatto, CRTC, nicolas.gatto@crtc.gc.ca
Celia Millay, CRTC, celia.millay@crtc.gc.ca
Iva Jurisic, CRTC, iva.jurisic@crtc.gc.ca
Simon Wozny, CRTC, simon.wozny@crtc.gc.ca
Filsan Gure, CRTC, filsan.gure@crtc.gc.ca
Rebecca Hume, CRTC, rebecca.hume@crtc.gc.ca
Karen Soriano Ley, CRTC, karen.sorianoley@crtc.gc.ca

Attach. (1)

Distribution List:

Appendix 1: Requests for information

1. Question for ICE Wireless & Iristel

Seeking updates to responses to 15 June 2022 RFIs

1.1 On 18 September 2022, Ice WirelessFootnote2 stated that it was unable to provide answers at that time to certain questions in the 15 June RFI letter:

Dues to ongoing technical issues, Ice Wireless was unable to provide this response on the 14 September 2022 deadline, and continues to be unable at this time to provide answers to questions related to subscriber numbers, revenue or other statistical data. Ice Wireless greatly regrets the delay and inconvenience that this may cause. Ice Wireless will provide answers to questions related to statistical data as soon as possible after the technical issue is resolved.

Ice Wireless is requested to provide:

  1. Answers to questions from the 15 June RFI letter related to subscriber numbers, revenue, or other statistical data; or,
  2. Provide an update on the technical issue as well as an estimated date of when Ice Wireless will provide answers to questions related to subscriber numbers, revenue or other statistical data from the 15 June RFI letter.

2. Questions for Northwestel

Overage fees paid by customers

2.1 In response to the 15 June RFI letter, Question 2.4, Northwestel submitted information regarding the number and percentage of terrestrial and satellite retail customers who paid overage fees in 2021.

  1. Provide the number and percentage of terrestrial and satellite retail customers who paid overage fees in each of the years 2017, 2018, 2019, 2020.
  2. Provide the available trend data for overage fees charged to (a) terrestrial and (b) satellite retail customers in 2022. Explain, with supporting rationale, whether you consider that the overage fees charged to customers in 2022 has decreased, remained the same, or increased.
  3. For 2021 only, provide the total number and percentage of retail customers who paid overage fees in 2021 by province/territory.
  4. For 2021 only, for customers who paid overage fees, provide an annual average of the overage fees paid by (a) terrestrial customers and (b) satellite customers.Footnote3

Revenues from overage fees

2.2 In response to the 15 June RFI letter, Question 2.4, Northwestel submitted information regarding the amounts it earned in overage fees from retail terrestrial customers and in overage fees from retail satellite customers in 2021.

  1. Provide the amount that Northwestel earned in overage fees from (a) terrestrial and (b) satellite retail customers in each of the years 2017, 2018, 2019, 2020.

Additional usage blocks purchased by customers

2.3 In response to the 15 June RFI letter, Question 2.4, Northwestel submitted information regarding the number and percentage of its terrestrial service customers who purchased additional usage blocks. Northwestel noted that this option is not applicable to satellite services. 

  1. Provide the number and percentage of terrestrial retail customers who purchased additional usage blocks in each of the years 2017, 2018, 2019, 2020.Footnote4
  2. Provide the available trend data for purchasing additional usage blocks in 2022. Explain, with supporting rationale, whether you consider that the purchase of additional usage blocks has decreased, remained the same, or increased in 2022.
  3. For 2021 only, provide the total number and percentage of retail customers who purchased additional usage blocks in 2021 by province/territory.
  4. For 2021 only, provide the amount that Northwestel has collected from fees for additional usage blocks.

Overage fees in relation to tariff changes during March to June 2020

2.4 In Telecom Order CRTC 2020-370, the Commission stated that “In March 2020, in order to alleviate increased Internet usage costs for customers resulting from the situation created by the COVID-19 pandemic, Northwestel Inc. (Northwestel) introduced a promotionFootnote5 to waive or reduce terrestrial residential Internet data usage charges for all residential cable and fibre-to-the-premises (FTTP) Internet packages. Furthermore, the company provided digital subscriber line (DSL) customers an extra 100 gigabytes (GB) of data usage in addition to their existing Internet monthly data usage allowance. The promotion, which was extended several times, expired on 30 June 2020.”

  1. Explain how the above-noted change to Northwestel’s tariff impacted the overage fees paid by terrestrial customers during March to June 2020.

Overage fees in relation to tariff changes since June 2020

2.5 In Telecom Order CRTC 2020-370, the Commission stated that “In its application, Northwestel proposed a more permanent solution to address the needs of consumers following the expiration of the promotional offerings for its terrestrial residential Internet services. Northwestel proposed to increase the usage allowance in certain residential and business cable, DSL, and FTTP Internet packages by 7% to 100%, without any corresponding increases in the retail rates. Northwestel submitted that it had observed a substantial year-over-year increase in DSL usage and an even larger surge in residential cable usage from January to April 2020. As a result, the company indicated that providing additional usage for the majority of its residential and business packages was required. Northwestel submitted that its proposal to increase data usage caps increases costs and reduces revenues for certain DSL services that are already offered at rates significantly below costs and that would not be able to pass a price floor test […] The Commission granted interim approval to the application in Telecom Order 2020-200.” The Commission gave final approval to the application in Telecom Order 2020-370.

  1. Explain how the above-noted change to Northwestel’s tariff impacted:
    • the overage fees that terrestrial customers have paid to Northwestel since June 2020;
    • the revenues Northwestel collected for overage fees since June 2020;
    • Northwestel’s overall revenues for terrestrial internet customers since June 2020; and
    • Northwestel’s internet traffic management practices (ITMPs) for terrestrial services since June 2020 (i.e. whether Northwestel introduced changes to its ITMPs in response to the increase in usage allowance).

The impact of a wholesale HSA service on Northwestel’s investments

2.6 At paragraph 269 of its formal intervention, Northwestel stated:Footnote6

We estimate that the introduction of wholesale HSA would reduce capital expenditures by approximately #  # per year due to a corresponding drop in revenue, and the impact would be felt most largely on discretionary capital projects. Potential projects that could be delayed or eliminated include:

  1. Provide supporting information, assumptions, and/or methodology used to estimate the decrease in revenue and corresponding reduction in capital expenditures indicated by Northwestel, as a result of the introduction of a wholesale HSA service.
  2. Discuss whether Northwestel’s statements at paragraph 269 of its formal intervention should be viewed as a commitment to complete projects within current or anticipated timelines or to ensure that potential projects are initiated, if Northwestel is not mandated to provide a wholesale HSA service as an outcome of this proceeding.

Northwestel’s estimated costs to provide a wholesale HSA service

2.7 At paragraph 494 of its formal intervention, Northwestel stated:Footnote7

The actual costs of creating a wholesale HSA service (which in this context would also include access to FTTP over GPON) are significant. Simply creating a wholesale HSA service, which would address about 69% of our terrestrial communities' population, could require an investment of over #      #. Supporting and designing two wholesale HSA services (i.e. a service on each of cable and FTTP infrastructure), as referenced above, could double the required investment to over #     #.

  1. Provide the methodologies and assumptions used to estimate the investment of designing the wholesale services over the cable and FTTP infrastructures referenced above.
  2. If Northwestel has developed Phase II cost studies for implementing the cable and FTTP wholesale HSA services in its operating territory, provide the cost studies, including the methodologies and assumptions used to estimate the costs.

3. Questions for SpaceX

LEO satellite operators currently providing telecommunications services in the Far North and wholesale services

Wholesale services means the provision of a telecommunications service or facility to a service provider, regardless of whether that service provider rebills the service or facility to another entity, or uses that service or facility internally to support the services it bills.

The provision of wholesale services primarily supports competition in various retail service markets, such as local phone, television, and Internet access service markets, by enabling competitors to access certain telecommunications facilities and network components from other facilities-based service providers, such as incumbent local exchange carriers (ILECs) and cable companies, so that competitors can extend their networks where necessary to provide their own services to consumers.

3.1 Considering the definition and description of wholesale services provided above, specifically address the following, along with any other information you deem relevant:

  1. Does Starlink currently provide any wholesale services to competitors in the Far North, or in any other region in Canada? If so, please list the services and provide all relevant details including, but not limited to, rates, speeds, bandwidth capacities, and terms and conditions.
  2. Does Starlink have any plans to provide any wholesale services to competitors in the Far North? If so, please list the services, along with a timeline of when the services are anticipated to be available, and all relevant details, including, but not limited to, rates, speeds, bandwidth capacities, and terms and conditions.

End of questions

2022-11-18
Date modified: