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

Ottawa, 17 July 2023

Our reference: 8740-N1-202304278

VIA EMAIL

Imran Khan
Chief Financial Officer & Vice-President
Northwestel Inc.
10th Floor 5201 Franklin Ave #100
Yellowknife, NT X1A 2P1
regulatoryaffairs@nwtel.ca

Subject: Northwestel Inc. Tariff Notice 1182 - Terrestrial Enterprise Internet Services

Dear Imran Khan:

On 29 June 2023, the Commission received an application from Northwestel Inc. (Northwestel), under Tariff Notice (TN) 1182, proposing changes to Northwestel’s General Tariff CRTC 3001 – Item 1736 – Terrestrial Enterprise Internet Services, to modify the definition of “Reserved Internet Protocol” (Reserved IP) and the service description for Enterprise Performance Service.

Paragraph 28(1) (a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure provides that the Commission may require parties to file information or documents where needed.

Northwestel is requested to provide comprehensive answers, including rationale and any supporting information, to the attached questions by 31 July 2023.

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 on why the relevant information qualifies for designation as 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.

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. The Commission requires the response or other documents to be submitted electronically by using the secured service “My CRTC Account” (Partner Log In or GCKey) and filling the “Telecom Cover page” located on this web page. 

A copy of this letter and all subsequent replies will be added to the public record of this proceeding.

Yours sincerely

Original signed by

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector

c. c.: Emily Fraser, CRTC, (873)-353-6549, emily.fraser@crtc.gc.ca

Attach. (1)

Request for Information

Northwestel is proposing to change the definition of Reserved IP from the following:

“"Reserved Internet Protocol (Reserved IP)" refers to Dynamic Host Configuration Protocol (DHCP) reservation is a feature in the DHCP server that allows the Company DHCP administrators to reserve one or more IP addresses for particular mission-critical devices only. In order to configure DHCP reservation, the administrators are required to know the physical addresses (a.k.a. MAC addresses) of the target devices for which the particular IP addresses are to be reserved. Once the MAC addresses are known, Company administrators can then reserve the appropriate IP addresses by mapping them with the MAC addresses.”

To:

“"Reserved Internet Protocol (Reserved IP)" refers to one or more public IP addresses assigned for the exclusive use of the customer.”

In its letter, Northwestel submitted that this change would more accurately reflect Reserved IPs provided to enterprise customers.

  1. Explain how the proposed definition was determined and why it would more accurately reflect the Reserved IPs provided to enterprise customers than the existing definition.
  2. Does this proposed change to the definition of Reserved IP reflect any changes to the way that enterprise customers would administer their Reserved IP? If so, describe these changes.
  3. Why is Northwestel proposing this change at this time? Please include any relevant events, circumstances, or customer communications that may have prompted it.
  4. The existing definition requires Northwestel to know the Media Access Control (MAC) addresses of the devices for which the IP addresses are to be reserved. The proposed definition eliminates this requirement. Please explain how the IP reservation will be carried out in absence of MAC addresses and provide detailed mapping of the end-to-end process, identifying the roles and responsibilities of Northwestel and the customer in the IP reservation.
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