Telecom - Commission Letter addressed to Philippe Gauvin (Bell Canada)
Ottawa, 22 July 2022
Our reference: 8000-N1-202204923 and 8020-1/22
BY EMAIL
Philippe Gauvin
Assistant General Counsel
Bell Canada
Floor 19
160 Elgin Street
Ottawa, Ontario K2P 2C4
bell.regulatory@bell.ca
RE: Request for Information – Confidential
Philippe Gauvin:
This letter sets out confidential requests for information (RFIs) directed towards Bell Mobility with respect to certain of its services. At this time, these questions are being asked for the general purpose of administration of the Telecommunications Act. This letter and any subsequent correspondence may be added to the public record of a proceeding in the future should it be determined that the information is relevant to the Commissioners’ 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 responses to the questions in this letter are due by 29 July 2022.
Confidential information
At this time, the questions posed in this letter are being maintained in confidence. 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
Fiona Gilfillan
Executive Director, Telecommunications Sector
Attach, (1)
APPENDIX 1
Text indicated by # text # is confidential.
#
Context
Telesat informed Commission staff of issues with its Anik F2 satellite.
Telesat confirmed to Commission that it has also informed Bell Mobility of these issues.
Questions for Bell Mobility
Telesat indicated that some services presently supported on the satellite will be adversely impacted as early as February 2023, while others will degrade over time (depending on the size of the antennas transmitting and receiving signals from the satellite).
Telesat informed the Commission that Bell Mobility’s services – public safety and emergency – that currently use the Anik F2 satellite as transport in Ontario may be “adversely impacted” as early as December 2023.
Emergency services
Identifying risk of adverse impacts
- Provide a complete explanation of how Bell Mobility’s public safety and emergency services in Ontario are at risk of being adversely impacted. In your response, specifically address whether the following may be impacted:
- access to 9-1-1
- access to public alerts
- your enterprise customers that provide public safety and emergency services
Identifying services or customers more at risk of adverse impacts
- Are certain of the public safety or emergency 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.
9-1-1
- Provide a complete explanation of any potential impacts the degradation of the Anik F2 satellite may have on continued access to 9-1-1 in affected regions.
- Provide an overview of your risk mitigation strategy to address these impacts and ensure all 9-1-1 emergency requests and associated data originating from devices on its network are successfully delivered to the 9-1-1 network. Specifically address the following, along with any other information you deem relevant:
- Detailed timeline for overall risk mitigation strategy
- All technical solutions under consideration (including associated costs and timelines)
- Notification to customers
- Whether Bell Mobility is collaborating with (a) 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 customers
Enterprise customers that provide public safety and emergency services
- Provide a complete explanation of any potential impacts the degradation of the Anik F2 satellite may have on enterprise customers that provide public safety and emergency services.
- Provide an overview of your strategy to ensure continued access to emergency services in affected communities.
National public alerting system
- Provide a complete explanation of any potential impacts the degradation of the Anik F2 satellite may have on the continued provision of public alerts via the National Public Alerting System (NPAS), including wireless public alerting (WPA).
- Provide an overview of your strategy to mitigate and address these impacts and ensure continued access to public alerts in affected communities.
Impact on Bell Mobility’s other services and customers
Identifying who is at risk of adverse impacts
- Are any other Bell Mobility services (e.g. mobile wireless, Internet, home phone) provided elsewhere in Canada (e.g. the Far North) at risk of adverse impacts due to the degradation of the Anik F2 satellite? If so, please describe in detail how these may be impacted.
- a) If applicable, 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
- b) If applicable, list the enterprise 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)
- industry/service type (e.g. hospital/medical services, government, education, power generation, mining)
- c) If applicable, 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
- If other Bell Mobility services (e.g. mobile wireless, Internet, home phone) are affected, 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.
- If other Bell Mobility services (e.g. mobile wireless) are affected, are certain communities, regions 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.
Risk mitigation
- Describe any technical challenges that Bell Mobility may face in adapting its network, including, but not limited to its satellite ground stations, to ensure continued connectivity for its telecom customers in affected regions.
- Provide an overview of Bell Mobility’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 you deem relevant:
- Detailed timeline for overall risk mitigation strategy
- All technical solutions under consideration (including associated costs and timelines)
- Notification to customers
- Whether Bell Mobility is collaborating with (a) 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 customers
- Explain how your new risk mitigation strategy is different from previous plans to ensure network resiliency. If applicable, provide an overview of your previous plan to ensure continued connectivity.
#
End of questions
- Date modified: