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Telecom - Staff Letter addressed to the Distribution List

Ottawa, 16 October 2024

Our reference: 8000-C12-202400282, 8663-T66-202402246

BY E-MAIL

Distribution list

Subject: TELUS Communications Inc., Part 1 Application to propose long-term connectivity options in three regions in British Columbia, Requests for information – 16 October 2024

On 1 May 2024, TELUS Communications Inc. (TELUS) filed a Part 1 application to propose long-term connectivity options in three regions in British Columbia, in response to its pending loss of access to 3.5 GHz spectrum in these regions. This will impact customers located in the following communities in British Columbia: Leading Hill and Espinosa in the Tahsis exchange, Nemiah Valley and the Xeni Gwet’in First Nations in the Alexis Creek exchange, and Red Lake, Tranquille Valley, Heller Creek and Green Stone Mountain in the North Kamloops exchange. TELUS stated that it is losing access to the 3.5 GHz band due to changes in spectrum policy instituted by Innovation, Science and Economic Development Canada (ISED) to transition this band of spectrum for use by mobile wireless services. TELUS identified alternative connectivity options (i.e. satellite-based VoIP services provided by other service providers) and proposed several options for network builds in these exchanges that would require funding.

This letter sets out questions (also called requests for information or RFIs) related to TELUS’ Part 1 application. Commission staff would appreciate input from the communities impacted, but their responses are not mandatory.

Responses to the questions in this letter are due by 29 October 2024.

Parties may then file comments in response to the RFI responses by 1 November 2024.

TELUS will then have an opportunity to file a reply by 6 November 2024.

Context

These RFIs will allow Commission staff to develop the record of TELUS’ application, update certain information, and address other gaps in the record collected to date.The questions are organized by appendices, as follows:

Appendix 1 sets out questions for TELUS. These include questions where Commission staff requests that TELUS work together with ISED to prepare a response.

Appendix 2 sets out questions for Xplore and Starlink.

Appendix 3 sets out questions for the Xeni Gwet’in First Nation Government, the Village of Tahsis, and the Municipality of Kamloops.

Filing Instructions

In your responses, if specific information is not available, provide estimates and assumptions.

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 of 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.: Simon Wozny, CRTC, simon.wozny@crtc.gc.ca
Loïc Yves Abena Fouda, CRTC, loicyves.abenafouda@crtc.gc.ca
Iva Jurisic, CRTC, iva.jurisic@crtc.gc.ca
Jordan Wegner, CRTC, jordan.wegner@crtc.gc.ca

Attachment (4) Appendix 1-2-3 & Distribution list.

Appendix 1: Questions for TELUS

  1. [TELUS] In its Part 1 application, TELUS makes several statements regarding its exchanges with ISED. Please provide supporting documentation regarding these exchanges, including copies of all correspondence with ISED related to the repurposing of 3.5 GHz spectrum band, including but not limited to any: notice of termination; request for extension; or authorization to extend TELUS’ use of 3.5 GHz spectrum.
  2. [TELUS] In response to question 3 of an RFI issued by Commission staff on 15 February 2024, TELUS stated that it could offer its business VoIP service to residential customers who have or wish to obtain Internet access from an alternative provider.
    1. Describe what service TELUS could provide, and what value it could bring customers in comparison to any other VoIP offering? Will TELUS commit to providing this service?
    2. How soon could TELUS make this service available?
    3. How affordable could TELUS make this service? List an estimate of all costs to the customer.
    4. Describe the quality of the voice services that it could make available, including how appropriate it may be to support access to emergency services, including NG911 and 988 services.

  3. [TELUS] In its Part 1 application, TELUS indicated that its plan to transition customers to alternative service providers included fair compensation so that customers could attain approximately one year of an alternative service. In its reply, PIAC noted that alternative satellite-based VoIP options raise considerable affordability concerns, and despite TELUS’ compensation to affected customers, it does not mean that all customers in these communities would be able to sustain such an expense beyond the first year of service. Also, a resident from Tranquille Valley, BC stated that: “We also have many residents for whom finances are a concern. They have been forced to move to a much more expensive communication system (with ongoing subscription expense-mine is $140/month), and in some cases have simply decided to forego communications at all-leaving them isolated.”

    Is TELUS prepared to provide additional compensation to its affected customers to ensure that they are able to continue to access voice services in TELUS’ incumbent local exchange territory? If so, please discuss what compensation it is prepared to provide and for how long. If not, how else is TELUS prepared to support the ongoing availability and affordability of voice services and fulfil its obligation to serve in its incumbent local exchange territory?

  4. [TELUS] TELUS has known about the discontinuation of the SR500 System since 2009, and the loss of their spectrum band authorization since at least 2019. During this period, has TELUS sought funding to build networks in the relevant communities from ISED’s Universal Broadband Fund, the government of British Columbia’s Connecting Communities BC program, or any other funding programs? If so, please provide details regarding what was proposed and the outcome. If not, why not?
  5. [TELUS] In its Part 1 application, TELUS described a microwave-based option based on Digital Subscriber Line Access Multiplexer (DSLAM) technology for North Kamloops that would be available to customers that have a copper last mile. TELUS indicated it would not be available for the four customers that have wireless direct-to-house last mile technology.
    • How many of the original 64 customers could be connected via this option?
    • What does TELUS propose for the four customers who do not have access to a copper last mile?
    • Provide more detail on deploying this new network. Include all the proposed steps from start to finish, and include time estimates for each.
    • Would the network connect all four North Kamloops communities listed in TELUS’ application? How many potential customers are there in each community?
    • Discuss the benefits and drawbacks of this approach, including with regard to the quality and reliability of voice services, and access to emergency services, compared to 1) the existing SR500 solution; and 2) satellite VoIP.
  6. [TELUS]: In its Part 1 application, TELUS also described a fibre to the home option for North Kamloops. It stated: “Fibre-based solutions [in North Kamloops] would require the supply of 45 kilometres of new transport fibre and support infrastructure, plus last mile fibre. Such a build would further require permits for access to Crown and First Nations land, as well as completing the environmental assessment process.”
    • Provide more detail on deploying this new network. Include all the proposed steps from start to finish, and include time estimates for each.
    • Would the fibre network connect all four North Kamloops communities listed in TELUS’ application? How many potential customers are there in each community?
  7. [TELUS] One intervenor stated: “I noticed that for the North Kamloops area the break down on alternatives did not include a cell phone tower. I know that our community association has been trying to work with TELUS for over a decade to get a tower installed but every time they've been told it's just too expensive. I feel that long term a cell phone tower is the most reasonable solution.”
    • Has TELUS considered building cell phone towers in the Tahsis and North Kamloops communities? Why or why not?
    • Discuss TELUS’ engagement with the community association in North Kamloops, as described by the intervenor. What concerns were raised by the community association, how did TELUS address them, and what was the outcome?

Appendix 2: Questions for Xplore and Starlink

  1. [Xplore, Starlink] Discuss how your satellite Broadband services can be used to access satellite VoIP services in Leading Hill and Espinosa in the Tahsis region, Nemiah Valley and the Xeni Gwet’in First Nations in the Alexis Creek region, and Red Lake, Tranquille Valley, Heller Creek and Green Stone Mountain in the North Kamloops region (together, the “relevant communities”) with regard to the following factors:
    • How does this service support satellite VoIP services? What features do these services include?
    • Is anything required in addition to your satellite Broadband services to access satellite VoIP services?
    • What is the monthly cost to customers to access satellite VoIP services using your Broadband satellite services? Include the price of your services, as well as any add-on services required to use it for satellite VoIP, and any hardware that a customer must purchase.
    • Do you have any plans to discontinue your provision of these services in the relevant communities?
    • Do you provide voice services directly in the relevant communities? Do you provide any other telecommunications services that can support voice services? If so, please describe each of those services with regard to the above factors as well.
  2. [Xplore, Starlink] Regarding your satellite Broadband Internet services:
    • How many subscribers do you currently have in each of the relevant communities? Indicate how many are residential, and how many are business subscribers.
    • Discuss how appropriate your satellite Broadband services are for accessing emergency services such as NG911 and 988 via satellite VoIP services. Provide performance estimates of the Broadband satellite services you provide in the relevant communities that may impact the reliability of accessing emergency services (i.e. availability, download speed, upload speed, packet loss, and latency). Discuss how these could be affected by increased usage over time and potential bandwidth constraints, particularly if more users transition to these services in the relevant communities.
    • How does poor weather and cloud cover impact your Broadband satellite services and/or satellite VoIP provided over those services?
    • How often does your Broadband satellite service available in the relevant communities experience outages? How long do they last, on average? What are their causes, and what steps do you take to mitigate and address these outages? Are any additional steps taken to ensure continual access to emergency services? Discuss these with regard to their impact on access to satellite VoIP services supported by your satellite Broadband services.
    • For any voice services that you provide directly, or any other services that you provide that can support voice services, please answer the above questions with respect to those services as well.

Appendix 3: Questions for Communities

  1. [Xeni Gwet’in First Nation Government, Municipality of Kamloops, Village of Tahsis] Describe your community’s experience with TELUS’ engagement efforts regarding the planned disconnection of TELUS’ telephone services. Has TELUS addressed your community’s concerns, and if so, how? What could TELUS have done better, if anything?

Distribution List:

TELUS: molly.samuelson@telus.com; regulatory.affairs@telus.com;
SpaceX: ted.price@spacex.com; shea.boyd@spacex.com; cassandra.heyne@spacex.com
Xplore: legal@xplore.ca; cindy.wallace@xplore.ca
Xeni Gwet’in First Nation Government: roger@xenigwetin.ca; xenimanager@gmail.com
Village of Tahsis: mayor@villageoftahsis.com; reception@villageoftahsis.com
Municipality of Kamloops: mayor@kamloops.ca 

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