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Telecom - Staff Letter addressed to the Distribution List

Gatineau, 6 November 2025

Reference(s): 8638-N1-202503721; 8622-S93-202008482; 1011-NOC2020-0367; 1011-NOC2022-0147

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Distribution List

Subject: Part 1 Application Seeking Approval of Proposed Configurations for an Ethernet-based Layer 2 Wholesale Connect Service by Northwestel Inc., Request for Information – 6 November 2025

The Commission is currently considering the above referenced Part 1 Application from Northwestel Inc. (Northwestel) seeking approval of proposed configurations for an Ethernet-based Layer 2 Wholesale Connect Service in the Far North. This application is a follow-up to Telecom Regulatory Policy CRTC 2025-9, Telecommunications in the Far North, where the Commission directed Northwestel to implement certain configuration changes for Wholesale Connect and to file proposed configurations for approval.

Pursuant to section 37 of the Telecommunications Act, the Commission may require any person to submit information that is necessary for the administration of the Act.To help develop a fulsome record and assist the Commission in its assessment of the Part 1 application, parties are to file responses to the questions included in the appendix below by 6 March 2026, serving their responses on the other parties to this letter by the same date. All parties will have until 27 March 2026 to comment on the request for information (RFI) responses. These comments must be limited to only the new information provided in the RFI responses.

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.

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
Jordan Wegner, CRTC, jordan.wegner@crtc.gc.ca
Michael Holmes, CRTC, michael.holmes@crtc.gc.ca
Ben Jones, CRTC, ben.jones@crtc.gc.ca
Vish Iyer, CRTC, vish.iyer@crtc.gc.ca

Attachment (2) – Appendix 1-2 & Distribution list.

Appendix 1: Questions for Northwestel, Iristel, SSi, and Telus

Northwestel

  1. In its Part 1 application, Northwestel indicated that using a Multi-Protocol Label Switching (MPLS) network to provide enhanced network reliability and redundancy would be preferred over a pure dedicated bandwidth approach for the new Ethernet-based Layer 2 Wholesale Connect Service (L2-WCON). Northwestel also indicated that it had discussions with Iristel and SSi during which it explained the benefits of using a MPLS network as the basis of the service, as opposed to the much costlier and limiting option of pure dedicated bandwidth network solution.

    Paragraph 8 of Northwestel’s Reply comments states that:

    To provide the opportunity to achieve near-dedicated bandwidth functionality, we have introduced in L2-WCON the option to subscribe to up to 100% class of service (CoS) at Medium, High or Highest CoS or up to 100 Mbps per site, whichever is lower. We believe that this negotiated solution balances the competing priorities of functionality (for example, providing dedicated bandwidth via CoS up to 100 Mbps and utilizing the redundancy and reliability of the MPLS network to support the service) and cost (a fully dedicated service would be significantly more expensive to the wholesale customer).
    1. Please describe the difference between the MPLS network approach versus a pure dedicated bandwidth approach to providing the new service.
    2. What are the benefits of using a MPLS network? In what ways is a pure dedicated bandwidth approach limiting?
    3. In its intervention, Telus noted that public sector customers desire dedicated access for privacy and security reasons. Does Northwestel’s proposed MPLS network solution address the privacy and security concerns of public sector customers? If so, how does the solution address these concerns?
    4. Explain, with supporting rationale, the additional costs of implementing a fully dedicated service, and how this would be significantly more expensive to the wholesale customer.
    5. If the Commission were to require Northwestel to offer dedicated bandwidth as part of L2-WCON, explain, with supporting rationale, how this would impact the information supplied in response to question 3.

  2. Regarding Ethernet ports and the demarcation point, section 1(d) of Northwestel’s current Wholesale Connect Service tariff states that:Footnote 1

    At each site, the Service is offered over one 10/100/1000 Mbps physical Ethernet port at the demarcation point and supports a maximum 4,500 routes.

    Please explain why this condition is absent in the revised tariff for L2-WCON provided by Northwestel.

  3. In its Part 1 application, Northwestel provided proposed configuration and tariff pages for its new L2-WCON.

    Although the scope of this proceeding is related to the configuration of the service, it is still important to understand the costs and rates associated with any proposed configuration at this stage.

    Provide proposed rates, and an associated cost study using the Phase II costing methodology, for the L2-WCON, based on the configuration proposed by Northwestel in its Part 1 application.

  4. Paragraph 3 of Northwestel’s Part 1 application states that:

    As a result of our consultations with Iristel and SSi, the proposed new L2-WCON offers the following key benefits and features that reflect the input received and needs expressed for the new service:
    1. Layer 2 point-to-point and/or point-to-multipoint Ethernet Virtual Private Line (EVPL) service that simplifies service provisioning and provides flexibility for wholesale customers of the new L2-WCON to self-manage their network;
    2. Service delivered over our MPLS network to provide enhanced network reliability and redundancy;
    3. 9,000 byte MTU to help increase network efficiency and performance;
    4. Supports VLAN tunneling (QinQ) to simplify service deployment and management;
    5. Provides four CoS options to choose from based on the wholesale customer's quality-of-service requirements;
    6. Allows the wholesale customer to allocate up to 100% of their purchased bandwidth (up to 100 Mbps) to be sent as higher priority traffic; and
    7. Standardized customer premises equipment (CPE) for all speed options, to support smooth bandwidth changes if required. This should also help minimize one-time charges for speed changes, as a service visit would not be required.

    Although the scope of this proceeding is related to the configuration of the service, it is still important to understand the potential impacts on rates of any modifications or enhancements to the service. Explain, with supporting rationale, the impact of each of these features on the information supplied in response to question 3.

Northwestel, Iristel, SSi

  1. Paragraph 20 of Northwestel’s Part 1 application states that:

    Given our distance from the defined Tier 1 cities, meeting the USOFootnote 2 for latency, packet loss, and jitter is not possible. Despite this, we are proposing improvements to the service level agreement (SLA) metrics for L2-WCON over those currently available in Wholesale Connect Service.

    1. Northwestel: Explain how distance from Tier 1 cities limits Northwestel’s ability to improve the SLA metrics of L2-WCON.
    2. Northwestel, Iristel, SSi: The only proposed improvement to the SLA metrics appears to be reducing packet loss for Medium Class of Service (CoS) targets from 2% to 1%. Discuss the impact that wholesale customers and their end users will likely experience as a result of this change. Will the impact be significant or minimal, and why? Could any additional improvements be made to the SLA metrics? Why or why not?

Northwestel, Iristel, SSi, Telus

  1. In its intervention, Telus requested that L2-WCON be revised to allow for the option to terminate the service in a Northwestel Co-Location (CoLo) site, subject to the terms, conditions, rates and charges set out in Northwestel’s applicable CoLo tariffs. Currently the service only provides for termination in a wholesale customer’s point of presence (PoP). Telus submitted that a CoLo arrangement would:

    1. Reduce the time and cost required for wholesale customers to utilize L2-WCON;
    2. Negate the need for further transport services for the wholesale customer; and,
    3. Alleviate the security concerns associated with having Northwestel’s customer premise equipment (CPE) in a wholesale customer’s PoP, as Northwestel would need physical access to the PoP.

    In its reply to Telus’s intervention, Northwestel submitted that:

    1. Companies with fewer resources than Telus have already established PoPs in the Far North; and,
    2. Telus’s security concerns are not equitable as there is no practical difference between Northwestel accessing the CPE associated with L2-WCON in a wholesale customer’s PoP, and wholesale customers accessing Northwestel’s Central Offices (COs).

    1. All: Comment on Telus’s proposal that access to Northwestel’s L2-WCON should be allowed via Northwestel’s CoLo tariffed service, as well as Northwestel’s reply comments. In particular:

      1. Describe the security concerns that would result from allowing wholesale customers to access Northwestel’s COs to establish a CoLo arrangement. Could these be mitigated, and if so how?
      2. Would offering CoLo services reduce the time and cost required for customers to be able to use L2-WCON as submitted by Telus? Why or why not?
      3. What are the benefits, if any, of requiring L2-WCON customers to establish their own PoPs in the Far North instead of allowing them to access CoLo services? Please explain.
    2. Northwestel, Iristel, SSi: Telus proposed certain specific changes to the proposed configuration for L2-WCON to allow for access via CoLo sites at paragraph 13 of its intervention. Comment on the changes proposed by Telus to the configuration for L2-WCON to address its concerns. Are they appropriate and/or adequate, and if not, why not?
    3. Northwestel: Northwestel appears to offer CoLo services under its Special Services Tariff in several communities where Wholesale Connect is available, including Whitehorse, Yellowknife, and Fort Nelson, under tariff items 746 and 750.Footnote 3 Comment on how the security concerns raised above are addressed under these circumstances. Why would similar arrangements not be appropriate for L2-WCON customers?
    4. Northwestel: Describe any concerns or challenges that may arise for Northwestel when offering L2-WCON at the CoLo in addition to a PoP. Would implementing a CoLo arrangement in place of the access structure established in the current Wholesale Connect tariff incur any additional costs on Northwestel? If so, please provide an estimate, with supporting rationale, of those additional costs.

    5. Telus: Paragraph 5 of Telus’s intervention states that:

      TELUS would like to be able to use [Northwestel’s] (NWTel’s) proposed L2-WCON Service to serve its business customers in Far North communities, however, the proposed service configuration should be adjusted to allow for the option to terminate either in the wholesale customer’s PoP or in NWTel’s CoLo site (in accordance with the terms and conditions of NWTel’s CoLo tariff).

      Does TELUS have access network connectivity to all of its business customers from Northwestel’s CoLo facilities?

      If not, how would these business customers obtain access to a Telus access network provided via L2-WCON without the local community-level access provided by a PoP:

      1. Would Telus be required to connect at a community-level PoP in addition to a Northwestel CoLo site to provide connectivity to these business customers? Why or why not?
      2. Are there any locations in the Far North where Telus currently connects to a Northwestel CoLo site? If so, please provide the location(s).

  2. In its intervention, Telus submitted that the proposed L2-WCON should support IPv6 and Multicast functionality to promote competition and to ensure that the needs of wholesale customers and their end-users are met. Telus added that without these features, wholesale customers will need to spend additional effort configuring their Internet solutions for their end business customers.

    In its reply, Northwestel submitted that:

    …[IPv6 and Multicast] functions happen at Layer 3 of the Open Systems Interconnection model, not Layer 2; therefore, L2-WCON neither prevents nor enables Layer 3 functionality. Layer 2 services such as L2-WCON look solely at the Ethernet frame and not the packets. We confirm that, so long as the wholesale customer follows industry standard processes associated with Layer 2 Ethernet frame transmission, L2-WCON will support the Layer 3 functionality.

    1. Northwestel: Please explain whether there would be any routing function involved as part of L2-WCON that would require Layer 2 to Layer 3 translation and vice versa; for instance, when frames enter/exit or travel through Northwestel’s network. If so:

      1. Could there be compatibility issues with Northwestel’s network if Layer 3 functionalities like IPv6 and Multicasting are implemented by wholesale customers?
      2. Would there be any cost borne by Northwestel to address potential incompatibilities?
      3. Would these costs affect the wholesale rates? Why or why not?
    2. Iristel, SSi: Do you believe that IPv6 and Multicast functionality are essential for L2-WCON? Why or why not?
    3. Iristel, SSi, Telus: Will you take advantage of IPv6 and Multicast services if L2-WCON allows you to do so, and if so, how?
    4. Iristel, SSi, Telus: Comment on excerpt from Northwestel’s reply to Telus’ intervention reproduced above. Is it adequate that L2-WCON neither prevents nor enables Layer 3 functionality such as IPv6 and Multicast, or will this create issues for wholesale customers?

Appendix 2: Questions for Iristel, SSi, and Telus

  1. Paragraph 4 of Northwestel’s Part 1 application states that:

    In general, it is our impression that both Iristel and SSi indicated they were satisfied with the technical design of L2-WCON (ignoring the concerns that they raised regarding matters that were out of scope, such as requests that the service should include access links in each community), although they remain concerned with the rates that will apply, which have not yet been developed… [Iristel and SSi] suggested changes to the Service Level Agreement (SLA) that we were not able to accommodate. We explained the benefits of using a MPLS network as the basis of the service, as opposed to the much costlier and limiting pure dedicated bandwidth approach.

    1. Are you satisfied with the technical design of L2-WCON? Why or why not?
    2. Is the rationale Northwestel provided for being unable to accommodate the suggested changes to the SLA sufficient? Why or why not?

    3. Are you satisfied with the additional Class of Service (CoS) subscription options and the MPLS network solution negotiated with Northwestel in place of a pure dedicated bandwidth approach? Furthermore, how would this solution impact:

      1. Your ability to provide services to your end-users?
      2. The speeds available to your end-users?
      3. The privacy and security of your network?
    4. Please explain any concerns you have regarding the potential rates for L2-WCON. Provide an estimate of what L2-WCON rates would need to be for you to have a business case to provide competitive services to your end users, with supporting rationale and any assumptions you rely on. Include details of what your retail service could provide for end users at the L2-WCON rate you have indicated.

  2. In its intervention, Telus indicated that it was interested in the option to have dedicated bandwidth as several public sector customers desire dedicated access for reasons of privacy and security.

    Paragraph 8 of Northwestel’s reply states that:

    To provide the opportunity to achieve near-dedicated bandwidth functionality, we have introduced in L2-WCON the option to subscribe to up to 100% class of service (CoS) at Medium, High or Highest CoS or up to 100 Mbps per site, whichever is lower. We believe that this negotiated solution balances the competing priorities of functionality (for example, providing dedicated bandwidth via CoS up to 100 Mbps and utilizing the redundancy and reliability of the MPLS network to support the service) and cost (a fully dedicated service would be significantly more expensive to the wholesale customer).

    1. All: Given the cap for CoS, would more than 100 Mbps per site for subscription to Medium, High or Highest CoS be necessary? If so, would acquiring more than 100 Mbps for higher-priority traffic be cost-prohibitive?
    2. All: Comment on Northwestel’s rationale that a pure dedicated bandwidth approach would result in a much more costly Wholesale Connect service for wholesale customers.
    3. Telus: Please explain, in detail, your concerns as to why Northwestel will not be able to uphold the privacy and security of Telus’ public sector customers on the MPLS network to the extent that Telus would require dedicated bandwidth instead. Can your concerns be mitigated? Why or why not?

Distribution List:

Northwestel Inc.: regulatoryaffairs@nwtel.ca;
Iristel Inc.: regulatory@sugarmobile.ca;
SSi Canada.: regulatory@ssimicro.com;
Telus Communications Inc.: regulatory.affairs@telus.com

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