Email: minister.industry@ic.gc.ca October 2, 2012 The Honourable Christian Paradis, PC, MP, Minister of Industry and Minister of State (Agriculture) Government of Canada, 235 Queen Street, Ottawa, Ontario K1A 0H5 Dear Minister, Application for International Submarine Cable Licence Pursuant to section 19 of the Telecommunications Act (S.C. 1993, c.38), Arctic Fibre Inc. herein applies for a terminating cable licence and a through cable licence. The bifurcated application is being made due to the fact that two of the four fibre pairs contained within the same cable will form an express international network between Maruyama, Japan and Bude, United Kingdom. The third express fibre will run from Maruyama, Japan to Milton, Newfoundland with onward connection to the United States via domestic terrestrial networks and international subsea fibre at Halifax. The fourth fibre will form a local network linking Maruyama, Japan to Milton, Newfoundland via intermediate points in the United States and Canada. Arctic Fibre will situate a cable landing station (CLS) at Cambridge Bay, Nunavut, Canada to regenerate the fibre optic signals but there will be no signal handoff between the three express pairs and Canadian domestic network. A network schematic and route map are appended to the application to provide clarity. Name of the Applicant: Arctic Fibre Inc. Address: 3 Otter Crescent, Toronto, Ontario, Canada M5N 2W1 Telephone Number: 416-613-6263 Email contact: doug@arcticfibre.com Incorporation Details: Arctic Fibre Inc. was incorporated under the laws of Ontario on December 18, 2007 under Ontario Corporation Number 002157999 The Intended Route of the Cable: Through (Express) Cable Landing Stations: Bude, Cornwall, England: 5047842N, 0433442W Cambridge Bay, Nunavut, Canada: 6906897N, 10503587W Maruyama, Japan: 3500327N, 13958525E Terminating (Canadian) Landing Stations: Milton, Newfoundland and Labrador: 481337N, 535745W Nain, Newfoundland and Labrador: 5708730N, 5627510W Iqaluit, Nunavut: 6343921N, 6827167W Cape Dorset, Nunavut: 6413814N, 7632961N Hall Beach, Nunavut: 6845212N, 8112591W Igoolik, Nunavut: 6922566N, 8147127W Taloyoak, Nunavut: 6930783N, 9330584W Goja Haven, Nunavut 6837528N, 9552942W Cambridge Bay, Nunavut: 6906897N, 10503587W Note: The beach manhole (BMH) coordinates provided for the Canadian landings are approximate and based upon desk top surveys. Further physical and marine survey work and commercial arrangements may result in a slight alteration in these coordinates. The Arctic Fibre express system will originate in London England with multiple fibre connections to several carrier hotels. Leased terrestrial fibre will carry the network through the Apollo Cable landing station at Bude, Cornwall, England across the Atlantic to an underwater branching unit (UBU) situated at approximately 6077536N, 6237300N. At this point the network intersects with the Milton/Iqaluit segment. Slightly north at the east end of the Hudson Strait (6060000N, 6300000W), the express line diverts from the Milton/Iqaluit spur and proceeds westerly through the Hudson Strait, Foxe Basin and the Gulf of Boothia to Lord Mayor Bay. A terrestrial crossing of the Boothia Peninsula (approximately 45 km) will take place to eliminate the cost and ice scour risk associated with a more northerly passage. The cable re-enters the water at Taloyoak and proceeds south through the Rae Strait to Cambridge Bay where dual approaches will take it into the Cambridge Bay CLS. Proceeding westerly the fibre leaves Canadian waters at 723800N, 1375100W and enters U.S. waters. The fibre crosses the Beaufort Sea, the Bering Strait and the Bering Sea with six spurs serving remote communities in Alaska. From the Aleutian Islands the fibre proceeds in international waters to the Maruyama, Japan CLS. Offshore Japan, provision is being made for an underwater branching unit to connect to another fibre system which would eventually land at Chongming (Shanghai), China. Network Technical Design: Arctic Fibre's network will consist of two "express" fibre pairs between Tokyo and London, each fibre pair having the capacity to transmit at least 80 wavelengths lit at 100 Gigabits. As such the theoretical combined capacity of the Tokyo to London express fibres is 16 terabits, the Tokyo to Newfoundland express segment capacity is 8 terabits and the local fibre running between Tokyo and Newfoundland serving Alaska, the Northwest Territories, Nunavut, Northern Quebec and Labrador will also have a theoretical capacity of 8 terabits. Additional spurs are proposed off the fourth fibre pair to provide future service to Labrador, the Nunavik region of Northern Quebec, and the Kivalliq and Qikiqtani regions of Nunavut. The network will provide more than 57,000 Canadians with their first broadband telecommunications service. The Arctic Fibre network will utilize Optical Add Drop Multiplexing (OADM) technology to ensure that if a spur from the backbone to any specific community is severed, service to other communities is not interrupted. Arctic Fibre has requested firm turnkey proposals from both Alcatel/Lucent and TE Subcom which are the dominant companies in the supply and installation of submarine networks worldwide. This requested inservice date is November 1, 2014. Compliance with the Canadian Environmental Assessment Act: Arctic Fibre has completed an end to end desk top survey (DTS) of the network between Bude, Cornwall, UK CLS and the Maruyama, Japan CLS which can be provided to Industry Canada upon request. It is our intention to complete the full marine survey of the route during 2013Q2-Q3 and which time the exact landing points will be determined having taken into account: fishing grounds, marine anchorages, tidal flows and currents, ice scour, nearshore seabed conditions and terrestrial linkages to the remote community points of presence. At that juncture Arctic Fibre will perform the requisite environmental reviews under the Canadian Environmental Assessment Act in consultation with the Nunavut Impact Review Board and Environment Canada. The installation of a subsea telecommunications network is recognized as being environmentally positive because of the resultant change in consumer behavior (i.e. telecommuting and fewer airline trips). The majority of the subsea fibre consists of inert, high-density polyethylene, single-armored fibre less than 18mm in diameter surface laid on the ocean floor. Nearshore double-armored cable is less than 38 mm in diameter and may be buried as deep as 2.6m dependent upon ice scour and seabed conditions. At Milton, Newfoundland and Labrador, Arctic Fibre is co-locating its facilities within the existing Tele-Greenland landing station constructed in 2008. These cable approaches were the subject of a detailed environmental assessment and permitting process and Trinity Bay has been utilized as a cable corridor without incident since 1866. In the determination of near shore landings elsewhere in Labrador, Nunavut and the Northwest Territories, Arctic Fibre took into consideration: water depths (deeper, steeper approaches being preferred), tidal activity, currents, wind and wave motion, ice scour, fishing areas, lobster beds, ship anchorages, proximity to terrestrial networks and services amongst other factors. At most landing sites, the fibre will be trenched into the sediment up to 1.3 metres to preclude ice damage. In virtually all instances, tidal and wave action results in little or no trace of the marine installation within one week. Both Alcatel/Lucent and TE Subcom have more than a half century's expertise in the installation of environmentally benign subsea cables, including those situated in Arctic regions. Term of the Licence: Arctic Fibre Inc. requests a licence for the maximum permitted term of 10 years with the provision to automatically renew. As the Minister may appreciate, the physical lifespan of submarine fibre should exceed 25 years. However, in order to reduce prices paid by carriers and consumers the system is being depreciated over a 20-year time frame as opposed to the licence term of 10 years. Telecommunications Policy Objectives: The Arctic Fibre project does more to satisfy the policy objectives as outlined in Section 7 of the Telecommunications Act, 1993 than any other singular telecommunications project in decades. Our project addresses the needs and issues clearly identified in the Arctic Communications Infrastructure Assessment published in April 2011. Specifically: 1. The network will extend affordable broadband services to Northern and Central Labrador, 52% of the Nunavut population on the backbone (and potentially 90% through network spurs) to unserved regions of Northern Quebec and the Northwest Territories; 2. The network will enhance the resilience of Canada's telecommunications network, by reducing dependence upon satellite transmissions from the Anik F2 satellite; 3. The network will assist the government in national defence and sovereignty; 4. The network will enable NAV Canada to provide safer air navigation to both domestic and foreign airlines; 5. The network will accelerate the development of competitive telecommunications in Newfoundland and Labrador, Quebec, Nunavut, and the Northwest Territories; and 6. The system will enhance the use of Canadian transmission facilities for both domestic and international telecommunications but also facilitate broadband capability on a global basis and enhance Canada's trade linkages with the Asia-Pacific region. The domestic and international segments of this network are inextricably linked from a physical, technical and economic perspective. The bandwidth demands of international carriers will subsidize the cost of providing much-needed bandwidth to Northern Canada. Ownership: As an international licencee Arctic Fibre Inc. will not be subject to the foreign ownership restrictions of the Telecommunications Act, 1993. It is Arctic Fibre's intention to finance its construction using equity provided by domestic institutional investors and to a lesser extent by foreign telecommunications carriers. Debt financing will be provided by Canadian chartered banks using guarantees provided by the United States Export-Import Bank or export credit agencies supported by the French government dependent upon the vendor selection. At present 100% of the shares of Arctic Fibre Inc. are owned by Network Research Inc., an Ontario incorporation with offices at 3 Otter Crescent, Toronto, Ontario M5N 2W1. All of the shareholders of Network Research are Canadian citizens. All four directors hold Canadian citizenship and have substantial experience in telecommunications. Network Equipment Supply and Maintenance: Arctic Fibre will enter into a turnkey supply contract with either Alcatel/Lucent or TE Subcom. These companies constitute two of three companies worldwide with the technical ability to construct a system of this length and complexity. There are no Canadian manufacturers of subsea telecommunications equipment and only one domestic company with limited installation capability, IT International Telecom. It is Arctic Fibre's intention to utilize IT International Telecom for ongoing maintenance work upon completion of the system and it would be our expectation that either turnkey contractor will subcontract a portion of the installation work to IT International Telecom. The company's landing stations at Cambridge Bay, Iqaluit and Milton will be staffed by Canadian residents. Arctic Fibre will outsource maintenance responsibilities at its other Canadian landing points to third parties who staff is Canadian. Licence Fee: A certified cheque in the amount of $100.00, payable to the Receiver-General for Canada, is appended to cover the licence fee for the first year of the permit. As you can appreciate, the international carrier community will not enter into enforceable contracts with Arctic Fibre until such time as the requisite licences are obtained from the Government of Canada. Some of these carriers are considering participation in the competing Russian Polarnet project and any undue delay in the grant of the requisite licence could undermine the economics of the Arctic Fibre project. You or your staff may direct any questions with regard to this application to the undersigned at the above number or by email at: doug@arcticifibre.com. Additional background information can be found on our website: www.arcticfibre.com Thank you for your consideration. Respectfully Submitted on Behalf of ARCTIC FIBRE INC. Douglas G. Cunningham President c.c.: The Right Honourable Stephen Harper PC, MP The Honourable Leona Aglukkaq PC, MP The Honourable Gary Goodyear, PC, MP The Honourable John Duncan PC, MP The Honourable Joseph Oliver PC, MP The Honourable Peter MacKay PC, MP The Honourable Peter Penashue PC, MP Senator Dennis Patterson PC, MP Premier Kathy Dunderdale, Newfoundland and Labrador Premier Eva Aariak, Government of Nunavut Premier Bob McLeod, Government of the Northwest Territories Terence Young, MP Oakville Secretary-General, Canadian Radio-Television and Telecommunications Commission Helen McDonald, Industry Canada Kelly Gillis, Industry Canada Adam Scott, Industry Canada Attachments: Arctic Fibre System Overview East and West (2 pages) Arctic Fibre Route Map Certified Cheque payable to Receiver General for Canada