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Letter
Ottawa, 16 December 2003
Our Files : 8740-T46-200307547 - 8740-T42-200307539
BY FAX
Deo Mathura
Director, Regulatory Compliance & Tariffs
Government & Regulatory Affairs TELUS
21-10020- 100 Street NW
Edmonton, Alberta
Canada T5J ON5
Dear Mr. Deo Mathura:
Re: FORMER TCI TARIFF NOTICE NO 515 and TCBC TARIFF NOTICE NO.4199
By letter dated 18 July 2003, Rogers Wireless Inc. (RWI) provided comments in respect of the above noted tariff notices associated with TELUS Communications Inc.'s (TELUS's) line-side wireless access service (WAS). RWI submitted that with Tariff Notices (TNs) 515 and 4199, TELUS had proposed to redefine its active telephone number and network access channel rate components as to include in the latter rate traffic-sensitive costs from TELUS's network to the Wireless Service Provider's (WSP) network. RWI argued that the net effect of this proposed redefinition was to significantly increase the proposed WAS network access channel rates and to significantly reduce the TELUS's active telephone number rates. RWI argued that the proposed significant increases to the monthly network access channel rates were entirely unjustified.
RWI argued that Bell Canada's line-side WAS telephone number and network access channels rates approved in Rates for co-location floor space, Direct Connection service, Wireless Access Service: Line-side Access services, and Wireless Service Providers Enhanced Provincial 9-1-1 Network Access service, Telecom Decision CRTC 2003-12, 18 March 2003, (Decision 2003-12), were significantly lower that the previously- approved rates for these services.
In its reply comments dated 5 August 2003, TELUS disagreed with RWI's statement that the proposed network access channel rates were inflated. TELUS argued that its proposed network access channel rates recovered the costs associated with the provisioning of the network access channels including the traffic-sensitive costs associated with the traffic flowing from TELUS to the WSP along with a 15% mark-up. TELUS also submitted that the proposed rate for its active telephone numbers no longer included the traffic-sensitive costs from TELUS to the WSP, and accordingly these rates were significantly lower than the current rates for active telephone numbers.
In order to permit the review of TELUS's proposal to redefine the active telephone number and access channel rates components and the associated cost studies, Commission staff considers it is necessary to review TELUS's costs under each of the existing and proposed service definitions. TELUS is requested to provide responses to the attached questions regarding its submission by 30 January 2004.
Yvan Davidson
Senior Manager
Competitor Services and Costing
Attachment
Attachment
1) With reference to TELUS's 18 June 2003 submission as amended on 23 June 2003, file revised cost studies and the corresponding revised rates based on the following changes to the cost assumptions:
-The active telephone rate includes the traffic-sensitive costs from TELUS's network to the WSP network and the network access channel rate excludes such costs.
-The cost study is to exclude the application of the annual standard inflation factors and the productivity factor (3.5%) applied during the study period, consistent with the costing approach to be used for Competitor Services as set out in the Commission staff's letter dated 14 July 2003 regarding Phase II costing information requirements.
2) With reference to the revised cost studies to be provided in response to question 1) above, provide a description of the major cost resources included in the Summary of Revenue and Cost Impacts, along with the associated cost methodology and assumptions.
Date modified: 2003-12-16
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