ARCHIVED - Letter

Ottawa, 9 July 2009

File No:   8740-T66-200907438

BY E- MAIL

Mr. Orest Romaniuk

Vice President & Controller

Regulatory Finance & Economic Affairs

TELUS Communications Company

21-10020 100 Street NW

Edmonton, Alberta

T5J 0N5

Regulatory.affairs@telus.com

Dear Mr. Romaniuk:

RE: TELUS Communications Company Tariff Application 361 – Construction Charges

Please find enclosed, interrogatories addressing issues associated with Tariff Notice (TN) 361.

Responses to these interrogatories are to be filed with the Commission by 23 July 2009.   Responses are to be received by the Commission, and not merely sent by this date.

Accordingly, the Commission will be unable to dispose of this tariff application within 45 business days.   The Commission expects to issue its decision regarding this application prior to the end of September 2009.

Yours sincerely,

Original signed by S. Bédard '

Suzanne Bédard

Senior Manager, Tariffs

Telecommunications

Attach.

cc:   Brendan Keown, CRTC, brendan.keown@crtc.gc.ca  

ATTACHMENT

TELUS Communications Company TN 361 Interrogatories

Issue 1

In tariff item 406.2(22), the company proposed that poles and other support structures on private property would become the property of the customer and the customer would be required to assume responsibility for their maintenance and replacement.

Q 1

a)      Provide the number of existing TCC 's customers that will be impacted by this proposal; and

b)      Provide an estimate of the company's annual cost of maintenance and replacement of poles on private property for the most recent three year period for which this data is available.

Q 2

a)      Has the company provided notice of its proposal to all affected customers?   If so, describe the manner(s) in which such notice was provided, the date(s) on which such notice was provided, and a copy of the notice(s) provided; and

b)      If notice was provided, provide the number of customer comments received in reply and a summary of all comments.

Q 3

a)      Confirm that, under the company's proposal, it would be the customer's responsibility to assess whether maintenance/pole replacement is required;

b)      Discuss how the company's proposal would affect poles on private property that are joint use poles.   Include a description of any changes to the customers' responsibilities with respect to such poles.   Also indicate whether the company has consulted with all joint pole owner(s) and, if so, discuss the outcome of those consultations; and

c)      Discuss whether, under the company's proposal, the customer would become responsible for dealings with, for example, hydro or cable companies that use also the pole.   If so, discuss whether the company proposes to continue to charge, under its support structure tariff, for attachments to poles on private property.   If so, discuss why.

Q 4

a)      Discuss whether the company intends to offer a pole inspection, maintenance and replacement service to affected customers; if so, include a copy of the draft terms and rates associated with any such service if available;

b)      Confirm that, under the company's proposal, affected customers will have the option of selecting the company that would perform any required maintenance and undertake any required pole replacement;

c)      Provide an estimate of the number of TCC 's existing customers that would have a choice of at least one alternate provider.   Provide the names, serving areas and website addresses (if any) of alternate providers that TCC is aware that could perform the work that TCC now performs with respect to poles on private property; and

d)      Discuss whether the company proposes to retain any right to approve work done on the poles in question, to set time periods within which, for example, any damage to a pole must be repaired, and if so, provide full details of the company's proposals in this regard.

Issue 2

Proposed tariff items 406.2.12 and 406.2.13 set out the company and customer's respective obligations with respect to the placement of temporary facilities and the costs incurred in replacing these temporary facilities with permanent facilities.   Proposed tariff item 406.2.12 addresses situations where the installation of temporary facilities has been deemed necessary by the company, while proposed tariff item 406.2.13 addresses those situations where such installation is done further to a customer request.   However, proposed tariff item 406.2.14 stipulates that the $2,500 allowance provided for in item 406.1 will not apply to customer requests made under Item 406.2.13.

Provide the rationale and justification for denying the $2,500 allowance to those customers who have requested and paid for the temporary facilities.   In providing an answer to this question, the company is to address why it would not be unjustly discriminatory for such customers to not benefit from any allowance for construction on public property while such an allowance would be provided to other customers.

Issue 3

Proposed tariff item 406.2.18(b) states that the customer will be responsible to provide or pay for among other items, all trenching, raceways and backfilling to extend network transmission facilities from the customer's property line up to and including the Network Demarcation Point.   However proposed item 406.2.16(a) states that in certain areas legislated as being buried areas, TCC will bury network facilities to the demarcation point at no additional charge to the customer.  

Clarify why the proposed customer responsibility or costs referenced in proposed item 406.2.18(b) should not be subject to the exceptions noted in proposed item 406.2.16(a).

Date modified:

2009-07-09