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Ottawa, 28 January 2010

File No.:  8638-C12-200817505


Mr. Ted Woodhead

Vice-President – Telecom Policy and Regulatory Affairs

TELUS Communications Company

215 Slater St., 8th Floor

Ottawa, ON  K1P 0A6

Dear Mr. Woodhead:

Re: Follow-up to Use of deferral accounts to improve access to telecommunications services for persons with disabilities and to expand broadband services to rural and remote communities, Telecom Decision CRTC 2008-1 (Telecom Decision 2008-1)

On 15 January 2010, the Commission received a submission from TELUS Communications Company (TCC) providing details of TCC’s proposed deferral-account funded broadband expansion program.

In Telecom Decision 2008-1, the Commission noted that TCC already interconnects with the Alberta SuperNet (SuperNet) in some areas and that there should be no serious impediment for TCC to use SuperNet in communities where broadband service would be provided using deferral account funds.  Accordingly, the Commission directed TCC to use the least-cost solution for each community where interconnection with the SuperNet backbone is available (i.e. SuperNet or its own backbone facilities).

In its 15 January 2010 submission, TCC proposed that for the seven communities where it has determined that the use of SuperNet is the least-cost solution, it would use its own facilities instead.  However, to ensure that it would draw from the deferral account no more than if it had implemented the least-cost SuperNet solution, TCC proposed to cap the amount drawn from the deferral account at the cost of using the SuperNet solution.  The additional funds required to provision broadband service using its own facilities would be provided directly by TCC.

To assist the Commission in its consideration of your broadband expansion proposal as it relates to the use of SuperNet, TCC is requested to provide a response to the attached interrogatories by 18 February 2010.

Yours sincerely,

Original signed by

Paul Godin

Director General

Competition, Costing & Tariffs


cc: Donald Heale, CRTC, (819) 997-2755,

Attached distribution list

Encl. Interrogatories

Distribution List



1. With reference to paragraph 8 of TCC’s 15 January 2010 submission, describe in detail the business arrangement and service interface with SuperNet that would be required if TCC were to use SuperNet backbone facilities in those communities where SuperNet is available.

2. Provide a description of the current arrangements that TCC has in place to use components of the SuperNet network and a list of the communities where such arrangements are in place.  Explain why similar arrangements could not be used to facilitate the use of SuperNet to provide broadband services in communities that are part of the TCC broadband expansion plan and where SuperNet is available.

3. In paragraph 9 of its answer to Axia SuperNet Ltd.’s Part VII Application to Review and Vary Telecom Decision 2008-1, dated 21 May 2008, TCC acknowledged that in most communities with SuperNet backbone facilities, it will be less costly to interconnect with the SuperNet backbone than to construct or upgrade its own backbone facilities.  It is the Commission’s understanding that there are at least 32 Alberta communities approved for deferral account funding that have SuperNet backbone facilities.  However, TCC states in its 15 January 2010 submission that in only 7 of these communities is it less costly to interconnect with the SuperNet backbone than to construct or upgrade its own backbone facilities.

a. For the communities where it is now more expensive to interconnect with SuperNet than to construct new facilities, identify the technology, costs and revenues assumed in the May 2008 analysis and the January 2010 analysis.  Explain why these technologies, costs, and revenues have changed between the May 2008 analysis and the January 2010 analysis, with supporting rationale.

b. Provide a comparison of the annualized equivalent costs studies using a TCC-only solution and using the SuperNet solution for all of the Alberta communities in the TCC broadband expansion program where SuperNet backbone facilities are available.  Further, provide the underlying methodology and assumptions used to develop the TCC analysis of both solutions and identify any changes in technology and assumptions since the May 2008 analysis.

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