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Ottawa, 29 October 2010
Our reference : 8740-T66-201015397
Mr. Hal Reirson
Senior Regulatory Advisor
Telecom Policy & Regulatory Affairs
TELUS Communications Company
21-10020-100 Street NW
Ms. Michelle Duguay
Conseillère principale réglementation – tarifs
Politique de télécommunication et réglementation
Société TELUS Communications
9, rue Jules-A.-Brillant, R 0901
RE: TELUS Tariff Notices 395 and TN 548
Dear Mr. Reirson and Madame Duguay:
On 8 October 2010 and 18 October 2010, the Commission received applications by TELUS Communications Company (TELUS) under cover of Tariff Notices 395 and 548, respectively. In Tariff Notice 395, TELUS is proposing to introduce Item 232, Wholesale Message Relay Service in Alberta and British Columbia and in Tariff Notice 548 the company is proposing to introduce Item 1.08, Service de Relais Grossiste in Quebec.
Commission staff notes that the terms and conditions of the proposed tariffs generally are associated with the services provided to the end customer, and considers that an amendment to the filing is required in order to identify the specific terms and conditions related to the provision of the proposed services to wholesale customers.
Further, TELUS is to provide the Commission with responses to the attached interrogatories.
Tariff amendments and responses to interrogatories should be filed within 10 business days of receipt of this letter.
Original signed by
Senior Manager, Tariffs
c.c.: Christine Bailey, CRTC, (819) 997-4557, email@example.com
1. In the cover letter to the tariff notices, TELUS stated that “Wholesale Teletypewriter Relay Service is also moved within this tariff offering as it is also currently delivered and rated on a per second basis within Commission approved Special Assemblies”.
a. Confirm whether or not it is TELUS’ intention to cease offering wholesale Relay Service per the terms in the company’s Local Network Interconnection and Component Unbundling tariffs (i.e. CRTC Tariff 1017, Item 105, CRTC Tariff 18008, Item 215, and CRTC Tariff 25082, Item 1.05) and confirm whether these terms would be replaced by the proposed tariff items. If not, explain how the company will determine which customers would be eligible for either the proposed service or the existing service.
b. If Wholesale Teletypewriter Relay Service is being replaced by tariffs other than the Local Network Interconnection and Component Unbundling tariffs, identify which tariffs are being replaced.
c. Explain why the company did not propose tariff pages removing Wholesale Teletypewriter Relay Service from the tariffs identified in (a) or (b) above in view of filing the introduction of Wholesale Message Relay Service and Service de Relais Grossiste.
2. In the cover letter, TELUS stated that it was proposing to introduce rate ranges for IP Relay and TTY Relay services pursuant to the approach described in paragraphs 21 to 23 of Follow-up to Decision 2006-75 – Range-within-a-range proposal, Telecom Decision CRTC 2007-36, 25 May 2007. Further, the company submitted that it has chosen to file the maximum rates on the public record while filing the minimum rates in confidence.
Given that in Rate ranges for services other than voice over the Internet Protocol services, Telecom Decision CRTC 2006-75, 23 November 2006; i) rate ranges were contemplated only for tariffed retail services; and ii) the Commission stated that the use of rate ranges would generally not be appropriate for services established to fulfill specific social policy objects (such as Message Relay Service), explain why the company considers that it would be appropriate for the Commission:
a. to permit rate ranges for a wholesale service categorized as a public good service1
b. to permit the company to file in confidence the minimum or the maximum rate of a wholesale service categorized as a public good service. ; and
1 In Revised regulatory framework for wholesale services and definition of essential service, Telecom Decision CRTC 2008-17, 3 March 2008 (Telecom Decision 2008-17), the Commission assigned message relay services to the public good category.
In Accessibility of telecommunications and broadcasting services, Broadcasting and Telecom Regulatory Policy CRTC 2009-430, 21 July 2009 (Broadcasting and Regulatory Policy 2009-430), the Commission determined that all references to "message relay service" in the existing relay service requirements set out in previous Commission decisions shall be read to include both Teletypewriter (TTY) Relay and Internet Protocol (IP) Relay.
3. In support of its applications, the company filed identical cost studies, including identical demand, in Tariff Notices 395 and 548.
Confirm whether or not the cost studies provided in support of tariff notice 395 includes all costs and demand associated with the provision of the Wholesale Message Relay Service in the company’s Quebec operating territory. If not, provide revised cost studies that include the costs and demand for the Quebec operating territory, or provide a separate cost study in support of the proposed rates for the Quebec operating territory.
4. Refer to Appendix 1, Table 5 titled “IP Relay Service - Detailed Summary of Causal costs” in each Tariff Notice.
a. Capital causal to service- Hardware costs: Provide a breakdown of the costs included in this category into the major hardware components, along with a description of each component. Confirm that these hardware costs are in addition to those approved for drawdown from the deferral account for accessibility initiatives for TELUS’ IP Relay service approved in TELUS Communications Company – Request for an additional drawdown from its deferral account for accessibility initiatives, Telecom Decision CRTC 2010-679, 10 September 2010.
b. Capital causal to demand –Land Building and Other: Provide a breakdown of costs into the categories -Land, Building and Other. Further, for costs associated with the Other category, provide details on the cost inclusions and provide the methodology and assumptions used to estimate these costs.
c. Expenses causal to demand –Other: Provide a breakdown of Other costs into the components indicated in Item 6.4.4 of Appendix 1. Explain the method used to estimate the costs associated with circuit switched calling. If a tariffed rate was used, provide the tariff item number and tariff rate, and the assumed demand for this rate element.
5. Refer to Appendix 2, Table 4 of Tariff Notice 395 titled “TTY Relay Service - Detailed Summary of Causal costs” and Appendix 2, Table 5 of Tariff Notice 548 titled “Message Relay Service - Detailed Summary of Causal costs”.
Expenses causal to demand –Other: Provide a breakdown of Other costs into the components indicated in Item 6.4.4 of Appendix 2. Provide the methodology and assumptions used to estimate these costs.
6. For each of the proposed wholesale TTY Relay service and the IP Relay service, provide the monthly per end-user average number of calls and average number of seconds per call assumed in the study.
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