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Ottawa, 12 May 2011

File No.: 8740-T69-201107574


Ms. Michelle Duguay
Senior Regulatory Advisor – Tariffs
Telecom Policy and Regulatory Affairs
TELUS Communications Company
9 Jules-A.-Brillant Street, R 0901
Rimouski, Quebec
G5L 7E4

RE: TCC Tariff Notice 560 – Price Cap filing

Dear Madam:

On 29 April 2011, the Commission received an application by TELUS Communications Company (the company) under the above mentioned Tariff Notice, in which the company proposed changes to the rates for services in its Other Capped Service Basket as part of its 2011 price cap filings. The company indicated that this applications was filed as a Group A retail tariff filing under Approval mechanisms for retail and CLEC tariffs, Telecom Decision CRTC 2008-74, 21 August 2008. The company provided the detailed impacts for the rate changes at the rate element and basket element level under separate cover in TELUS’ Price Cap Model Update dated 29 April 2011.

Commission staff notes that, pursuant to Telecom Information Bulletin CRTC 2010-455, Approval processes for tariff applications and intercarrier agreements, 5 July 2010, retail tariff filings qualify as Group A filings if the associated revisions are restricted to one or more of the following:

a) changes to previously approved rates for retail services where the revised rates meet the Commission’s price cap or price regulation rules and the price floor test, as applicable;
b) the following housekeeping changes to existing tariffs for retail services:

i) corrections of typographical errors or administrative errors on approved tariff pages;
ii) updates to approved tariff pages to correct cross-references or to remove an expired promotion or special facilities tariff; and
iii) updates to approved tariff pages to reflect changes to corporate or service names or titles; and/or

c) updates to tariff pages to incorporate forborne exchanges or routes, consistent with Commission forbearance decisions.

Commission staff has reviewed this application and considers that it does not meet the definition of Group A retail tariff filings as it does not meet the Commission’s price cap rules.

In particular, after reviewing the company’s Price Cap Model Updates for the years 2007 to 2011, it appears that the company has made errors in the calculations of its Service Basket Limits (SBLs) and the Service Basket Indexes (SBIs) for its Residence, Business, and Other Capped Services baskets. In Commission staff’s view, correcting these errors would leave the SBIs higher the SBLs for the Other Capped Services baskets if all the tariffs changes in this application were to become effective.

Commission staff notes that the company could withdraw the above noted application and file a new corrected application as Group A retail tariff filing at a later date.

If the company chooses not withdraw its application, the Commission will process the application on a going forward basis as Group B retail tariff filings. However, this application will not be approved on an interim basis on the 15th calendar day after it was received, as the company would need to submit an amended application that meets the price cap rules for the Commission’s review.

To address the errors in the company’s calculations of its SBLs and SBIs, Commission staff requests the company submit a corrected Price Cap Model Update at the same time, or prior to, submitting any new Group A applications or amendments to the existing application.

Yours sincerely,


‘Original signed by S. Bédard’

Suzanne Bédard
Senior Manager, Tariffs

cc: Sylvie Labbé, CRTC, 819-953-4945,
Hal Reirson, TELUS Communications Company,

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