ARCHIVED - Letter

Ottawa, 12 May 2011

File Nos.: 8740-T42-201107798
              8740-T66-201107772
              8740-T46-201107806

BY E-MAIL

Mr. Hal Reirson
Senior Regulatory Advisor
Telecom Policy & Regulatory Affairs
TELUS Communications Company
21-10020-100 Street NW
Edmonton, Alberta
T5J 0N5
hal.reirson@telus.com

Re: TCC Tariff Notice 409, TCI Tariff Notice 634, TCBC Tariff Notice 4346 – Price Cap Filing

Dear Sir:

On 5 May 2011, the Commission received applications by TELUS Communications Company (the company) under the above mentioned Tariff Notices, in which the company proposed changes to the rates for services in its Business Service basket and Other Capped Service Basket as part of its 2011 price cap filings. The company indicated that these applications were 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 these applications and considers that they do not meet the definition of Group A retail tariff filings as they do 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 Business and Other Capped Services baskets if all the tariffs changes in these applications were to become effective.

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

If the company chooses not withdraw its applications, the Commission will process the applications on a going forward basis as Group B retail tariff filings. However, these applications will not be approved on an interim basis on the 15th calendar day after they were received, as the company would need to submit amended applications that meet 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 applications.

Yours sincerely,

‘Original signed by S. Bédard’

Suzanne Bédard
Senior Manager, Tariffs
Telecommunications

cc.: Sylvie Labbé, CRTC, 819-953-4945, sylvie.labbe@crtc.gc.ca
Michelle Duguay, TELUS Communications Company, michelle.duguay@telus.com

Date modified:

2011-05-12