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Ottawa, 26 July 2012

Our Reference: 8663-S4-200813833


Mr. Ted Woodhead
Telecom Policy and Regulatory Affairs
TELUS Communications Company

Dear Sir:

RE: Interconnection with small ILECs through leased facilities

By letter dated 17 July 2012, TELUS Communications Company (TELUS) provided comments after reviewing the documents filed by Téléphone Guèvremont inc., Téléphone Milot inc., Sogetel inc, and CoopTel (the small ILECs) in response to Commission staff letters dated 6 July 2012 requesting each company to file with the Commission mutually agreed timelines to finalize implementation of local competition in their respective territories.

TELUS submitted, among other comments, that it is hopeful that interconnection with each small ILEC can be achieved by the end of October 2012, assuming TELUS can effect interconnection through leased facilities.  TELUS requested that the Commission confirm that leasing interconnection facilities is an option that has always been available in rolling out local competition in Canada.

Commission staff notes that while interconnection between carriers is generally based on the joint-build of facilities with the appropriate cost-sharing arrangements as set out in Telecom Decision 97-8, Local Competition, 1 May 1997, parties may instead, based on negotiated bilateral agreements, use leased facilities for interconnection.

Where leased facility services are provided by the small ILEC, then a competitor may use those services for its interconnection arrangement with the small ILEC, but these leased facilities are not subject to cost-sharing arrangements.

Yours sincerely,

‘Original signed by K. Wardle for M. Bertrand’

Mario Bertrand
Director, Dispute resolution and decisions

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