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Ottawa, 19 October 2012

Our reference: 8740-T42-201209073


Mr. Hal Reirson
Senior Regulatory Advisor
Telecom Policy & Regulatory Affairs
TELUS Communications Company
30-10020-100 Street NW
Edmonton, Alberta T5J 0N5

Re: TELUS Communications Company Tariff Notice 643 and 4356

Dear Mr. Reirson:

On 5 October 2012, the Commission received interrogatory responses from TELUS Communications Company (TELUS) on its proposed revised monthly co-location power rates in the applications noted above.

Disclosure requests:

On 15 October 2012, MTS Allstream Inc. (MTS Allstream) filed comments on TELUS’ 5 October 2012 interrogatory responses, and requested disclosure of information that TELUS claimed in confidence, particularly with respect to responses to TELUS(CRTC)13Sept12-1 and TELUS(CRTC)13Sept12-2. Notwithstanding the change in process dates set out below, TELUS may file comments by 24 October 2012 in respect of MTS Allstream’s disclosure requests.

Further process:

Commission staff has determined that there is need for further information in order to properly assess TELUS’ proposed co-location power rates. The additional interrogatories are provided in the attachment.

Accordingly, Commission staff sets out the following revised process dates:

TELUS’ responses to Commission interrogatories 6 November 2012
Comments may be filed by parties 13 November 2012
Reply comments may be filed by TELUS 20 November 2012

With respect to TELUS’ 6 November interrogatory responses, the level of disclosure of information should be consistent with previous disclosure rulings and those to be specified in the Commission’s upcoming ruling regarding MTS Allstream’s 15 October 2012 disclosure requests. Any additional comments by parties due on 13 November 2012 are to be made solely in relation to TELUS’ 6 November 2012 interrogatory responses.

Consistent with the guidelines set out in Broadcasting and Telecom Information Bulletin CRTC 2010-959, copies of comments and interrogatory responses referred to above are to be served on all parties to this proceeding. Copies of the documents should also be sent to pamela.cormier@crtc,

A French version of this document will be sent out shortly.

Yours truly,

‘Original signed by Y. Davidson’

Yvan Davidson
Director, Competitor Services and Costing
Telecommunications Directorate

Trichur Krishnan, CRTC
Yvan Davidson, CRTC



1. Refer to the company’s response to TELUS(CRTC)13Sep12-3 where the company proposed a working fill factor (WFF) for all power components in all co-location power plants in Alberta and British Columbia.

  1. Provide the vintage of the proposed WFF for the power components used in the company’s proposed regulatory economic study.
  2. Confirm that the WFF proposed by the company in response to the interrogatory TELUS(CRTC)13Sep12-3 is a company-specific WFF. If not, explain what the proposed WFF represents and why it is appropriate for use in the proposed regulatory economic study.
  3. If the response to part b) above is yes, explain how the WFF measure used satisfy the conditions specified in paragraph 46 of Review of the use of company-specific working fill factors and the recovery of past introduction costs not fully recovered, Telecom Regulatory Policy CRTC 2009-274 (TRP 2009-274), where the Commission issued certain conditions that an ILEC must satisfy when it files a company-specific working fill factor of a particular facility for regulatory economic study purposes. The response should further provide on the public record the value(s) of the proposed WFF, consistent with paragraph 3-82 of the company’s regulatory economic study manual.

2. Refer to TELUS(CRTC)13Sept12-4 where the company indicated that the company relied on 2007 ABC study maintenance costs for AC Unprotected and Protected power services, but did not use the same data to determine the DC power maintenance costs.

  1. For each of the AC Unprotected and Protected power services, identify and quantify the retrospective Expense Increase Factors (EIF) and Productivity Improvement Factors (PIF) used to restate the 2007 ABC data into 2012 (i.e., the beginning of the study period), with supporting rationale. The response should further identify and quantify the prospective EIFs and PIFs applied to the maintenance costs over the ten-year study period, with supporting rationale.
  2. Explain whether the company can similarly estimate the DC power maintenance costs based on 2007 or more current ABC data. If not explain in detail why not. If yes, provide revised DC maintenance costs (MEC) using this approach. The response should identify both the retrospective and prospective EIFs and PIFs used in this calculation.
  3. For AC Unprotected and Protected power services, the company stated that an average fused amp maintenance cost was determined by dividing the total yearly maintenance costs by the total capacity (amps) provided. Explain how the cost per amp is converted to a cost per fuse amp for these services and provide the associated calculations.

3. Refer to the response to TELUS(CRTC)13Sept12-6, part b) regarding the company’s development of a credit and collection factor. Further refer to Appendix F of the company’s Regulatory Economics Studies Manual where the company described ‘bad debt’ as the amount of revenue from sales that is uncollectible.

Indicate what part, if any, of the proposed 0.77% bad debt factor used to determine the bad debt expense that is based on uncollectible revenues, and provide the vintage and sources of the uncollectible revenue data used. Further, confirm that the bad debt was based on uncollectible wholesale revenues. If not, provide revised bad debt expenses based on a bad debt ratio that excludes bad debt associated with retail revenues in the calculations, specifying the revised bad debt factor.

4. Refer to the company’s response to TELUS(CRTC)13Sept12-3 a) where the company stated that the capital material costs were obtained by analyzing 88 projects and updating specific material items with the 2012 price list.

  1. Identify the range of vintages of the 88 projects and explain how the project information was used along with the 2012 price list to determine the capital material costs.
  2. Using the ‘Modular Rectifier – 200A Emersion Vortex 1231 V1’ DC power equipment as an example, identify the list price, including any associated discount, and vintage, that was used to determine the associated capital material cost identified in the table provided on page 2 of 5 of the interrogatory response. The response should explain how the company made use of the project information in its calculations, with supporting rationale.
  3. With respect to the line item D20 Power – DC & UPS: Capitalized Group A labour costs associated with the DC power equipment identified in the table provided on page 2 of 5 of the interrogatory response, provide the cost methodology and assumptions used to develop the cost estimate. The response should identify the source and vintage of the cost data used and the adjustments made to convert the vintage data to 2012. The response should further explain if and how the company made use of the project information in its calculations.
  4. With respect to the DC and AC capital costs identified in the above interrogatory response, identify and quantify the prospective CIFs and PIFs applied to each capital cost over the ten-year study period, with supporting rationale.

5. Refer to paragraph 103 of Bell Canada and TCC – Co-location power service rates, Telecom Decision 2006-42, where the Commission noted that the AC power provisioning guideline limits the demand load placed on devices protecting the branch circuit to be 80%. Further refer to the company’s response to TELUS(CRTC)13Sep12-7 b) where the company provided a Table showing calculations to convert ‘Cost of AC / K Wh’ to ‘Cost per AC fused amp / Month’.

  1. Confirm that TELUS’ AC power provisioning guidelines also limits the demand load placed on devices protecting the branch circuit to be 80%. If not, provide the limit on the AC power demand load used by TELUS with supporting assumptions and rationale.
  2. Explain if and how the above protection loading factor (to convert cost per AC amp / month to cost per AC fused amp / month) has been incorporated in the company’s response to TELUS(CRTC)13Sep12-7 b). If not, explain why not. If yes, explain in detail how this factor was included.
  3. Using the case of Alberta as an example, provide the formula and specific input data used and show detailed calculations of how the company estimated the ‘Cost per DC amp / Month’ from ‘Cost of AC / W / Month’. Further provide the formula as well as the detailed and specific input data and the sources of the data used to calculate the AC / DC watt conversion factor.
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