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Ottawa, 7 June 2013
Our reference: 8740-T66-201209099 - 8740-T46-201209122 - 8740-T42-201209114
BY EMAIL
Mr. Hal Reirson
Senior Regulatory Advisor
Telecom Policy & Regulatory Affairs
TELUS Communications Company
30-10020-100 Street North West
Edmonton, Alberta T5J 0N5
regulatory.affairs@telus.com
hal.reirson@telus.com
Re: Outstanding Rating Issues of Tariff Notices # 438 / 644 / 4357
Dear Mr. Reirson:
TELUS Communications Company (TCC) filed Tariff Notices 438 / 644 / 4357 to add a 2.5 Gbps interconnecting carrier to interconnecting carrier (IC-to-IC) cross-interconnection link.
To assist the Commission in disposing of these applications, TCC is required to provide responses to the attached interrogatories which are to be filed with the Commission by 14 June 2013.
All parties may file written comments to the Commission by 21 June 2013. TCC may file reply comments by 28 June 2013.
Where a document is to be filed or served by a specific date, the document must be actually received, not merely sent, by that date. Copies of the documents should also be sent to abderrahman.elfatihi@crtc.gc.ca
Each paragraph of all submissions should be numbered. In addition, the line ***End of document*** should be entered following the last paragraph. This will help the Commission.
Yours sincerely,
Original signed by
Lyne Renaud
Director, Competitor Services & Costing
Telecommunications
Attach (1)
c.c: Abder Rahman El Fatihi abderrahman.elfatihi@crtc.gc.ca
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Telus TNs 438 / 644 /4357
Introduction of IC-to-IC cross-interconnecting link at 2.5 Gbps
1. Consistent with the format of the company’s report filed on 6 December 2012 in support of Tariff Notices (TNs) 438 / 644 / 4357, provide a revised economic evaluation and propose a) revised monthly charge (i.e. no one-time charge) and b) revised one-time charge and revised monthly charge assuming the following:
i) 10 year study period
ii) Negative capital increase factor (CIF) of 10% applicable to transmission equipment
iii) Include company specific Productivity Improvement Factor (PIF) and Expense Increase Factor (EIF) over the study period, as applicable
iv) Maintenance expenses at 10% of the plants in service.
2. Consistent with the format of the company’s report filed on 6 December 2012 in support of TNs 438 / 644 / 4357 provide a revised economic evaluation and propose a) revised monthly charge (i.e. no one-time charge) and b) revised one-time charge and revised monthly charge assuming the following:
i) 10 year study period
ii) Exclude all costs related to monitoring traffic
iii) Include company specific Productivity Improvement Factor (PIF) and Expense Increase Factor (EIF) over the study period, as applicable
3. Refer to the response to interrogatory TN-438/644/4357 TELUS(CRTC)14Aug12-5, file on 7 September 2012 where the company provided the installed first costs (IFC) per port of the Transmission Equipment, provide a breakdown of the capital unit cost into its sub-component (e.g. fibre, main chassis, cabinet, line card, software, etc.).
4. Refer to response to interrogatory TN-438/644/4357 TELUS(CRTC)14Aug12-3, filed on 7 September 2012, where the company provided the description and breakdown of expenses causal to the service associated with billing.
Provide a step-by-step calculation in Excel format to explain how billing costs have been calculated; further, provide the associated present worth of annual costs (PWAC).
5. Refer to Telecom Decision CRTC 2012-209, dated 5 April 2012 - Bell Aliant Regional Communication, Limited Partnership and Bell Canada – Application to review and vary Telecom Decision 2011-355 pertaining to the co-location rule. In paragraph 31, the Commission decided that upon receiving a request from a co-located competitor for interconnection links to connect to another co-located competitor, an ILEC may require one or both co-located competitors to demonstrate (emphasize added) that they are adhering to the co-location rule.
Also, refer to TELUS’ Carrier Access, CRTC 1017 Item 110 Co-location arrangements for interconnecting Canadians Carriers, section C, Terms and Conditions – General. In that section it stated that in co-locating the transmission equipment in the Company premises, the Interconnecting Carrier (IC) shall ensure that the primary purpose of co-location is to interconnect with Company network facilities or access Company unbundled-network-components. The Company reserves the right to require the IC to demonstrate (emphasize added) that the capacity dedicated to interconnection with or access to Company network facilities is greater than that dedicated to IC-to-IC cross-interconnection
a) In view of the above, explain why the approach implied for DS-1 and DS-3 IC-to-IC links cannot be implemented for IC-to-IC link at 2.5 Gbps (i.e. without having to monitor the traffic between co-locators) with supporting rationale.
b) Explain with supporting rationale how currently co-locators demonstrate compliance to co-location rule in DS-1 and DS-3 IC-to-IC links environment.
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