ARCHIVED - Telecom Commission Letter addressed to Tom Woo (TELUS Communications Company)

Ottawa, 30 June 2015

Our reference:  8740-T66-201503970

By Email

Mr. Tom Woo
Senior Regulatory Advisor
Telecom Policy and Regulatory Affairs
TELUS Communications Company
30-10020-100 Street NW
Edmonton, Alberta  T5J 0N5
tom.woo@telus.com

RE:  TELUS Communications Company Tariff Notice 494 – Request for Information & Establishment of Additional Process

Dear Sir:

On 1 May 2015, the Commission received an application by TELUS Communications Company (TCC) under cover of Tariff Notice 494 (TN 494), in which the company proposed to revise the monthly pole rental rate from $1.44 (established in Telecom Decision CRTC 2010-900) to $1.60 as a result of the determinations of Telecom Decision CRTC 2014-645.

The Commission has received comments from Shaw Communications Inc. (Shaw), Bragg Communications Inc. carrying on business as Eastlink (Eastlink), and Allstream Inc. (Allstream) related to the application.

Commission staff is seeking supporting information from TCC in the above-noted TN 494 proceeding and is setting out additional process related to the application. TCC is to provide its responses to the attached questions by no later than 17 July 2015.  These submissions must be received, not merely sent, by that date.

Further, Commission staff is of the view that the other interested parties in the TN 494 proceeding should be given the opportunity to comment on the responses of TCC to this request for information.   Accordingly, any party that has already submitted comments on TN 494 may comment on TCC’s response within 10 business days of the response being filed with the Commission.  Thereafter, TCC may reply to the points raised by the interveners within 5 business days of the deadline for intervener comments.
Sincerely,

Original signed by

Lyne Renaud
Director, Competitor Service & Costing Implementation
Telecommunications Sector
c.c.:  Curtis Eagan, Analyst, CRTC 819-953-4947, curtis.eagan@crtc.gc.ca
Shaw, regulatory@sjrb.ca
Eastlink, regulatory.matters@corp.eastlink.ca
MTS Allstream, iworkstation@mtsallstream.com
Attach. (1)

Appendix 1 -- Request for Information

Question 1

In the interrogatory phases of the proceeding leading to Telecom Decision CRTC 2010-900, TCC submitted the following in response to questions posed by Commission staff:

• “TELUS confirms that it had a total of 826,663 owned poles in AB/BC” [TELUS(CRTC)28May10-12; Response to question 12]
•  “TELUS has included service poles within its Total Pole count data” [TELUS(CRTC)17Mar10-13; Response to question 13]

In the proceeding leading to Telecom Decision CRTC 2014-645, TCC stated in its comments: 

• “The cost of the pole not purchased and/or placed by TELUS was not included in the cost study submitted to, and approved by, the Commission.” [TELUS(Raftview)25Aug14-45; paragraph 45]

In light of the above, please respond to the following:

1. Clarify whether the total pole count of 826,663 included only poles (e.g., mainline or service) that were owned by TCC.  If the answer is “no”, please clarify what was included in the total pole count (i.e., what types of poles, owned by whom).
2. Clarify whether the “denominator used to calculate original pole embedded costs” referred to by TCC in TN 494 is TCC’s total pole count of 826,663 from Telecom Decision 2010-900.  If not, please specify what this denominator is and describe, with supporting rationale, how TCC has arrived at this number.
3. Clarify, with supporting rationale, how the determinations of Telecom Decision 2014-645 have resulted in a reduction of 78,894 service poles from the denominator used to calculate TCC’s original pole embedded costs.

Question 2

In TN 494, TCC is seeking approval to recover proposed additional costs of $0.16 per month per billed unit for 518,715 billed units between July 2011 to June 2015.  TCC submitted that 518,715 billed units was the average number of billed units for the relevant period.  To support the Commission in its analysis, provide the information on billed units requested below.  The response is to incorporate the impacts of the determinations of Telecom Decision CRTC 2011-406 (the approval of service pole rates that are equal to pole rates) and Telecom Decision CRTC 2014-645 (withdrawal of invoices for privately owned service poles that TCC does not control):

1. For each of the years 2008 to 2014, provide the year-end information on billed units charged to licensees for the following:
   1. Total billed units for poles
   2. Total billed units for rental poles
   3. Total billed units for wholly owned and jointly owned poles
   4. Total billed units for owned service poles
   5. Total billed units for privately owned service poles for which TCC has an agreement in place through which it has the right to provide licensees with access to the poles
2. For each month of the time period from June 2011 to June 2015 provide the month-end information for the following:
   1. Total billed units for poles
   2. Total billed units for rental poles
   3. Total billed units for wholly owned and jointly owned poles
   4. Total billed units for owned service poles.
   5. Total billed units for privately owned service poles for which TCC has an agreement in place through which it has the right to provide licensees with access to the poles

Date modified:

2015-06-30