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

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Ottawa, 15 December 2015

Our reference:  8740-T66-201503970


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

RE:  TELUS Communications Company Tariff Notice 494 – Requests for Information

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. TCC is to provide its responses to the attached questions by no later than 22 January 2016. Any party that has already submitted comments on TN 494 may subsequently comment on TCC’s response by 5 February 2016. Thereafter, TCC may reply to the points raised by the interveners by 12 February 2016. These submissions must be received, not merely sent, by that date.


Original signed by

Lyne Renaud
Director, Competitor Service & Costing Implementation
Telecommunications Sector

c.c.:  Curtis Eagan, Analyst, CRTC, 819-953-4947,
MTS Allstream,

Attach. (1)

Appendix 1 -- Request for Information

In order to assist the Commission in its analysis, please respond to the questions below:

Question 1
Confirm the total number of poles for which TCC withdrew invoices or provided refunds pursuant to Telecom Decision 2014-645 in (a) Alberta and (b) British Columbia.

Question 2
Please provide TCC’s total count of mainline poles that TCC wholly owns and jointly owns in:

  1. Alberta
  2. British Columbia
  3. Both Alberta and British Columbia combined

Question 3
TCC has submitted the total number of its service poles in confidence with the Commission, which it further broke down into number of billable service poles, which was also submitted in confidence, and number of service poles on private property, which was submitted on the public record.  TCC submitted that these numbers were the result of the census conducted by the company pursuant to Decision 2014-265Footnote 1

  1. Please confirm whether the number of billable service poles includes billable service poles for both Alberta as well as British Columbia. If not, provide TCC’s estimate of the number of billable service poles in these two provinces that have not been included. Explain how the estimate is determined and provide a breakdown by province.
  2. Please confirm that the number of billable service poles is equal to the number of service poles owned and controlledFootnote 2 by TCC. If not, provide the number of service poles owned and controlled by TCC in (i) Alberta, (ii) British Columbia, (iii) both Alberta and British Columbia combined
  3. What is TCC’s rationale for filing the total number of service poles and the number of billable service poles in confidence?

Question 4
TCC has submitted that it is responsible for maintaining poles located on private property.Footnote 3 In Telecom Decision 2014-645, the Commission determined that TCC “does not provide support services” in respect of service poles that it does not own or control.  Accordingly, the Commission directed TCC to withdraw invoices to Raftview Communications Ltd. and similarly placed licensees for such service poles.
In light of the above please respond to the following questions:

  1. In TCC’s view, is it responsible for maintaining any poles that it does not own or control and is this dependent on where the poles are located?  Please reference the specific tariff items (or sub-items, if applicable) or Commission determinations that support this view and explain why this is the case.
  2. In TCC’s view, is it appropriate to recover costs associated with maintaining service poles that it does not own or control from licensees if it does not provide support structure services in respect of such poles and cannot bill licensees in respect of such poles?
  3. Refer to TCC’s response to TELUS(CRTC)17Jun10-4 in Telecom Notice of Consultation CRTC 2009-432, where the company provided its pole maintenance costs for 2007, 2008, and 2009. If TCC has included maintenance costs associated with poles it does not own or control in the above response, specify the dollar amount of these maintenance costs for each of the years 2007, 2008 and 2009. In addition, explain in detail, with supporting rationale how these maintenance costs have been determined.

Question 5
During the proceeding leading up to Telecom Decision 2011-406Footnote 4, TCC noted in paragraph 6 of its 14 March 2011 reply comments that “service poles are not required for all customers” and that in TCC’s view, “the percent-utilization factor also provides a reasonable approximation of the number of service poles used by third parties and an appropriate proportion of service pole costs in the pole costs attributable to third parties.” Is this a view that TCC still holds? If not, please explain how and why TCC’s view has changed.


Footnote 1

SeeTCC reply to comments on TELUS(CRTC)30June15, TN494 , dated 7 August 2015, para. 14

Return to footnote 1

Footnote 2

owned or controlled poles refers to poles that, irrespective of their location: (1) TCC wholly or jointly owns or; (2) are privately owned but for which TCC has an agreement in place through which it has the right to provide licensees with access to the poles. These should not include the poles that TCC withdrew invoices for as a result of the determinations of Telecom Decision CRTC 2014-645.

Return to footnote 2

Footnote 3

See TCC reply to comments on TELUS(CRTC)30June15, TN494 , dated 7 August 2015, paras. 9 – 13.

Return to footnote 3

Footnote 4

Follow-up to Review of the large incumbent local exchange carriers’ support structure service rates, Telecom Decision CRTC 2010-900 (File No.: 8638-C12-201017137)

Return to footnote 4

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