Telecom Commission Letter Addressed to Distribution List
Ottawa, 13 March 2018
Our reference: 8740-T66-201711250
RE: TELUS Communications Inc. Tariff Notice 532 - Introduction of Service Entrance Conduit Charge - Request for additional information
Dear Madam, Sir:
On 30 November 2017, the Commission received an application from TELUS Communications Inc. (TCI), Tariff Notice (TN) 532, in which the company proposed a revision to its General Tariff (CRTC 21461) Item 404, Support Structure Service, introducing a charge for service entrance conduit in British Columbia (B.C.).
TCI is hereby requested to provide responses to the attached Commission staff interrogatories, serving copies on all parties, by 3 April 2018. The information provided in response to the interrogatories should be disclosed in accordance with the guidelines established in Confidentiality of Information used to establish wholesale service rates – Telecom Regulatory Policy CRTC 2012-592 (TRP 2012-592), dated 26 October 2012.
Parties may file additional written comments with the Commission solely in relation to the responses to the interrogatories serving copies on all interested parties, by 13 April 2018. TCI may file reply comments with the Commission by 20 April 2018.
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.firstname.lastname@example.org
Original signed by Abderrahman El Fatihi for
Director, Competitor Services & Costing Implementation
c.c.: El Fatihi, Abderrahman, Abderrahman.email@example.com
TELUS Communications Company, firstname.lastname@example.org
Tom Woo, TELUS Communications Company, email@example.com
Paul Cowling, Shaw Cable systems G.P., firstname.lastname@example.org
TCI TN 532 – Service Entrance Conduit
- Refer to Item 404.1 of TCI’s proposed tariff pages filed as part of Tariff Notice (TN) 532 application filed on 30 November 2017, where the company defines a “Service Entrance Conduit” (SEC) as extending from a service box on public property through to the point of interconnection on the outside wall or inside the customer’s premises on private property.
- Confirm whether the SEC, for which TCI is proposing a new rate, includes only the portion on the public property (and excludes the portion on the private property), or it extends from the service box on the public property to the point of interconnection on the outside wall or inside the customer’s premises on private property.
- If the SEC includes the portion on the on private property as well, explain how it is consistent with charges applicable for facilities on the private property (i.e. Item 406 – Construction Charges and Item 404.2.20 Service Entrance Conduit on Private Property).
- Refer to the ‘Report on the Economic Evaluation for Wholesale Access to Service Entrance Conduit in British Columbia’ (‘the Study Report’), filed as an attachment to TCI’s TN 532 application, where, at Paragraph 17 TCI submitted that ‘the embedded capital cost amount of TELUS’ conduit structure is accumulated in the asset class A70 – Conduit Structures’.
- With regards to B.C. SEC costs, confirm whether this asset class A70 includes only the engineering costs related to SEC on public property.
- If not, identify what other types of cost elements associated with B.C. SEC are included in this asset class. Further, explain how it is consistent with charges applicable for facilities on the private property (i.e. Item 406 – Construction Charges, Item 404.2.19 - Conduit on Private Property, and Item 404.2.20 - Service Entrance Conduit on Private Property).
- Refer to ‘the Study Report’, ‘Table 1: Total Embedded Cost Data’.
- Provide this Table in an Excel spreadsheet showing all the formulas used, as appropriate.
- Refer to the row titled ‘Number of Conduit’ in Table 1.
- Specify whether each of these input data includes mainline conduit only, service entrance conduit (SEC) only, or both.
- Provide source and vintage of these data as well as how each of these values are estimated. Clearly indicate whether these numbers represent annual or monthly (i.e., annual times 12) demand, and whether it includes total TCI and competitor demand together, or competitor demand only.
- Refer to ‘the Study Report’, ‘Table 1: Total Embedded Cost Data’.
- For the row ‘Embedded cost (original or book value)/ unit’, identify all cost elements included under each column (i.e., material cost, installation labor, engineering labor, etc.).
- Using an excel spreadsheet, provide a detailed derivation of how the each of embedded cost, NBV depreciation numbers per unit were calculated for each of the column in Table 1, starting with the original data in asset class 70 of TCI’s SAP financial records system. The response should also identify any other sources of data and / or assumptions used. The calculations should clearly show how the engineering costs associated with SEC are derived, including adjustments made to reflect a higher weighting of the engineering costs associated with SEC as explained in paragraph 19 of the ‘Study Report’.
- Refer to TCI’s reply submission to Shaw’s comments, filed on 17 January 2018, paragraph 14, where TCI stated that the total annual engineering labour cost portion associated with asset class A70 is calculated by applying the labour-to-material ratio specific to engineering labour. In the Excel spreadsheet,
- Provide a detailed derivation of the engineering labour to material ratio for TCI’s asset class A70. The response should clearly identify what is included in the numerator (i.e. installation labour, engineering labour, or both combined) as well as what is included in the denominator (material cost only or total material, labour and engineering costs).
- Provide a detailed derivation of the engineering costs using the ratio in a) above.
- Confirm that the engineering labour to material ratio was applied only to material costs in asset class A70. If the response is yes, explain how the material cost only was calculated from the total costs in asset class A70. If not, explain why with supporting rationale. Further, provide a revised calculation of engineering costs where the engineering labour to total costs ratio (show calculation) is applied against total cost in asset class A70.
- Refer to the Study Report, Section 5.0, Table “Results and Template”, where TCI provided details on the calculation of ‘Monthly cost per billing unit’ of SEC in B.C.
- Provide in an Excel spreadsheet and in the same format the calculation of ‘Monthly cost per billing unit’ of SEC in B.C showing all formulas used, and where appropriate, links to other values in the in the spreadsheet.
- For the items ‘Maintenance’ and ‘Other Costs (Indirect labour loading)’ in this table, provide the sources and vintage of data as well as the calculations used to derive these costs.
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