ARCHIVED - Telecom Procedural Letter Addressed to the Distribution List

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Ottawa, 14 May 2018

Our reference: 8740-T66-201711250


Distribution List

Re: TELUS Communications Inc. Tariff Notice 532B - Introduction of Service Entrance Conduit Charge

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 (SEC) in British Columbia (BC). The application included a supporting cost study as well as a proposed rate for the SEC service in BC. On 17 January 2018, TCI submitted TN 532A to further clarify the nature of the company’s SEC service.

On 17 April 2018, TCI filed with the Commission TN 532B, as an amendment to TN 532A, including a revised cost study as well as a revised proposed rate for the SEC service.

On 24 April 2018, the Commission received intervention on TCI’s TN 532B application from Shaw Cablesystems G.P. (“Shaw”) and a submission from the Canadian Cable Systems Alliance (“CCSA”) supporting Shaw’s intervention.

On 4 May 2018, the Commission received TCI’s reply comments in response to Shaw’s and CCSA’s interventions.

On 8 May 2018, Shaw filed additional intervention in response to TCI’s reply comments, and on 10 May 2018, TCI filed further response to TCI’s intervention, submitting that Shaw’s letter on 8 May 2018 is out of process and should be immediately struck from the record of the Application.

Additional Intervention by Shaw (8 May 2018)

The additional intervention filed by Shaw on 8 May 2018 does not conform to the revised dates for the TN 532 interrogatory process set by Commission staff on 29 March 2018. Commission staff considers this additional intervention out of process, and, therefore, will not be entered as part of the record of this proceeding.

Procedural Relief Request by Shaw

In its 24 April 2018 intervention, Shaw requested the following procedural relief from the Commission, with regard to TCI’s TN 532B application, that:

  1. TCI be directed to amend TN 532B to provide for a proposed effective date of the service that is at least 30 calendar days after the date when TCI files a complete tariff application as well as its interrogatory responses dated 17 April 2018 with the appropriate level of public disclosure, on the Commission’s public record;
  2. TCI be directed to provide public disclosure of certain information in the TN 532B Cost Study and in TCI’s 17 April 2018 responses to the Commission’s request for information, as detailed in Shaw’s intervention submission; and,
  3. interested parties be provided with at least 30 calendar days after the date when TCI has served and filed a complete tariff application on the Commission’s public record to comment on TN 532B.

With regard to Shaw’s request for TCI to amend its TN 532B application to defer the proposed effective date of the SEC service, Commission staff considers that this issue will be addressed by the Commission when it renders the final decision on TCI’s application.

With regard to Shaw’s request for further public disclosure of certain information related to this TNFootnote1 , Commission staff notes that having reviewed the details of the proposed TN and the participants’ submissions on the disclosure of confidential information on the public record, the potential harm to TCI in disclosing such information outweighs the benefits to the other parties as submitted by Shaw. The specific and narrow scope of TN 532 requires a different threshold for disclosure compared to other proceedings, where the Commission may have released similar information on the public record. Therefore, no further disclosure from TCI is required under TNs 532/532A and 532B.

Shaw also requestedFootnote2 for TCI to provide on the public record, in an Excel spreadsheet, the calculation of ‘Monthly cost per billing unit’ of service entrance conduit in the Province of British Columbia, including all formulas and input data used. TCI has provided this information in the abridged version of the economic study report on TN 532B, and no further disclosure in an Excel spreadsheet is required.

Commission staff will issue further process, including additional interrogatories to TCI on TN 532B, in the coming days.  Commission staff anticipates a further round of comment and reply after the interrogatory process is complete, to ensure that all parties have sufficient opportunity to comment.


Original signed by

Lyne Renaud
Director, Competitor Services & Costing Implementation
Telecommunication sector

c.c.: Lloyd, William,
Krishnan, Trichur,

Distribution list:

TELUS Communications Company,
Tom Woo, TELUS Communications Company,
Paul Cowling, Shaw Cablesystems G.P.,
Christopher J. Edwards,

Date modified: