Telecom Commission Letter Addressed to Distribution List

Ottawa, 31 May 2018

Our reference: 8740-T66-201711250

BY EMAIL

Distribution List

RE:   TELUS Communications Inc. Tariff Notice 532B - Introduction of Service Entrance Conduit Charge – Additional Commission Staff Interrogatories

Further to Commission staff letter of 14 May 2018, please find attached additional staff interrogatories to TELUS Communications Inc. (TCI) related to the TN 532B application filed by TCI on 17 April 2018.

TCI is hereby requested to provide responses to these interrogatories, serving copies on all parties, by 22 June 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.

After the interrogatory process is complete, Commission staff will establish further process to ensure that all parties have sufficient opportunity to comment on TCI’s application.

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.

Sincerely,

Original signed by

Lyne Renaud
Director, Competitor Services & Costing Implementation
Telecommunication sector
c.c.: Lloyd, William, William.Lloyd@crtc.gc.ca
Krishnan, Trichur, Trichur.Krishnan@crtc.gc.ca

Distribution list:

TELUS Communications Company, regulatory.affairs@telus.com
Tom Woo, TELUS Communications Company, tom.woo@telus.com
Paul Cowling, Shaw Cable systems G.P., regulatory@sjrb.ca
Christopher J. Edwards, info@ccsa.cable.ca

Attach. (2)

  1. Interrogatories below
  2. Excel document attached in the email

TCI TN 532B – Service Entrance Conduit Interrogatories

  1. Refer to TCI’s response to interrogatory TELUS (CRTC)13March18-5, where the company stated the following:
  2. The ‘Engineering labour cost / Material cost’ as well as the ‘Installation labour cost / Material cost’ ratios “are calculated based upon detailed analysis of the cost transactions within TELUS asset management system. In this regard, TELUS uses five years of rolling historical data. Each transaction is assigned a cost element, which is in turn assigned to one or more cost types, e.g., engineering, material, etc. Since the five year historical data would result in an average ratio that is at least 2.5 years old, TELUS applies an overall trend in the corporate LMR to restate each estimate to the start of the study period.

  1. In the attached Excel spreadsheet ‘TCI TN 532B cost transaction summary - Interrogatory Attachment 2’, based on the company’s actual historical cost transaction data, fill in the Table provided with actual historical cost totals (i.e., total of all cost transactions), summarized by each cost component, for each of the five historical years, identifying the vintage year of the data. The cost data should be inputted at the lowest level it is available.  If the data for a particular cell is not available, mark it as ‘N/A’. 
  2. Provide the company’s rationale if the requested cost information in (i) above is not available at the lowest level required as shown in the spreadsheet.
  3. Explain whether the ‘five years of rolling historical data’ used by TCI is the same as the actual historical data for each of the five years provided in answer to interrogatory 1.(i) above, or is the actual historical data for each of the five years processed further to estimate the ‘five years of rolling historical data’? If the latter, explain clearly how the actual historical data is transformed into rolling historical data for each of the five years.  Further, provide the company’s rationale for using rolling averages instead of actuals.
  4. Based on the response to interrogatory 1.(i) above, explain in detail how TCI calculated an average ratio for each of ‘Engineering labour cost / Material cost’ and ‘Installation labour cost / Material cost’, resulting in a ratio that is 2.5 years old. Further, provide the sources, data (including vintage) and formula used by TCI to convert this ratio to the start of the study period.
  1. Refer to paragraph 29 of TCI’s submission on 4 May 2018 related to the company’s TN 532B application, where the company stated that it has assumed equal weighting of “internal” and “contract” engineering labour costs to allocate engineering costs uniformly between mainline and SEC.  Provide the company’s rationale and evidence to substantiate this assumption.
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