ARCHIVED - Telecom Commission Letter addressed to Michelle Dupuis (TELUS Communications Inc.)

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Ottawa, 4 December 2018

Our reference:  8740-T66-201809039


Ms. Michelle Dupuis
Senior Regulatory Legal Counsel
Telecom Policy & Regulatory Affairs
215 Slater Street
Ottawa, Ontario  K1C 6Y3

RE:  TELUS Communications Inc. Tariff Notice 542 - Introduction of a 150 Mbps wholesale Internet ADSL service speed for residential and business services - Request for additional information

Dear Madame Dupuis:

On 22 October 2018, the Commission received an application from TELUS Communications Inc. (TCI), Tariff Notice (TN) 542, in which the company proposed a revision to its Carrier Access Tariff (CRTC 21462) Item 226, Wholesale Internet ADSL Service, introducing a new speed component – 150 Mbps Residential and Business Services.

TCI is hereby requested to provide responses to the attached Commission staff interrogatories by 12 December 2018, serving copies on all parties.

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.

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.


Original signed by

Lyne Renaud
Director, Competitor Services & Costing Implementation
Telecommunication sector

c.c.:  El Fatihi, Abderrahman,
Distribution List

Attach. (1)

Distribution List:

Lyne Renaud, CRTC,
Abderrahman El Fatihi, CRTC,;
David Mah, CRTC,;
Michelle Dupuis, TELUS Communications Company,
Bell Canada:;
MTS Inc.:;
Zayo Canada Inc.:;
Saskatchewan Telecommunications:;
TELUS Communications Company:;
Cogeco Cable Inc.:;
Quebecor Media Inc. (Videotron):;
Rogers Communications Canada Inc.:;;
Nathan Jarret:;;
Shaw Cablesystems G.P.:;
CNOC Regulatory: ;
TekSavvy Solutions Inc.:;
Vaxination Informatique:;
VMedia Inc.:;
Steve Sorochan:;
Darren Parberry:;
Marcus Schultze:;
Kathleen Turnsek:;
Tacit Law:;
Distributel Communications Limited:;

TCI TN 542

  1. Refer to the “CashFlows” worksheet in Excel Workbook “TCI TN 542 – D2 – Cost Collator – WS – Internet ADSL 150 (-26.4% CIFs)” and Excel Workbook “TN 542 - Support Service start-up costs- 150 ADSL” where TCI included the following five service start-up cost service elements:
    • Retail and Wholesale – service development costs to support residential and business service streams;
    • Wholesale – Business Transformation and Operation service development costs;
    • Wholesale – Partner Solutions marketing costs;
    • Wholesale – Billing Code development; and,
    • Wholesale – Process adjustments and training.
    1. Explain with supporting rationale, why the above referenced start-up costs should not qualify as “Pre-Introduction Expenses - Sunk expenses” and should be excluded from the cost studies, consistent with Telecom Decision CRTC 2008-14 Footnote1 .
    2. Explain with supporting rationale why the company assumed that the start-up costs referenced above (except for Wholesale – Business Transformation and Operations) are assumed to apply only to the development of 150 Mbps Internet DSL service and not for all other lower speeds.
    3. For “Wholesale – Business Transformation and Operations service development costs” service element:
      1. Provide the sources of input data, methodology, assumptions and calculations used to estimate the number of “hours” as well as the “Avg. $ /hr” for each of the sub-activities identified therein.
      2. Explain with supporting rationale why the company allocated the costs equally to 75 Mbps and 150 Mbps services. The response should also address why these costs are not assigned to other speeds.
    4. For each of the following (i) Retail and Wholesale – service development costs to support residential and business service streams and (ii) Wholesale – Business Transformation and Operation service development costs, update the description provided so as to provide a clear and concise description of what functions or tasks are performed.
    5. For each of the following: (i) “Wholesale – Billing Code development”; and (ii) “Wholesale – Process adjustments and training, identify and provide a short description of each of the major sub-activities.  Also provide costs associated with each major sub-activity.
    6. Expand any acronyms/abbreviations used in the tables where the above referenced start-up costs are provided.
    7. For the “Retail and Wholesale – service development costs to support residential and business service streams” service element:
      1. Provide the sources of input data, methodology, assumptions and calculations used to estimate these costs.
      2. Explain with supporting rationale how the company assigned these costs to retail and wholesale services.
  2. Confirm whether the life estimates of the capital expenditures associated with the start-up costs have been approved by the Commission, if so provide decision number. If not, provide a detail description explaining how the company has estimated these life estimates.
  3. Refer to the “Input Sheet” worksheet in Excel Workbook “TELUS - TN_542 - D2 EASE WS Internet ADSL 150 (-26.4% CIFs).XLS” where all capital and expense cash-flows are labelled as “one-time”. Explain whether the company has treated all these cash-flows as “one-time” cash flows in the cost model and if so provide rationale for this assumption.
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