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Telecom - Commission Letter addressed to Carol Ho (TELUS)

Ottawa, 24 September 2021

Our references:  8740-T42-202105965, 8740-T46-202105973, 8740-T69-202105981

BY EMAIL

Carol Ho
Senior Regulatory Advisor
Telecom Policy & Regulatory Affairs
TELUS
510 West Georgia St. Floor 7
Vancouver, B.C. Halifax, Nova Scotia
V6B 0M3
carol.ho@telus.com

RE:  Telus Communications Inc. Tariff Notice 677, Telus Communications (B.C.) Inc. Tariff Notice 4406, Telus Communications (Quebec) Inc. Tariff Notice 641 – Connection to in-building Wire

Dear Carol Ho:

On 27 August 2021, the Commission received applications from Telus Communications Inc. (TELUS) under the following Tariff Notices proposing to update these tariffs pursuant to Access to in-building wire in multi-dwelling units, Telecom Regulatory Policy CRTC 2021-239, 27 July 2021 (TRP 2021-239):

  1. Under TN 677, revisions to TCI’s Carrier Access Services Tariff CRTC 18008, Item 215 - Local Network Interconnection and Component Unbundling;
  2. Under TN 4406, revisions to Telus Communications (B.C.) Inc.’s Carrier Access Tariff CRTC 1017, Item 105 – Local Network Interconnection and Component Unbundling, and;
  3. Under TN 641, revisions to Telus Communications (Québec) Inc.’s Access Services Tariff CRTC 25080 -  Section 1.05, Interconnexion de réseaux locaux et dégroupement des composantes réseau.

Paragraph 28(1)(a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure provides that the Commission may require parties to file information or documents where needed. TELUS is requested to provide comprehensive answers, including rationale and any supporting information, to the attached questions by 5 October 2021.

On receipt of the company responses, interested parties may file comments by 15 October 2021 in response to only the new information provided in this request for information and TELUS may file reply comments by 21 October 2021.

As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation on why the relevant information qualifies for designation as confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.

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.The Commission requires the response or other documents to be submitted electronically by using the secured service “My CRTC Account” (Partner Log In or GCKey) and filling the “Telecom Cover page” located on this web page. 

A copy of this letter and all subsequent replies will be added to the public record of this proceeding.

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector
c.c: Joanne Baldassi, CRTC, 819-997-3498, joanne.baldassi@crtc.gc.ca
Philippe Gauvin, Bell Canada, bell.regulatory@bell.ca
Lori MacLean, Eastlink, lori.maclean@corp.eastlink.ca

Attach. (1)

Request for Information

In TRP 2021-239, the Commission issued a number of determinations regarding access to in-building wire (IBW) in multi-dwelling units (MDUs). Among other things, the Commission directed all local exchange carriers (LECs) that have responsibility for, and control of, copper IBW in an MDU to file proposed amended or new tariff pages, within 30 days of the date of that decision, in order to provide all carrier Internet service providers (ISPs) that provide their facilities to the MDU with access to copper IBW in MDUs, on the same basis as registered LECs. Footnote1

Commission staff notes that the wording proposed by the various companies in their tariffs does not accurately reflect the wording in TRP 2021-239. Several tariffs indicate that the companies will permit the “CLEC or carrier ISP” to connect to and use the company’s copper in building wire at no charge, as opposed to the “LEC or carrier ISP.”

  1. Explain, with supporting rationale, why the company has chosen to use wording that is inconsistent with the directive in TRP 2021-239.
  2. Explain why it would not be appropriate to modify the companies’ current wording of “CLEC and carrier ISP” to “LEC and carrier ISP”, which would more accurately reflect the wording of TRP 2021-239. If the wording of TRP 2021-239 would otherwise be appropriate, submit revised tariff pages for each company reflecting that wording.
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