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Telecom - Commission Letter addressed to Carol Ho (Telecom Policy & Regulatory Affairs)

Ottawa, 14 January 2022

Our reference: 8740-T66-202107490

BY EMAIL

Carol Ho
Senior Regulatory Advisor
Telecom Policy & Regulatory Affairs
510 West Georgia St, Floor 7
Vancouver BC V6B 0M3
carol.ho@telus.com

Re:  Associated with TELUS Tariff Notice 565 – Introduction of Next Generation 9-1-1 (NG9-1-1) Service- Requests for Information

Dear Carol Ho,

On 1 November 2021, the Commission received an application from TELUS Communication Inc. (TELUS) pursuant to Telecom Regulatory Policy CRTC 2017-182 Footnote1 and Telecom Decision 2021-199 Footnote2 , requesting approval for proposed changes to General Tariff CRTC 21461 to introduce item 1001 – Next generation 9-1-1 (NG9-1-1) Service. In Decision 2021-199, the Commission directed all NG9-1-1 network providers to file proposed wholesale and retail tariffs no later than 1 November 2021. These tariffs are to include proposed rates supported by cost studies that reflect the incremental costs of adding new NG9-1-1 networks, services, and functionalities. 

Commission staff requests that TELUS respond to the attached request for information by 31 January 2022. Please note 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 “Broadcasting and Telecom Cover page” or the “Broadcasting Cover Page” located on the Commission’s website. There, you will also find information on the submission of applications to the Commission “Filing Broadcasting and Canadian Program Certification documents with the CRTC: Privacy and Security.”

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

As set out in section 39 of the Telecommunications Act Footnote3 and in Broadcasting and Telecom Information Bulletin CRTC 2010-961 Footnote4 , 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 designated information is 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.

Sincerely,

Original signed by

Chris Noonan
Director, Competitor Services & Costing Implementation
Telecommunications Sector

c.c.: B. Natraj (Nat Natraj), CRTC, 819-953-5081, nat.natraj@crtc.gc.ca
Stais Armstrong, CRTC, 819-997-9253, stacey.armstrong@crtc.gc.ca

Attach. (1)

NG9-1-1 Request for information

  1. Refer to Attachment 1 (Abridged) of TELUS Communications Inc. TN 565 titled “Report on the Economic Evaluation for Introduction of Next Generation 9-1-1 Voice Services” (Study report) dated 1 November 2021:
    1. Refer to paragraphs 16 and 18 where TELUS stated:
      •  “TELUS has contracted a third-party vendor to install and operate Next Generation Core Services (NGCS) for the Company.”
      • At paragraph 18, TELUS stated that it operates the LIS Footnote5 and ADR Footnote6 and offers to host these functionalities on behalf of the ONPs. In its response to extensions and disclosure request Footnote7 dated 18 November 2021, TELUS indicated that its vendor contract for the NG9-1-1 core service was priced as a single component and LIS and ADR costs are not specifically identified or described within the contract. Hence, TELUS indicated that it cannot provide the costs of the LIS and ADR components.
        1. Confirm that this is so.
        2. If a breakdown is possible, provide your best estimate of the LIS and ADR breakdown from the third-party vendor contract.
    2. Refer to paragraph 50:
      1. Explain with supporting rationale why the percentage used to exclude costs Footnote8 based on the percentage of population Footnote9 methodology detailed in this paragraph is a good proxy to estimate costs recovered through commercial agreements. The response should address why the population served by CityWest is included in the calculation.
      2. Provided the name of the other ILECs that partially rely on TELUS’ NG9-1-1 network for providing service in their operating territory.
    3. Refer to paragraph 82, paragraph 83 and diagram 5:
      1. Explain in which costing line item the costs of the equipment relating to Central Office Readiness for Hosting NGCS are included. Provide the Attachment name, tab name, and the applicable row and column reference where the above costs are included.
    4. Refer to paragraph 113, where TELUS stated that “TELUS will pay the vendor a fee for implementing and updating routing policies for the NGCS once the service is launched.”
      1. Explain what “updating routing policies” represents.
      2. Explain if the vendor fee includes the transport of calls to the NGCS/ESInet. If the transport of calls is not included in the vendor fee, explain where it is included.
    5. Refer to paragraphs 116 and 117 (and Item 7.1.2 “Service fees for TELUS Quebec Wireline”) where TELUS indicates that it has an agreement with a third-party NG9-1-1 service provider to provide NG9-1-1 service for TELUS Quebec Wireline:
      1. Does the proposed NG9-1-1 monthly recurring fee in paragraph 117 for TELUS Quebec cover all of the applicable start-up costs and annual fees Footnote10 applicable to TELUS Quebec Wireline?
      2. If the proposed NG9-1-1 service fee for TELUS Quebec Wireline does not cover all of the applicable start-up and annual fees applicable to TELUS Quebec Wireline, provide a revised rate with all start-up and annual costs included.
  2. Refer to “TELUS Communications Inc. - TN-565 Att 2  Abridged”
    1. Refer to tab “Impute W”
      1. Provide revised Tables 1 and 2 that include third-party costs for TELUS operating territories of Alberta and British Columbia only when calculating wholesale and retail costs and NG9-1-1 rates for Alberta and British Columbia.
      2. Explain, with supporting rationale, why and how the company separated third-party costs between wholesale and retail. The response should address if there are different requirements for wholesale and retail NG9-1-1 service. If there are not different requirements for wholesale and retail NG9-1-1 service, explain why an average cost for the third party costs is not appropriate.
        1. Provide a revised tab “Impute W” based on third-party costs averaged over wholesale and retail demand.
      3. Explain the differences between the values in Tab “Impute W” in Table 1 (under column “3rd party services (K)” for row items “Causal to Service” and “Causal to Demand” (for wholesale and retail) as compared to the values shown in “Table 8a” columns “NG911 Wholesale Present Worth of Costs($K)”, “NG911 Retail Present Worth of Costs($K)” respectively.
    2. Refer to tab “Table 3”:          
      1. Confirm that the wholesale demand does not include wholesale wireless.
      2. For row item “Retail”, provide the list of retail services included in this demand category.
      3. Confirm that the row item “Non-tariffed” reflects TELUS retail wireless demand. If this is the case, rename this row item “Wireless” and provide the demand broken down between TELUS Wireless retail and Wholesale Wireless non-TELUS. If not, explain what it reflects.
    3. Refer to tab “NG911”:
      1. If the demand in column “Wholesale” (row item “Present Worth of Major Demand (000s)”) does not include wholesale wireless, provide a revised “Table 5- NG911 Detailed Summary of Causal costs”, estimated using the all carrier demand, including demand for wireless services.   
      2. If any adjustments are required given the above questions, make any applicable changes to the Tabs “Table 3” and “Impute W” and provide the updated data.
    4. Refer to tab “Table 6a – Expenses”, row 10 titled “Default Call Routing”:
      1. Explain how the “Cost Driver Demand Forecast (thousands)” for each of column J through N in row 10 were estimated. The response should provide the methodology, assumptions and detailed calculations used to estimate the cost drivers.
      2. Confirm if the cost driver in each instance is NG9-1-1 calls.
    5. Refer to TELUS Regulatory Economic Studies Manual and provide the table “Table 6b Capital” for all hardware and software costs.
    6. Refer to tab “Table 8c Third Party Costs”:
      1. Explain how the “Cost Driver Demand Forecast” provided in each of the columns L through P was estimated for each of the rows under the column “Third Party Activity”. The response should include the methodology, assumptions and detailed calculations used to calculate the demand.
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