Search

Telecom - Staff Letter addressed to Carol Ho (TELUS)

Ottawa, 12 September 2024

Our reference: 8740-T66-202300177

BY EMAIL

Carol Ho
Senior Regulatory Advisor
TELUS
Floor 12
10035, 102 Avenue NW
Edmonton, AB, T5J 0E5
regulatory.affairs@telus.com

Subject: Associated with TELUS Communications Inc. Tariff Notice (TN) 576A – Amendment to Support Structure Service – request for information

On 5 July 2024, the Commission received an application from TELUS Communications Inc. (TCI) proposing changes to amend the language contained in its Support Structure Service, CRTC 24161, Item 404.2.8. On 9 August 2024, Rogers Communications Canada Inc. (Rogers) and Quebecor Media Inc. (QMI) filed interventions, to which TCI replied on 19 August 2024.

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. Commission staff considers that additional information is required in order to obtain a full and complete record in this proceeding.

As such, TCI, Rogers and QMI are requested to provide comprehensive answers, including rationale and any supporting information, to the attached requests for information by 26 September 2024. Parties may file reply comments by 3 October 2024.

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 responses or other documents to be submitted electronically by using the secured service https://crtc.gc.ca/eng/forms/form_index.htm and filling in the “Telecom Cover Page” located on this webpage. Copies of the answers and reply comments should also be sent to the other parties and to christine.brock@crtc.gc.ca at the same time.

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 ActFootnote1and in IB 2010-961,Footnote2 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.

Yours sincerely,

Original signed by Philippe Nadeau

Michel Murray
Director, Dispute Resolution and Regulatory Implementation
Telecommunications Sector

c.c.: Christine Brock, CRTC, 873-353-5852, christine.brock@crtc.gc.ca
Pamela Dismore, Rogers Communications Canada Inc., Pamela.Dinsmore@rci.rogers.com
Yanick Boily, Quebecor Media Inc., regaffairs@quebecor.com

Attach (1)

Request for information

  1. In paragraph 10 of the amended tariff application, TCI submitted that they would need to introduce new accounting practices and processes to separate compensation if they exclude Pole Cost Reimbursement from the calculation of compensation sharing. Provide a description of the new accounting methods that would need to be introduced and provide an example of the impact they would have on the Component C, Administrative Costs.
  2. For components A, Relocation Compensation Dollars, and B, Pole Cost Reimbursement, provide the following:
    1. The actual MOTI compensation payments received (split by component A and component B) for each pole relocation occurrence for the years of 2019 to 2024.
    2. A description of the instances that would cause component B to make up a larger percentage of component A.
  3. Regarding component C, Administrative Costs:
    1. Provide the following:
      1. Using the proposed formula, an estimate of the minimum, maximum, and average expected administrative costs. Also, provide the labour unit cost, time, and materials associated with each calculation.
      2. A complete list of material cost items that could or would be included in the calculation of component C.
      3. A detailed explanation of all formulae, assumptions, and rationale along with supporting documentation demonstrating the calculation.
    2. How can attachers be assured that TCI will not increase its declared administrative costs or amount of reimbursement related to poles to reduce the compensation to attachers?
    3. Should TCI provide in advance an estimate of the administrative costs (e.g. number of hours and charges) used for component C to attachers?
    4. Should the labour charge of component C be defined in TCI’s tariff, for example, as referenced in General Tariff 21461, item 405.3 note 4?
  4. Could a static administrative cost be adopted to reduce the administrative burden and to reduce calculation fluctuations?
    1. Provide a static predetermined average which could be used in place of component C in the formula along with a justification for the reasonableness of that figure.
    2. Provide a detailed explanation of the calculations, assumptions, and rationale along with supporting documentation.
  5. Should TCI be required to provide to attachers detailed information on the amounts used for the calculation of the compensation?
  6. In its proposed formula, TCI would provide the same compensation amount to all attachers. However, costs to relocate facilities could be unequal from an attacher to another. In such a situation, how would TCI formula be fair for all attachers?
Date modified: