Telecom - Staff Letter addressed to Carol Ho (TELUS Communications Inc.)

Ottawa–Gatineau, 30 January 2025

Our reference: 8740-T66-202402238

BY EMAIL

Carol Ho
Senior Regulatory Advisor, Telecom Policy & Regulatory Affairs
TELUS Communications Inc.
25 York Street, Floor 28
Toronto, ON, M5J 2V5
regulatory.affairs@telus.com

Subject: TELUS Tariff Notice 590 - Support Structure Pole Rental Rate Change – Supplemental Requests for Information

On 26 April 2024, the Commission received an application from TELUS Communications Inc. (TELUS) proposing updated tariff pages and proposed rates for TELUS's General Tariff CRTC 21461, Item 404 – Support Structure Service.

On 20 September 2024, Commission staff addressed requests for information (RFIs) to TELUS. In response, TELUS provided the requested information on 25 October 2024.

To clarify the responses referenced above, TELUS is to file responses to the supplemental RFIs set out in Attachment 2 of this letter.

In that respect, the process and associated dates are as follows:

• Commission staff requests that TELUS submit its respective responses to the attached requests for information (RFIs) no later than 21 February 2025.
• Parties can submit comments with respect to the response(s) to the attached RFIs, by 28 February 2025.
• Parties may file replies to the above noted comments by 7 March 2025.

Commission staff notes that its analysis is ongoing and further RFIs may be forthcoming in due course.

All documents filed and served must be received, not merely sent, by the date provided. Parties are to send an electronic copy of all documents to Commission staff copied on this letter.

The Commission requires the responses 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 the Commission’s website.

As set out in section 39 of the Telecommunications Act and in Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Broadcasting and Telecom Information Bulletin CRTC 2010-961, 23 December 2010, 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.:   Josée Line Gendron, CRTC JoseeLine.Gendron@crtc.gc.ca
Lauren Purdy, CRTC Lauren.Purdy@crtc.gc.ca
Distribution List

Attach. (2)

• Distribution List
• Requests for Information (RFI) Questions

Distribution List

TELUS Communications Inc. regulatory.affairs@telus.com
Bragg Communications Inc. regulatory.matters@corp.eastlink.ca
Quebecor Media Inc. regaffairs@quebecor.com
Rogers Communications Canada Inc. rwi_gr@rci.rogers.com
Lytton Area Wireless Society daniel@lyttonnet.com
BC Broadband Association admin@bcba.ca
CityWest Cable & Telephone Corp. denise.duncan@cwct.ca

Requests for Information

For the following questions, the file “TELUS Application TN-590 Attachment 1” dated 26 April 2024 will be referenced as “the report” and “TELUS Application TN-590 Attachment 2” dated 26 April 2024 will be referenced as “the cost study”. Additionally, the file “TN-590 RFI Responses – Attachment" dated 25 October 2024 will be referenced as “the request for information (RFI) response document”.

1. Refer to the report paragraph 24 regarding the warehouse & distribution (W&D) cost.
   1. Provide the specific formulae and the numerical values (including the numerators and the denominators) used to calculate the W&D factor.
   2. For each of the years 2018-2023, provide the mathematical functions and the numerical values used to calculate the associated W&D cost.
2. Refer to the RFI response document tab “RFI #10”, regarding vegetation and tree trimming. For each of the years 2018-2023, provide the following, including all values, calculations and assumptions:
   1. For “Climate Change/Vegetation costs for TELUS owned poles”, break down the total cost into two categories: climate change costs and vegetation costs.
   2. Further itemize and break down the total cost by:
      1. Labour-related costs (by Labour Unit Costs, time estimates, and total cost)
      2. Travel-related costs (by Labour Unit Costs, time estimates, and total cost)
      3. Categorized non-labour-related costs
   3. Confirm whether there are any climate change charges incorporated into the “TELUS’ contribution for vegetation and tree trimming of jointly owned poles with BC Hydro” cost item.
      1. If yes, break down the total cost into two categories: climate change costs and vegetation costs.
   4. Provide documentation and all supporting rationale, including any historical costs, to support the “TELUS’ contribution for vegetation and tree trimming of jointly owned poles with BC Hydro” costs.
3. Refer to the cost study tab “Loss in Productivity”.
   1. Refer to the intervention submitted by CityWest dated 5 June 2024, paragraph 29, related to average span length used to calculate the number of aerial cable spans installed in 2023. Per CityWest, a more reasonable average span length would approach 65m.
      1. Discuss and justify TELUS’ source and use of an average span length of 36.6m.
      2. Discuss, with supporting rationale, the use of a longer average span length in the calculation of the loss in productivity cost.
   2. Discuss the suitability of using Bell Canada’s (Ontario and Quebec) data as a proxy for the components of TELUS’ (Alberta and British Columbia) calculation of the Loss in Productivity cost, specifically:
      1. Average span length
      2. Additional time required due to the presence of third party attachers
      3. Percentage of spans with third party attachers
4. In the cost study tab “Pole and attacher counts”, TELUS indicated that in the sample of 29,525 poles there were 135,052 TELUS attachments and 90,087 third-party attachments. Complete the table below, amended from the RFI response document tab “RFI #15”, indicating the number of both TELUS and third-party attachments, and reconciling to the amounts noted in the cost study.

* 0 (zero) indicates that the pole only contains TELUS attachments.

Date modified:

2025-01-30