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

Gatineau, 2 October 2025

Reference: 8740-T66-202500108

BY EMAIL

Carol Ho
Senior Regulatory Advisor
TELUS Communications Inc.
10035 102 Ave NW, Floor 12
Edmonton, Alberta T5J 0E5
regulatory.affairs@telus.com

Subject: TELUS Communications Inc. Tariff Notice 599 – New Speed for Ethernet CO Connecting Link (AB/BC)

On 10 January 2025, the Commission received an application from TELUS Communications Inc. (TELUS) proposing revisions to its Carrier Access Tariff (CRTC 21462), Item 221, Ethernet CO Connecting Link Arrangements (“Ethernet CO Connecting Link” or “ECCL”) for its ILEC territory in the provinces of Alberta and British Columbia.

On 20 February 2025, the Commission approved TN 599 on an interim basis in Telecom Order 2025-53Footnote 1.

Commission staff notes that analysis is ongoing to approve final rates, but additional information is required. To assist in the analysis, Commission staff requests that TELUS provide responses to the following requests for information (RFI).

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

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 in the “Telecom Cover Page” located on the Commission’s website.

As set out in section 39 of the Telecommunications Act and in the 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

Attach. (1): Request for Information (RFI) Questions

Request for Information (RFI) Questions

For the following questions, the file “TELUS – TN-599 Att 1 Abridged” dated 10 January 2025 will be referenced as “the study report”, “TELUS – TN-599 Att 1, App 1 Abridged REVISED” dated 16 January 2025 will be referenced as “the monthly-recurring cost (MRC) cost study”, and “TELUS – TN-599 Att 1, App 2 Abridged REVISED” dated 16 January 2025 will be referenced as “the non-recurring cost (NRC) cost study”.

  1. Provide electronic copies (i.e., Excel spreadsheets) of the cost models used to calculate the proposed rates (MRC and NRC) provided in this application. Include all formulae and avoid the use of hard coded numbers that are not supported by either an internal/external reference, explanation or other supporting rationale. The populated model should include all the associated linked spreadsheet files that contain supporting data used to develop the costs. Additionally, a description of the input data variables, the vintage of the input data used, explanations of all modelling assumptions with supporting rationale, and any other pertinent costing information and details should be provided.
  2. Refer to the study report, page 9, paragraph 40. Explain in detail, with supporting rationale, values and calculations, how TELUS determined the annual corporate average repair and maintenance factor.

  3. Refer to the study report, page 4, Figure 1.

    1. Explain the technological purpose of the intermediate fiber patch panels (FPPs).
    2. Explain why three intermediate FPPs are required to provide connectivity as indicated in the figure, whereas only two FPPs are required per TELUS’s TN 663 application for its Quebec ILEC territoryFootnote 2.
    3. Demonstrate how the capital costs related to the intermediate FPPs are captured in the cost study.

  4. Refer to the MRC cost study, tab “Table 6a - Expenses”.

    1. Provide the source, supporting formulae, assumptions, and methodology used to determine the cost driver “Cumulative capex causal to demand and capex causal to the service”, namely the values in columns J-N, row 6.
    2. Explain how these values are causal to the ECCL service.

  5. Refer to the MRC cost study, tab “Table 6a – Expenses”, column C, row 20. For the Major Activity, “High-level customer interaction”:

    1. Provide the sub-tasks and time estimates, in minutes, such that each sub-task does not exceed 15 minutes in duration.
    2. Explain how each sub-task is causal to the ECCL service.
  6. Refer to the MRC cost study, tab “Table 6b – Capital”, column F, row 6. Explain in detail how this value was calculated, providing the supporting formulae, assumptions, methodology, and underlying factors.
  7. Refer to the MRC cost study, tab “Table 6b – Capital”, row 26. Provide and explain the methodology used to calculate the Major Capital Item “Shared Fiber from TELUS Network Equipment FPP to FPP on which Service Provider dedicated fiber cable terminates”. Include all sub-costs that make up this item. Include all formulae, assumptions, and methodology used to arrive at the value submitted in column P, row 26.

  8. Refer to the NRC cost study, tab “Table 6a – Expenses”. For each task in column D, rows 17-20, “Order processing”, “Design”, “Project management”, and “Turn up and testing activities”:

    1. Provide the sub-tasks and time estimates, in minutes, such that each sub-task does not exceed 15 minutes in duration.
    2. Explain how each sub-task is causal to the ECCL service.

  9. Refer to the NRC cost study, tab “Table 6a – Expenses”, row 25.

    1. Provide and explain the methodology used to calculate the “Billing code – license” Major Expense Item. Include all sub-costs that make up this item. Include all formulae, assumptions, and methodology used to arrive at the value submitted in column O, row 25.
    2. Explain how each sub-cost is causal to the ECCL service.
  10. If any of the above questions resulted in changes to the proposed costs, provide electronic copies of the updated TELUS cost study, the associated revised proposed rates, and cost information, while identifying and explaining each adjustment completed. Include all the associated linked spreadsheet files that contain supporting data used to develop the costs.
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