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

Gatineau, 2 October 2025

Reference: 8740-T69-202401719

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 663 – Changes to Ethernet CO Connecting Link (Quebec)

On 5 April 2024, the Commission received an application from TELUS Communications Inc. (TELUS) proposing revisions to its Access Services Tariff (CRTC 25082), Item 4.03, Installations de liaison de raccordement de central Ethernet (“Ethernet CO Connecting Link” or “ECCL”) for its ILEC territory in the province of Quebec.

Commission staff notes that analysis is ongoing 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-663 Att1 (Abridged)” dated 5 April 2024 will be referenced as “the study report” and “TELUS – TN-663 Att1 App1 (Abridged)” dated 5 April 2024 will be referenced as “the cost study”.

  1. Provide an electronic copy (i.e., Excel spreadsheets) of the cost model used to calculate the proposed rates 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. Provide a detailed explanation justifying the use of a single one-time charge for ECCL in this application - TN-663 – rather than the combination of a non-recurring charge and a monthly recurring charge such as those presented in TELUS’s TN-599 application.
  3. Provide a detailed explanation justifying the proposed rate increase from TELUS’s current ECCL 1G rate.
  4. Provide a detailed explanation justifying the difference between TELUS’s proposed rates for Quebec and those approved on an interim basis for Alberta and British ColumbiaFootnote 1.

  5. Refer to the study report, page 7, paragraph 32.

    1. Explain the technological purpose of the intermediate fiber patch panels (FPPs).
    2. Explain the rationale for the specific number of intermediate FPPs required.
    3. Demonstrate how the capital costs related to the intermediate FPPs are captured in the cost study.
  6. Refer to the study report, page 8, paragraph 35. Explain in detail, with supporting rationale, values and calculations, how TELUS determined the annual corporate average repair and maintenance factor.
  7. Refer to the study report, page 8, paragraph 36, regarding the “Service Provisioning” cost. Provide a detailed list of and quantify the costs that form this cost category for both the 1G and 10G speeds.
  8. Refer to the cost study tab “Table 4”. Provide a revised Table 4 containing the appropriate financial parameters for the province of Québec, as outlined in TELUS’s Regulatory Economic Studies Manual, Appendix V, Table 1.
  9. Refer to the cost study, tabs “1G Link” and “10G Link”. For the maintenance costs found in column D, row 24 of each tab, provide the supporting formulae, assumptions, and methodology applied.
  10. Refer to the cost study, tabs “1G Link” and “10G Link”, columns D-E, row 10. Explain, in detail, why a “Billing – Related” cost is applicable to the 10G speed but not applicable to the 1G speed.
  11. Refer to the cost study, tabs “1G Link” and “10G Link”. Provide a detailed explanation justifying the difference between the “Service Provisioning” cost proposed for the 1G speed and the 10G speed.

  12. Refer to the cost study, tab “Table 6a – Expenses 1G”.

    1. Provide and explain the methodology used to develop the SME time estimates in column I, rows 18 and 19, for the “process map development” and “ongoing product management” activities, respectively.
    2. For each Major Activity, “process map development” and “ongoing product management”, provide the sub-tasks and time estimates, in minutes, such that each sub-task does not exceed 15 minutes in duration.
    3. Explain how each sub-task is causal to the ECCL service.

  13. Refer to the cost study, tab “Table 6a – Expenses 10G”.

    1. Provide and explain the methodology used to develop the SME time estimates in column I, rows 18 and 19, for the “process map development” and “ongoing product management” activities, respectively.
    2. For each Major Activity, “process map development” and “ongoing product management”, provide the sub-tasks and time estimates, in minutes, such that each sub-task does not exceed 15 minutes in duration.
    3. Explain how each sub-task is causal to the ECCL service.
    4. Provide a detailed explanation justifying the difference between the SME time estimates provided for the 1G speed and the 10G speed.
  14. Refer to the cost study, tab “Table 6a – Expenses 1G”, row 24. Provide and explain the methodology used to calculate the “Fiber build” cost. Include all sub-costs that form this Major Expense Item. Include all formulae, assumptions, and methodology used to arrive at the value submitted in column O, row 24.
  15. Refer to the cost study, tab “Table 6a – Expenses 10G”, row 24. Provide and explain the methodology used to calculate the “Fiber build” cost. Include all sub-costs that form this Major Expense Item. Include all formulae, assumptions, and methodology used to arrive at the value submitted in column O, row 24.

  16. Refer to the cost study.

    1. Provide a tab “Table 6b – Capital” for the 10G speed.
    2. Provide a detailed explanation for the difference in capital costs for the 1G and 10G links.
  17. Refer to the cost study, tab “Table 6b – Capital 1G”, columns J-O, row 6. Explain in detail how the incremental cost driver demand forecast values were determined. Include all supporting formulae, assumptions, and methodology.
  18. Refer to the cover letter submitted by Bell Canada under its Tariff Notice 7685, dated 16 January 2024. Paragraph 2 states, “As there are no material differences in the cost to provision a 100GE Ethernet Central Office Link than for a 10GE or 1GE link […]”. Comment on this statement by Bell Canada and provide a detailed explanation for why TELUS’s proposed cost for the 10G service is greater than the proposed cost for the 1G service.
  19. 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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