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

Gatineau, 19 March 2026

References: 8740-T69-202401719, 8740-T66-202500108, 8740-T66-202506048

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. – Ethernet CO Connecting Link Tariff Notices – Requests for Information

On 5 April 2024, the Commission received an application, Tariff Notice (TN) 663, 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.

Further, on 10 January 2025, the Commission received an application (TN 599) from TELUS proposing revisions to its Carrier Access Tariff (CRTC 21462), Item 221, Ethernet CO Connecting Link Arrangements for its ILEC territory in the provinces of Alberta and British Columbia.

Lastly, on 5 December 2025, the Commission received an application (TN 610) from TELUS proposing additional revisions to its Access Tariff (CRTC 21462), Item 221, Ethernet CO Connecting Link Arrangements 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 2025-53.

Commission staff sought clarification on TN 663 and TN 599 through requests for information (RFI) to TELUS sent 2 October 2025. In response, TELUS provided its answers on 21 November 2025.

To supplement the information received from responses to the previous RFI, as well as to provide additional information related to TN 610, TELUS is to file a response to the RFI set out in Attachment 1 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 RFI no later than 30 April 2026.
• Parties can submit comments with respect to the response(s) to the attached RFI by 14 May 2026.
• TELUS may file a reply to the above noted comments by 21 May 2026.

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
Michael Holmes, CRTC Michael.Holmes@crtc.gc.ca
Ben Jones, CRTC Ben.Jones@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, refer to the table below to identify which file is being referenced.

1. Refer to TELUS’s response to TN 599 RFI #5, Table 1. For each sub-task requiring a headcount greater than 1, justify, with supporting details, why the sub-task requires the associated headcount. If, through the course of providing this response, the company needs to revise its original submission, provide a revised Table 1 if necessary.

2. Refer to TELUS’s response to TN 599 RFI #5, Table 1, sub-tasks 2.1 through 3.4, inclusively:

   1. Considering the nature of each sub-task, explain, with supporting details, why it is appropriate to include each of these sub-tasks in the TN 599 MRC study specifically.
   2. Explain why it would or why it would not be appropriate to include these sub-tasks (tasks 2.1 through 3.4, inclusively) in the TN 599 NRC study.
   3. Provide revised TN 599 MRC and NRC cost collators and associated documents with the identified sub-tasks transferred from the MRC study to the NRC study.

3. Refer to the TN 599 NRC cost collator, tab “CashFlows”, row 10, column G:

   1. Explain, with supporting details, why TELUS classified this expense cashflow as one-time as opposed to ongoing.
   2. Explain why it would or why it would not be appropriate to classify this expense cashflow as ongoing.
   3. Provide a revised TN 599 NRC cost collator with the identified cashflow (row 10) classified as ongoing.

4. Refer to the TN 599 OPEX support sheet, row 9:

   1. Provide and explain, with supporting details, the sub-tasks, in minutes, that make up the time duration provided for this activity, such that each sub-task does not exceed 15 minutes in duration. Provide the source and vintage of each time estimate. For any sub-tasks requiring a headcount greater than 1, justify, with supporting details, why the sub-task requires the associated headcount.
   2. Explain how each sub-task is causal to the ECCL service.

5. Refer to the TN 599 FPP install sheet, tab “Summary”:

   1. Refer to rows 10, 17, 25, 33, and 41, column B. Explain, with rationale and justification, how the values were calculated. Provide the source and vintage of each value.
   2. Refer to rows 18, 26, 34, 42, and 50, column B. Justify, with supporting details, the requirement to perform this activity for each individual ECCL service.
6. Refer to the TN 599 FPP costing sheet, rows 7 through 9, columns C through J, inclusively. Explain, with rationale and justification, how the values in column F were obtained. Provide all associated calculations, inputs and supporting documentation as well as the source and vintage, for each value.

7. Refer to TELUS’s response to TN 663 RFI #12, Table 1:

   1. Refer to sub-tasks 1.1 through 1.9, inclusively. Justify, with supporting details, the required headcount associated with each sub-task.
   2. Sum the total minutes required for sub-tasks 1.1 through 8.10, inclusively, then, refer to the TN 663 cost collator, tab “Data”, row 43, column E. Compare these values and justify any differences.

8. Refer to the TN 663 cost collator, tab “Data”:

   1. Refer to the activity listed on row 40. Provide the sub-tasks associated with this activity and their time estimates and explain how each is causal to the ECCL service. For any sub-task requiring a headcount greater than 1, justify, with supporting details, why the sub-task requires the associated headcount.
   2. Refer to the activities listed on rows 22 and 23. Provide the sub-tasks associated with each of these activities and their time estimates and explain how each is causal to the ECCL service. For any sub-task requiring a headcount greater than 1, justify, with supporting details, why the sub-task requires the associated headcount.

9. Refer to the TN 610 NRC cost study, tab “Table 6a – Expenses”. For each task in row 21, column D:

   1. Provide the sub-tasks and time estimates, in minutes, such that each sub-task does not exceed 15 minutes in duration.
   2. For each sub-task, explain with rationale and justification how it is causal to the ECCL service.
   3. For each sub-task, explain, with rationale and justification, why it is appropriate to include each of these tasks in the NRC study specifically.
   4. If a sub-task requires a headcount greater than 1, justify, with supporting details, why the sub-task requires the associated headcount.

10. Refer to the TN 610 FPP install sheet, tab “Summary”:

    1. Refer to rows 10, 17, 25, 33, and 41, column B. Explain, with rationale and justification, how the values were calculated. Provide the source and vintage of each value.
    2. Refer to rows 18, 26, 34, 42, and 50, column B. Justify, with supporting details, the requirement to perform this activity for each individual ECCL service.

11. Refer to the TN 610 FPP costing sheet, rows 7 through 9, columns C through J, inclusively.

    1. Explain, with rationale and justification, how the values in column F were obtained. Provide all associated calculations, inputs and supporting documentation as well as the source and vintage, for each value.
    2. Explain, with supporting rationale and justification, the increase in costs for the above noted values compared to those provided in the TN 599 FPP costing sheet.

12. Refer to the TN 610 MRC cost collator, tab “Table 6a – Expenses”, for each task in row 21, column C:

    1. Provide the sub-tasks and time estimates, in minutes, such that each sub-task does not exceed 15 minutes in duration.
    2. For each sub-task, explain with rationale and justification how it is causal to the ECCL service.
    3. For each sub-task, explain, with rationale and justification, why it is appropriate to include each of these tasks in the MRC study specifically.
    4. If a sub-task requires a headcount greater than 1, justify, with supporting details, why the sub-task requires the associated headcount.
13. For all studies, revise any activities and/or tasks that are performed offshore by applying the appropriate offshore labour rate. For each revised activity or tasks, provide all associated calculations, inputs, and results to support the updated values.
14. For all questions above, if any adjustments result 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.

Date modified:

2026-03-19