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Telecom - Staff Letter addressed to the Distribution List

Gatineau, 19 March 2026

Our reference: 8740-T66-202505173

BY EMAIL

Distribution List

Subject: TELUS Communications Inc. Tariff Notice 607 – New Speed for Network-to-Network Interface Service (AB/BC)

On 15 October 2025, the Commission received an application from TELUS Communications Inc. (TELUS) proposing revisions to its Carrier Access Tariff (CRTC 21462), Item 236, Wholesale Internet FTTP Service for its ILEC territory in the provinces of Alberta and British Columbia to introduce a new speed of 100 Gbps for its Network-to-Network (NNI) service.

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.:     Michael Holmes, CRTC Michael.Holmes@crtc.gc.ca
Ben Jones, CRTC Ben.Jones@crtc.gc.ca

Attach. (2):

Request for Information (RFI) Questions
Distribution List

Request for Information (RFI) Questions

For the following questions, the file “TN-607 Att 1” dated 15 October 2025 will be referenced as “the study report”, “TN-607 Att 2 Confidential_Cost Collator NNI 100G MRC v3” dated 15 October 2025 will be referenced as the “ 100G MRC cost study”, the file “TN-607 Att 2 Confidential_Support_Time tracking with 2025 SLRs“ dated 15 October 2025 will be referred to as “Support_Time_tracking_with_2025_SLRs”, the file “TN-607 Att 2 Confidential_Support_LabourMaterialRatios” dated 15 October 2025 will be referred to as “Support_LabourMaterialRatios” and “TN-607 Att 2, Confidential_Cost Collator NNI 100G NRC v2.0” dated 15 October 2025 will be referred to as the “100G NRC cost study”.

The document “TN-607 Att 2 Confidential_Support_SE 7750 FPS Small SR1 per 100G Uplink Port”, dated 15 October 2025 will be referred to as the “Small 100G Uplink Port”, the document “TN-607 Att 2 Confidential_Support_SE 7750 FPS Small-Medium SR1 per 100G Uplink Port” dated 15 October 2025 will be referred to as the “Medium 100G Uplink Port” and the document “TN-607 Att 2 Confidential_Support_SE 7750 FPS Small-Large SR1 per 100G Uplink Port”, dated 15 October 2025 will be referred to as the “Large 100G Uplink Port”.

The files, “2023-06-22_NNI monthly charge_Collator for 1G and 10G NNI”, “2023-06-22_NNI installation service charge_NNI Service Charge Collator” and “TN-584_583A_657A Att 4”, each dated 28 June 2023, will collectively be referred to as the “1G & 10G cost study”.Footnote1

  1. Refer to the study report, page seven, paragraphs 32-36. Explain, with supporting rationale  and justification, why expenses categorized under “Other” have been allocated to the 100G service but were excluded from the previous cost studies for the 1G & 10G NNI services.
  1. Refer to the 100G NRC cost study, tab “Table 6a – Expenses”. For each task in column D, rows 21-25:
    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 NNI 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.
  1. Refer to document titled Support_Time_tracking_with_2025_SLRs, tab “Filing Input”:
    1. Explain, with supporting rationale and justification, the inclusion of time under activities in row 8, given that these activities were accounted for in the previous cost study for 1G & 10G services.
    2. Explain, with supporting rationale and justification, why the Standard Labour Rate (SLR) in cell B2 has increased by 71% compared to the previous 1G & 10G cost study.
  1. Refer to the 100G MRC cost study, tab “Table 6a – Expenses”, for each task in column C, rows 22-29:
    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 NNI 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.
  1. Refer to the 100G MRC cost study, tab “Data”, rows 18-20. Explain, with supporting rationale and justification, why the current (amps) used by a 100 Gbps Router port was used to calculate Power Equipment expenses (DC [D20], AC [D21] and Batteries [D22]), rather than the Structure Cost Factor-based approach applied in the 1G & 10G cost study.
  2. Refer to the 100G MRC cost study, tab “Data”, row 28, columns I through M inclusive. Explain, with supporting rationale and justification, the change in methodology from the 1G & 10G cost study.
  3. Refer to the 100G MRC cost study, tab “Data”, row 43. Explain, with supporting rationale and justification, why a total cost is shown for the activity, despite the “Duration (hours)” and “SLR” both being 0. If applicable, provide the duration and SLR for the item listed in row 43.
  4. Refer to the 100G MRC cost study, tab “Data”, Cell K15:
    1. Provide a rationale and justification for the calculation used. In your response, describe the key assumptions, justifications and methodology that informed the calculation.
    2. Provide the forecasted number for each of the large, medium, and small routers and the associated demand for each throughout the study period.
  1. Refer to the documents, Small 100G Uplink Port, Medium 100G Uplink Port and Large 100G Uplink Port:
    1. Explain, with supporting rationale and justification, the process required to upgrade a router from Small to Medium and from Medium to Large.
    2. Refer to tab “E10”. Explain, with supporting rationale and justification, why the 80% engineered fill factor was applied to the router, whereas a 100% fill factor was applied to the 1G & 10G cost study.
    3. Refer to the Small 100G Uplink port, tab “Power”. Explain, with supporting rationale and justification, why the value in cell G7 varies from that in cell G7 of the Small 100G Uplink port and Medium 100G Uplink port.
  1. Refer to document Support_LabourMaterialRatios, tab “Ratios”. Explain, with supporting rationale, justification, and calculations, the increase in Labour-to-Material ratios (LMRs) for the following cost items between the 1G & 10G cost study and the 100G cost study:
    1. Items listed in row 28.
    2. Items listed in row 29 and
    3. Items listed in row 30.
  1. 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.

Distribution List:

TELUS Communications Inc.: regulatory.affairs@telus.com;
Quebecor Media Inc,: regaffairs@quebecor.com;
CNOC: regulatory@cnoc.ca;
Bell Canada: bell.regulatory@bell.ca;
TekSavvy: regulatory@teksavvy.ca

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