|
Telecom Letter Decision
|
|
Ottawa, 1 December 1989
|
|
Telecom Letter Decision CRTC 89-26
|
|
To: . Bell Canada
|
|
. British Columbia Telephone Company. Interested Parties
|
|
Re: Proposed Revisions to the Phase III Manual Update Procedure
|
In Telecom Decision CRTC 88-7, 6 July 1988 (Decision 88-7), the Commission approved a procedure for updating the Phase III Manuals of Bell Canada (Bell) and British Columbia Telephone Company (B.C. Tel). Under this procedure, the carriers are required to file any updates to their Phase III Manuals by 30 April of each year. By 31 December, the carriers must file revisions to their Manuals reflecting the updates that received Commission approval. This revised Manual is used to generate Phase III results for that calendar year. These results are submitted, along with an audit report, by 30 September of the following year. Therefore, under the existing procedure, the Phase III results filed in September will be produced and audited on the basis of Manuals that reflect only those updates that were proposed by April of the previous year and subsequently approved by the Commission.
|
|
On 13 June 1989, Bell wrote to the Commission proposing certain revisions to the Phase III Manual update procedure. This proposal, developed jointly with B.C. Tel, would allow the companies to file updates more frequently and would permit the filing of audited Phase III results based on more recently updated Manuals. Specifically, Bell and B.C. Tel would have the option of filing, by 31 May, 31 October, 15 January and 31 March, reports identifying proposed updates to the Phase III Manuals and explaining the reasons for each. The companies would also propose a "latest required decision date" for each update, by which time the Commission would advise whether it was approved, denied or subject to further study. By 30 June, the companies would file Manual pages incorporating any updates that had been filed by 31 March and subsequently approved by the Commission. The 30 June version of the Manuals would form the basis for the production and audit of the results for the previous year. The audited results would be filed by 30 September.
|
|
In a letter to the Commission dated 19 June 1989, B.C. Tel expressed concurrence with the proposed revisions to the update procedure. However, while Bell proposed to submit draft Manual pages only for significant updates, B.C. Tel stated that it would prefer to submit draft pages for all proposed updates.
|
|
The Commission received and considered comments from CNCP Telecommunications (CNCP) and the Government of Ontario, as well as submissions from Bell and B.C. Tel.
|
As indicated above, Phase III results are audited on the basis of Manuals that incorporate only approved updates. Under the procedure specified in Decision 88-7, Phase III results would not be filed until 17 months after the filing of the latest proposed updates to the Manuals on which they would be based. As a result, the potential exists for the audit reports filed by the carriers to identify a number of qualifications and explanations. Under Bell's proposal, the interval between the filing of the latest proposed updates and the submission of results would be reduced to 6 months. Thus, the potential for a qualified audit report would also be reduced, as the Phase III results would reflect the carriers' current Phase III procedures to a much greater extent.
|
CNCP suggested that the carriers be required to serve Phase III updates on interested parties at the same time they are filed with the Commission. The Commission considers this unnecessary, as it did in Decision 88-7. The Commission agrees with Bell that the present practice of issuing a Public Notice with respect to significant updates is appropriate, in that it expedites the approval process for routine updates while providing for public comment with respect to those updates that require greater scrutiny.
|
|
Neither does the Commission consider it necessary to impose a requirement, also suggested by CNCP, that every proposed update be accompanied by a description, a justification and an estimate of its impact on the Phase III results. Bell's proposal specifies that update reports would include the reasons for each update. The Commission agrees with Bell that the filing of impact estimates for all updates would be impractical, given the number of updates and the possible need for dozens of runs of the Phase III results. Similarly, the Commission agrees with Bell that it is not necessary that draft Manual pages be filed for minor or routine updates. It is sufficient if the carriers file draft Manual pages only with respect to significant updates, although they may file draft pages with respect to all updates, if they so desire.
|
|
In light of the above, the Commission approves the proposed modifications to the Phase III update procedure. Bell and B.C. Tel are directed to file the first of their update reports by 15 January 1990.
|
In Telecom Decision CRTC 89-12, 15 September 1989, the Commission directed Bell and B.C. Tel to file certain specified proposals with their next update submissions. In light of the revised update procedure approved in this Letter Decision, Bell and B.C. Tel are directed to file this material by 15 January 1990.
|
|
Fernand Bélisle
|
|