ARCHIVED -  Telecom Order CRTC 97-1032

Telecom Order

Ottawa, 24 July 1997

Telecom Order CRTC 97-1032

The Commission received a letter dated 29 May 1997 from AT&T Canada Long Distance Services Company (AT&T Canada LDS) with respect to Telecom Order CRTC 97-567 dated 29 April 1997 (Order 97-567).

File No.: 96-2477

1. In Order 97-567, the Commission approved AT&T Canada LDS' application for contribution exemption for circuits used to carry transit traffic on an interim basis effective 12 November 1996 (the date of activation of the circuits) with final approval subject to confirmation by the applicant, within 30 days, that appropriate control procedures are in place to ensure the continued compliance of the configuration with the conditions for exemption.

2. AT&T Canada LDS submitted that the appropriate control procedures are in place and are functioning effectively to ensure the continued compliance with the conditions for exemption. AT&T Canada LDS stated that as noted by the Commission in AT&T Canada - Contribution Accounting and Reporting Practices, Telecom Decision CRTC 97-3, 25 February 1997: ..."the Commission is of the view that AT&T Canada appears to have developed and implemented adequate control procedures to restore the integrity of AT&T Canada's accounting and reporting practices and that the proper corrective and control procedures appear to have been established to ensure the system can be relied upon in the future."

3. AT&T Canada LDS submitted that, the Auditor's Report on Control Procedures (Auditor's Report) which was filed with the Commission on 6 September 1996, in the course of the proceeding initiated by Unitel Communications Inc. - Contribution Accounting and Reporting Practices, Telecom Decision CRTC 95-18, 24 August 1995 (Decision 95-18), clearly identifies the control procedures that are in place to ensure the continuing compliance for contribution exemption for each configuration granted an exemption by the Commission.

4. Additionally, AT&T Canada LDS noted that the Auditor's Report contains a description of many other control procedures in place and indicates that these controls are currently the subject of annual internal audits, the first of which is currently under way (and is subject to review by Ernst & Young). Finally, AT&T Canada LDS noted that the configuration under consideration with respect to Order 97-567 is the same configuration (using different facilities) as is in place for another customer, the earlier configuration having received final approval for an exemption in Telecom Order CRTC 96-828 dated 2 August 1996. AT&T Canada LDS stated that the transit configuration in place for AT&T Canada LDS' first transit customer was evaluated during the larger contribution audit ordered as part of Decision 95-8 (sic: should read Decision 95-18). AT&T Canada LDS stated that the procedures in place for monitoring continued compliance of first transit configuration with the conditions for exemption are the same as in the present case.

5. Based on the foregoing, AT&T Canada LDS submitted that it has appropriate control procedures in place to ensure continued compliance of the configuration with the conditions for exemption.

6. By letter dated 25 June 1997, Bell noted that in its previous submissions on the matter, AT&T Canada LDS did not make reference to or identify that appropriate control procedures are in place. Bell stated that it has reviewed the Audit Report referenced above and noted that AT&T Canada LDS has now clarified and confirmed in this latest submission that the procedures described by the Auditor during the proceeding associated with Decision 95-18 are still in place and, in the view of AT&T Canada LDS, such procedures comply with the Commission's requirements for control procedures in this case.

7. Based on its review of the documentation provided, Bell agreed that these procedures appear to satisfy the requirement to ensure the continued compliance of the configuration to the requirement for a contribution exemption. Accordingly, Bell agreed with AT&T Canada LDS' request that the Commission grant final approval of the exemption application.

8. The Commission considers that the description of AT&T Canada LDS' control procedures as set out in Decision 95-18 demonstrates that the status of the circuits in question will be monitored by its Traffic and Measurement Departments both on a daily and monthly basis, in the context of self-reporting to Bell. The Commission is of the view that this evidence satisfies its requirements as set out in Order 97-567.

9. Based on the foregoing, the Commission orders that AT&T Canada LDS' application is granted final approval.

Laura M. Talbot-Allan
Secretary General

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