ARCHIVED -  Telecom Order CRTC 97-172

Telecom Order

Ottawa, 13 February 1997

Telecom Order CRTC 97-172

IN THE MATTER OF an application by Direct Dial Inc. (Direct Dial) dated 3 January 1996 (enclosing two affidavits dated 22 December 1995), for contribution exemption for Centrex systems used for both single-hop and double-hop services, and for circuits used for administrative traffic.

Reference: 96-2094

WHEREAS in Telecom Order CRTC 96-1057 dated 25 September 1996 (Order 96-1057), the Commission granted to Direct Dial interim approval for exemption from contribution charges for interconnecting circuits (Public Switched Telephone Network connections) for Centrex systems located in the Toronto, Ajax, Claremont, Oshawa, Oak Ridges, Mount Albert and Bethany exchanges effective 3 January 1996;

WHEREAS the Centrex systems are used to provide single-hop or a combination of single-hop and double-hop services;

WHEREAS Order 96-1057 provided that final approval would be subject to: (1) the clarification of which of the seven Centrex systems are configured as single-hop or a combination of single-hop and double-hop services and (2) the provision of a technical audit to verify the usage and separation on systems configured for single-hop and double-hop services;

WHEREAS by letter dated 21 November 1996, Direct Dial provided the technical audit report and auditor's affidavit in support of its application, and clarified that Toronto, Ajax, Claremont and Oshawa were configured for single-hop and double-hop services;

WHEREAS by letter dated 5 December 1996, Bell Canada (Bell) noted that in Telecom Order CRTC 96-507 dated 29 May 1996, with respect to technical audits for such configurations, the Commission clarified the nature of the information that should be included with a technical audit: "... technical audits should verify the usage and separation of administrative, single-hop and double-hop services. The audit should also verify the accuracy of the switching data in the software tables to determine the existence of, as well as the nature of, any controls in place to ensure the continued compliance of the configuration to the conditions on which the exemption is based. The audit should also provide a sworn affidavit affirming that the information provided in the report accurately reflects the results of the audit, and that the service configuration has been accurately described by the applicant.";

WHEREAS Bell stated that it has reviewed the audit report provided on behalf of Direct Dial with consideration of these requirements;

WHEREAS Bell stated that with respect to the Toronto, Ajax and Claremont systems, the audit report indicates that calls are classified as single-hop or double-hop by comparing the Calling Line ID (CLID) and the called number to various tables maintained in the system;

WHEREAS Bell stated that the auditor has confirmed that, based on his review of the software, sample calls and a physical examination of the system, calls are treated correctly by the system hardware and software for contribution purposes;

WHEREAS accordingly, Bell agreed that the audit has satisfactorily confirmed that the system hardware and software functions are as described by the applicant;

WHEREAS Bell also noted that the auditor has indicated that an archive log of all calls is maintained by the system software, and that "periodic examination of these records would provide a thorough and accurate representation of the system's functions";

WHEREAS Bell stated that the auditor has not identified whether procedures are in place to ensure that this data is retained for some reasonable period of time for such purposes, nor has the auditor identified if any control procedures or documentation thereof exists, which would identify how updates to the software tables are made, and would ensure that any such updates that may affect the routing of calls are appropriately authorized, recorded and controlled;

WHEREAS with respect to the Oshawa system, Bell noted that the auditor has confirmed that the present operation of this location correctly handles exempt and contribution attracting traffic, but that the applicant proposes to modify this location to conform to the same configuration employed in the other systems;

WHEREAS Bell agreed that, based on the evidence provided, such a change of configuration should continue to satisfy the requirements for an exemption;

WHEREAS Bell submitted that once this change is completed, an affidavit by the applicant affirming that the system is configured in the same manner as those which were audited would be sufficient to satisfy the evidentiary requirements for an exemption;

WHEREAS Bell also noted that the affidavit provided by the auditor confirms that he is a registered professional engineer, and that the system configuration and results of the audit are accurately reflected in the audit report;

WHEREAS accordingly, based on the evidence submitted by Direct Dial, and subject to confirmation that control procedures exist and are suitably documented as noted in its comments above, Bell agreed that final approval should be granted to the systems in question;

WHEREAS Bell submitted that, as with similar cases where control of the routing of calls is maintained by the applicant, the configuration should be subject to the possibility of future random audits to ensure continued compliance;

WHEREAS the Commission is of the view that Direct Dial has filed a satisfactory technical audit to support final approval of the systems configured for single-hop and double-hop services and notes that Bell also agrees;

WHEREAS the Commission is of the view that the configurations should be subject to the possibility of future random audits to ensure continued compliance, which conforms with Commission practice; and

WHEREAS the Commission agrees with Bell that should the applicant modify the Oshawa location to conform to the same configuration employed in the other systems, an affidavit by the applicant affirming that the system is configured in the same manner as those which were audited would be sufficient to satisfy the evidentiary requirements for the continuation of an exemption -

IT IS HEREBY ORDERED THAT:

1. Final approval is granted to the systems located in Toronto, Ajax, Claremont, Oshawa, Oak Ridges, Mount Albert and Bethany, effective 3 January 1996 as mentioned in Order 96-1057, subject to confirmation within 30 days that control procedures exist and are suitably documented for the sites covered by the technical audit (Toronto, Ajax, Claremont and Oshawa).

2. The systems configured for single-hop and double-hop are subject to the possibility of future random audits to ensure continued compliance.

3. Direct Dial is directed (should the Oshawa system be reconfigured in the future to match the other systems with single-hop and double-hop circuits) to file an affidavit, within 30 days of the reconfiguration, affirming that the system is configured in the same manner as those which were audited.

Allan J. Darling
S ecretary General