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ARCHIVED -  Telecom Order CRTC 97-604

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Telecom Order

Ottawa, 7 May 1997
Telecom Order CRTC 97-604
Applications by Telehop Long Distance Service Ltd. (Telehop) dated 17 July 1996 for contribution exemption with respect to: (1) three Centrex systems (Barrie, Mount Albert and Sutton) used for administrative and data purposes; (2) a Centrex system located in Moonstone used for single-hop and double-hop calling; and (3) a Centrex system located in Alliston used for administrative, data, and double-hop calling.
File No.: 96-2307
1. By letter dated 5 December 1996, Telehop submitted a technical audit and an affidavit in response to Telecom Order CRTC 96-1124 (Order 96-1124) dated 10 October 1996.
2. Telehop requested that the interim approval granted under Order 96-1124 be made final and that the contribution exemptions be made effective the date of installation.
3. By letter dated 23 December 1996, Bell Canada (Bell) submitted that the audit report appears to be a summary rather than the detailed audit report itself and that the report was deficient in several aspects.
4. Bell stated that the submission does not provide a detailed description of the service configuration for each location and does not specify the precise tests or examinations performed at each location, or the findings and results thereof, including any findings with respect to the accuracy and completeness of the routing tables as required by Order 96-1124.
5. Bell also stated that the summary refers briefly to control procedures but does not explicitly identify which procedures, if any, have been implemented.
6. Bell stated that Telehop has not provided notification to the Commission confirming that satisfactory ongoing control procedures have been implemented.
7. Bell stated that the sworn affidavit does not affirm that the service description has been adequately described by Telehop.
8. Bell noted that the auditor's summary also stated that: "It is recommended that (the technical) audit not be forwarded to either Bell or the CRTC because of the confidential (telephone numbers) and proprietary (software and routing table information) nature of the information contained in the audit."
9. Bell submitted that, contrary to the auditor's view, it is necessary to provide the detailed technical audit to the Commission and the respondent telephone company, in this case, Bell.
10. Bell stated that the purpose of a technical audit is to satisfy the evidentiary requirements for an exemption from contribution charges; of necessity, therefore, the material must be part of the record of the proceeding in order to be considered evidence.
11. Bell further noted that any information which is considered confidential can be so identified in the submission.
12. In such cases, Bell noted that the applicant may request that the Commission direct that such information not be placed on the public record, and that its use by Bell be limited solely to the purposes of this proceeding.
13. By letter dated 15 January 1997, Telehop submitted the full unabridged technical audit together with a new affidavit and requested that the audit be treated in confidence, not be placed on the public record and that its use by Bell be limited solely to the purpose of this proceeding.
14. By letter dated 24 February 1997, Bell noted that the auditor has indicated that certain aspects of the service configuration are provided by Bell and can only be confirmed by Bell.
15. In this respect, Bell stated that it can verify that the routing codes and Virtual Facility Groups are described accurately in the report.
16. Bell stated that the auditor's report confirms that switch data tables, routing controls and operation of the system accurately separate single-hop and double-hop calls.
17. Bell noted that certain administrative calling arrangements involving multiple-hop services are not completely verified by the audit results, but, as noted by the auditor, could be confirmed by subsequent audits of other locations involved.
18. Bell stated that the auditor also indicated that test calls were made to verify the operation of the system.
19. Bell also stated that the auditor indicated that the control procedures in place prevent changes to the software and data tables which control routing of calls by persons that are not authorized to make such changes.
20. Bell stated that by way of explanation, the auditor has specifically identified that physical access to the equipment is limited, and that software access is password restricted.
21. Bell noted that in support of similar previous applications, satisfactory control procedures have typically required that the applicant establish written procedures which include a means of tracking or recording of changes to the system or the software programming.
22. Furthermore, Bell stated that control procedures often include monthly reviews to verify the continuing accuracy of the software data tables, and to confirm the continued compliance of the system to the conditions for exemption.
23. Bell stated that such monthly reviews are typically performed by a switch technician or programmer and signed by an officer or other authorized person in the company.
24. Bell stated that all such documentation and reports are then retained for future inspection in the event that future random audits are required to confirm that the arrangement continues to qualify for an exemption.
25. Bell submitted that comparable control procedures would be appropriate in Telehop's case.
26. Based on the information provided, Bell agreed that the service configuration appears to be as represented by the applicant and as such qualifies for a contribution exemption.
27. Accordingly, subject to the establishment of suitable control procedures as recommended above, Bell agreed with the requested exemption.
28. By letter dated 21 March 1997, Telehop submitted its report regarding internal control procedures.
29. The Commission notes that with respect to Telehop's request that contribution exemptions be approved for administrative, single-hop and data circuits effective the date of installation, Bell has not made any comments.
30. However, the Commission also notes that its previous Orders in this area, together with the Commission's determination in Effective Date of Contribution Exemptions, Telecom Public Notice CRTC 95-26, 12 June 1995, indicate that, generally, contribution exemptions for single-hop and data circuits will be effective the date of application, while the effective date for administrative circuits will be the date of installation.
31. In the Commission's view, Telehop provided no evidence to support a departure from this practice.
32. The Commission is of the view that Telehop has provided a satisfactory technical audit and has provided evidence in accordance with Applications for Contribution Exemptions, Telecom Decision CRTC 93-2, 1 April 1993.
33. The Commission also is of the view that Telehop has provided a satisfactory report regarding control procedures.
34. In light of the foregoing, the Commission orders that:
(a) Telehop's application for single-hop and data circuits is approved effective the date of application (17 July 1996).
(b) Telehop's application for administrative circuits is approved effective the date of installation.
(c) Telehop's configuration is subject to future random audits.
Allan J. Darling
Secretary General
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