ARCHIVED -  Telecom Order CRTC 99-315

This page has been archived on the Web

Information identified as archived on the Web is for reference, research or recordkeeping purposes. Archived Decisions, Notices and Orders (DNOs) remain in effect except to the extent they are amended or reversed by the Commission, a court, or the government. The text of archived information has not been altered or updated after the date of archiving. Changes to DNOs are published as “dashes” to the original DNO number. Web pages that are archived on the Web are not subject to the Government of Canada Web Standards. As per the Communications Policy of the Government of Canada, you can request alternate formats by contacting us.

Telecom Order

Ottawa, 1 April 1999
Telecom Order CRTC 99-315
On 30 January 1998, TELUS Communications Inc. (TCI) filed Tariff Notices (TN) 1009 and 1010 to:
i) clarify TCI's position on attachment of multiline, concentrating, or multiplexing equipment to Centrex Service;
ii) change the name of "High Usage" rates to "Centrex Multiline/High Usage System Attachment" and grandfather the Key System attachment rates;
iii) clarify TCI's position on contract assignment; and
iv) make a number of general housekeeping changes in its Centrex Service and National Centrex Service tariffs respectively.
File Nos.: TCI TNs 1009, 1010, 1058, and TCEI TNs 66, 68, 69
1.Simultaneously, TELUS Communications (Edmonton) Inc. (TCEI) filed TNs 66, 68, and 69 to make similar changes to its PHONEFLEX Service, National Centrex Service and Centrex III Service respectively.
2.On 17 June 1998, TCI filed TN 1058 to propose further changes to the Centrex Multiline/High Usage System Attachment rates proposed in TNs 1009 and 1010. The company also requested that TN 1058 be disposed of simultaneously with TNs 1009 and 1010.
3.Interventions were received on some of the above TNs by AT&T Canada Long Distance Services Company (AT&T Canada LDS), London Telecom Network, Inc. (London Telecom), MetroNet Communications Corporation (MetroNet), and Optel Communications Corporation.
4.Reply comments were filed by TCI on behalf of itself and TCEI.
5.TCI and TCEI proposed changes to their Centrex Service tariffs to address conditions of service in the current tariffs which are unclear or inappropriate in today's communications environment. The companies stated that it is becoming increasingly difficult to administer the tariffs and that the proposed changes are required to increase clarity and to ensure consistency in customer treatment throughout Alberta.
6.TCI and TCEI proposed the introduction of the Centrex Multiline/High Usage System Attachment rates to deal with provisions in the present tariffs which are unenforceable, and as such create a potential for significant abuse.
7.TCI and TCEI proposed that Centrex Multiline/High Usage System Attachment rates would apply when any one of the following three conditions applies:
i) multiline, concentrating or multiplexing terminal equipment is connected to a Centrex line;
ii) % Hunt on 2500-type lines exceeds 30%; or
iii) a customer's traffic occupancy rate in the customer's peak hour exceeds 5.6 CCS per line on average over all lines in the customer's Centrex system.
8.TCI and TCEI further stated that these conditions would provide a consistent method for applying the High Usage Centrex rates.
9.Interveners were mainly concerned with the proposed Multiline/High Usage System Attachment service conditions and rates, the restrictions on the assignment of a contract, the grandfathering of the existing Key System attachment rates and the requirement to dial an access code (e.g. dial '9' for an outside line) to reach the public switched telephone network (PSTN).
10.Some of the interveners suggested that the tariff changes had been targeted at the new local competitors.
11.AT&T Canada LDS argued that only lines that exceed the 5.6 CCS should be required to pay the higher rate, rather than all lines in a system where the average exceeds the 5.6 CCS, as indicated in the proposed tariff.
12.AT&T Canada LDS stated that it was not clear as to how TCI intended to monitor Centrex line usage, and that this could lead to preferential treatment of some customers.
13.London Telecom submitted that TCI's proposal to charge the High Usage rates to lines that are connected to multiline, concentrating or multiplexing terminal equipment was in contravention of section 27(1) of the Telecommunications Act because it was not reasonable to assume that all such lines would generate high usage.
14.MetroNet submitted that the proposed Multiline/High Usage rate discriminates against resellers because (1) resellers use call forwarding and hunting arrangements to maintain their customers' existing telephone numbers and (2) these customers generally attach key systems to their lines; both of which applications attract the new higher rates.
15.All interveners objected to the restrictive conditions for the assignment of a contract. MetroNet submitted that the proposed contract assignment provisions are unjustly discriminatory because they are specifically designed to limit resellers' activity.
16.The interveners also challenged TCI's proposal to make the access code to the PSTN a standard Centrex feature.
17.TCI filed reply comments that addressed all interventions on both its own and TCEI's tariff notices.
18.TCI argued that it only matters that the 5.6 CCS is exceeded on average across all lines of a customer group.
19.TCI stated that Centrex line hunting is used primarily to maximize the use of trunks/lines that support incoming calls. TCI added that hunting on a large percentage of 2500 type lines would be indicative of high levels of usage of Centrex service. Contrary to MetroNet's allegation, hunting on Centrex lines is not required to maintain an end customer's telephone numbers.
20.With respect to grandfathering the existing Key System attachment rates, TCI stated that there would be significant customer disruption if existing customers were required to switch to the new rate structure. TCI added that there was no discrimination in the proposed approach since the existing rates were available to all customers and the proposed rates will
apply to new lines ordered on a going forward basis for all customers.
21.Regarding the provision of the PSTN Access Code, TCI stated that such an access code has been a feature of Centrex service since its inception and that this proposal simply clarifies the tariff to ensure that all customers will be treated equally.
22.The Commission agrees with TCI that the current multiline rate structure based on the ratio of lines to terminals (the 1:1 rule) is no longer enforceable and therefore needs to be replaced.
23.In response to a Commission question concerning the criteria for measuring a customer's traffic occupancy under TCI's proposal, TCI stated that: "Line usage is not measured continuously. Usage studies are conducted on an as required basis for customers whose line usage is expected or known to be high. A Centrex line usage study for a single customer is normally conducted for a period of one or two continuous weeks."
24.The Commission has concerns with the above approach. The Commission considers that both the determination as to which customer should be measured and the measurement procedures are subjective and could lead to discrimination in the application of the tariff.
25.The Commission considers that TCI's proposal to limit assignment of Centrex contracts to instances where (i) the customer name that appears on the Agreement is the same as the name of the party to whom the agreement is assigned, or (ii) the customer name that appears on the Agreement is an affiliate of the party to whom the Agreement is assigned, is too restrictive.
26.In light of the above concerns, the Commission denies TCI TNs 1009, 1010 and 1058 and TCEI TNs 66, 68 and 69.
27.The Commission directs TCI to file, within 60 days of the date of this Order, proposed tariffs that will replace the 1:1 rule.
28.The Commission notes that the TCEI Centrex tariff which was proposed to be modified in this proceeding reflects usage sensitivity through rates which are dependent on the number of access lines that are part of the group of Multiline Service accesses.
29.Regarding concerns raised with respect to the requirement to dial an access code to reach the PSTN, the Commission notes that, in general, the PSTN is accessed from Centrex systems through such an access code.
This document is available in alternative format upon request and may also be viewed at the following Internet site:
Secretary General

Date modified: