ARCHIVED - Telecom Order CRTC 97-81
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Ottawa, 20 January 1997
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Telecom Order CRTC 97-81
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Reference: 96-2396
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WHEREAS by letter dated 4 September 1996, HKTel filed a technical audit to support its application;
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WHEREAS by letter dated 2 October 1996, BC TEL noted that applications for exemption from contribution may be made for overseas access circuits which are used to provide a dedicated voice or data service or a joint-use interexchange data service, but that there is no reference to enhanced services as an exemption category in the current contribution exemption regime;
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WHEREAS BC TEL submitted that the enhanced services described by HKTel in its application are apparently joint-use interexchange data services, and therefore, it assumed that HKTel's application would be treated as such;
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WHEREAS BC TEL stated that it is generally satisfied that the information in the technical audit indicates an intention to restrict the use of the Australian IPLCs to data services;
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WHEREAS BC TEL submitted that prior to disposing of HKTel's application, the Commission may wish to obtain clarification or further information on the four issues set out below;
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WHEREAS by letter dated 22 October 1996, HKTel responded to the four issues raised by BC TEL;
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WHEREAS the first issue relates to the potential carriage of voice traffic;
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WHEREAS BC TEL noted that in Item 4 (page 2) of the technical audit, it is stated that all 011 and 1 + calls incoming to the switch are routed to trunk group 300 (Westel) or 302 (fONOROLA) with the exception of 011-852-172-XX-XXXX calls which were routed to trunk group 310 (Australian IPLCs);
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WHEREAS BC TEL assumed that this statement referred to 011 and 1 + calls incoming to the switch on trunk groups 100 and 101 only;
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WHEREAS BC TEL noted that the Australian IPLCs are HKTel's preferred routing for overseas termination of store and forward facsimile messages;
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WHEREAS BC TEL stated that for calls incoming into HKTel's switch on trunk group 350 (the trunk group assigned to HKTel's store and forward fax service) for overseas termination, the Australian IPLCs would appear to accept overseas destinations other than 011-852-172-XX-XXXX;
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WHEREAS BC TEL submitted that further explanation of the interaction between trunk group 350, HKTel's store and forward equipment and the Australian IPLCs may be appropriate;
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WHEREAS HKTel stated that BC TEL is correct in its statement regarding this issue;
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WHEREAS HKTel noted that, as indicated in the technical audit, the only incoming trunk groups that are programmed into the switch are trunk groups 100, 101 and 350;
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WHEREAS HKTel stated that the only calls which could access the Australian IPLCs that are not 011-852-172-XX-XXXX numbers are calls which originate from trunk group 350;
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WHEREAS HKTel noted that, as indicated in the last line of paragraph 2 of the technical audit, "[the auditor] physically verified by visual inspection that only circuits from the facsimile facility accessed TG 350";
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WHEREAS HKTel stated that trunk group 350 receives no traffic other than incoming store and forward facsimile transmissions;
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WHEREAS HKTel stated that the auditor concluded, in his summary of findings on page 3 of his technical audit, that "the facsimile store and forward facility at the Dunsmuir CO will not support voice services in its current configuration";
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WHEREAS HKTel stated that it is clear that, as is evident by Exhibit 3 of the technical audit (a letter from Atlas Telecom [the manufacturer] of the facsimile store and forward device), voice traffic cannot be carried on the platform as purchased and configured;
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WHEREAS HKTel stated that, thus, there is no possibility of trunk group 350 being used to carry voice services and there is no possibility that the Australian IPLCs will carry voice services;
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WHEREAS the Commission notes that the audit relies on written evidence from the equipment supplier to support its argument that trunk group 350 cannot carry voice traffic;
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WHEREAS in the Commission's view, the evidence on which the audit is based is insufficient to conclude that voice traffic cannot be carried over trunk group 350;
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WHEREAS the Commission considers that since the configuration is still in place, it would be appropriate for the auditor to return to the site and perform actual test calls to ensure that there is no possibility of trunk group 350 being used to carry voice services, and that there is no possibility of the Australian IPLCs (trunk group 310) being used to carry voice services;
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WHEREAS the Commission finds that HKTel's application should be deferred pending receipt of a revised technical audit demonstrating that the auditor has performed actual test calls to ensure that there is no possibility of trunk group 350 and the Australian IPLCs (trunk group 310) being used to carry voice services;
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WHEREAS the second issue relates to call routing;
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WHEREAS BC TEL noted that it does not appear that attempts were made to test whether voice calls could be terminated to destinations outside of Australia via trunk group 350, HKTel's store and forward fax service and the Australian IPLCs;
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WHEREAS BC TEL stated that given its comments on the first issue above, such testing may be appropriate;
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WHEREAS BC TEL questioned, whether letters provided from outside suppliers fulfill the evidentiary requirements to support a finding by the Commission that an exemption from contribution is warranted;
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WHEREAS HKTel stated that as indicated by the technical audit, the store and forward facsimile equipment was configured not to process voice calls;
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WHEREAS HKTel stated that as such, the concern raised by BC TEL, as indicated in HKTel's answer to issue one, is not valid;
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WHEREAS the Commission considers that the issue of voice calls terminating in destinations outside of Australia via trunk group 350 and the Australian IPLCs is not relevant for the purpose of establishing whether a contribution exemption is justified;
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WHEREAS the third issue relates to the numbering plan;
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WHEREAS BC TEL stated that in the technical audit, after reviewing programming tables to verify routing codes for 011,1 + and 011-852-172-XX-XXXX calls, the auditor made a number of attempts to place calls to the Hong Kong public switched telephone network (PSTN) via the 852-172-XX-XXXX numbers;
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WHEREAS BC TEL stated that the auditor concluded that although not exhaustive, the series of test calls indicate that the 172 InfoLine service is a playback type of information service that does not permit "joint use" voice service traffic to pass through to the PSTN in Hong Kong, or elsewhere;
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WHEREAS BC TEL submitted that neither the auditor nor HKTel has indicated if the 172-XX-XXXX numbering scheme is controlled by the local telephone company in Hong Kong or by HKTel;
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WHEREAS BC TEL stated that HKTel, therefore, may not be in a position to restrict the use of 172-XX-XXXX numbers to prevent carriage of voice services which access the Hong Kong PSTN;
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WHEREAS BC TEL submitted that it may be appropriate to determine if the 172-XX-XXXX numbering series has been reserved by the local telephone company in Hong Kong solely for the "playback" type of services described by the auditor or if HKTel controls the use of these numbers and has appropriate controls in place to prevent their use for voice services;
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WHEREAS in replying to this matter, HKTel attached select pages from "The Numbering Plan for Telecommunications Services in Hong Kong" (the Plan) as determined by the Hong Kong Telecommunication Regulatory Authority, Office of the Telecommunications Authority (OFTA);
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WHEREAS HKTel stated that at page 4 of the Plan, all phone numbers beginning with the digits 172 are classified as "Information services" by OFTA;
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WHEREAS HKTel stated that this numbering plan addresses BC TEL's concern;
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WHEREAS the Commission finds that HKTel has provided a satisfactory answer to BC TEL's concern;
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WHEREAS the fourth issue relates to ongoing control procedures;
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WHEREAS BC TEL submitted that given that HKTel's configuration is based, in part, upon switch software controls (controls on dialed numbers, one-way trunks, data-only configurations), there is a need for evidence of procedures in place to ensure that such controls are not altered;
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WHEREAS BC TEL noted that the technical audit does not indicate if any such procedures have been put in place by HKTel;
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WHEREAS BC TEL noted that in Telecom Order CRTC 96-507, 29 May 1996, the Commission stated that applicants for contribution exemptions "... 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.";
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WHEREAS in order to satisfy the evidentiary requirements for an exemption from contribution, BC TEL submitted that the Commission should determine that ongoing procedures are required to ensure that the software controls in HKTel's switch and facsimile store and forward equipment continue to function in compliance with the requirements for such an exemption;
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WHEREAS HKTel stated that it would be prepared to implement the following monthly review system: HKTel will conduct a monthly review that will verify that the circuits are still in the trunk route and that the switch translation and routing tables have not been modified for those circuits subject to the contribution exemption; and the monthly report will be prepared and signed by the switch engineer and reviewed and approved by the appropriate officer of HKTel; and
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WHEREAS the Commission is of the view that this proposed plan is acceptable, but that HKTel should confirm in writing that the program has, in fact, been formally introduced -
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IT IS HEREBY ORDERED THAT:
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1. HKTel's application is deferred pending receipt of a revised technical audit within 30 days, serving a copy on BC TEL, demonstrating that the auditor has performed actual test calls to ensure that there is no possibility of trunk group 350 (store and forward facsimile) and trunk group 310 (the Australian IPLCs) being used to carry voice service.
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2. HKTel is to confirm in its revised technical audit that its proposed plan for ongoing control procedures has been formally introduced.
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3. The configuration will be subject to future random audits (consistent with normal Commission practice) should the Commission find at a later date that a contribution exemption is appropriate.
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Allan J. Darling
Secretary General |
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- Date modified: