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Telecom Decision CRTC 97-16
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QUALITY OF SERVICE INDICATORS FOR USE IN TELEPHONE COMPANY REGULATION
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I INTRODUCTION
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In Review of Regulatory Framework, Telecom Decision CRTC 94-19, 16 September 1994 (Decision 94-19), the Commission stated that, under the new regulatory framework:
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(a) as in the past, a proper determination of just and reasonable telephone rates will continue to involve an assessment of the service quality provided by telephone companies to their subscribers;
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(b) the Commission will continue to monitor the quality of service of all telephone companies under its jurisdiction, with respect to essential Utility services, bottleneck facilities, and toll service in regions where the telephone company is the sole provider actively marketing such service;
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(c) in regions where the telephone company is the sole provider actively marketing toll service, the Commission will continue to take into account the dependence of remote and rural communities on long distance service, due to population dispersal and distance from essential services; and
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(d) the Commission will ensure that carriers continue to maintain the quality of the above-noted services.
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In Decision 94-19, the Commission also stated its intention to initiate a general proceeding on quality of service regulation. The Commission stated that it would use the four points noted above as guidelines, taking into account the particular circumstances of individual companies, in considering quality of service indicators, standards and other related matters.
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Consistent with the above, the Commission issued Review of the Quality of Service Indicators, Telecom Public Notice CRTC 94-50, 21 October 1994 (PN 94-50), initiating a proceeding (the Quality of Service proceeding) to consider issues related to the quality of service of BC TEL, Bell Canada (Bell), The Island Telephone Company Limited (Island Tel), Maritime Tel & Tel Limited (MT&T), The New Brunswick Telephone Company, Limited (NBTel), NewTel Communications Inc. (NewTel) (formerly Newfoundland Telephone Company Limited) and TELUS Communications Inc. (TCI) (formerly AGT Limited).
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The Commission also included in the proceeding consideration of appropriate quality of service regulation for MTS NetCom Inc. (MTS) (formerly Manitoba Telephone System), Northwestel Inc. (Northwestel) and the largest of the independent telephone companies that came under its jurisdiction as a result of the Supreme Court of Canada's Decision in Attorney-General of Quebec et al. v. Téléphone Guèvremont Inc., specifically, TELUS Communications (Edmonton) Inc. (TCEI) (formerly Edmonton Telephones Corporation), Northern Telephone Limited (Northern), Québec-Téléphone, Télébec ltée (Télébec) and The Corporation of the City of Thunder Bay - Telephone Division (Thunder Bay Telephone), i.e., those with 25,000 or more Network Access Services (NAS). In Regulatory Framework for the Independent Telephone Companies in Quebec and Ontario (Except Ontario Northland Transportation Commission, Québec-Téléphone and Télébec ltée), Telecom Decision CRTC 96-6, 7 August 1996, the Commission dealt with the quality of service regulation of the independent telephone companies with less than 25,000 NAS.
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In PN 94-50, the Commission identified a number of issues upon which it invited proposals and comments. BC TEL, Bell, Island Tel, MT&T, NBTel, NewTel, MTS, Northwestel, Northern, Québec-Téléphone, Télébec, Thunder Bay Telephone, TCI and TCEI (the telephone companies) were made parties to the proceeding and were directed to file, among other things, submissions with respect to the issues set out in PN 94-50. These issues are discussed below in Parts II and IV.
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In response to PN 94-50, the telephone companies filed submissions by 7 April 1995.
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By 2 June 1995, the following interveners filed comments on the telephone companies' submissions: AT&T Canada Long Distance Services Company (AT&T Canada LDS) (formerly Unitel Communications Inc.); the Government of British Columbia (B.C.); The Canadian Association of the Deaf; Consumers’ Association of Canada, Alberta Branch (CACAlta); Consumers’ Association of Canada, Fédération nationale des associations de consommateurs du Québec and the National Anti-Poverty Organization (CAC/FNACQ/NAPO); Public Interest Advocacy Centre (PIAC) Ottawa and The British Columbia Old Age Pensioners' Organization, Council of Senior Citizens' Organizations West End Senior’s Network, Senior Citizens' Association, Federated Anti-Poverty Groups of B.C., Local 1-217 IWA Seniors (collectively, BCOAPO et al.) represented by B.C. PIAC; Rogers Cantel Inc. (Cantel); the Telecommunications Workers Union (TWU) and Yukon Government.
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By 28 July 1995, TWU and Stentor Resource Centre Inc. (Stentor), on behalf of the telephone companies, filed reply comments.
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By letter dated 6 November 1995, the Commission stated that it considered it essential to the development and functioning of an effective price cap regime that quality of service be maintained. The Commission stated that some method of providing credits or rebates to customers may be appropriate to ensure that rates for service received are just and reasonable where the quality of service fails to meet an acceptable standard. Accordingly, the Commission directed the telephone companies to file further submissions with respect to a scheme of credits and rebates. The telephone companies filed their submissions on 16 February 1996 in response to the Commission’s letter of 6 November 1995. On 12 March 1996, AT&T Canada LDS, BCOAPO et al. and PIAC filed comments.
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In the proceeding initiated by Price Cap Regulation and Related Issues, Telecom Public Notice CRTC 96-8, 12 March 1996 (the price caps proceeding), TWU, the Communications Energy and Paperworkers Union of Canada, the Atlantic Communications and Technical Workers Union, the International Brotherhood of Electrical Workers and the Telecommunications Employees Association of Manitoba (TWU et al.) and CAC filed evidence relating to quality of service.
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On 29 August 1996, the Commission received a letter from Stentor requesting confirmation that the issue of quality of service, including proposals to include a service quality index in the price cap formula, was not being addressed in the price cap proceeding, and that any evidence in relation to that issue would not be considered in that proceeding.
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By letter dated 12 September 1996, the Commission ruled on Stentor’s application, stating that it would be more appropriate to deal with all matters relating to mechanisms for the maintenance of quality of service under a price cap regime (including penalties, rebates and the inclusion of a quality of service factor in the price cap formula) in the Quality of Service proceeding. Accordingly, the Commission ruled that it would not consider in the price cap proceeding the evidence of TWU et al. or CAC relating to quality of service mechanisms. By letter dated 25 September 1996, as amended by letter dated 17 October 1996, the Commission modified the procedure for the Quality of Service proceeding to permit the filing of additional submissions by TWU and CAC, as well as all parties to the proceeding, with respect to mechanisms for the maintenance of a quality of service in a price cap regime (including penalties, rebates and the inclusion of a quality of service factor in the price cap formula).
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By 16 October 1996, AT&T Canada LDS, CACAlta, CAC/FNACQ/NAPO and TWU et al., and by 24 October 1996, the telephone companies filed submissions with respect to mechanisms for the maintenance of quality of service in a price cap regime. By 13 December 1996, AT&T Canada LDS, BC TEL, Bell, B.C., BCOAPO et al., CACAlta, CAC/FNACQ/NAPO, MTS, TCI, TCEI and TWU et al. filed reply comments.
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On 19 December 1996, the Commission received a letter from TCI objecting to the introduction of new evidence by CAC/ FNACQ/NAPO in their reply comments of 13 December 1996, namely a copy of a draft report from the National Regulatory Research Institute (NRRI) Report 96-11, March 1996, entitled "Telecommunications Service Quality". TCI noted that CAC/FNACQ/NAPO had contended that the draft NRRI report was filed earlier in this proceeding by PIAC.
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By letter dated 20 December 1996, PIAC responded to TCI’s letter stating that it had originally referred to the report in question in its 12 March 1996 submission. PIAC stated that shortly thereafter it provided a copy of the report to Bell (in response to Bell’s request) and to the Commission, but did not copy other parties due to the length of the report and the fact that no other party requested copies. PIAC stated that, if its references to the NRRI report and subsequent filing with Bell and the Commission were not considered as "filing on the record of this proceeding", then CAC/ FNACQ/NAPO could withdraw their references to the report in question.
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Because all parties to the Quality of Service proceeding were not provided a copy of the NRRI report, the Commission has not considered the NRRI report as part of the record of this proceeding.
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II Q-FACTOR IN THE PRICE CAP INDEX
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In Price Cap Regulation and Related Issues, Telecom Decision CRTC 97-9, 1 May 1997 (Decision 97-9), the Commission announced that it had decided not to include a quality of service factor, i.e., Q-factor, in the price cap index and that the determination would be addressed more fully in the decision to be issued in the Quality of Service proceeding.
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A Q-factor is a discrete numerical value built into the price cap index formula, designed to reflect a telephone company’s performance in respect of a set of objective quality of service indicators. Its principal purpose is to act as a deterrent to the telephone companies from downgrading service quality to increase profits under a price cap regime. A Q-factor could be designed such that an adjustment triggered by sub-standard service would be calculated and the price cap lowered. Alternatively, an increase in the price cap could result if quality exceeds pre-set thresholds.
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The telephone companies were opposed to a Q-factor. However, in case the Commission decided to include a Q-factor in the price cap formula, BC TEL and Bell submitted proposed models for a Q-factor. Both models focused on two service interfaces: Provisioning and Repairs. For Provisioning, BC TEL and Bell proposed to measure the interval within which new services can be furnished, business office access and appointments missed. For Repairs, BC TEL and Bell measured the length of service outages, the accessibility of repair bureau and appointments missed. Under BC TEL’s model, the Q-factor would be adjusted in every month of below-standard or above-standard performance. The sum of these monthly adjustments, if any, calculated over a 12-month period would be totalled, resulting in the operative Q-factor in the price cap index for the subsequent year. Unlike BC TEL, Bell’s proposal provided for a three-month grace period, which would have resulted in a monthly deduction only if below quality of service in a month had been preceded by three consecutive sub-standard months of service.
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TWU proposed a Q-factor which involved, among other things, elements that would trigger credits for billing rebates.
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The Commission notes that the implementation of a Q-factor is based on the presumption that telephone companies will sacrifice service quality to increase profits, especially in an increasingly competitive marketplace.
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The Commission considers that there are a number of shortcomings associated with a Q-factor, among them that a Q-factor does not address the "injured party" specifically but affects all subscribers by lowering the price cap and that a Q-factor would result in a time lag between the period in which service quality was below standard, and the imposition of the Q-factor penalty.
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Based on the experience with reporting under the Quality of Service Indicators for Use in Telephone Company Regulation, Telecom Decision CRTC 82-13, 9 November 1982 (Decision 82-13), the Commission further considers that its close monitoring of key service indicators and its ability to deal with problems on a case by case basis as they arise have proven to be a sufficient safeguard of service quality in the past.
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The Commission notes that the monitoring model, which is set out in Part IV of this Decision and which is based in part on the reporting requirements of Decision 82-13, is intended to ensure that quality of service is maintained. Accordingly, as stated in Decision 97-9, a Q-factor will not be included in the price cap index.
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III COMMISSION MANDATED REBATES
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In its letter of 25 September 1996, the Commission directed the telephone companies to file submissions with respect to mechanisms for the maintenance of quality of service in a price cap regime including, among other things, rebates.
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The telephone companies were opposed to Commission mandated rebates, but in response to interrogatory (CRTC)25Sept96-101, proposed that, if there must be rebates, only objective quality of service indicators, rather than customer satisfaction indicators, should be used for rebate considerations. In addition, the telephone companies addressed possible rebate mechanisms.
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AT&T Canada LDS proposed various rebates for customers that are also competitors.
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With respect to AT&T Canada LDS’ proposal, the Commission agrees with the telephone companies that rebates for customers that are also competitors are a matter that is more appropriately dealt with in the proceeding to be initiated to consider whether current tariff provisions require change with respect to providing rebates to competitors, as stated in the Commission’s letter of 19 December 1995 to Sprint Canada.
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Based on the submissions of parties, the Commission notes that a mandated rebate scheme would provide direct compensation to specific customers affected by poor service quality.
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The Commission notes, however, that a mandated rebate scheme is difficult to administer fairly in that what is deemed just compensation to one individual may not be sufficient to another. In addition, a telephone company may decide that providing rebates is less expensive than maintaining good service quality.
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Moreover, as stated in Part II above, the monitoring model set out in Part IV is intended to ensure that quality of service is maintained.
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In the circumstances, the Commission is of the view that mandated rebates are not warranted at this time.
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In Telecom Order CRTC 96-940, 24 August 1996, the Commission approved the introduction by MTS of a service guarantee for individual and party-line customers when the company does not meet scheduled installation or repair appointments. Under the service guarantee, MTS can offer, among other things, as compensation for installation or repair appointments missed two calling features for two months or one calling feature for four months at no charge (e.g., call forwarding, call waiting, voice messaging, etc.). In addition, in Telecom Order CRTC 97-748, 4 June 1997, the Commission approved the introduction by BC TEL of a market trial involving service guarantees and automatic customer rebates to certain individual business line customers. The Commission stated that, should BC TEL file, in the future, a similar application for permanent service offering it would be appropriate for BC TEL to address the extension of service guarantees to both business and residence subscribers.
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The Commission, therefore, would entertain voluntary rebate proposals. Such proposals should be uniformly applied to customers in a manner that would not result in unjust discrimination.
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IV QUALITY OF SERVICE MONITORING
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A. Monitoring Model
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In Decision 82-13, the Commission established a set of quality of service indicators. Pursuant to Decision 82-13, BC TEL, Bell and Northwestel, the telephone companies that were under the Commission's jurisdiction at the time of the Decision, are required to report details of their performance, on a quarterly basis, for a number of indicators dealing with eight service interfaces.
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In their initial submissions in this proceeding, Island Tel, MT&T, NBTel, NewTel and TCI (which were not under the Commission’s jurisdiction at the time that Decision 82-13 was issued and were therefore not required to file reports pursuant to Decision 82-13), requested that they be exempted from reporting on quality of service and that market forces be relied on to provide incentives to ensure that quality of service is maintained.
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As noted earlier, the Commission stated in the regulatory framework Decision (Decision 94-19) that it would monitor the quality of service of all telephone companies under its jurisdiction with respect to essential Utility services, bottleneck facilities, and toll service in regions where the telephone company is the sole provider actively marketing such services. The Commission remains of the view, stated in its letter of 6 November 1995, that market forces are not sufficient incentives to ensure that quality of service with respect to essential Utility segment services and bottleneck facilities does not deteriorate under a price cap regime. The Commission also notes that the effects of local competition, if any, on quality of service are not known at this time. Therefore, the request of Island Tel, MT&T, NBTel, NewTel and TCI to be exempted from reporting on quality of service is denied.
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The Commission notes that, under the current monitoring model, the service quality standards required for the three reporting telephone companies, i.e., BC TEL, Bell and Northwestel, have generally been met or exceeded. On this basis, the Commission is satisfied that the current monitoring model has worked reasonably well in safeguarding service quality and provides an appropriate framework upon which to develop a monitoring model for the telephone companies that are parties to this proceeding. Therefore, in Appendix A to this Decision, the Commission has determined a set of interfaces, indicators and standards based on those established in Decision 82-13 and modified them to reflect the issues raised in this proceeding as discussed in Section B below. The telephone companies are directed to use the new monitoring model in Appendix A to file quality of service reports on a quarterly basis commencing with the year 1998. The reports are to be filed within 45 days of the end of each quarter.
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With respect to indicators, the Commission notes that the current reporting requirements use a number of subjective indicators based on regular surveys of customer satisfaction.
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The Commission notes that the telephone companies preferred the use of subjective indicators but, with respect to rebates, indicated that they were in favour of using objective criteria. Interveners generally favoured the use of objective indicators.
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The Commission notes that, with the use of subjective indicators, the results of customer surveys may be distorted simply by customers being dissatisfied with other factors, such as a rate increase, rather than with an actual change in the service quality of a specific indicator.
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Accordingly, the Commission is of the view that subjective indicators are not appropriate and directs the telephone companies to employ indicators based on objective criteria in the new monitoring model.
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Currently, BC TEL, Bell and Northwestel report quality of service performance using company-specific standards. Under the new monitoring model, the 14 telephone companies will be reporting on service quality using uniform national standards. In the Commission’s view, it would be appropriate to obtain actual data before finalizing a set of national quality of service standards. Therefore, the standards for the monitoring model set out in Appendix A for the telephone companies are established on an interim basis until 31 December 1998.
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BC TEL, Bell and Northwestel are directed to continue to report under the Decision 82-13 requirements as well as the new monitoring model in Appendix A. The Commission has set out in Part V of this Decision directions for a process to finalize a set of national quality of service standards, to be effective 1 January 1999. At that time, BC TEL, Bell and Northwestel will no longer be required to report under the indicators set out in Decision 82-13.
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B. Key Issues Raised in PN 94-50
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1. Uniformity of Quality of Service
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The first issue was whether there should be different approaches to quality of service regulation to reflect any differing circumstances of the various telephone companies.
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The telephone companies generally favoured uniformity in principles.
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Interveners generally favoured uniformity for comparison purposes.
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The Commission agrees that uniformity and consistency should be encouraged to the greatest extent possible, so that all Canadians can be assured of having a similar high quality of service, consistent with the objectives set out in section 7 of the Telecommunications Act.
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2. Urban/Rural Reporting
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The second issue was whether there should be separate reporting of rural and urban quality of service indicator performance.
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The telephone companies generally agreed to report separately on provisioning and repair interfaces for urban and rural subscribers but opposed separate reporting for indicators which have common delivery systems, such as Operator Services and Billing, arguing there would be no difference in the quality of service provided to urban versus rural areas.
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TCI opposed separate reporting for urban and rural subscribers on the basis that service to both customer sectors should be the same. TCI stated that it provides the same service to all areas of its serving territory.
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MTS proposed a separate category called "remote" for areas not accessible by road year-round.
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Interveners supported disaggregated reporting for rural and urban areas based on a concern that the telephone companies would lower the quality of service in high cost areas in order to cut costs and maximize profits.
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The Commission notes that the cost of maintaining quality of service is greater in rural areas than in urban areas because of the distances that have to be travelled and the human resources required to provide and repair service. The Commission also notes that persistent problems with rural service quality would not be as noticeable under a company-wide reporting system because the number of quality of service problems reported would be spread over the total base of urban and rural subscribers. Further, competitive market forces are less likely to be a disciplining factor in rural areas. Accordingly, the Commission considers separate reporting of rural and urban service indicators to be appropriate. The Commission notes, however, that there is a common delivery system for Operator Services and Billing. Therefore, the telephone companies will be required to report separately for Provisioning and Repair service.
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With regard to establishing an appropriate delineation between urban and rural areas, the Commission notes that in Local Competition, Telecom Decision CRTC 97-8, 1 May 1997 (Decision 97-8), it approved, on an interim basis, Stentor’s proposed rate bands for local loops based on length and density. The Commission noted that the smaller, less dense exchanges were generally characterized as constituting Bands C and D by Stentor in the proceeding leading to Decision 97-8, but that some exceptions exist, for instance, for NBTel.
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The Commission notes that eight telephone companies (i.e., BC TEL, Bell, Island Tel, MT&T, MTS, NBTel, NewTel and TCI) that will be subject to price caps will have their territories delineated by rate bands. Further, the bands will be finalized in the proceeding established by Implementation of Price Cap Regulation, 1997 Contribution Charges and Related Issues, Telecom Public Notice CRTC 97-11, 25 March 1997. The Commission considers, therefore, that for BC TEL, Bell, Island Tel, MT&T, MTS, NBTel, NewTel and TCI the use of the rate bands is an appropriate classification for the reporting of rural and urban subscribers, i.e., Bands A and B, considered to be urban areas, and Bands C and D, considered to represent both rural and remote areas.
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With respect to Northern, Northwestel, Québec-Téléphone, TCEI, Télébec and Thunder Bay Telephone, the Commission notes that these companies are not subject to the rate band designation established in Decision 97-8. Therefore, the Commission considers that, based on the population and density of subscribers in their respective territories, Northern, Northwestel, Québec-Téléphone, Télébec and Thunder Bay Telephone can be regarded as rural and TCEI can be regarded as urban for reporting purposes.
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3. Service Interfaces
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The third issue was whether the eight service interfaces (i.e., Provision of Service, Repair Service, Local Service, Long Distance Service, Operator Services, Directory Service, Billing and Complaints) set out in Decision 82-13 are still appropriate, and whether new service interfaces such as network reliability should now be included in the new regulatory framework.
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Most of the telephone companies agreed to maintain the eight interfaces, with the exception of Long Distance Service which they proposed be discontinued.
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Several telephone companies proposed to measure the quality of service provided to competitors under a new separate interface called Access to Essential Utility Services (Interconnection Services).
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Interveners were generally in favour of retaining the eight service interfaces as well as the addition of a new interface for Interconnection Services.
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Both Cantel and AT&T Canada LDS proposed additional indicators for Interconnection Services.
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While the Commission finds that the interfaces established in Decision 82-13 continue to be a valid framework upon which to measure quality of service, the Commission considers that interfaces that have been rendered superfluous due to technological and market developments over the past 15 years should be phased out, specifically Interface #4: Long Distance Service; Interface #5: Operator Services and Interface #7: Billing.
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With respect to Interface #4: Long Distance Service, the Commission notes that, with the proliferation of optical fibre, carrying capacity of the intertoll telephone network has substantially exceeded current usage. Also, excellent voice quality is attained with digital technology. Tone dialing, common channel signalling (CCS7) and digital switches provide almost instant dial tone. Therefore, the Commission concludes that the Interface dealing with Long Distance Service no longer needs to be monitored, except in areas without competitive service providers. For those areas, the Commission will track the number of complaints under the Interface: Complaints, where Long Distance is reported as a separate category.
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With respect to Interface #5: Operator Services, the Commission notes that since Direct Distance Dial became popular, very few customers use toll operators compared to a decade ago. Further, the convenience of calling cards has further reduced the need to use Operator Services. For those customers requesting Operator Services, the interface is for the most part handled by Voice Interactive Recording. In light of the above, the Commission concludes that the Interface dealing with Operator Services no longer needs to be monitored. The Commission will, however, track the number of complaints under the Interface: Complaints, where Operator Services is reported as a separate category.
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With respect to Interface #7: Billing, the Commission notes that with the high degree of computerization, billing errors are not expected to be a serious problem with consistent 99% to 100% accuracy reported by the telephone companies. On the other hand, customer caused adjustments are becoming increasingly frequent as more and more enhanced services are tried and cancelled by subscribers. Because the percentage of bills showing adjustments are no longer indicative of the telephone companies’ faulty accounting, the Commission concludes that the Interface dealing with Billing no longer needs to be monitored. The Commission will, however, track the number of complaints under the Interface: Complaints, where Billing is reported as a separate category.
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With respect to whether new service interfaces such as network reliability should now be included in the new regulatory framework, the Commission considers network reliability to be covered under the Repair Service Interface.
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With respect to the proposal for new interfaces for Interconnection Services (i.e., for competitors), the Commission considers that such interfaces are not necessary as the new indicators for competitors are included under Provisioning and Repair Interfaces.
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4. Maintaining Quality of Service under Price Caps
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The fourth issue raised in PN 94-50 has been dealt with under Parts II and III above.
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5. Regulatory Responses to Below-Standard Performance
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The fifth issue was what regulatory responses should be considered when actual measured performance falls below the standard performance level.
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The telephone companies took the position that market forces obviated the need for regulatory action. In the alternative, the telephone companies generally argued that an explanatory report with an action plan, when needed, would be sufficient response to below standard service.
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Interveners disagreed with the telephone companies on the basis that market forces would not develop fast enough nor operate evenly throughout the telephone companies’ territories. Interveners were of the view that continued regulatory oversight was therefore imperative to safeguard the public interest.
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The Commission notes that, depending on the severity of quality deterioration, regulatory responses could range from increasing the frequency of reporting from quarterly to monthly and demanding a plan of action, to progressively severe measures, such as requiring customer-specific rebates, a general rebate, or a downward adjustment to the price cap index as contemplated in a Q-factor. The Commission is of the view that no change in regulatory treatment is needed at this time, except that an explanation of below-standard performance, if necessary, is to be filed concurrent with, rather than 15 days after, the filing of a quarterly report which is filed 45 days after the end of the quarter.
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6. Sub-Standard Threshold Rebates
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The sixth issue was, as a means to ensure that rates to subscribers appropriately reflect the service quality provided to them, whether rebates or rate reductions are appropriate when actual measured performance for certain specified indicators (e.g., dial tone delay, repair, operator answer) falls below a pre-set threshold lower than the standard performance level.
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This issue has been addressed in Part III above.
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7. New Indicators
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The seventh issue was whether certain quality of service indicators should be provided as a sub-set of other quality of service indicators, for example:
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(a) Provisioning of Bottleneck Facilities for competitors as a sub-set of customer provisioning or business customer provisioning;
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(b) Message Relay Service (MRS) as a sub-set of Operator Services quality;
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(c) Average Installation Interval (in days) from receipt of order to available for service as a sub-set of held orders; and
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(d) Average Repair Interval (in hours) from receipt of trouble report to available for service as a sub-set of repair.
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With respect to the provisioning of bottleneck facilities, both the telephone companies and interveners generally supported the introduction of indicators measuring the provision and repair of interconnected services provided to competitors. As well, AT&T Canada LDS and Cantel proposed additional indicators.
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On the basis of parties’ proposals, the Commission directs the addition of three new indicators: (1) percentage of competitors' installation appointments met; (2) on time Primary Interexchange Carrier (PIC) activation; and (3) percentage of competitors' repair appointments met.
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As to the other indicators proposed by AT&T Canada LDS and Cantel, the Commission notes that some of those proposed by AT&T Canada LDS were subjective indicators and are therefore not appropriate as previously stated. For the remaining proposed indicators, because interconnection service agreements are approved by the Commission and the terms and conditions under which interconnection services are offered are subject to supervision by the Commission (including its Competitive Dispute Resolution process), the Commission considers that the monitoring of the remaining proposed indicators is not necessary.
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With respect to MRS, the Canadian Association of the Deaf (CAD) proposed that it be included as a new indicator.
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The telephone companies stated that MRS already is subject to sufficient scrutiny from various organizations and that the telephone companies have co-operated extensively with various agencies to facilitate service for persons with disabilities.
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The Commission notes that CAD acknowledged the labour and cost-intensive nature of MRS, the dedication of the telephone companies in providing this service and the great benefits this service has brought to deaf and hearing people alike. Given that there is no evidence of poor service, the Commission is of the view that a separate indicator for MRS is not required at this time.
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With respect to average installation interval, the telephone companies were opposed to reporting on this indicator.
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The Commission considers that it is appropriate to include an indicator for average installation interval in order to determine how long it takes to provide service from the date of the initial request. Average installation interval is shown as indicator 1.1 - Provisioning Interval in Appendix A.
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With respect to average repair interval, the telephone companies stated that they currently report on out-of-service trouble cleared within 24 hours and that they preferred to retain this indicator.
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The Commission is of the view that the current indicator for out-of-service trouble reports cleared within 24 hours remains appropriate.
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The Commission notes that NBTel proposed to report on a new set of indicators. In view of the monitoring model set out in Appendix A, NBTel’s proposal is denied.
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8. Below-Standard Reporting Rules
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The eighth issue was whether the current requirement for a telephone company to report below-standard service quality, where it occurs over three consecutive months or over seven months in a 12-month period, should remain the same. In particular, the Commission sought comments on, or proposed alternatives to, the following possible reporting requirements:
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(a) where service quality falls below standard for three consecutive months, the affected indicator should be reported to the Commission monthly until its performance level is at or above standard; and
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(b) where service quality falls below standard for seven out of 12 consecutive months, the affected indicator should be reported immediately to the Commission, rather than on the regularly scheduled quarterly report due date.
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Parties generally agreed that it would be appropriate to continue the current practice of requiring telephone companies that report below-standard performance with respect to any indicator for three consecutive months or seven out of 12 consecutive months, to provide the Commission (a) with an explanation of the cause of quality degradation; and (b) with an action plan describing how the telephone company intends to rectify and prevent the situation from recurring.
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The Commission agrees with parties and directs that in circumstances where a telephone company reports an indicator with below-standard quality for three consecutive months, or seven out of 12 consecutive months, it is to file for that indicator monthly reports within 15 days of the end of the month, rather than quarterly reports, until quality meets or exceeds the standard for three consecutive months, and provide an explanation of the cause of quality degradation and an action plan describing how it intends to rectify and prevent the situation from recurring.
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9. Basis for Standards
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The ninth issue was whether the 90% satisfaction objective stated in Decision 82-13 is still appropriate, or whether an alternative objective should be considered.
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The Commission concurs with both the telephone companies and interveners that the 90% customer satisfaction objective is still appropriate.
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10. Reporting of Internal Measures
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The tenth issue was whether all telephone companies should employ network measurements and adjust, on a periodic basis, their respective service quality standards based on their impact upon customer satisfaction and, if so, for which service quality standards.
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The telephone companies indicated that they employ internal measures to meet customers’ expectations.
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The Commission considers that the telephone companies’ approach is appropriate.
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11. Service Guarantees
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The eleventh issue was whether a "Customer Service Guarantee Policy" for utility service subscribers should be considered, for example, one similar to that offered by the Georgia Power Company, shown in Attachment 1 to PN 94-50.
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The telephone companies took the position that service guarantees were an operational and marketing strategy and that they should have the freedom to consider these options at their discretion. They submitted that, where service guarantees are offered, quality of service reporting should cease in that the service guarantee itself would ensure that an adequate level of service quality is provided; if it is not, the customer would be compensated in accordance with the service guarantee.
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TWU was of the view that such a guarantee is appropriate.
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As noted in Part III above, the Commission is of the view that mandated rebates are not warranted at this time. Similarly, the Commission is of the view that mandated service guarantees are not warranted at this time. However, the Commission would entertain proposals for voluntary service guarantees. Such proposals should be uniformly applied to customers in a manner that would not result in unjust discrimination.
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12. Quality Management Programs
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The twelfth issue was whether quality management programs such as the International Standards Organization ISO 9000 (ISO 9000), or certain aspects thereof, should be considered in developing quality of service indicators to be reported to the Commission.
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The telephone companies generally considered quality management programs, such as ISO 9000, as tools more suitable for management purposes than for regulatory oversight.
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The Commission concurs with the telephone companies that internal management tools are not the purview of the regulator unless serious problems arise as a direct result.
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13. Company Employee Compensation Plans
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The thirteenth issue was, where telephone companies employ internal management systems (e.g., total quality management) or tie Commission reported quality of service indicator performance to compensation plans for management, whether quality-versus-compensation results of such systems should be provided to the Commission on an annual basis.
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The telephone companies were opposed to identifying service elements used in a company’s compensation plan, arguing that how a company achieves desired performance levels is an internal matter.
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TWU argued that the quality of service components utilized in BC TEL’s company compensation plan have failed to attain the desired quality of service levels. In TWU’s view, such elements could not serve as a substitute for Commission oversight.
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The Commission agrees with the telephone companies that compensation plans are properly within the purview of company management.
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14. Common Report Format
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The fourteenth issue was whether the quality of service periodic reports filed by the telephone companies should have a uniform format and, if so, what format should be appropriate.
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The telephone companies considered desirable a common report format across all telephone companies.
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The telephone companies proposed that the administrative details of submissions would be best determined following a decision in this proceeding and, at that time, that meetings between the telephone companies and Commission staff could be held to determine the administrative details regarding the reporting format.
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PIAC and TWU supported a uniform format for the quality of service reports.
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The Commission is of the view that details on a common reporting format should be developed through consultations with Commission staff subsequent to the release of this Decision. The telephone companies and other interested parties are therefore directed to notify the Commission, within 10 days of this Decision, of the name of the person to contact with respect to this matter. The format should be finalized by 31 December 1997.
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15. Machine-Readable Filings
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The fifteenth issue was whether procedures should be developed that would eventually enable the telephone companies to file the periodic quality of service reports in electronic format.
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In general, the telephone companies were of the view that the use of an electronic media format for filing quality of service results would be appropriate.
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PIAC was supportive of electronic filings as a way of reducing costs for the companies and the Commission.
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The Commission notes that it began receiving electronic filings with respect to its telecommunications activities on 1 January 1996 and since then has successfully received over 22,000 documents filed electronically mostly by Stentor and its members. The Commission further notes that Commission staff is available to assist all telephone companies, that have not used electronic filing, on the process involved. The Commission considers that, once all telephone companies are familiar with the process, they will be able to file the first quality of service reports, as set out in Part IV, in electronic format.
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C. Other Issues - Changing Indicators and Standards
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To streamline the process of changing indicators and standards, Bell and BC TEL, with the concurrence of the other telephone companies, proposed a process for introducing changes.
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Under the proposed process, the telephone companies would file, 90 days before implementing changes, a proposal with the Commission providing details and a rationale for the change. Before the end of the 90 days, if the Commission does not respond, the changes would be implemented by the telephone companies. Following implementation of the change, the telephone companies would report for two consecutive quarters both old and new indicators or standards so that users would be able to compare the changes. At the end of the two quarters, the old indicator would be discarded.
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The Commission considers the proposed process for changing indicators and standards to be generally appropriate. The Commission considers, however, that interested parties should have an opportunity to comment on any proposed changes. In view of this, the Commission, therefore, directs the telephone companies to use the following procedure when changes to indicators and standards are proposed:
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(a) 90 days before implementing any proposed change, the telephone companies are to file a proposal with the Commission, providing details and a rationale for the change, serving a copy on interested parties to this proceeding and any other interested parties. The submission should include data for the two most recent quarters showing results for both old and new indicators, in order to allow interested parties to compare the effects of the change and comment;
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(b) Interested parties will have 30 days to comment and telephone companies will have 10 days to reply to any comments; and
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(c) If there is no other impediment, the Commission should be able to render its determinations before the proposed implementation date.
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V PROCESS TO FINALIZE THE STANDARDS
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BC TEL, Bell, Island Tel, MT&T, NBTel, NewTel, MTS, Northwestel, Northern, Québec-Téléphone, Télébec, Thunder Bay Telephone, TCI and TCEI (the telephone companies) are made parties to this proceeding.
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Other parties wishing to participate in this proceeding must notify the Commission of their intention to do so by writing to Mrs. Laura M. Talbot-Allan, Secretary General, CRTC, Ottawa, Ontario, K1A 0N2, fax: 819-953-0795, by 30 June 1998. Parties are to indicate in their notice their Internet email address, if available. If parties do not have access to the Internet, they are to indicate in their notice whether they wish to receive disk versions of hard copy filings. The Commission will issue a complete list of parties and their mailing addresses (including Internet email addresses if available), identifying those parties who wish to receive disk versions.
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The telephone companies are directed (1) to file submissions to finalize the standards, (2) for those telephone companies unable to meet the national standard, to provide a company-specific standard proposal with supporting rationale, and (3) to provide any other proposals that the companies may wish to put before the Commission. All such material is to be filed with the Commission and served on all parties by 14 August 1998.
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All other parties may file comments on the telephone companies’ proposed standards and submissions, serving copies on all parties, by 15 September 1998.
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The telephone companies may file reply comments serving copies on all parties by 25 September 1998.
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Where a document is to be filed or served by a specific date, the document must be actually received, not merely sent, by that date.
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In addition to hard copy filings, parties are encouraged to file with the Commission electronic versions of their submissions in accordance with the Commission's Interim Telecom Guidelines for the Handling of Machine-Readable Files, dated 30 November 1995. The Commission's Internet email address for electronically filed documents is public.telecom@crtc.gc.ca. Electronically filed documents can be accessed at the Commission's Internet site at www.crtc.gc.ca .
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Laura M. Talbot-Allan
Secretary General
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This document is available in alternative format upon request.
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