ARCHIVED - Decision CRTC 2000-24

Decision CRTC 2000-24

Ottawa, 20 January 2000

Final standards for quality of service indicators for use in telephone company regulation and other related matters

File No.: 8660-C12-05/99

The Commission has concluded it will not relax the existing quality of service standards that Canadian telephone companies are required to meet.

Although some telephone companies have asked to have certain quality standards made less stringent, they will be required to maintain the same standards the Commission adopted on an interim basis in July 1997. Telephone companies have been responsible for maintaining specific service standards since 1982.

Among the 16 indicators that telephone companies must monitor and report, some new indicators have been created. For example, the Commission is seeking comment on how telephone companies should report the amount of time it takes to field customer requests and inquiries. The telephone companies should indicate if they prefer either a service indicator based on the total length of time it takes to handle a customer inquiry, how long a customer was placed on hold, or a combination of the two.

There is also a new provision to report the percentage of customer complaints which have not been satisfied within 10 working days. Telephone companies should also provide comment on what standards should be used to monitor the speed and accuracy of directory assistance.

The indicators will not override any time frames negotiated by the CRTC Interconnection Steering Committee (CISC). Those service intervals and standards have already been approved by the Commission for transferring customers' local service from the telephone companies to their competitors.

The alternative service providers that compete with the telephone companies are also customers when they use portions of the existing network. The Commission wants to monitor the quality of service the telephone companies provide to their competitors who are also customers. Within 90 days of this decision, the telephone companies are required to propose how this can best be accomplished.

In recognition of the unique business environment in the far north, Northwestel will be required to report certain service indicators at a community level. Northwestel's special status as a rural service provider will be examined in the coming months as the Commission creates a custom-made, competitive framework for the far north.

Introduction

1. In Quality of Service Indicators for Use in Telephone Company Regulation, Telecom Decision CRTC 97-16, 24 July 1997 (Decision 97-16), the Commission provided interim standards for quality of service indicators. The Commission expressed the view that it would be appropriate to obtain actual data before finalizing a set of national quality of service standards. The Commission directed the telephone companies subject to the decision, i.e., TELUS Communications (B.C.) Inc. (formerly BC TEL) referred hereafter as TCBC, Bell Canada (Bell), Island Telecom Inc., (formerly The Island Telephone Company Limited), Maritime Tel & Tel Limited, MTS Communications Inc., NBTel Inc. (formerly The New Brunswick Telephone Company, Limited), NewTel Communications Inc., Northern Telephone Limited (Northern), Northwestel Inc. (Northwestel), Québec-Téléphone, Télébec ltée, TELUS Communications Inc. (TCI) and The Corporation of the City of Thunder Bay - Telephone Division, (collectively the telephone companies), to file quarterly (45 days after the end of each quarter), quality of service monthly performance reports commencing with the year 1998, for each of the indicators using the monitoring model in Appendix A of the decision.

2. The Commission also directed the telephone companies:

(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.

3. Appendix 1 to this decision contains a list of parties that participated in this proceeding.

4. This decision deals with the standards for the service indicators that will be required by the Commission from the larger telephone companies in Canada for their quarterly quality of service reports. The Commission relies upon these reports to ensure that subscribers receive acceptable service from their respective carriers, to isolate service quality problems as they arise and to work with the telephone companies to implement corrective actions where needed.

5. While the Commission will use objective service indicators as a measure of company performance, it recognizes that good customer service involves many subjective factors such as courtesy, timely resolution of real or perceived problems, and generally good rapport between a customer and the supplying telephone company. The Commission encourages all companies to monitor their total customer service performance and to consider the objective measurements as required by the Commission as only one part of their responsibility to provide a high level of quality of service.

Final standards

6. In this proceeding, several of the telephone companies proposed changes to the interim standards for the following service indicators:

1.1 - Provisioning Interval Urban and Rural

1.3 - Held Orders Urban and Rural

1.5 - Access to Business Office

2.1 - Out of Service Troubles Cleared Urban and Rural

2.3 - Initial Customer Trouble Reports per 100 NAS Urban and Rural

2.5 - Access to Repair Bureau

4.1 - Directory Accuracy

7. In general, the changes would have reduced the standards for these indicators.

8. The Commission has considered the telephone companies' proposals and the comments from interested parties and is of the view that changes to the standards are not required at this time. The Commission is satisfied that the standards set on an interim basis in Decision 97-16 have worked reasonably well for the purpose of monitoring the quality of service of the telephone companies and considers that these standards continue to be appropriate. Therefore, the Commission denies the telephone companies' requests to change any of the interim standards set in Decision 97-16, and approves, on a final basis, all of the standards for the quality of service indicators approved on an interim basis in Decision 97-16. The final standards for monitoring quality of service indicators are set out in Appendix 3 to this Decision. The standards approved in this Decision will be considered the minimum level of quality of service performance for each telephone company.

Proposals regarding other aspects of service indicators and new service indicators

A. General

9. In addition to proposals to change the standards for certain indicators, as noted in Paragraph 6 of this decision, the telephone companies also proposed a number of changes related to other aspects of the indicators. These proposed changes are discussed below as are the Commission's conclusions regarding new indicators.

B. Indicator 1.4 – Held Upgrades

10. With respect to Indicator 1.4 – Held Upgrades, Northwestel stated that it currently has less than 100 multi-party lines in service and therefore, this statistic is no longer meaningful in assessing the demand for service upgrades. The company suggested that this statistic be reported only when the number of party lines is 200 or more for a telephone company.

11. Northern requested a reporting exemption for Indicator 1.4 on the basis that it cannot meet the interim standard because its current offering for basic service is four-party service. Northern stated that it would resume reporting if and when the company has completed its individual line service program and is therefore able to offer individual line service as part of its basic service.

12. The Commission notes that the issue of establishing a monitoring program to track service improvement plans has been addressed in Telephone Service to High-Cost Serving Areas, Telecom Decision CRTC 99-16, 19 October 1999 (Decision 99-16). The Commission concludes that if a telephone company's service improvement program is to be tracked by a monitoring program established by the Commission as a result of Decision 99-16, the quarterly reporting of this indicator would no longer be required. However, the Commission is of the view that the progress report resulting from monitoring the program to track service improvement plans as set out in Decision 99-16 should be filed as part of the quality of service quarterly report filing.

13. The Commission considers that, subject to the above, the status quo is appropriate. The Commission denies Northwestel's request to report only when the number of party lines is 200 or more and Northern's request to be exempted from reporting Indicator 1.4.

C. Indicator 1.7 – On-time Activation of PIC Alternate Providers of Long Distance Service

14. With respect to Indicator 1.7 – On-time Activation of Primary Interexchange Carrier (PIC) Alternate Providers of Long Distance Service, TCI submitted that this indicator should be reported on an exception-only, complaint basis given that all companies have consistently met standards.

15. The Commission notes that only TCI proposed to discontinue the regular filings for this indicator. The Commission notes that this indicator monitors the quality of service performance provided to competitors. Given the importance placed by competitors on timely installation of facilities, and the possibility of anti-competitive behaviour in this regard, the Commission is of the view that data on the on-time activation of PICs should be collected. Therefore, the Commission denies TCI's proposal to discontinue the reporting of Indicator 1.7.

D. Indicator 2.1 – Out-of-Service Trouble Reports Cleared Within 24 Hours

16. With respect to Indicator 2.1 – Out-of-Service Trouble Reports Cleared Within 24 Hours, Northwestel stated that it serves a large geographic area, many of the communities it serves are remote, and the facilities in those communities may be unmanned and accessible by technicians only by air. The company proposed that for purposes of setting quality of service standards for this indicator, a third classification called "remote" should be created (in addition to urban and rural), which would be defined as any community with less than 500 Network Access Services (NAS) and where access to the community from a larger centre is either by aircraft or by road with more than three hours of normal driving. For this category, the company proposed a standard of 70% of out-of-service troubles cleared in 10 working days.

17. The Government of the Northwest Territories (GNWT) objected to a separate indicator for remote areas on the basis that it would fail to satisfy 90% of customers, and that by any criteria, this would be considered very poor service.

18. The Commission notes that the "remote" category was also proposed by Northwestel in the proceeding which led to the issuance of Decision 99-16. The Commission also notes that quality of service in Northwestel's territory is an issue to be dealt with in the proceeding initiated by Northwestel Inc. – Implementation of Toll Competition and Review of Regulatory Framework, Quality of Service and Related Matters, Telecom Public Notice CRTC 99-21, 1 October 1999 (PN 99-21). The Commission considers that the PN 99-21 proceeding is the appropriate venue to deal with Northwestel's request for a "remote" category and will not address it here.

E. Indicator 2.6 – Competitor Repair Appointments Met and Indicator 2.2 –Repair Appointments

19. TCI noted that it does not have methods in place to separate data for Indicator 2.6 – Competitor Repair Appointments Met and Indicator 2.2 – Repair Appointments, and submitted that the standard should be the same for both, and that a company-specific indicator should be established for this indicator by subsuming it within Indicator 2.2.

20. The Commission notes that the same problem is being experienced by some of the other telephone companies. The Commission also notes that both Indicators 2.6 and 2.2 already have the same standards. At this time, the Commission considers that the telephone companies may report the combined data in Indicator 2.2 and show N/A (not available) in the reporting of Indicator 2.6. However, the telephone companies are to report progress on their efforts to separate data for Indicator 2.6 from Indicator 2.2 as part of the fourth quarter quality of service quarterly report filed with the Commission.

F. Indicator 3.1 – Dial Tone Delay

21. With regard to Indicator 3.1 – Dial Tone Delay, TCI submitted that this indicator should be reported on an exception-only, complaint basis given that all companies have consistently met the standard.

22. In Decision 97-16, the Commission stated that while the telephone companies have consistently reported scores well above the standard, the Commission is concerned that widespread use of Internet services may cause congestion in the future. On this basis, the Commission remains of the view that this indicator should continue to be monitored. Therefore, the Commission denies TCI's proposal to discontinue the reporting of Indicator 3.1.

G. Indicator 4.1 – Directory Accuracy

23. With respect to Indicator 4.1 – Directory Accuracy, Northwestel stated that competitive directories exist in its two major markets – Yellowknife and Whitehorse. Given the high directory accuracy maintained by Northwestel and the competitive nature of directory advertising, the company proposed that Indicator 4.1 is no longer required.

24. GNWT opposed Northwestel's request to eliminate Indicator 4.1 stating that the company's rationale is only applicable in two of over 90 communities served by Northwestel.

25. The Commission concurs with GNWT and denies Northwestel's request to discontinue reporting the quality of service performance of this indicator.

26. TCI provided a variation on the reporting procedure for Indicator 4.1. TCI noted that it was unable to provide the required information due to problems in implementing a process to gather the data. TCI also stated that implementing the required procedure would be extremely expensive, labour-intensive and arduous and would yield only questionable results. On this basis, TCI proposed to gather the information by way of random samples of customers, and that a company-specific indicator which would require the reporting of the survey results on a quarterly basis with the standard being 90% should be implemented.

27. In Decision 97-16, the Commission was of the view that subjective indicators are not appropriate and directed the telephone companies to employ indicators based on objective criteria. The Commission also notes that only TCI is unable to report on this indicator and accepting TCI's proposed reporting procedure would not allow the Commission to compare TCI's quality of service performance for this indicator against the other telephone companies. The Commission directs TCI to report within 60 days of this decision, on the feasibility, cost and earliest implementation date of adapting the TCBC procedure for its reporting of Indicator 4.1.

H. Additional Indicator – On hold time or total call duration

28. The Commission is of the view that Indicator 1.5 – Access to Business Office alone may not accurately depict the interaction between the customer and the telephone company business office. For example, the customer's call may be answered within 20 seconds but the customer could be put on hold for a long time. The Commission is of the preliminary view that an additional indicator should be established for measuring either the total length of time customers are placed on hold or the duration of the call when they call a telephone company business office. The Commission directs the telephone companies to file proposals, within 45 days of this decision, for a standard for a new indicator to measure either on hold time or duration of call.

I. Indicator 5.1 – Customer Complaints, Additional Reporting Requirements

29. With respect to Indicator 5.1 – Customer Complaints, MTS requested that verbal complaints no longer be included in this measure. In MTS's view, eliminating the verbal component of this indicator would ensure that complaints are of a serious nature and would eliminate or reduce the likelihood of a single complainant being counted more than once.

30. The Public Interest Advocacy Centre (PIAC) opposed MTS's submission for a number of reasons including that for many customers, there is an expectation that verbal complaints will be treated in the same manner as written complaints, and the fact that many people do not have the time or energy to submit written complaints. PIAC noted that MTS's position was not supported by any of the other telephone companies.

31. Northwestel submitted that only complaints referred by the Commission should be counted because there may be different interpretations as to what constitutes a complaint.

32. Northwestel's position was opposed by GNWT on the basis that a further definition of what constitutes a complaint could resolve the problem. GNWT noted that failure to achieve perfect uniformity on how different companies report indicator results should not prevent the use of an indicator.

33. The Commission notes that the recording of both verbal and written complaints addressed to the Commission and the companies has been ongoing since Quality of Service Indicators for Use in Telephone Company Regulation, Telecom Decision CRTC 82-13, 9 November 1982. The Commission further notes that complaints per 1000 NAS was adopted by all the telephone companies to facilitate comparison between them. The Commission continues to believe that this measurement is a useful tool for monitoring quality of service. The Commission concludes that in the interest of uniformity in reporting complaints and to continue to facilitate comparison between telephone companies, the process of recording of both verbal and written complaints to the Commission and to the company will remain unchanged.

34. However, the Commission is also concerned that the number of complaints reported under Indicator 5.1 by itself does not give as full a picture as possible of the quality of service being provided. The Commission is of the preliminary view that, in addition to the above, the telephone companies should also report the percentage of complaints not resolved within 10 working days with a standard of 90% being acceptable. The Commission directs the telephone companies to file comments, within 45 days of this decision, on the above-noted reporting requirement and standard.

J. Directory Assistance

35. In Decision 97-16, the Commission noted 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 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. The Commission concluded that the interface dealing with operator services no longer needed to be monitored. However, the Commission stated that it would track the number of complaints under the Interface: Complaints, where Operator Services is reported as a separate category.

36. The Commission notes that Directory Assistance is now a tariffed item and customers are required to pay for the use of this service. The Commission is of the preliminary view that an additional indicator should be established to measure the speed and accuracy of directory assistance. The telephone companies are to file within 45 days of this decision proposals for the definition, methods of measurement and the standard for an indicator for directory assistance.

Other related issues

A. Impact of the final standards on standards developed by the CRTC Interconnection Steering Committee

37. Call-Net Enterprises Inc. (Call-Net) stated that various members of the Ordering and Billing Sub-Working Group of CISC have worked diligently to reach an agreement on the interval for loop migration between an incumbent local exchange carrier (ILEC) and a competitive local exchange carrier (CLEC). Furthermore, work continues on the intervals for other carrier requests such as loop provisioning and repair. Call-Net requested that the Commission ensure that the approved quality of service indicators do not impact the ratified intervals developed in CISC and that the indicators are not used by the ILECs as a baseline when deliberating service intervals with other parties participating in CISC.

38. The Commission notes that all parties who addressed this issue are in agreement. The Commission notes that the quality of service indicator standards approved in this proceeding should not impact the ratified intervals developed in Commission-approved committees such as the CISC.

B. Request for additional indicators for customers who are also competitors

39. AT&T Canada Long Distance Services Company, now AT&T Canada Corp. (AT&T Canada), maintained that the public interest would be best served by the expansion of the current indicators to include specific measures of the quality of service to customers who are also competitors. AT&T Canada requested, among other things, separate indicators and standards for a number of items including:

(1) unbundled network elements, in particular, unbundled loops by types;
(2) Local Number Portability porting;
(3) co-location; and
(4) interconnecting circuits with trunk side access.

40. TCBC, Bell and TCI submitted that AT&T Canada's request is beyond the scope of the procedure set out in Decision 97-16, and AT&T Canada is attempting to re-argue many of the issues which have already been dealt with in that decision.

41. The Commission agrees with TCBC, Bell and TCI that the request by AT&T Canada for other quality of service indicators has been dealt with in paragraph 79 of Decision 97-16. It states that "because interconnection service agreements are approved by the Commission and the terms and conditions under which interconnection services are offered subject to supervision by the Commission (including its Competitive Dispute Resolution process), the Commission considers that the monitoring of the (specific competitor's) indicators is not necessary."

42. The Commission also notes Call-Net's request that the Commission ensure that the finalized standards do not affect the agreed to intervals developed in the CISC working group. Therefore, the Commission denies AT&T Canada's request for additional quality of service indicators. However, in order to confirm that the actual quality of service performance vis-a-vis competitors is in compliance with the standards negotiated in CISC and approved by the Commission, the Commission directs the telephone companies to file within 90 days of this decision for inclusion in the quarterly quality of service report a methodology for reporting compliance with any intervals and standards negotiated in CISC and approved by the Commission. The proposal should include the actual quality of service performance, including definitions, methods of measurements and standards concerning the relevant indicators negotiated under the sanction of the Commission.

C. Need for community-level indicators

43. GNWT expressed its concern that reporting of quality of service data only on a company-wide basis can mask severe problems that may be faced with respect to service quality in particular communities. GNWT further stated that while establishing separate reporting of quality of service results for rural and urban areas addresses this problem to some extent for companies serving rural and urban areas, it does not address the situation at all for companies such as Northwestel which are classified as serving wholly rural areas. GNWT requested that Northwestel, in addition to providing aggregate service quality results, be required to continue to report its service quality results on an individual community basis as done in the past.

44. Northwestel stated that tracking quality of service along community lines has, due to the large number of communities involved, proven to be an increasingly burdensome task from an administrative perspective and that community level quality of service reporting has been discontinued in other parts of Canada. The company suggested that community-level quality of service issues be addressed through complaints sent to the CRTC by customers.

45. The Commission is of the viewthat it would be appropriate for Northwestel to report quality of service indicators at the community level. Northwestel is directed to file within 60 days of this decision a proposal for community level reporting for quality of service.

D. Need for continued standards monitoring

46. TCI argued that because the local market is now open to competition, the reporting of local service results should be discontinued. None of the other telephone companies proposed this approach.

47. PIAC noted that the Commission has stated 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 has noted that the effects of local competition, if any, on quality of service are not yet known. PIAC also stated that there has been no material change in circumstances since Decision 97-16 to justify reversal of this determination by the Commission. In PIAC's submission, the Commission would be in breach of its duties under the Telecommunications Act if it were to discontinue monitoring quality of service in telecommunications at this point.

48. The Commission concurs with PIAC that it is premature to allow TCI or the other companies to discontinue reporting local service results at this time. Therefore, the Commission denies TCI's request to discontinue the reporting of its local service results at this time.

E. Proposals re: Quality of service reporting made in high-cost serving areas

49. PIAC stated that a number of parties in the proceeding dealing with service to high-cost serving areas have emphasized the ongoing need for regulatory measures designed to ensure an acceptable level of quality of service in rural and remote communities and that this should be considered in this proceeding as well.

50. The Commission notes that Decision 97-16 only covers the telephone companies previously identified, whereas the high-cost decision covers all telecommunications service providers serving in high-cost serving areas. The Commission also notes that in the re-banding proceeding (announced inDecision 99-16) the Commission will consider the regulatory treatment of quality of service in high-cost serving areas. Accordingly, the Commission will not deal with that issue in this decision.

F. Acceptance of comments from non-registered parties

51. A Chronology of Interested Parties' Submissions appears in Appendix 2. The telephone companies noted in their reply comments, that more than half of the comments received were from organizations that failed to register as interested parties in this proceeding. Although some of the telephone companies addressed items they considered of substance, Bell requested that the Commission serve notice that such an abuse of process will not be tolerated in the future. The company further stated that continuing to accept comments filed out of process signals to organizations that registration as an interested party is purely optional. The company further submitted that in the future, any such comments should be denied status by the Commission.

52. The Commission considers that the telephone companies are not prejudiced by the addition of these comments to the record of this proceeding as they had the opportunity to address the comments in their reply comments, and in fact did so. In these circumstances, the Commission is of the view that the comments should be accepted. However, the Commission wants to remind these interested parties that in future they should register in accordance with the Commission's procedures, and that failure to do so could result in the exclusion of their comments from the record of a proceeding.

Process to include additional new indicators

53. The telephone companies are directed to file submissions with respect to new indicators for call completion for access to the business office (paragraph 28), directory assistance (paragraph 36) and the reporting of complaints outstanding after 10 working days (paragraph 34). All such material is to be filed with the Commission by 6 March 2000, serving copies on all other parties to this proceeding.

54. Interested parties may file comments on the telephone companies' submissions, serving copies on all parties, by 5 April 2000.

55. The telephone companies may file reply comments serving copies on all parties by 20 April 2000.

56. 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.

57. 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 e-mail address for electronically filed documents is procedure.telecom@crtc.gc.ca. Electronically filed documents can be accessed at the Commission's Internet site at http://www.crtc.gc.ca.

Secretary General

This decision is available in alternative format upon request, and may also be viewed at the following Internet site: http://www.crtc.gc.ca

Reference Documents

Interested Parties