ARCHIVED - Decision CRTC 2001-217

Decision CRTC 2001-217

Ottawa, 9 April 2001

CRTC creates new quality of service indicators for telephone companies

Reference: 8660-C12-05/00

Table of contents

Paragraph

The decision in brief

The quality of service evolution

1

New indicators proposed in Decision 2000-24

4

Access to business office

7

Call duration not reliable indicator

7

Hold time

9

More indicators for directory assistance needed

19

Directory assistance and speed of answering

23

Directory assistance accuracy to be monitored

28

New indicator created for customer complaints

38

Directory accuracy compliance for TCI

43

Community-level quality of service indicators in Northwestel's territory

44

Competition-related intervals and standards

52

Unbundled Type A and B Loop Order Service Intervals Met

56

Local Number Portability (LNP) Order (Standalone) Service Interval Met

66

Interconnection Trunk Order Service Interval Met

73

Unbundled Loop Trouble Reports Cleared Within 24 Hours

81

Completion Notifications Received

89

Call-Net's other proposals

95

Indicator 2.6 - Competitor Repair Appointments Met and Indicator 2.2 - Repair Appointments Met

98

Appendix 1 - Reference documents

Appendix 2 - Interested parties

Appendix 3 - New Indicators

Appendix 4 - Community-level quality of service indicators in Northwestel's territory

Appendix 5 - Indicators for reporting compliance with intervals and standards negotiated in CISC and approved by the Commission

Appendix 6 - Definitions

The decision in brief

The Commission continues its quest for stringent quality of service indicators that are fair to the telcos, their customers and their competitors. Canadian telcos have been bound by quality of service indicators since 1982.

This decision introduces new service indicators that fine-tune customer complaint procedures, directory assistance speed and accuracy, and other services. Some of the new indicators have been created to improve the relationship between telcos and their competitors, who are also customers when they use portions of the telcos' networks.

This decision also asks working groups of the CRTC Interconnection Steering Committee (CISC) to recommend intervals for specific service indicators that have been identified. The CISC working groups have 30 days from the release date of this decision to report their recommendations to the Commission.

The CRTC is grateful to those that contributed to this proceeding. This decision directly reflects many of their ideas and suggestions.

The quality of service evolution

Final standards for quality of service indicators for use in telephone company regulation and other related matters, Decision CRTC 2000-24, dated 20 January 2000 directed the telcos to maintain the existing quality of service standards adopted on an interim basis in Quality of service indicators for use in telephone company regulation, Telecom Decision CRTC 97-16, dated 24 July 1997.

In Decision 2000-24, the Commission:

a) expressed the preliminary view that three new indicators should be established and directed the telephone companies to file comments on:

(i) Access to Business Office - Hold Time or Call Duration;

(ii) Directory Assistance (DA) - Speed and Accuracy; and

(iii) Customer complaints;

b) directed TELUS Communications Inc. (TCI) and Northwestel Inc. to file comments on the following company-specific matters:

(i) TCI - Directory accuracy; and

(ii) Community-level quality of service indicators in Northwestel's territory; and

c) directed the telephone companies to file comments on the following two competitor-related matters:

(i) The methodology for reporting compliance with intervals and standards negotiated in CISC and approved by the Commission; and

(ii) Indicator 2.6 - Competitor Repair Appointments Met and
Indicator 2.2 - Repair Appointments Met.

Appendix 2 to this decision contains a list of the interested parties in this proceeding.

New indicators proposed in Decision 2000-24

In this proceeding, the telcos generally suggested that no new indicators should be required because competition would ensure adequate levels of service quality. They argued the competitive market provides a powerful incentive to maintain very high levels for customer satisfaction and they are sensitive to their customers' perceptions and needs.

Consumer groups submitted that there is a continuing need for regulation of telcos' quality of service because local competition is not sufficient to deliver adequate levels of service quality.

The Commission is satisfied there is a need for continuing telco regulation on quality of service due to low levels of competition in some areas and customers are still largely captive to their incumbent local carriers and in some cases competitors are dependent on the telcos for their ability to compete.

Access to business office

Call duration not reliable indicator

The telcos contend that call duration would not be a useful measure for gauging customer satisfaction because call length is dependent primarily on the complexity of the issue being discussed.

The Commission agrees and further notes that such an indicator may encourage customer service representatives to rush customers, without addressing all of their concerns. The Commission concludes that a call duration indicator would not accurately depict the interaction between the customer and the telco and finds that no such indicator is required.

Hold time

The telcos generally were of the view that:

· Indicator 1.5 - Access Business Office, provides a representative measurement of customer interaction with the business office and no new measures are required;

· Given the variation in call complexity, it would not be possible to establish a meaningful standard for an indicator based on the length of time a customer is on hold; and

· Not all companies are capable of measuring holding time duration. Québec-Téléphone stated that it is uncertain that its system could calculate the hold time period.

Consumer groups submitted that Indicator 1.5 only measures the time taken to answer a call and that it can be easily circumvented by answering, then putting the customer on hold for an extended period of time. Consumer groups submitted that it would be appropriate to measure the total hold time before the customer is connected to the appropriate service representative. They proposed that the new indicator would require that a minimum of 90% of calls are connected to the appropriate service representative within 20 seconds of having been answered.

The companies represented by Bell Canada (see Appendix 2) stated that:

· it is neither their policy, nor practice, to answer and then immediately put the customers on hold;

· when a client representative answers a call, the customer is put on hold only if it is necessary for the client representative to go off-line to pursue matters related to that customer's inquiry;

· to immediately put a customer on hold would neither be in the companies' nor their customers' interest; and

· doing so would unnecessarily tie up call centre facilities and would exacerbate customer frustration.

The Commission agrees that the variation in complexity of calls may affect the time period that customers are on hold after the call has been answered and while the service representative may be consulting with other persons. For this reason, it would be difficult to construct a meaningful indicator of hold time duration. The Commission considers that the situation which should be addressed by a new indicator, however, is where the telco responds to a call and then immediately places the caller on hold, prior to connecting the caller to a service representative.

The Commission confirms its preliminary view in Decision 2000-24 that a new indicator should be established to measure the total length of time customers are placed on hold. This duration should measure the time prior to the beginning of a dialogue with a service representative. The Commission directs the telcos to report on new Indicator 1.5 - Access to Business Office - On Hold Duration in their monthly quality of service reports. This indicator will be reported in every quarter, commencing with the third quarter of 2001, using the monitoring model in Appendix 3 of this decision.

The telcos may discontinue reporting on Indicator 1.5 - Access to Business Office which was established in Decision 2000-24, at the same time they report on the new Indicator 1.5.

The companies represented by Bell Canada and Québec-Téléphone submitted that it is not possible for all of them to measure total hold time duration.

The telcos have been able to establish procedures for measuring other time periods, such as for Indicator 1.5 - Access to Business Office. The Commission directs the companies represented by Bell Canada and Québec-Téléphone that consider they are not able to establish procedures for measuring total hold time duration, to show cause within 30 days of this decision, why they should not report on the new Indicator 1.5 - Access to Business Office - On Hold Duration.

The Commission directs that in Indicator 2.5 - Access to Repair Bureau, established in Decision 2000-24, the standard of "80% or more" be changed to "90% or more". This reflects the Commission's determination of the minimum performance standard for new Indicator 1.5 - Access to Business Office - On Hold Duration. The Commission directs the telcos to report on Indicator 2.5 - Access to Repair Bureau in their monthly quality of service reports. This indicator will be reported in every quarter, commencing with the third quarter of 2001, using the monitoring model in Appendix 3.

The Commission directs the telcos that believe the performance standard for Indicator 2.5 - Access to Repair Bureau of "90% or more" may not be appropriate to show cause, within 30 days of the decision, why they should not report on this basis.

More indicators for directory assistance needed

The companies represented by Bell Canada and Québec-Téléphone submitted that indicators on DA service would not be appropriate because, in an increasingly competitive environment, competitive local exchange carriers (CLECs) can compete with the incumbent telcos by providing their own DA service and some customers have alternative access to DA information through the Internet.

The consumer groups submitted that DA service should be subject to quality of service reporting because it is a tariffed service in its competitive infancy and market forces are not yet sufficient to ensure an acceptably high level of service.

The Commission believes competition in local telephone service and DA service is not sufficiently established to permit reliance on market forces alone to ensure an acceptably high level of DA service.

The Commission finds it appropriate to establish new indicators for DA service and confirms its preliminary view that additional indicators should be established on DA services.

Directory assistance and speed of answering

TCI submitted that a meaningful indicator of speed of answer is difficult to structure because of variables that include the number of rings prior to response and the nature and quality of a customer's request, all of which can influence the length of a DA call. Consumer groups submitted that a new indicator to measure the speed of answer is necessary to ensure an acceptable quality of DA service.

TCI submitted that only the number of rings prior to a response should be measured because it is the only factor that is completely within the company's control. The companies represented by Bell Canada proposed that, since the DA function is essentially a call centre operation, a new indicator should be similar to the existing measures for Indicator 1.5 - Speed of Answer to the Business Office and Indicator 2.5 - Speed of Answer to the Repair Bureau, where 80% of calls should be answered in 20 seconds or less. Consumer groups proposed a standard of at least 90% of calls to DA service should be answered within 20 seconds.

The Commission believes a telco's speed of answer, which is the subject of new Indicator 1.5 - Access to Business Office - On Hold Duration, is an important indicator of quality of service performance. The Commission is of the view that customer satisfaction with the speed of answering by DA service is as important.

The Commission agrees with TCI that the number of rings before a telco answers is completely within its control and is the appropriate subject matter to measure.

The Commission confirms, therefore, its preliminary view in Decision 2000-24 that an additional indicator should be established to measure the speed of DA. The Commission directs the telcos to report on Indicator 4.2 - Access to Directory Assistance in their monthly quality of service reports. This indicator will be reported in every quarter, commencing with the third quarter of 2001, using the monitoring model in Appendix 3.

Directory assistance accuracy to be monitored

TCI submitted that only the accuracy of a company's own databases and customer service representatives should be measured because all other DA service, including other telephone companies' databases, are outside a company's control.

The companies represented by Bell Canada submitted that:

· an accuracy standard of 90% recognizes that there are many potential causes for a customer being unsatisfied with a number obtained from DA, including incomplete customer provided information, inaccurate customer provided information, database errors, DA operator errors and the customer incorrectly recording or dialing the number obtained; and

· if a level higher than 90% was established, the methodology used to determine that standard would have to be adjusted to eliminate customer-originated errors as well as errors that are not attributable to the companies represented by Bell Canada.

TCI submitted that, if such a methodology could be developed, it would result in a complex process that would involve considerable work, effort and cost.

Consumer groups want a new indicator to ensure an acceptable quality of DA service and proposed the standard of at least 95% of DA listings should be provided without error.

The Commission notes that customer satisfaction with directory accuracy, as noted in existing Indicator 4.1 - Directory Accuracy, is an important quality of service indicator. The Commission considers that customer satisfaction with the accuracy of listings provided orally by DA service is as important.

The Commission disagrees with TCI's submission that the accuracy of listings provided by a company from its own databases and by its own customer service representatives are the only elements that should be measured. Since the telcos update each other on DA listings and DA service includes all such listings, the telcos should measure the accuracy of all listings provided, whether the listing is for customers within their own operating territory or not.

As noted in Decision 2000-24, an additional indicator should be established to measure accuracy of listing provided by DA service. The Commission directs the telcos to report on Indicator 4.3 - Directory Assistance Accuracy in their monthly quality of service reports. The Commission considers that a performance standard of 93.8% or more without error is appropriate. This indicator will be reported in every quarter, commencing with the third quarter of 2001, using the monitoring model in Appendix 3.

The telcos will report to the Commission, no later than 45 days after the third quarter of 2001, on their methodology for conducting the customer sampling referred to in new Indicator 4.3 - Directory Assistance Accuracy.

Consumer groups noted the telcos charge for DA calls that are unsuccessful, including queries when the requested number is not found. They proposed a new indicator, for those companies which charge for such requests, that would measure the rate of unsuccessful DA requests due to operator or database error. While acknowledging that this would be difficult, they stated that the new standard should assess whether the error originated with the customer or the company.

TCI stated that the proposed indicator for unsuccessful DA service requests could not be adequately defined because the failure to provide the requested number may arise for many reasons, including an error by the service representative, another telco's database, or the customer. TCI stated that, consequently, it would be difficult to effectively and consistently implement a performance standard.

When there is an unsuccessful DA service request, it would be difficult to identify when it originates from a telco or customer error. It is the Commission's view that it would not be appropriate to establish an indicator for unsuccessful DA service requests due to the problem of determining the origin of the error. The Commission intends to monitor complaints regarding unsuccessful DA service requests in case follow-up action is required.

New indicator created for customer complaints

The telcos contend that existing Indicator 5.1 - Customer Complaints and the complaint process established in section 56(3) of the CRTC Telecommunications Rules of Procedure (the Rules) provide sufficient information for the Commission to adequately monitor the complaint process and that no additional indicator is required.

TCI submitted that the range and complexity of complaints would make any measure of the resolution time meaningless as an indicator of service quality or customer satisfaction. TCI contends that customers understand that time is required to investigate a complaint and subscribers care more about the quality of the resolution than the time it took to reach it. Consumer groups countered that speed of complaint resolution is critical to customer satisfaction.

The Commission believes customers care about both the ultimate quality of the resolution achieved and the speed of that resolution. While Indicator 5.1 - Customer Complaints and the existing complaint process provide useful information on the number of complaints, it is important to have a measure of a company's success in resolving complaints.

The Commission confirms its preliminary view in Decision 2000-24 that an additional indicator should be established to measure the resolution of customer complaints. The Commission directs the telcos to report on Indicator 5.2 - Customer Complaints Resolved in their monthly quality of service reports. The Commission considers that a performance standard of 90% or more is appropriate. This indicator will be reported in every quarter, commencing with the third quarter of 2001, using the monitoring model in Appendix 3.

The consumer groups proposed changing the provision in Section 56(3) of the Rules from a 20-day response period to 10 working days. This addresses an issue that is outside the scope of this proceeding and the Commission will consider amending Section 56(3) in the future.

Directory accuracy compliance for TCI

TCI began reporting for Indicator 4.1 - Directory Accuracy, commencing with the third quarter of year 2000. The Commission directs TCI to continue reporting on this indicator on a quaterly basis.

Community-level quality of service indicators in Northwestel's territory

Decision 2000-24 directed Northwestel to file a proposal for community level reporting for quality of service. Long-distance competition and improved service for Northwestel customers, Decision CRTC 2000-746, dated 30 November 2000, directed Northwestel to continue reporting quality of service indicators on an individual community basis.

Northwestel submitted that its existing quality of service reporting provides a representative measurement of service levels throughout its operating territory. It said that the reporting of quality of service indicators at a community level that would meet the corporate standards is not realistic. In the proceeding leading to Decision 2000-746, Northwestel identified a number of reasons why it cannot meet the service indicators for all communities at all times, including its unique geography, human resources, scheduling, environmental and weather issues. The Government of the Northwest Territories (GNWT) submitted that community-level indicators would be appropriate for Northwestel.

Northwestel proposed to provide quarterly reports at the community level similar to the quarterly submissions at the corporate level containing nine community-level indicators. GNWT submitted that Northwestel should be required to report at the community level, unless it can justify otherwise, on the following existing indicators: 1.5 - Access to Business Office; 1.6 - Competitor Installation Appointments Met; 1.7 - On-Time Activation of PICs for Alternate Providers of Long Distance Service (APLDS); 2.5 - Access to Repair Bureau; 2.6 - Competitor Repair Appointments Met; and 3.1- Dial Tone Delay.

Northwestel's operating territory presents unique challenges. Services are delivered to a few large communities and a large number of significantly less populated rural areas. The Commission believes, however, that reporting on a company-wide basis alone would not capture Northwestel's delivery of service at the community level and its conclusions in Decision 2000-24 and 2000-746.

The Commission notes that Northwestel proposed that nine of the existing 16 quality of service indicators be reported at the community level. These indicators deal with the delivery of service at the community level and the Commission agrees they should be reported. The other seven indicators focus on types of service delivered on a company-wide basis and it would not be appropriate for Northwestel to report on them at the community level.

Northwestel has not proposed a performance standard for the nine community-level indicators. Decision 2000-746 directed Northwestel to report on a new quality of service Indicator 2.1C - Out-of-service trouble reports cleared "remote", with a standard of 90% or higher within five working days and this indicator is one of the nine indicators proposed by Northwestel. The Commission believes that the appropriate performance standards would be the same as those recently found to be appropriate in Decision 2000-24, except for Indicator 2.1C - Out-of-service trouble reports cleared "remote".

In its proposed Indicator 5.1 - Customer Complaints, Northwestel has excluded "Total Customer Complaints Per 1000 NAS" (network access service). However, this is one of the eight categories specified in Decision 2000-24. The data that Northwestel would provide on the total customer complaints per 1000 NAS would be an aggregation of the customer complaints for the other seven categories, namely, Provisioning, Repair, Local Service, Long Distance Service, Operator Service, Directory Service and Billing Service. The Commission's view is that it would be appropriate for Northwestel to include in its reporting format for Indicator 5.1 (at the community level) all eight categories established in Decision 2000-24.

The Commission, therefore, determines that Northwestel will report, at the community-level, on the indicators in Appendix 4. Northwestel will file quarterly a quality of service monthly performance report commencing with the third quarter of 2001, using the monitoring models in Appendix 4.

Competition-related intervals and standards

The telcos contend that there is a well-established complaint process that can be used by any carrier if service issues exist that require the immediate attention of the carriers or the Commission.

The competitive local exchange carriers (CLECs) submitted that indicators for service intervals and standards must be monitored to assess whether the telcos are meeting their CISC commitments and to ensure the viability of local competition.

The Commission agrees with the CLECs that monitoring service intervals and standards is appropriate to foster local telephone competition. It is therefore appropriate to establish indicators to monitor certain service intervals and standards negotiated in CISC and approved by the Commission subsequent to Decision 97-16.

The Commission is creating five indicators on the following service intervals.

Unbundled Type A and B Loop Order Service Intervals Met

The Commission has approved specific intervals to provide new and migratedunbundled loops (types A and B - which are defined in Appendix 6) by incumbent local exchange carriers (ILECs) to CLECs. The interval for the provisioning of new unbundled loops (types A and B) by ILECs to CLECs, which was approved in a CRTC letter decision dated 31 October 2000, are service intervals no greater than those within which the ILECs provide loops to themselves, at least 90% of the time. The interval for the provisioning of migrated unbundled loops (types A and B) by ILECS to CLECs, in the operating territories of former BC TEL and TELUS, was approved in a letter decision dated 8 October 1998, wherein the interval was established at 90% or more completed within five working days. Bell Canada and the other ILECs subsequently agreed to the same standard for all urban areas in their operating territories.

In light of the different service intervals for the provisioning of new and migrated unbundled loops, the Commission believes it is appropriate to establish a separate indicator for each.

It is appropriate to measure the percentage of occasions that the due dates for provisioning of new and migrated Type A and B local loops are met. The Commission is creating Indicator 1.8 - New Unbundled Type A and B Loop Order Service Intervals Met and Indicator 1.9 - Migrated Unbundled Type A and B Loop Order Service Intervals. The Commission directs the telcos to file quarterly a quality of service monthly performance report commencing with the third quarter of 2001, for these Indicators, using the monitoring model in Appendix 5 of this decision. The telcos will report on each of these indicators on a CLEC by CLEC basis, without combining the data for all CLECs into one report.

The Commission agrees with Optel Communications Corporation that it would be appropriate to require that the loop be delivered in working condition and according to the loop specifications agreed to by the industry. Therefore, in Indicator 1.8 - New Unbundled Type A and B Loop Order Service Intervals Met and Indicator 1.9 - Migrated Unbundled Type A and B Loop Order Service Intervals Met, "due dates . met" means the above conditions have been met.

Call-Net Enterprises Inc. proposed the creation of an indicator to measure and report the average provisioning time for the agreed-upon migration date.

Decision 2000-24 indicated the Commission intends to consider establishing the appropriate methodology for service intervals and standards negotiated in CISC which it approved. The interval submitted by Call-Net, however, was not negotiated in CISC or approved by the Commission.

New Indicator 1.9 measures the percentage of time that due dates for providing migrated unbundled local loop (Type A and B) orders are met. It would report whether the time period was met in accordance with the performance standard. This indicator would not, however, capture data on the actual length of the provisioning time taken by the telcos for occurrences that do not meet the performance standard. In light of the specific focus of Indicator 1.9, this criterion, while known to the telcos and the CLECs, would not be reported to the Commission.

The Commission considers that Call-Net's proposal has merit because it would measure and report on the average provisioning time for the agreed upon migration date whichwould capture the actual length of time for occurrences that are outside the performance standard.

The Commission believes an indicator on the average provisioning time for the agreed-upon migration dates for unbundled local loop (Type A and B) ordersas proposed by Call-Net or an alternate interval that would achieve the same goal would be appropriate. Accordingly, the Business Process Working Group of CISC (BPWG) is directed to establish, within 30 days of this decision, an interval the Commission can use to create an indicator that would capture the actual length of time for occurrences that are outside the performance standard of Indicator 1.9.

The companies represented by Bell Canada submitted that the CLECs should also file an equivalent quality of service indicator. While CLECs are responsible for steps within the loop migration, the Commission finds that the purpose of establishing a methodology for reporting compliance with service intervals and standards is to measure ILEC, and not CLEC, compliance. It would not therefore be appropriate to require CLECs to also file equivalent quality of service indicator measurement results.

Local Number Portability (LNP) Order (Standalone) Service Interval Met

A CRTC letter decision issued 8 April 1999 approved intervals for the porting of standard telephone numbers at five business days for the first telephone number within an NXX, and at three business days for subsequent telephone numbers within an NXX.

The Commission concurs with the companies represented by Bell Canada and Optel's submissions that, while recognizing there is a five-day interval for first port in an exchange, the measurement of initial ports will become less important as competition expands and the focus should be on day-to-day porting activities.

It is appropriate therefore to measure the percentage of occasions that the agreed-upon due date is not met for the standalone porting of numbers. This includes the provisioning interval for porting telephone numbers at three business days for day-to-day, and not initial porting, of telephone numbers within an NXX. The Commission directs the telcos to report on Indicator 1.10 - Competitor LNP Order (Standalone) Service Interval Met in their monthly quality of service reports. This indicator will be reported in every quarter, commencing with the third quarter of 2001, using the monitoring model in Appendix 5. The telcos will report on this indicator on a CLEC by CLEC basis, without combining the data for all CLECs into one report.

Call-Net proposed an indicator that would measure and report on the average provisioning time for standalone porting of numbers, but it is not based on an interval negotiated in CISC or approved by the Commission.

The Commission notes that Indicator 1.10 - Competitor LNP Order (Standalone) Service Interval Met, would measure the percentage of occasions that the agreed-upon due date for standalone porting of numbers are met. It would report whether the due dates were met in accordance with the performance standard. This indicator would not, however, capture data on the actual length of the time taken by the telcos companies for occurrences that do not meet the performance standard. In light of the specific focus of Indicator 1.10, this criterion, while known to the telephone companies and the CLECs, would not be reported to the Commission.

Call-Net's proposal has merit because it would measure and report the average provisioning time for standalone porting of numbers to show the actual length of time for occurrences that are outside the performance standard.

An indicator on the average provisioning time for standalone porting of numbers as proposed by Call-Net, or an alternate interval that would achieve the same goal, would be appropriate. The Commission therefore directs the BPWG to establish within 30 days of this decision an interval which the Commission could use to establish an indicator that would show the actual length of time for occurrences that are outside the performance standard of Indicator 1.10.

Interconnection Trunk Order Service Interval Met

The CISC Ordering and Billing Sub-Working Group (OBSWG) Consensus Report BORE003b, dated 23 October 1998, and approved in a CRTC letter decision issued 8 April 1999, established service intervals for the ongoing installation of (bill and keep) interconnecting trunks between local exchange carriers. The intervals are 20 business days where facilities exist and 35 business days where facilities are required.

The Commission finds that the indicator proposed by the companies represented by Bell Canada on the percentage of occasions that the agreed-upon due date for the turn-up of bill and keep interconnection trunks are met, with a standard of 90% or more, would effectively measure and report on the service intervals for the provisioning of (bill and keep) interconnection trunks.

The Commission directs the telcos to report on Indicator 1.11 - Competitor Interconnection Trunk Order Service Interval Met in their monthly quality of service reports. This indicator will be reported in every quarter, commencing with the third quarter of 2001, using the monitoring model in Appendix 5. The telcos will report on this indicator on a CLEC by CLEC basis, without combining the data for all CLECs into one report.

The Commission agrees with Optel's submission that it would be appropriate to require that the trunk be delivered in working condition and according to industry specifications. Therefore, in Indicator 1.11 - Competitor Interconnection Trunk Order Service Interval Met, "due date met" means the above conditions have been met.

Call-Net proposed an indicator that would measure and report on the average provisioning time for bill and keep interconnection trunks. However, Call-Net's proposal is not based on an interval negotiated in CISC or approved by the Commission.

Indicator 1.11 - Competitor Interconnection Trunk Order Service Interval Met would measure the percentage of time that the agreed-upon due date for the turn-up of bill and keep interconnection trunks are met. It would report whether the due dates were met in accordance with the performance standard. This indicator would not, however, capture data on the actual length of the time taken by the telephone companies for occurrences that do not meet the performance standard. In light of the specific focus of Indicator 1.11, this criterion, while known to the telephone companies and the CLECs, would not be reported to the Commission.

Call-Net's proposal has merit because it would measure and report on the average provisioning time for bill and keep interconnection trunks, to showthe actual length of time for occurrences that are outside the performance standard.

The Commission considers that an indicator on the average provisioning time for bill and keep interconnection trunks as proposed by Call-Net, or an alternate interval that would achieve the same goal, would be appropriate. The Commission therefore directs the BPWG to establish within 30 days of this decision an interval the Commission can use to create an indicator to show the actual length of time for occurrences that are outside the performance standard of Indicator 1.11.

Unbundled Loop Trouble Reports Cleared Within 24 Hours

The CISC Network Operations Working Group (NOWG) Consensus Report NOCO006L, dated 18 October 1999, and approved in a letter decision issued 18 January 2000, established a service interval wherein ILECs are to endeavour to provide the CLECs' unbundled loop trouble reports with a repair service level comparable to that which the ILECs provide to their end-customers.

The companies represented by Bell Canada maintain that information relating to repair intervals for facilities provided to competitors is already included in existing Indicator 2.1 - Out-of-Service Trouble Reports Cleared Within 24 Hours. They say that unbundled loop repair intervals should not be subject to new quality of service reporting requirements.

The Commission believes that combining the percentage of occasions that CLECs' and ILECs' end-customers' initial unbundled loop trouble reports are cleared within 24 hours does not sufficiently break out the data. It fails to identify shortfalls in the quality of the ILEC repair service to competitors.

The Commission therefore considers it appropriate to measure the percentage of occasions that the repair interval for unbundled loops provided to competitors are met. The Commission directs the telcos to report on Indicator 2.7 - Competitor Out-of-Service Trouble Reports Cleared within 24 Hours in their monthly quality of service reports. This indicator will be reported in every quarter, commencing with the third quarter of 2001, using the monitoring model in Appendix 5. The telcos will report on this indicator on a CLEC by CLEC basis, without combining the data for all CLECs into one report.

Optel proposed an indicator that would measure and report on mean time to repair local loops, but the interval submitted by Optel was not negotiated in CISC or approved by the Commission.

Indicator 2.7 - Competitor Out-of-Service Trouble Reports Cleared within 24 Hours, would measure the percentage of trouble reports that are clearedin accordance with the performance standard. This indicator would not, however, capture data on the actual length of time taken by the telcos for occurrences that do not meet the performance standard. In light of the specific focus of Indicator 2.7, this criterion, while known to the telephone companies and the CLECs, would not be reported to the Commission.

Optel's proposal has merit because it would measure and report on the mean time to repair local loops which would capture the actual length of time for occurrences that are outside the performance standard.

The Commission considers that an indicator on the mean time to repair local loopsas proposed by Optel, or an alternate interval that would achieve the same goal, would be appropriate. The Commission therefore directs the NOWG within 30 days of this decision to establish an interval which the Commission can use to create an indicator to show the actual length of time for occurrences outside the performance standard of Indicator 2.7.

Completion Notifications Received

Call-Net proposed an indicator that would measure the percentage of completion notifications received by the CLEC from the ILEC, notifying the CLEC that the local service migration or completion of new service is complete at the ILEC end.

A service standard was approved in a CRTC letter decision dated 8 December 1998. It provides that, after an ILEC has completed the cutover of migrated loops at its own end, it is required to immediately notify the CLEC. The cutover is to be completed within 15 minutes, with a standard of 90% or more.

It would be appropriate to measure the percentage of completion notifications received by the CLEC from the ILEC for migrated loops. The Commission directs the telcos to report on Indicator 2.8 - Migrated Local Loop Completion Notices to Competitors in their monthly quality of service reports. This indicator will be reported in every quarter, commencing with the third quarter of 2001, using the monitoring model in Appendix 5. The telcos will report on this indicator on a CLEC by CLEC basis, without combining the data for all CLECs into one report.

There is currently no approved service standard that requires an ILEC to notify a CLEC when it has cutover a new loop at the ILEC end.

Notification of newservice is an integral step in the relationship between ILEC and CLEC. Call-Net's proposal to measure the percentage of notifications received by the CLEC from the ILEC, and notifying the CLEC of completion of new service at the ILEC end, would be a useful measure.

The Commission therefore directs the NOWG to establish within 30 days an interval the Commission can use to create an indicator to address the above criteria for new loops.

Call-Net's other proposals

Call-Net proposed four other indicators that would measure the following:

a) Trouble Reports Cleared Within 48 Hours - the percentage of CLECs degraded trouble reports cleared by ILECs within 48 hours of notification, with a proposed standard of 90%.

b) Rate of Reject of Loop Service Request (LSR) - the LSR rejectionrate; that is, the percentage of LSRs submitted by CLECs that are returned due to errors perceived by the ILECs. Call-Net stated that this measurement would indicate any biases by certain ILECs in rejecting LSRs.

c) LSR 48-Hour Turnaround Time - either the percent of occasions when the 48-hour turnaround time is met by ILECs in response to LSRs submitted by CLECs; or the average turnaround time, with a standard of 90% or greater.

d) Firm Order Commitment (FOC) Met - the percentage of firm order commitments met by the ILECs, for each type of local service request where the CLEC and the ILEC have agreed to a date for completion, with a standard of 90% or greater.

The Commission recognizes that there are no service standards or intervals that have been approved for Call-Net's proposed indicators, but it agrees that these would be useful measures.

The Commission therefore directs the NOWG to establish within 30 days of this decision an interval for Call-Net's first proposed indicator listed above, Degraded Trouble Reports Cleared Within 48 Hours, which the Commission can use to create an indicator. The Commission directs the BPWG to establish within 30 days intervals for Call-Net's three other proposed indicators which the Commission can use to create indicators.

Indicator 2.6 - Competitor Repair Appointments Met and Indicator 2.2 - Repair Appointments Met

Decision 2000-24 directed the telcos to report progress on their efforts to separate data for Indicator 2.6 from Indicator 2.2 as part of the fourth quarter 2000 quality of service quarterly report filed with the Commission. In the interim, the telcos were allowed to report the combined data for all customers, including competitors, in Indicator 2.2 and show N/A (not available) in the reporting of Indicator 2.6. At this juncture, the telcos have not filed their fourth quarter 2000 quality of service quarterly reports.

To expedite the telcos' reports on the indicators, the Commission believes it would be not be appropriate to await their fourth quarter 2000 quality of service quarterly reports before making a determination. The telcos will therefore file quarterly a quality of service monthly performance report commencing with the third quarter of year 2001, separately for Indicator 2.2 - Repair Appointments Met and Indicator 2.6 - Competitor Repair Appointments Met.

Secretary General

This document is available in alternative format upon request and may also be examined at the following Internet site: www.crtc.gc.ca 

Appendix 1

Reference documents

Public notice

Northwestel Inc. - Implementation of toll competition and review of regulatory framework, quality of service and related matters, Telecom Public Notice CRTC 99-21, dated 1 October 1999

Decisions

Quality of service indicators for use in telephone company regulation, Telecom Decision CRTC 82-13, dated 9 November 1982

Local competition, Telecom Decision CRTC 97-8, dated 1 May 1997

Quality of service indicators for use in telephone company regulation, Telecom Decision CRTC 97-16, dated 24 July 1997

Final standards for quality of service indicators for use in telephone company regulation and other related matters, Telecom Decision CRTC 2000-24, dated 20 January 2000

Long-distance competition and improved service for Northwestel customers, Decision CRTC 2000-746, dated 30 November 2000

Letter decisions

CRTC Letter Decision, dated 8 December 1998, re: CRTC Interconnection Steering Committee - Ordering and Billing Sub-Working Group, ConsensusReport, BORE002, dated 8 June 1998

CRTC Letter Decision, dated 8 April 1999, re: CRTC Interconnection Steering Committee - Ordering and Billing Sub-Working Group, ConsensusReport, BORE003a, dated 12 November 1998

CRTC Letter Decision, dated 18 January 2000, re: CRTC Interconnection Steering Committee - Ordering and Billing Sub-Working Group, Consensus Report, BORE006l, dated 18 October 1999

CRTC Letter Decision, dated 31 October 2000, re: CRTC Interconnection Steering Committee Dispute on ILEC service intervals associated with the provision of new unbundled loops (Type A&B) (BODI011a)

News Release

CRTC revamps service standards for telephone companies, dated 20 January 2000

Appendix 2

Interested parties

The following registered as interested parties or were made party to this proceeding. Some of these parties filed submissions:

· TELUS Communications (B.C.) Inc. (formerly BC TEL) referred hereafter as TCBC

· Bell Canada

· Island Telecom Inc. (formerly The Island Telephone Company Limited)

· Maritime Tel & Tel Limited

· MTS Communications Inc.

· NBTel Inc.

· NewTel Communications Inc.

· Northern Telephone Limited

· Northwestel Inc.

· Québec-Téléphone

· Télébec ltée

· TELUS Communications Inc.

· The Corporation of the City of Thunder Bay - Telephone Division

    (collectively the telcos)

Bell Canada made submissions on behalf of:

· Bell Canada

· Island Telecom Inc.

· Maritime Tel & Tel Limited

· MTS Communications Inc.

· NBTel Inc.

· NewTel Communications Inc.

· Northern Telephone Limited

· Northwestel Inc.

· Télébec ltée

(collectively, the companies represented by Bell Canada)

TCI made submissions on behalf of:

· TCBC

· TCI

(collectively, TCI)

· Action Réseau Consommateur, the Consumers' Association of Canada, and the National Anti-Poverty Organization

· B.C. Old Age Pensioners' Organization

· Call-Net Enterprises Inc.

· Optel Communications Corporation

· The Government of the Northwest Territories

Appendix 3

New Indicators

Indicator 1.5 - Access to Business Office - On Hold Duration

Definition: The percentage of calls to a business office that are connected to a service representative of the business office within 20 seconds or less.

Measurement Method: All incoming calls to the business offices are measured to determine the percentage of calls that are connected to a service representative of the business office within 20 seconds or less.

Geographical Basis: Company-wide.

Proposed Standard: 90% or more.

Reporting Format: Indicator 1.5 - Access to Business Office - On Hold Duration

Indicator 2.5 - Access to Repair Bureau

Definition: The percentage of calls to a repair bureau answered in 20 seconds or less.

Measurement Method: All incoming calls to the repair bureau are measured to determine the percentage of calls answered in 20 seconds or less.

Standard: 90% or more.

Geographical Basis: Company-wide, as these calls are all centrally handled irrespective of where the calls originate.

Reporting Format: 2.5 - Access to Repair Bureau

Indicator 4.2 - Access to Directory Assistance

Definition: The percentage of calls to Directory Assistance that are answered in 20 seconds or less.

Measurement Method: All incoming calls to Directory Assistance are measured to determine the percentage of calls answered in 20 seconds or less.

Geographical Basis: Company-wide.

Standard: 80% or more.

Reporting Format: 4.2 - Directory Assistance - Access

Indicator 4.3 - Directory Assistance - Accuracy

Definition: The percentage of directory listings provided to customers without error.

Measurement Method: The number of customers in a monthly sample who report an error in the provided number, as a percentage of the sample size.

Geographical Basis: Company-wide.

Standard: 93.8% or more without error.

Reporting Format: 4.3 - Directory Assistance - Accuracy

Indicator 5.2 - Customer Complaints Resolved

Definition: The percentage of Indicator 5.1 complaints, oral and written, addressed to the telephone companies resolved within 20 working days.

Measurement Method: Complaints are tabulated as resolved either within 20 working days or greater than 20 working days.

Geographical Basis: Company-wide.

Proposed Standard: 90% or more.

Reporting Format: 5.2 - Complaints Resolution

Appendix 4

Community-level quality of service indicators in Northwestel's territory

Indicator 1.1 - Provisioning Interval

Definition: Number of days required to provide service from the date of customer's request.

Measurement Method: Completed rural orders are each sorted to determine the actual number and percentage completed in 10 working days or less.

Geographical Basis: Community

Standard: 90% or more completed within 10 working days.

Reporting Format: 1.1C - Provisioning Interval - Community

Indicator 1.2 - Installation Appointments Met

Definition: The total number of appointments booked and the number met, with percentage of those met relative to the total booked.

Measurement Method: Completed orders are sorted to determine the actual number and percentage completed on the appointed date.

Geographical Basis: Community

Standard: 90% or more.

Reporting Format: 1.2C - Installation Appointments Met - Community

Indicator 1.3 - Held Orders per 100 Network Access Services Inward Movement

Definition: The number of outstanding requests for NAS which were not met on the due date because of facility shortages, expressed as a percentage of 100 NAS Inward Movement (Orders).

Measurement Method: The compilation of orders for NAS outstanding at the end of the month, which were not met on the due date.

Geographical Basis: Community

Standard: 90% or more.

Reporting Format: 1.3C - Held Orders per 100 Network Access Services Inward Movement - Community

Indicator 1.4 - Held Upgrades per 100 Upgrade Requests - Rural

Definition: The number of rural outstanding requests for higher grades of service (e.g., from 4-party to 2-party service) unfilled for more than 30 days.

Measurement Method: A count of rural held upgrades (i.e., unfilled requests for upgrades) is taken at the end of each month, and those held over 30 days are calculated as a percentage of all upgrade requests (new requests plus requests unfilled from previous month).

Geographical Basis: Community

Standard: 90% or more.

Reporting Format: 1.4C - Held Upgrades per 100 Upgrade Requests - Community

Indicator 2.1 - Out-of-Service Trouble Reports Cleared "Remote"

Definition: The total of initial out-of-service trouble reports and those cleared within 24 hours. Percentages of those cleared relative to this total.

Measurement Method: A compilation of trouble report data gathered at each repair bureau.

Geographical Basis: Community

Standard: 90% or more.

Reporting Format: 2.1C - Out-of-Service Trouble Reports Cleared "Remote" - Community

Indicator 2.2 - Repair Appointments Met

Definition: The actual number and percentage of repair appointments met.

Measurement Method: Completed repair orders are compiled and the number and percentage of appointments met are reported.

Geographical Basis: Community

Standard: 90% or more.

Reporting Format: 2.2C - Repair Appointments Met - Community

Indicator 2.3 - Initial Customer Trouble Reports per 100 Network Access Service

Definition: A report of a trouble from a customer indicating improper functioning of service on which there is no outstanding trouble report.

Measurement Method: The total number of initial trouble reports (excluding duplicate/multiple reports of the same outage) and calculated as a percentage of NAS in service.

Geographical Basis: Community

Standard: 5% or less.

Reporting Format: 2.3C - Initial Customer Trouble Reports per 100 NAS - Community

Indicator 2.4 - Community Isolation

Definition: Community isolation resulting from trunk failure that lasts one hour or more.

Measurement Method: Actual incidents that occurred and the communities affected. Count each occurrence.

Geographical Basis: Community

Standard: Not applicable.

Reporting Format: 2.4C - Community Isolation - Community

Indicator 5.1 - Customer Complaints

Definition: The number of complaints addressed (in written or verbal form) to Officers and Department Heads of the telephone companies and the Commission.

Measurement Method: This indicator categorizes complaints into the seven interfaces and totals all customer complaints divided by NAS. To facilitate comparison between telephone companies, complaints per 1000 NAS will be reported.

Geographical Basis: Community

Interim Standard: 90% or more.

Reporting Format: 5.1C - Total Customer Complaints Per 1000 NAS - Community

5.1C1 - Provisioning Customer Complaints Per 1000 NAS - Community

5.1C2 - Repair Customer Complaints Per 1000 NAS - Community

5.1C3 - Local Service Customer Complaints Per 1000 NAS - Community

5.1C4 - Long Distance Service Customer Complaints Per 1000 NAS - Community

5.1C5 - Operator Service Customer Complaints Per 1000 NAS - Community

5.1C6 - Directory Service Customer Complaints Per 1000 NAS - Community

5.1C7 - Billing Service Customer Complaints Per 1000 NAS - Community

Appendix 5

Indicators for reporting compliance with intervals and standards negotiated in CISC and approved by the Commission

Indicator 1.8 - New Unbundled Type A and B Loop Order Service Intervals Met

Definition: The percentage of time that the due dates for the provisioning of new unbundled types A and B local loop orders are met.

Measurement Method: Tracking of due dates met.

Geographical Basis: Company-wide urban.

Standard: 90% or more.

Reporting Format: Indicator 1.8 - New Unbundled Type A and B Loop Order Service Intervals Met

Indicator 1.9 - Migrated Unbundled Type A and B Loop Order Service Intervals Met

Definition: The percentage of time that the due dates for the provisioning of migrated unbundled types A and B local loop orders are met.

Measurement Method: Tracking of due dates met.

Geographical Basis: Company-wide urban.

Standard: 90% or more.

Reporting Format: Indicator 1.9 - Migrated Unbundled Type A and B Loop Order Service Intervals Met

Indicator 1.10 - Competitor Local Number Portability Order (Standalone) Service Interval Met

Definition: The percentage of time that the agreed upon due date relating to standalone porting of numbers are met.

Measurement Method: Tracking of due dates met.

Geographical Basis: Company-wide.

Standard: 90% or more.

Reporting Format: Indicator 1.10 - Competitor Local Number Portability Order (Standalone) Service Interval Met

Indicator 1.11- Competitor Interconnection Trunk Order Service Interval Met

Definition: The percentage of time that the agreed upon due date for the turn-up of bill and keep interconnection trunks are met.

Measurement Method: Tracking of due dates met. The due date interval is 20 business days when augments to existing trunk groups are required where facilities exist and 35 business days when new trunk groups are required where no facilities exist.

Geographical Basis: Company-wide.

Standard: 90% or more.

Reporting Format: Indicator 1.11 - Competitor Interconnection Trunk Order Service Interval Met

Indicator 2.7 - Competitor Out-of-Service Trouble Reports Cleared within 24 Hours

Definition: The total of initial out-of-service trouble reports and those cleared within 24 hours. Percentages of those cleared relative to this total.

Measurement Method: Compilation of trouble report data gathered at each repair bureau.

Geographical Basis: Company-wide.

Standard: 80% or more.

Reporting Format: Indicator 2.7 - Competitor Out-of-Service Trouble Reports Cleared within 24 Hours

Indicator 2.8 - Migrated Local Loop Completion Notices to Competitors

Definition: The total number of completions of migrations of local loops and the number of notifications given on time by the incumbent telephone company to the competitors, notifying that the local loop migration is complete at the facilities of the incumbent telephone company, with the percentage of notifications given on time relative to this total.

Measurement Method: Completions of migrated local loops and the notifications given on time are sorted to determine the actual numbers and the percentage of notifications given on time.

Geographical Basis: Company-wide.

Standard: 90% or more.

Reporting Format: Indicator 2.8 - Migrated Local Loop Completion Notices to Competitors

Appendix 6

Definitions

A Type A local loop is an analogue transmission path that supports the transmission of a voice-grade signal of approximately 3 kHz usable bandwith terminating in a two wire electrical interface at both the end-customer's premises and at the central office.

A Type B local loop is an digital transmission path that supports the transmission of an ISDN Basic Rate Interface type signal terminating in a two wire electrical interface at both the end-customer's premises and at the central office.