ARCHIVED - Telecom - Commission Letter - 8660-C12-200303751 - Public Notice CRTC 2003-3 - Retail quality of service rate adjustment plan and related issues - Requests for further responses to interrogatories

Ottawa, 27 October 2003

Our File: 8660-C12-200303751

By email

To: Parties to PN 2003-3

Re: Public Notice CRTC 2003-3 -Retail quality of service rate adjustment plan and related issues - Requests for further responses to interrogatories

This letter provides the determination with respect to requests for further responses to interrogatories and amends the process established in PN 2003-3, as modified by the Commission's letters dated 15 July and 6 October, 2003.

Requests for further responses to interrogatories

Requests were received from the Public Interest Advocacy Centre on behalf of the Consumers' Association of Canada, the National Anti-poverty Organization and L'Union des consommateurs and from the Telecommunications Workers Union.

Responses to these requests were received from Aliant Telecom Inc., Bell Canada, MTS Communications Inc., Saskatchewan Telecommunications and Télébec, Limited Partnership and TELUS Communications Inc., TELUS Communications (Québec) Inc. (TCI) (collectively, TELUS).

Parties are to file with the Commission all information to be provided pursuant to this letter by 10 November 2003, serving copies on all interested parties by the same date. This material should be received, and not merely sent, by that date.

This letter reflects the Commission's objective of ensuring that all parties have the benefit of the maximum amount of information placed on the public record at the earliest appropriate stage, in order to facilitate a more efficient and effective proceeding.

Requests for further responses are addressed below and in the Attachment to this letter.

With regard to requests for further responses, the requirements of subsection 18(2) of the Rules apply. The general principles enunciated by the Commission in past proceedings include the considerations set out below.

The major consideration is the relevance of the information requested to the matter at issue. Another factor considered is the extent to which an interrogatory answer is responsive to the interrogatory as it was originally asked.

The availability of the information requested is also a factor, which is balanced against the relevance of the information. If the provision of the information sought would require an effort disproportionate to the probative value of the information itself, further responses will not be required.

Having regard to the above considerations, the parties in question are to provide further responses to the extent set out in Attachment I to this letter. These responses are to be provided on the public record.

In order to obtain additional information, supplementary interrogatories are set out in Attachment II to this letter.

Process

The process set out initially in PN 2003-3, as modified by the Commission's letters dated 15 July and 6 October 2003, is further modified as follows:

Paragraph 25:

A determination will be issued with respect to requests for further information and public disclosure as soon as possible. Any information to be provided pursuant to that determination will be required to be filed with the Commission and served on all parties by 10 November 2003

Paragraph 26:

Parties may file argument with the Commission on any matters within the scope of this proceeding, serving a copy on all other parties by 24 November 2003.

Paragraph 27:

Parties may file reply arguments with the Commission, serving a copy on all other parties by 8 December 2003.

Parties are advised that the following documents regarding quality of service issues submitted in the proceeding leading to Regulatory Framework for Second Price Cap Period, Telecom Decision CRTC 2002-34, 30 May 2002, are being placed on the present record for the Commission's consideration, as they may be relevant to matters before the Commission in this proceeding:

i. Appendix A to the Final Argument of Aliant Telecom Inc., Bell Canada, MTS Communications Inc., and Saskatchewan Telecommunications (October 22, 2001);

ii. Section 2.3 "Quality of Service" of the Reply Argument of Aliant Telecom Inc., Bell Canada, MTS Communications Inc., and Saskatchewan Telecommunications (October 31, 2001);

iii. "Quality of Service Incentive" section of the Final Argument of ARC et al and BCOAPO et al (October 22, 2001); and

iv. Appendix A to the Reply Argument of ARC et al and BCOAPO et al (October 31, 2001)

Yours sincerely,

(Original signed by Mario Bertrand)

Mario Bertrand
Acting Director, Consumer Affairs

Attachments

c.c: Brenda Jolicoeur, CRTC (819) 997-4571
May Lynn Soong, CRTC (819) 977-4555

Attachment I
Page 1 of 1

FURTHER RESPONSES TO INTERROGATORIES


TELUS(Consumer Groups)20June03-102 d)

TELUS is directed to provide an explanation of their calculation for the number of NAS associated with Centrex or Centrex-like services that are included in the retail rate adjustment process.

TELUS(Consumer Groups)20June03-104

TELUS is directed to provide information on whether its personnel compensation is tied to the quality of service results for those indicators included in the rate adjustment plan as posed in part a) of this interrogatory.

Télébec(Consumer Groups)20June03-105

Télébec is directed to identify the title and date of the document referred to in its response to this interrogatory in its statement: "Télébec also uses Bell Canada's manual on the subject of quality of service".

Companies(CRTC)20June03-128

The Companies are directed to review and modify their initial response to Companies(CRTC)20June03-128 and provide complete information as requested.

Aliant is directed to provide its manual in response to Companies(CRTC)20June03-128 (i).

Attachment II

SUPPLEMENTARY INTEROGATORIES

Bell Canada(CRTC)27October03-200
MTS(CRTC)27October03-200
SaskTel(CRTC)27October03-200
TELUS(CRTC)27October03-200
Télébec(CRTC)27October03-200

Refer to the "business rules" submitted by the company in response to interrogatory Companies(CRTC)20June03-128(i).

Identify the name(s) of the system(s) or application program(s) that determine whether a work order would be included or excluded in the results of an indicator. If this is a manual process, indicate the employee classification and staff level of the personnel who would apply these "business rules". Also, indicate the name(s) of the system(s) or application program(s) that store this "processed" information.


Aliant(CRTC)27October03-200

Refer to the "business rules" that will be submitted by the company in response to interrogatory Companies(CRTC)20June03-128(i).

Identify the name(s) of the system(s) or application program(s) that determine whether a work order would be included or excluded in the results of an indicator. If this is a manual process, indicate the employee classification and staff level of the personnel who would apply these "business rules". Also, indicate the name(s) of the system(s) or application program(s) that store this "processed" information.


TELUS( CRTC)27October03-201

Once a call is placed in the calling waiting queue for more than 20 seconds, how is the call dealt with? How is the call wait time measured and reported in the quality of service results? For example, is the length of time beyond the 20 seconds measured? If yes, explain how. If not, explain why not?


ILECs( CRTC)27October03-202

For each of the 13 indicators of the interim plan:

a) Identify the name(s) of the system(s) or the database(s) that capture the details of the work order or tasks which are subsequently used to determine whether or not the standard of the indicator has been met;

b) Identify the name(s) of the system(s) or application program(s) that would determine whether or not the standard of an indicator has been met. If this is a manual process, indicate the employee classification and staff level of the personnel who would make the determination;

c) Identify the name(s) of the system(s) or application program(s) that would calculate the monthly results. If this is a manual process, indicate the employee classification and staff level of the personnel who would calculate the monthly results. Describe, in detail, the timing and actions taken by the system(s), application program(s) or employee in the case of the standard for an indicator not being met for that month.


ILECs(CRTC)27October03-203

For each of the 13 indicators of the interim plan, explain whether the monthly reported result is based on a consensus of all data associated with the indicator or based on a sampling or survey of the data. If a sampling or survey, provide an explanation of the methodology and algorithm used to determine the monthly result. Also, for each indicator, provide both the sample size and the percentage of the total data that the sample size represents.


ILECs(CRTC)27October03-204

Provide copies of all instructions to staff and other documentation explaining how each indicator result is derived, as follows:

Indicator 1.1:
a) How does the company record requests for service where the necessary facilities are not yet in place?

b) How does the company record partial provision of service, where further work is necessary to provide full service at normal standards of quality?

c) Are requests for optional services only (i.e., where the customer already has basic service) included in this indicator?

d) Where the service requested includes both basic and optional services, how does the company record partial provision of service, where basic service is provided but further work is necessary to provide the requested optional services?

Indicators 1.2 and 2.2:
b) What are all the possible options provided to customers in terms of appointments for service installation or repair? Please include in your answer the specific time periods used for the purposes of setting appointments.

c) When the company cannot meet an appointment, and therefore contacts the customer to re-schedule, how is this treated for the purposes of reporting under these indicators?

Indicator 1.3:
a) How are "due dates" set under this indicator? What role, if any, does the customer play in setting due dates?

b) When a due date cannot be met, what action does the company take and how is this treated for the purpose of reporting under this indicator?

c) Are there any circumstances in which due dates are not set when a customer requests service? If so, please explain why.

Indicators 1.5 and 2.5:
a) Is customer time spent navigating the company's IVR system included?

b) Is customer time spent listening to company promotional messages before being put in a queue for a CSR included?

c) Is customer time spent waiting while the telephone rings counted?

d) How are calls that result in busy signals reported?

e) When a customer is asked to leave a message and await a return call, how is this reported?

f) How do you report customers' time when they reach a CSR who cannot assist them, and are put on hold until i) a CSR who can assist or ii) a manager is available?

g) Does the company know (in real-time) when the customer wait time will be more than the prescribed standard? If so, what actions are taken and by whom?

h) If a customer were to be transferred to a secondary or call overflow queue for more efficient handling of the call, how is the wait time in the secondary or call overflow queue reported?

Indicator 2.1:
a) Are there circumstances in which the measurement of time under this indicator is temporarily stopped, or not commenced until some time after the customer's initial call? Please provide an explanation of each of these circumstances.

b) When repair work has been only partially completed at the 24 hour mark, such that the customer does not yet have full service at normal standards of quality, how is this recorded for the purposes of this indicator?


Companies(CRTC)27October03-205

Refer to the companies' response to interrogatory Companies(CRTC)20June03-100 ii).

a) Provide a reference for the companies' statement: "[T]he companies further noted that ARC et al, which had originally proposed the quantum of the Total Maximum Adjustment Value in its evidence in the Price Caps proceeding, suggested in Final Argument that a maximum penalty of approximately half the amount it had proposed may constitute an appropriate balance between the need for a significant incentive to meet service quality standards and a desire to avoid over-provisioning."

b) In Regulatory Framework for Second Price Cap Period, Telecom Decision CRTC 2002-34, 30 May 2002, paragraph 706; the Commission stated that the quality of service standards are "the minimum level of performance for each associated indicator". In the interim rate adjustment plan the Commission has established a range of acceptable levels of service, for example, for indicators 1.5 and 2.5, 80% - 100% of calls to the business or repair office are to be answered within 20 seconds. Why therefore would results over the standard for any indicator risk "over-provisioning" when results between the standard and 100% are acceptable? Provide full rationale.

c) If a rate adjustment plan compensates an affected class of customers for service that does not meet the standards for quality of service indicators, how is a rate adjustment plan that provides for a maximum pay out up to $28 (based on 2002 revenues) to each customer punitive?


TELUS(CRTC) 27October03-206

For each of the TELUS companies complete the following table, converting the 25% adjustment value to a $ per NAS value. Calculation should be as follows: Total Maximum Adjustment Value / Total number of indicators = TMAV per indicator X 25% Standard Adjustment = Total rate adjustment for the indicator / NAS. Use the 2002 quality of service results, NAS and revenues to complete the table.
 

SaskTel(CRTC) 27October03-207

Refer to Section 2.1.2 paragraph 27 of your evidence. Based SaskTel's 2002 Quality of Service results and extrapolating to a full year of results, complete the following table, converting the 25% adjustment value to a $ per NAS value. Calculation should be as follows: Total Maximum Adjustment Value / Total number of indicators = TMAV per indicator X 25% Standard Adjustment = Total rate adjustment for the indicator / NAS. Use the 2002 extrapolated results, NAS and revenues to complete the table. In addition, convert the Total Annual Quality of Service Adjustment into terms of $ per NAS.
 

ILECs(CRTC) 27October03-208

For each of the Companies and each of the TELUS companies, calculate the Total Rate Adjustment based on the Current Interim Plan for 2003 to-date. Use the January to September 2003 quality of service results, the NAS and revenues as of 30 September 2003 as the basis for these calculations. For the purposes of this calculation, include Centrex lines in your count of NAS. Show the amount of Total rate adjustment, the NAS and the Total rate adjustment per NAS.

Date modified:

2003-10-27