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PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Communications Division

RESOLUTION T- 17358

Policy Analysis Branch

March 8, 2012

R E S O L U T I O N

Resolution T-17358 approves staff recommendations regarding the scope, parameters, specifications and timing of a customer satisfaction survey of the Limited English Proficient (LEP) telecommunications customers in California. This resolution delegates to the Commission's Executive Director the authority to proceed with the implementation of the LEP survey, and to seek reimbursement for its cost from carriers with $10 million or more in annual intrastate revenue. A decision about the frequency with which the survey will be repeated -- to assess changes in LEP customer satisfaction over time -- will be addressed after results of this first survey are reviewed.

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Summary

This resolution establishes the scope, parameters, specifications and timing of the customer satisfaction survey of Limited English Proficient (LEP) telecommunications consumers ordered by Decision (D.) 08-10-016. This resolution delegates to the Commission's Executive Director the authority to proceed with the implementation of the LEP survey and to seek reimbursement for its cost from carriers with $10 million or more in annual intrastate revenue.

Pursuant to D.08-10-016 the Commission, among other things, directed the Communications Division (CD) staff to undertake steps to retain an organization to conduct a pilot test and customer satisfaction survey of LEP telecommunications consumers.1 D.08-10-016 directed Commission staff to convene thereafter a workshop to develop recommendations on the final scope, parameters and specifications of the pilot test and survey, and to present staff recommendations in a resolution for the Commission's consideration.2 This resolution responds to the Commission's directives.

Background

D.08-10-016 considered, among other things, whether telecommunications carriers who served LEP consumers should be required to track or report LEP consumer complaints and language preference. However, D.08-10-016 concluded that a carrier-funded consumer satisfaction survey of LEP consumers should first be conducted to help the Commission obtain information on LEP customers and to assess the effectiveness of this approach before requiring carriers to establish language preference and LEP complaint tracking and reporting systems.

D.08-10-016 directed staff to undertake steps to retain an organization to conduct both a pilot test and customer satisfaction survey of LEP telecommunications consumers throughout California. In accordance with this directive and following an open competitive bidding process, the CD selected Field Research Corporation of San Francisco (Field Research), and entered into a contract with Field Research on October 10, 2011 to conduct the survey.3

D.08-10-016 also required CD staff and its consultant to hold a public workshop with stakeholders to develop recommendations on the final scope, parameters and specifications of the pilot test and survey, and to present those recommendations in a resolution for the Commission's consideration. On November 3, 2011, a letter by CD staff was distributed to stakeholders4 announcing the workshop and indicating that it would be held on December 14, 2011, in the Commission's Auditorium, at 505 Van Ness Avenue, in San Francisco.

As part of stakeholders' preparations for the workshop, the letter encouraged interested parties to respond to two questions relating to topics that could be addressed by the survey, and to provide their answers to CD staff by December 1, 2011. The questions were as follows:

At the December 14 workshop, Field Research presented its recommendations regarding the proposed structure and topic areas to be addressed by the survey. Field Research also provided an overview of the methods to be used to conduct the survey. Throughout the course of the three-hour workshop, stakeholders were encouraged to offer their comments and reactions to the survey and to the survey's proposed topic areas. At the conclusion of the workshop, CD staff also asked stakeholders to provide any additional comments and feedback regarding the survey's proposed topic areas in written form by email to the Commission by January 9, 2012. DRA, the CTIA-the wireless Association, AT&T, Greenlining Institute and the Utility Reform Network submitted their additional comments and feedback on January 9, 2012.

These comments and suggestions were carefully reviewed and were incorporated into the survey questionnaires whenever possible, as part of the questionnaire development process. Attachment A of this resolution contains Field Research's responses to these comments, which have been reviewed and accepted by CD staff. Field Research's responses are hereby incorporated into this resolution and adopted by this Commission.

CD staff now seeks formal authorization to proceed with the implementation of the pilot test and customer satisfaction survey as proposed by Field Research and accepted by CD staff.

Discussion of Survey Methodology, Scope and Timelines

Consistent with the design parameters specified in the contract, the survey will be administered by telephone through a stratified random sampling of approximately 8,300 telephone customers across California.5 This survey will include interviews with approximately 6,800 LEP telephone customers whose primary language is one of the following: Spanish, Cantonese, Mandarin, Korean, Vietnamese, or Tagalog. In order to compare LEP customer satisfaction levels to those of other customers, a control sample of approximately 1,500 English-proficient customers will also be conducted. The average length of the telephone interview to be administered will not exceed 15 minutes across all languages.

Sampling of LEP customers will be derived from a combination of sources, including 1) a statewide cross-section sample of telephone customers from random digit dial listings of telephone numbers including all areas of the state in proportion to population, excluding areas with very low concentrations of Latinos and Asian/Pacific Islanders; 2) a random digit dial sampling of telephone households restricted to high density Latino and Asian/Pacific Islander population areas; and 3) telephone listings targeting residents who have Hispanic, Chinese, Korean, Vietnamese or Tagalog surnames drawn from telephone directories and other list sources.

In addition, a smaller sample of up to 700 recent non-telephone customers will be identified and interviewed during the screening interviews conducted as part of the larger LEP customer survey. This population will be surveyed via a different questionnaire that also will not exceed 15 minutes in length across all languages. It will assess recent non-customers' reasons for going without telephone service during their service interruption, the problems they faced when being without telephone service, and factors leading to their re-entry into the telephone market.

All survey development and pilot test phases will take approximately five months to complete, with full-scale survey administration, analysis and preparation of reports summarizing its results taking another 19 months. Key milestones of the survey are:

D.08-10-016 requires a further order of the Commission to decide the frequency with which the survey would be repeated in order to assess changes in LEP customer satisfaction over time. Staff is directed to prepare a resolution with recommendations on whether the survey should be one-time or periodic, and if periodic, the frequency with which the survey should be repeated.6 CD staff recommends postponing such decision until after results of the first survey have been reviewed. Following the report and the results of the first survey, if there is a need for recurring surveys a subsequent resolution will be issued.

Survey Costs

Decision (D.) 08-10-016 directed staff to seek reimbursement for the costs of implementing the pilot test and survey from carriers with $10 million or more in annual intrastate revenue. CPUC entered into a contract with Field Research on October 10, 2011, for $875,500. The costs for retaining the services of Field Research subject to a research contingency of plus or minus 10% are reasonable. Staff will seek reimbursement of this survey contract costs following conclusion of the survey. Approximately sixty of carriers reported annual intrastate revenue in excess of $10 million in 2010.

Comments

Public Utilities Code Section 311(g)(1) provides that this resolution must be served on all parties and subject to at least 30 days public review and comment prior to a vote of the Commission. Accordingly, this draft resolution was mailed to stakeholders for comments at least 30 days prior to being considered by the Commission.

Findings and Conclusions

1. In 2008, the Commission in Decision D.08-10-016 directed Commission staff to undertake steps to retain an organization to conduct the pilot test and LEP customer satisfaction survey.

2. The Commission authorized staff to proceed with the implementation of the LEP survey and to seek reimbursement for its cost from carriers with $10 million or more in annual intrastate revenue.

3. D.08-10-016 directed Commission staff to convene thereafter a workshop to develop recommendations on the final scope, parameters and specifications of the pilot test and survey, and to present staff recommendations in a resolution for the Commission's consideration.

4. The CD staff selected Field Research Corporation and entered into a contract with Field Research on October 10, 2011.

5. On November 3, 2011, CD staff distributed a notice of workshop to all carriers and stakeholders requesting pre-workshop comments and feedback.

6. On December 14, 2011, a workshop was conducted and Field Research presented its recommendations regarding the proposed structure and topic areas to be addressed by the survey. Field Research also provided an overview of the methods to be used to conduct the survey.

7. At the workshop stakeholders were encouraged to offer their comments and reactions to the survey and to the survey's proposed topic areas.

8. At the conclusion of the workshop, CD staff asked stakeholders to provide additional comments and feedback regarding the survey's proposed topic areas in written form by email to the Commission by January 9, 2012.

9. On January 9, 2012, the CTIA-the wireless Association, AT&T, Greenlining Institute, the Utility Reform Network and DRA submitted additional comments and feedback.

10. Staff with the help of Field Research carefully reviewed parties' comments and suggestions and incorporated them into the survey questionnaires whenever possible.

11. CD staff now seeks formal authorization to proceed with the implementation of the pilot test and customer satisfaction survey as proposed by Field Research and accepted by CD staff.

12. A Notice of Availability was e-mailed to the parties of record in R.07-01-021 and all the carriers on February 2, 2012.

13. The parties' comments and the Commission's responses to those comments are addressed in this resolution.

14. It is reasonable to delegate to the Commission's Executive Director the authority to proceed with the implementation of the LEP survey.

15. It is reasonable to retain the services of Field Research at the costs of $875,500 subject to a contingency of plus or minus 10%.

16. It is reasonable for staff to seek reimbursement for Field Research costs from approximately sixty carriers having $10 million or more in annual intrastate revenue.

17. A decision about the frequency with which the survey will be repeated -- to assess changes in LEP customer satisfaction over time -- will be addressed after results of this first survey are reviewed.

THEREFORE, IT IS ORDERED that:

This Resolution is effective today.

I hereby certify that the Public Utilities Commission adopted this Resolution at its regular meeting on March 8, 2012. The following Commissioners approved it:

 

ATTACHMENT A

TO: Ms. Simin Litkouhi, California Public Utilities Commission

FROM: Mark DiCamillo / E. Deborah Jay, Field Research Corporation

RE: LEP Survey - Reactions to stakeholder comments about proposed survey topics

DATE: January 30, 2012

Below is our reaction to the various suggestions made by stakeholders about the proposed topics to be included in the LEP customer and non-customer surveys.

Reactions to CTIA/AT&T comments

The CTIA submitted a fairly detailed five-page set of written comments. In a separate letter, AT&T stated that it "supports the comments submitted by CTIA." Thus, we view the CTIA written commentary as also being reflective of the views of AT&T.

1. The CTIA suggests that the customer survey not ask customers to classify their telephone service into one of three types -- landline, cell and VoIP -- due to possible customer confusion with regard to whether or not their phone service is VoIP. We agree that this is a possibility and now propose asking customers to report only whether the phone(s) they use to make personal calls is a cell (or wireless) phone vs. some other type of phone. Since we will be capturing the name of their telephone service provider, in data analysis it may be possible to further subdivide users of phones other than cell phones into landline and VoIP phone types by grouping together companies known to be a provider of landline or wireline phone services only and those known to be a provider of VoIP service only.

2. The CTIA suggests that assessments of customer satisfaction about their telephone service beyond a customer's overall satisfaction and their likelihood of recommending the service provider to others should be limited only to matters that can potentially be affected by a customer's ability or inability to be English proficient. We concur, and have limited the subtopics of customer satisfaction addressed only to such items. For this reason, we have chosen not to include questions on matters such as the quality of repair or installation or reception quality since these would not be impacted by a customer's English proficiency.

3. The CTIA suggests limiting the time frame for the evaluation of customer interactions with their phone provider to the past six months due to concerns about the reliability of customer recall of events that occurred before this. We feel this is overly restrictive and would limit the types and quantity of information captured. When evaluating specific service-related contacts with the company, we propose to limit answers only to a customer's last contact with the company. Because we will also be asking customers to answer in broad terms when this last interaction occurred (e.g., within the past six months, past year, past two years, etc.), answers can be analyzed according to its recency of occurrence, with greater weight given to interactions that occurred more recently and less weight given to those that happened years ago.

4. CTIA expresses concerns about potentially repetitious customer satisfaction assessments. For example, our workshop presentation slides listed items that on one slide included satisfaction with their carrier's initial sales contact and then on another satisfaction with the provider's in-language services during their sales contact. Because of this, we have eliminated items that could be viewed as duplicative. The survey now obtains a single measure for each item with comparisons made between English-speakers and LEP speakers to examine whether there are higher levels of dissatisfaction among the LEP population.

5. CTIA expresses concerns about including customer satisfaction questions that are overly broad, and similar to its concerns expressed in (1) above, are unrelated to a customer's English proficiency. We concur and have attempted to focus our attention on aspects of each service that could have bearing on a customer's English proficiency. For example, instead of attempting to measure satisfaction about the general cost of their telephone service, we ask their satisfaction with explanations of their phone charges. However, we do believe it is important to include a satisfaction with a customer's perception of the accuracy of the charges on their bill and do not go along with the CTIA's suggestion that this item be deleted.

6. CTIA stated that because 9-1-1 emergency service is not carried out by individual carries it should be removed from the survey. We disagree. We believe the intent of the survey should be to assess potential problems with access to in-language services across different LEP populations, and assess the extent of language-related telephone service problems even when the carrier itself is not the source of the problem.

7. The CTIA states that the definition of a recent non-telephone customer was not made explicit in our presentation slides when we referred to a non-customer as a "current customer who reports having been without access to any form of telephone service for three months or longer in the recent past," because the term "recent past" was not defined. CTIA goes on to suggest using a past six-month time frame for this. In our proposal to the CPUC, we explicitly defined recent non-customers as customers who have gone without access to any telephone service for personal use for at least three months or more within the past three years. Thus, the survey will be employing a far broader timeframe than CTIA's suggestion to limit this to the past six months. This is needed to enable the Non-Customer Survey to identify a sufficient number of recent non-customers to attempt to meet the CPUC's stated preference of including 700 respondents in this sample. Limiting the time frame only to customers who had gone without telephone service in the past six months would severely reduce the number of eligible non-customers identified and prevent us from meeting your sample size target.

8. Regarding the non-customer survey, CTIA expresses concerns about several of the specific customer satisfaction measures alluded to in our workshop presentation slides. However, once we began developing the non-customer survey questionnaire, we found that time limitations prohibited us from including any specific customer satisfaction questions other than their overall assessments of their service provider and whether they would recommend the company to a relative or friend. Because of this, CTIA's concerns about these more specific satisfaction questions are moot, since they are not being included in the non-customer survey questionnaire.

Reactions to Greenlining Institute/The Utility Reform Network comments

The Greenlining Institute and the Toward Utility Reform Network (TURN) teamed up to submit a joint set of written comments about the survey's proposed topic areas. The following is our reaction to their suggestions and comments.

1. We disagree with the Greenlining Institute/ TURN's suggestion about including questions designed to establish the telephone usage patterns of not just the respondent, but of other household members as well. To do so would add significantly to the survey's length and because the average length of the survey interview is limited to no more than 15 minutes, this cannot be accommodated. In addition, with the inclusion of cell phone listings into the sample, the survey results will be projectable to individual adult telephone customers, not to households per se. This differs from past CPUC-sponsored Affordability Surveys in which households comprised the study's sample frame, since they were derived from lists of the major carriers' home landline customers.

2. We concur with the Greenlining Institute/ TURN's view that it is important for the survey to examine customer satisfaction with specific services, such as 9-1-1 emergency service or 411 directory assistance, even if they are not directly provided by the carrier. We share their view that the survey's purpose here is not to place blame on any single party but to identify potential problems that LEP customers may be having with their service.

3. Greenlining Institute/ TURN take the position that the survey should make distinctions between the types of service included in each customer's plan and possibly include satisfaction assessments for each type. In making determinations of what specific customer satisfaction measures to include, our guiding principle was to include matters that could potentially be affected by a customer's ability or inability to be English proficient. Thus, questions regarding the carrier's explanation of their charges on their billing statement, the information given them about service alternatives, calling features and costs when first choosing their carrier, as well as the explanation of when late fees and early termination fees and when service can be disconnected are relevant and will be included. However, survey length considerations prevent us from including items that attempt to delineate the telephone provided by carrier agents or resellers, evaluations of the telephone handset or other equipment being used, charges placed on their bill by companies other than their phone provider, among others.

4. In its comments about the non-customer survey, Greenlining Institute/ TURN suggests making distinctions between individuals who are without telephone access and households who are without access. Similar to our reaction to (1) above, if the non-customer survey were to attempt to assess the telephone usage or access to telephone service of other household members, this would add significantly to the survey's length, and for this reason cannot be accommodated.

Reactions to DRA comments

In providing feedback to us, DRA chose to enter additional bullet points onto various pages of our workshop presentation graphics and returned this to us as suggestions for the inclusion of additional items to the survey.

1. DRA suggests adding customer satisfaction assessments in several areas. We used the same decision rules as previously described to determine what specific areas to include (i.e., matters that could potentially be affected by a customer's ability or inability to be English proficient were generally included, while most others were not). Because of this, the survey includes a question about satisfaction with the billing format, mistakes on their bill and whether customers have been crammed in our somewhat broader assessments of the carrier's explanation of their phone charges on billing statements and the accuracy of these charges. As DRA suggests, the survey addresses the amount of time it took for LEP customers to get through to a service representative, and customer assessments of whether their questions were answered and problems resolved.

2. DRA suggests asking customers whether or not they are aware that the CPUC is a place they can contact to register complaints about their phone service or their bills. We agree with this suggestion and have added a question to the customer satisfaction survey specifically asking customers if they were aware that they could contact the CPUC about these matters.

3. With regard to the non-customer survey, DRA suggests asking recent non-customers their reasons for deciding to obtain telephone service again. We concur and have included a question series address this.

4. Due to survey length constraints, we chose not to include a set of questions that would attempt to identify customer calling plans, features, and functional capabilities of their telephone service, and address DRA's suggestion to identify customers' most important function desired.

1 Ordering Paragraph No. 3.

2 Ordering Paragraph No. 4.

3 On July 11, 2011, CD staff issued Solicitation #10PS5886 requesting proposals to conduct the LEP Survey, and setting an August 15, 2011 deadline for submitting proposals to the Commission. After evaluating proposals, the Commission issued a Notice of Intent to award the project to Field Research on September 1, 2011. After the required five-day protest period had passed, the project was awarded to Field Research, culminating in signed a contract agreement between the Commission and Field Research on October 10, 2011 (Agreement # 11PS5886, formerly IFB -10PS5886).

4 Staff calendared the workshop notice on the Daily Calendar and sent the workshop notice, the agenda, and list of questions to all certificated carriers. Since there was no active service list and the inactive service list was very old, staff communicated via phone and in person with DRA and other CBOs. At the workshop staff created a service list for all who were present in person or dialed in via telephone and after the workshop via email solicited parties' comments.

5 At the workshop on December 14, 2011, two PowerPoint documents were presented--1) Overview of the LEP Survey and 2) Proposed Structure and Topic Areas.

6 D.08-10-016, P.142. OP 4, "The survey workshop shall also consider whether the customer satisfaction survey should be periodically repeated, and, if so, how frequently this should be done and the estimated cost of doing so."

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