3. Current In-Language Efforts of Telecommunications Carriers
In D.06-03-013, we recognized that carriers should be the first and most important source of information for consumers.16 In preparing the Report, Staff contacted all registered and certificated (wireless and wireline) telecommunications corporations in California asking for information on carrier services for and interactions with LEP consumers. Of the carriers contacted, only approximately 11% responded (109 responses were received on behalf of 147 carriers out of a total of approximately 1,300 carriers). However, we did receive responses from most incumbent local exchange carriers (ILECs) that serve over 90% of ILEC customers, major competitive local exchange carriers (CLCs), and major wireless carriers and these carriers serve the majority of telecommunications customers in California. Many respondents stated that they do not track this information or do not provide non-English services, and were unable to provide information on LEP customers. Nevertheless, several carriers provided information on their multilingual marketing, education, and outreach services, and the language demographics of their customers. We estimate that through the service territories of Verizon and AT&T alone, over 90% of residential customers have access to in-language support.
The Report found many telecommunications carriers provide their own in-language marketing, outreach, and education for existing customers and prospective customers in order to provide better service or to attract new customers. Certain other in-language activities are undertaken to comply with prior Commission orders.17 Common carrier practices include soliciting a customer's preference for receiving information in a language other than English at the time a customer opens an account, and tracking a customer's language preferences to enable the carrier to send future information (ranging from written order confirmations to bills, new service offerings, and other information) in the customer's preferred language.
The Report found that larger carriers are more likely than smaller carriers to serve larger linguistic groups (e.g., Spanish, Chinese) with in-house employees, and to use Language Line telephone interpretation services for others. 18 Several smaller carriers do not provide any non-English educational materials because these carriers do not see a need for such services among their customers.19 Some carriers serving multi-ethnic customers also provide in-house customer service in languages other than English, most commonly Spanish, but also several Asian languages, as well as Russian, Armenian, Arabic, and others. Carriers that do not have bilingual staff and do not utilize Language Line translation services suggest that LEP customers obtain their own interpreters to assist them when they shop for telecommunications services or translators to help them understand written communications from service providers.
In workshops, carriers reported that, in general, when they become aware of fraud or abusive marketing on the part of their dealers, and agents, the carriers discontinue contracts with those dealers. According to the Report, carriers expressed support for a voluntary and collaborative process for resolving the challenges faced by LEP consumers, primarily through cooperation between carriers, CBOs, and the Commission in resolving individual customer complaints.20
The Report also reviewed the results of a 2005 CUDC survey of the language policies and practices within the CUDC utility companies and the Commission, and concludes those results largely agreed with information Staff received from telecommunications companies.21 The CUDC survey found all of those surveyed provide some level of customer service in at least one non-English language, and were either expanding their multilingual services or, in the case of the smaller companies, considering it. The CUDC survey also found most of those surveyed regularly monitor customer service telephone calls for quality assurance, several of those surveyed use telephone interpreter services to serve non-English speaking customers, all of those surveyed state most of their LEP customers speak Spanish, all of those surveyed translate some materials to Spanish, most of those surveyed provide diversity and cultural awareness training, and some of those surveyed offer pay differential for multilingual employees.
The Report found that larger carriers and those serving more diverse areas offer more services in more languages than smaller carriers. Services provided in-languages other than English include marketing and outreach information (such as brochures on understanding your phone bill) and customer service. Carriers providing in-language support usually provide information only in the most commonly spoken non-English languages, and few carriers provide in-language service contracts or in-language key terms and conditions.
Based on input from consumer advocates and from public participation hearings (PPHs), the Report concludes there is a need for more in-language information and services for LEP consumers, increased and speedier enforcement to address fraudulent activities and other violations, and increased attention to carriers' oversight of dealers, agents or resellers.22 According to the Report, consumer groups report the absence of in-language contracts or written summaries of terms and conditions makes it more difficult for LEP consumers to verify the services purchased are those represented during an in-language sale, with a potential for fraud or marketing abuse.
Although carriers and consumer groups commenting on the draft Report challenged Staff's recommendations, no commenter disagreed with or refuted the Report's assessment of telecommunications carriers' current in-language efforts.23 Therefore, we accept the Report's assessment of telecommunications carriers' current in-language efforts.
16 D.06-03-013, p. 118.
17 For example, D.96-10-076 requires competitive local exchange carriers (CLCs) to provide specific information to customers in Spanish, Mandarin, Cantonese, Vietnamese, Korean, Japanese, and/or Tagalog, if they market services in those languages.
18 Language Line Services provides professional interpreters of 170 languages 24 hours a day, 7 days a week, 365 days a year. See: http://www.languageline.com/
19 Report, p. 68.
20 Report, p. 63.
21 The companies included in the CUDC survey were AT&T California, Verizon California, Pacific Gas and Electric, Southern California Edison Company, San Diego Gas & Electric Company, Southern California Gas Company, Southern California Water Company, and San Jose Water Company.
22 Report, pp. 72-73.
23 The CTR disagreed with the Report's statement that "California is uniquely a state in which no ethnic group constitutes a majority," asserting Latinos are clearly the state's ethnic majority. CTR Recommendations and Comments on the Draft Report (September 14, 2006), p. 15.
