V. Preliminary Remarks About Service Quality Data

A. Comparisons Among Carriers

While all parties concede some difficulty in using existing CPUC and FCC reports to compare carriers, all parties engage in such comparisons. ORA and TURN tend to focus on Pacific more than on Verizon.

ORA argues, for example, that Pacific's FCC service quality reporting of held orders shows that Pacific was the second worst performer when compared with the other twelve SBC companies in other states. Pacific urges us to pay greater attention to the carrier comparison offered by its own expert, Dr. Hauser, made by conducting a regression analysis of six FCC service quality measures for installation and repair. Pacific states that four of the six regressions show that its performance was statistically the same as or better than the average of the other SBC states.

By the same token, all parties criticize the comparisons made by one or more of the other parties. For example, Pacific claims Dr. Hauser's comparison is better than ORA's because he focused on several measures rather than on just one FCC measure, as Pacific contends ORA did. Likewise, ORA and TURN criticize Dr. Hauser's comparisons of Pacific to the average result of the top ten LECs because even Pacific has criticized similar comparisons in the context of a complaint case challenging Pacific's out-of-service intervals.⁴¹ Pacific concedes its comparisons across companies "may not be perfect," while it criticizes others' comparisons as flawed.⁴²

Although we acknowledge that any comparison may be subject to criticism due to variances in the data each carrier maintains and the methods used in making the comparisons, we will examine parties' carrier vs. carrier comparisons in this proceeding given that each party agrees that, to some extent, such comparisons are valid.

B. Comparisons of One Company's Performance Over Time

By relying on Dr. Hauser's regression analysis, Pacific conceded that comparing one company's results with its own results over time is an appropriate step.⁴³ However, when ORA attempted to do the very same type of comparison in its customer survey, Pacific was highly critical of the analysis. While we discuss ORA's survey below, we note at the outset that the survey is largely valid and most useful because it compares Pacific's own results to itself over time. Pacific's concession about the usefulness of such comparisons in one context undermines its criticism of similar comparisons in the context of the ORA survey.

Parties are also sometimes selective about the time frames during which they argue service quality is good/improving or bad/deteriorating. For example, Pacific chooses the period since 1998 to assert that it "has shown significant improvement in reducing [residential repeat out-of-service intervals, initial out-of-service intervals, and business installation] intervals,"⁴⁴ while ORA chooses the period between 1999 and 2001 to assert that "Pacific is performing poorly relative to other SBC states for held orders. . . ."⁴⁵

C. Aggregation of Data

One final threshold point: TURN criticizes Pacific for aggregating data as part of Dr. Hauser's regression analysis. We agree with TURN that combining several measures to come up with an aggregate score can mask serious problems, which may be concealed or diluted when measures are combined. Indeed, we warned against the dangers of such aggregation in D.01-12-021, where we found that "aggregating data in the manner Pacific proposes has the effect of masking poor service quality in one area."⁴⁶ We also agree with TURN that "single measures . . . can and do indicate significant areas of service quality decline" and that we can "find significant decline in service quality if an important measure declines relative to past performance."⁴⁷

Predictably, ORA and TURN focus on errors where Pacific's or Verizon's performance is substandard, while Pacific and Verizon emphasize areas in which performance is good or shows improvement. We recognize that the carriers show good results in a number of areas, and should be commended for these results.

By the same token, it is not adequate to show good performance only in some instances. When service quality appears to have improved under NRF, we will acknowledge that improvement. However, if there are instances of poor service quality, we do not believe any party would disagree that we should require improvement in these areas. It is on these areas that we focus in this decision, obviously, because we are interested in encouraging the best possible service for California ratepayers served by Pacific and Verizon. This focus should not be interpreted as disregard for the positive results Pacific and Verizon demonstrate. However, those results do not cancel out the negative results or mean that customers suffering in the areas where performance is poor experience positive service quality.