VII. Self Monitoring - Pacific

Pacific's witness Rick Resnick acknowledged that Pacific's internal tracking of service quality by and large is no more specific or rigorous than the regulatory requirements we and the FCC impose:

Q. Do you believe that Pacific's own internal standards for service quality are more stringent and detailed than those prescribed in GO 133(b)?

A. . . . I believe that our internals are designed to really line up with our reporting requirements, whether it's MCOT or ARMIS or GO. . . . But we use our internals to make sure that the overall reporting requirements are indeed met.

. . .

Q. Is it correct that Pacific internally tracks items that are germane to service quality that it doesn't necessarily report on pursuant to either GO 133(b), ARMIS, MCOT or any other requirement?

A. We may call some of those differences, but they get at the same type of measure. . . .

Q. If you at the company had to be left only with MCOT, GO 133(b) and ARMIS reporting as the totality of information that you had internally to assess Pacific's service quality, would you be satisfied with that?

. . .

A. I think, as I said, the reporting requirements on ARMIS, MCOT, GO, do a good job of measuring service quality. So I believe our service quality measurements and our ability to measure service would be intact on the whole.¹³⁶

Therefore, our reporting requirements, and those other regulators impose, are critical to the process of tracking and evaluating Pacific's service quality. It is not clear that Pacific would maintain the specific records we require if we did not require it to report its results. Thus, we agree with TURN that Commission oversight is essential to our ability to monitor and control Pacific's service quality.

Pacific's testimony is even more revealing when compared to Verizon's testimony in response to the same questioning. Verizon's witness candidly admitted Verizon's service quality managers view the GO 133-B and FCC reporting requirements as a minimum, and that Verizon takes many additional steps internally that no regulator requires. Its goal in doing this appears to be customer satisfaction.¹³⁷ That Pacific had an opportunity to demonstrate a similar commitment on questioning, and did not, is telling evidence of its reluctance to self-monitor. Thus, the evidence further supports our conclusion that we must carefully monitor and regulate Pacific's service quality in order to ensure it is satisfactory.