IV. Revisions to Existing Measures and Standards

We intend to revise the rules for measuring and reporting:

As discussed above, existing G.O. 133-B measures for determining Business Office Answering Time (BOAT) and Trouble Report Service Answering Time (TRSAT) do not anticipate the use of ARUs, and the present measures and standards are not meaningful in an ARU environment. Therefore, we propose to establish separate rules when ARUs are used, in addition to measures and standards where personnel directly answer calls made to business offices or to repair offices.

We seek comment on how our existing rules should be modified to recognize the use of ARUs in order to ensure that callers receive prompt and timely responses.

Pacific (and possibly other carriers) excludes calls to the business office encountering busy signals ("busy calls") from the computation of its BOAT results.56 We believe this practice makes Pacific's BOAT performance appear to be better than it actually is. As mentioned above, Pacific reported BOAT results of 80.3% for September 1998 (just exceeding the 80% minimum standard), even though a substantial percentage of all calls to the business office encountered busy signals and, consequently, many calls to the business office were not answered during that same month.

It is not known how many other carriers exclude busy calls from BOAT, or whether carriers similarly exclude busy calls to their repair offices from the computation of TRSAT. Therefore, we propose to require carriers to include busy calls in the computation of BOAT and TRSAT.

We believe that inaccessibility to the business or repair offices due to busy signals is an important measure of service quality problems. Therefore, we propose to require reporting of busy call volumes and rates for calls to business offices and to repair offices, and may establish standards and SQAMs in the future. We seek comment on what standards for busy call rates may exist in other states, and what standards should be adopted for busy call rates in California. We also seek comment on what SQAM should be adopted to ensure busy call rates are minimized.

We also seek comment on whether call abandonment rates are an indicator of service quality, and if so, whether standards are needed. If call abandonment standards are needed, we seek comment on what standards should be adopted for call abandonment rates in California and whether a SQAM should be adopted.

In response to staff's request for information on procedures used to measure held service order activity for primary telephone line installation57, some carriers report that they count their held orders each day during a monthly reporting period, and at the end of that month the totals for each day are added together for reporting purposes (i.e., a "rolling" count). Pacific, on the other hand, reports that one day each month, it counts service orders that have been held over thirty days as of the date the count takes place (i.e., a "snapshot" count).58

Because some carriers are employing methods that do not report orders delayed well beyond 30 days as "held", we find it necessary to prescribe more explicitly the methods carriers may use for compiling and reporting service quality measures so the Commission receives consistent, accurate and comparable information. Therefore, we intend to clarify that carriers should count all access line orders held over 30 days during any day of a month, (i.e., carriers should use the "rolling count" method).

We seek comment on whether this procedure is sufficiently explicit to ensure consistent and accurate reporting of held service orders. Where commenters contend the proposed procedure is insufficient, we ask for specific changes to the proposed procedure which will ensure accuracy and consistency of data.

We seek comment on whether carriers should separately report held orders for primary lines and additional lines, or whether held orders for access lines should be reported with no distinction between primary and additional lines. We seek comment on whether standards should be established for held orders, and if so, what are the appropriate standards.

The "commitments met" measure was designed to measure carriers' performance for responding to "requests [to establish or change] non-key telephone individual and party-line service that normally involve plant activity."59 However, we have found that some carriers include data for establishing vertical services and other services not related to access line installation when measuring commitments met. Because installation of vertical services can be done almost instantly, the practice of including these and other non-access line services in service quality results makes a carrier's performance on commitments met for access line installation appear better than it actually is. Therefore, we propose to require separate reporting of commitments met for primary access line installation, additional access line installation, and for installation of other services. We seek comment on whether reporting of commitments met for primary access line installation, additional access line installation, and for installation of other services is sufficient, or whether additional detail is necessary.

We have noted that Pacific presently excludes billing inquiries in its measurement of BOAT while Verizon, AT&T and perhaps others include billing inquiries in its BOAT measurement. Verizon's and AT&T's practice is inconsistent with G.O. 133-B. G.O. 133-B describes BOAT as "[a] measurement of time for the business office representative to answer business office calls"60 and defines "business office" as "[a] Centralized Service Group which receives Small Business and/or Residence Customer requests for new installation or change in existing service. This does not include billing center inquiries."61 (Emphasis Added).

Although we believe our rules are clear that billing inquiries should not be included in their BOAT results, we intend to modify the rules to make this explicit. However, because we believe carriers' handling of billing inquiries is also an important aspect of service quality, we propose to establish a separate and distinct measure and standard for BOAT billing inquiries.

We seek comment on whether a separate and distinct measure and standard for BOAT billing inquiries is appropriate, or whether billing inquiries should instead be included with other business office calls for the purpose of measuring BOAT. Where commenters recommend that billing inquiries should be separately measured, we also seek comment on whether the proposed rule concerning exclusion of billing inquiries from BOAT is sufficiently explicit to eliminate confusion as to which calls should be included in the BOAT measure.

G.O. 133-B presently includes measures:

However, today's customers increasingly depend on more complex services, including DSL for Internet access. As such, we believe some of the current measures are inadequate for assessing service quality in sufficiently meaningful ways. Therefore, we propose to establish separate measures and standards and refine existing measures and standards for all telephone access lines, DSL lines, and other (e.g., vertical) services.

We seek comment on whether separate measures and standards for primary telephone lines, additional telephone lines, DSL lines, and other (e.g., vertical) services are adequate to measure service quality related to these services. We seek comment on whether reporting of DSL service will be undermined by provisioning DSL service through an ISP or unregulated entities, and if so, how the Commission might best address such situations.

Also, we believe that our rules should be "technology neutral", and that the technology underlying a telecommunications service is irrelevant when the telecommunications service is used to complete intrastate calls. We have jurisdiction to apply our service quality rules to any intrastate telecommunications service, including any services using Internet Protocol (IP) telephony. Anticipating this emerging technology, we intend for the rules we adopt in this proceeding to apply to similar services regardless of the technology used to provide the service.

We seek comment on whether the measures and standards proposed for telecommunications services using traditional technologies are adequate and appropriate for application to services that use IP telephony. We seek comment on whether additional measures are needed for telecommunications services offered over an IP platform.

Our review of trouble report standards for other states indicates that California has among the most lenient standards. For example, California requires reporting of initial trouble reports when they exceed from six to ten reports per 100 working lines (depending on the size of the serving central office), where other states have set the standard at three reports per 100 lines.62

All carriers now use digital central offices and fiber optics in parts or all of their networks. Therefore, we believe our standards need to be updated to recognize the technology in use today.

We do not intend to compete with other states with respect to stringency of service quality standards. However, we recognize that most Californians are served by carriers that are subsidiaries of corporations with affiliates operating in multiple states. We also recognize that these carriers or their affiliates may face penalties for failure to meet service quality standards in the other states where they operate.

Given the financial incentives to meet service quality standards in other states, carriers may be motivated to shift resources from low-standard low-penalty states to those with higher standards and penalties as a way to minimize the parent corporation's overall financial exposure and the resources invested in maintaining service quality. We will not permit Californians to be the losers from this "service quality arbitrage." Therefore, we intend to establish customer trouble report standards and enforcement mechanisms that ensure carriers provide high quality service to Californians.

56 See Response to D.R. 02-01-001, TD 003173. 57 Held orders are "requests for service delayed over 30 days due to lack of telephone utility plant" (G.O. 133-B, Section 3.1). 58 See Response to D.R. 02-01-001, TD 003159. 59 G.O. 133-B, Section 3.2(a). See also Section 1.3(p). 60 Section 3.9 (a) 61 Section 1.3(b) 62 For example, see Ohio Rule 4901:1-5-20 (B)(2) and Oregon Service Quality rules (2 reports per 100 lines).

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