V. Additional Service Quality Measures and Standards

We believe that service quality measures should go beyond technical performance measures, and should also include measures of customer service and related consumer impact measures.63 We also believe that additional technical performance and consumer impact measures and reports are needed to adequately measure service quality. Additional technical performance measures include installation and repair intervals. Additional reports include existing major service interruption reports that should be consolidated in our rules.

Where appropriate, we intend to require additional or consolidate existing reporting of carrier compliance with certain consumer protection rules to help the Commission better assess the effectiveness of those rules, and to provide valuable information to the Commission on where its consumer protection rules may need modification. These consumer protection reporting requirements may include reporting of slamming, cramming and other informal complaints, and compliance with carriers' four-hour appointment obligations.

We seek comment on whether the additional technical and consumer protection-related measures and standards proposed for telecommunications services are adequate. We also seek comment on service quality issues not addressed by our proposal.

While G.O. 133-B requires carriers to track access line installation commitments met, this measure provides no indication of how long it takes a carrier to meet its commitments (i.e., installation intervals). Thus, a carrier can ensure it meets its commitments merely by advising customers that installation of service will require an extended period of time, and committing to a date sufficiently far into the future.

Where customers have few or no alternatives, customers have little or no bargaining power and are left with the choice of either accepting an installation date far into the future, or not receiving service at all. Thus, merely measuring the percent of commitments met fails to provide any useful information on another important measure of service quality; the interval of time required to install service.

Also, G.O. 133-B presently does not measure repair intervals. In D.83-11-062, the Commission stated that the repair interval was one of the factors that affect customers perception service quality, and recommended that the G.O. 133 Review Committee give careful consideration to establishing a measure for it. Unfortunately, the G.O. 133 Review Committee never proposed a measure for repair intervals, and, to date, none has been adopted.

As mentioned above, the Commission found in D. 01-12-021 that Pacific's deteriorating residential repair intervals were unreasonable. The Commission established standards for initial and repeat out-of-service repair intervals, and will impose financial penalties if Pacific fails to meet the standards. The FCC presently requires certain carriers to regularly report on among other things, various service quality measures under ARMIS. Although the FCC collects installation and repair interval data for certain carriers, we do not believe the FCC's ARMIS reports are adequate for our oversight of service quality.

This is because, unlike G.O. 133-B, the FCC requires only local exchange carriers subject to price cap regulation to report service quality measures. CLECs, interexchange carriers (IECs), and most incumbent local exchange carriers (ILECs) do not report ARMIS data. Also, ARMIS reports suffer from many of the same shortcomings described above for G.O. 133-B reports. Finally, ARMIS reports have other limitations, in that they do not address many of the measures that California believes are important indicators of service quality, including Held Orders, Commitments Met, TOAT, DAOAT, BOAT and TRSAT.

Although we believe the limitations described above prevent us from relying on ARMIS reports exclusively for our service quality purposes, we nevertheless believe that installation intervals and repair intervals are important measures of service quality. Therefore, we propose to establish measures and standards in our service quality rules for installation and repair intervals applicable to primary lines, additional lines and other services.

We seek comment on whether the measures for installation and repair intervals should be reported separately for primary lines and additional lines or combined as a single measure. We seek comment on whether the measures for installation and repair intervals for other services are necessary and should be reported. We want our rules to be consistent with the best available practices, and invite parties to illustrate what they believe are the best practices in place for this measure in other jurisdictions.

We also seek comment on whether the proposed standards for installation and repair intervals are adequate, and whether the proposed SQAM will ensure that carriers consistently meet the proposed standards. Where commenters contend that the proposed standards and SQAM are insufficient, we ask for specific changes to the proposed SQAM that will ensure compliance with standards. We want our rules to be consistent with the best available practices, and invite parties to illustrate what they believe are the best practices in place for this measure in other jurisdictions.

We believe that speedy installation and repair of service is an important aspect of service quality, especially when a customer is without service altogether. While measuring repair intervals is a useful tool, we also believe measuring how often carriers fail to promptly repair service or repair service by the time agreed are other important indications of service quality. Therefore, we propose to establish measures to determine the percentage of initial out-of-service trouble reports and repeat out-of-service trouble reports that are cleared within a 24-hour (i.e., 8 working hours) period from the time the trouble was reported by the customer to the carrier. We propose separate measures for trouble related to installation of service (i.e., trouble reported within 30 days of installation) and for non-installation related trouble. Because wireless service does not require installation, we propose that only the non-installation related trouble measure apply to CMRS, and that it apply from the date of service activation.

We seek comment on whether initial and repeat trouble report out-of-service clearing time should be reported separately for primary lines and additional lines or combined as a single measure. We seek comment on whether trouble report clearing time measures for other than out-of-service conditions are necessary and should be reported. We want our rules to be consistent with the best available practices, and invite parties to illustrate what they believe are the best practices in place for this measure in other jurisdictions.

Our rules presently require reporting of installation commitments met64, but do not require reporting of repair commitments met. However, we believe that repairing service when promised is just as important an aspect of good service quality as is installing service when promised.

The National Association of Regulatory Commissioners (NARUC) Technology Policy Subgroup issued its "Service Quality White Paper" in 1998, identifying service quality measures that, among other things, "are considered by the states to be meaningful and significant indicators of service quality" and comprise data that "most, if not all, telephone companies already capture ... for internal management purposes."65 Thus, it is likely that the data for service quality measures we believe is important is also available, and our desire to adopt new measures will not impose an unreasonable burden on carriers.

Pacific and Verizon currently report to the FCC their performance on meeting repair commitments under the SBC/Ameritech and the Bell Atlantic/GTE merger agreements, respectively. Also, Verizon provides a "Service Performance Guarantee (SPG)" when it fails to complete repairs when promised. 66

Thus, while G.O. 133-B does not presently require reporting repair commitments met, California's largest carriers already report, and in some cases provide guarantees, for repair commitment performance. Therefore, we propose to establish measures and standards addressing commitments met for initial and repeat out-of-service repair of primary and additional lines, and for other than out-of-service repairs, and apply those measures to wireline and CMRS carriers as proposed above for Out-of-Service Clearing Time.

We seek comment on whether the measures for initial and repeat out-of-service repair commitments met should be reported separately for primary lines and additional lines or combined as a single measure. We seek comment on whether the measures for initial and repeat repair commitments met for other services are necessary and should be reported. We want our rules to be consistent with the best available practices, and invite parties to illustrate what they believe are the best practices in place for this measure in other jurisdictions.

We also seek comment on whether the proposed standards for initial and repeat out-of-service repair commitments met are adequate, and whether the proposed SQAM will ensure that carriers consistently meet the proposed standards. Where commenters contend that the proposed standards and SQAM are insufficient, we ask for specific changes to the proposed SQAM that will ensure compliance with standards. We want our rules to be consistent with the best available practices, and invite parties to illustrate what they believe are the best practices in place for this measure in other jurisdictions.

We believe frequent or widespread service outages have the potential to pose a significant threat to public safety and place an unwarranted inconvenience to telephone users. California law requires every public utility to furnish and maintain adequate, efficient, just, and reasonable service, instrumentalities, equipment, and facilities, including telephone facilities...necessary to promote the safety, health, comfort, and convenience of the public.67

Although staff has requested that all carriers report major telephone service interruptions, the standards and procedures for reporting outages are contained in a 1977 memorandum of which many carriers are not generally aware.68 Moreover, the information contained in that memorandum is substantially out of date. Importantly, some carriers have questioned the staff's authority to impose this reporting obligation on carriers via memorandum. We note that Pacific and Verizon are currently required to report major service interruptions as part of NRF monitoring.69

We believe that tracking and reporting major service interruptions continues to be an important way for the Commission to be apprised of service interruptions that may affect public safety, and to assess changes that may be necessary to ensure that the public receives adequate, efficient, just, and reasonable telephone service, including uninterrupted access to 911 emergency services. Therefore, we propose to include in our revised G.O. 133-B rules requiring all carriers to report major service interruptions.

We seek comment on whether the rules for reporting major service interruptions are adequate. We direct carriers operating in other states to list by state all rules for reporting major service interruptions to which they are currently subject. We seek comment on whether standards and SQAM should be established to encourage carriers to minimize major service interruptions.

Where commenters recommend standards or SQAM, we ask for specific proposals for what the standards should be and why, and what SQAM would ensure compliance with standards and how the SQAMwould be applied. We want our rules to be consistent with the best available practices, and invite parties to illustrate what they believe are the best practices in place for this measure in other jurisdictions.

G.O. 133-B presently requires reporting of initial reports from customers and users of telephone service relating to dissatisfaction with telephone company-provided equipment and/or service (customer trouble reports).70 However, our rules do not require reporting the frequency of repeat trouble reports. Repeat trouble reports are those relating to a previously reported trouble which occurs after the initial or first customer trouble report has been cleared and the customer notified. Reports made before the initial or first customer trouble report has been cleared are not considered to be repeat reports.71

SBC currently provides service quality data to the FCC's Merger Compliance Oversight Team (MCOT) under the terms of the SBC/Ameritech merger agreement. This data includes "Percent Repeat Troubles" for business and residence customers in the 13 states where SBC operates.72 Verizon also provides similar service quality data to the FCC's MCOT under the terms of the Bell Atlantic/GTE merger agreement.73

Few things can be more aggravating to customers than repeated unsuccessful attempts to have the same problem fixed. As Verizon puts it, "[customers tell] us that the quality with which we... [complete] work correctly the first time is very important."74 Verizon internally measures the quality of its repair and installation technicians' workmanship by the percent of time its technicians fail to solve a complaint the first time. Pacific also has internal standards for completing installations and repairs "right the first time."75

We, too, believe that the frequency of repeat trouble is an important indicator of service quality. Therefore, we propose to establish a measure requiring carriers to report the percent of repeat troubles for residential and business customers. We also intend to establish a standard that we believe is reasonable.

We seek comment on whether the measures for repeat trouble reports should be reported separately for primary lines and additional lines or combined as a single measure. We seek comment on whether the measures for repeat trouble reports for other services are necessary and should be reported. We want our rules to be consistent with the best available practices, and invite parties to illustrate what they believe are the best practices in place for this measure in other jurisdictions.

We also seek comment on whether the proposed standards for repeat trouble reports are adequate, and whether the proposed SQAM will ensure that carriers consistently meet the proposed standards. Where commenters contend that the proposed standards and SQAM are insufficient, we ask for specific changes to the proposed SQAM that will ensure compliance with standards. We want our rules to be consistent with the best available practices, and invite parties to illustrate what they believe are the best practices in place for this measure in other jurisdictions.

SBC and Verizon currently provide data on the Percent of Installations Completed within 5 Working Days to the FCC's MCOT under the terms of their respective merger agreements. These carriers also have internal measures for percent of installations completed within five days,76 or for average number of days to install.77 Other states have also established standards requiring a specified percentage of installations to be completed within five days. For example, Ohio requires carriers to complete all requests for local service within five business days78, New York requires carriers serving more than 500,000 lines to complete 80% of requests for basic local service within five working days79, and Alabama requires 90% of requests for residential service to be completed within five working days80. We, too, propose to establish a measure and standard requiring installations to be completed within five working days.

We seek comment on whether the measures for installations to be completed within five working days should be reported separately for primary lines and additional lines or combined as a single measure. We want our rules to be consistent with the best available practices, and invite parties to illustrate what they believe are the best practices in place for this measure in other jurisdictions.

We also seek comment on whether the proposed standards for installations to be completed within five working days are adequate, and whether the proposed SQAM will ensure that carriers consistently meet the proposed standards. Where commenters contend that the proposed standards and SQAM are insufficient, we ask for specific changes to the proposed SQAM that will ensure compliance with standards. We direct carriers operating in other states to list by state all performance mechanisms related to standards for installations to be completed within five working days to which they are currently subject, and to which lines (primary, or primary and additional) the performance mechanisms apply.

We believe that input from customers is a valuable tool for identifying areas needing improvement and for assessing the effectiveness of the technical objective service quality measures we've established. Therefore, we intend to take steps to develop ways to measure different kinds of customer concerns by defining what information carriers should collect (i.e., reportable complaints") and the different categories for tracking and reporting customer concerns. Therefore, the scope of this rulemaking will include prescribing a definition of customer complaint for service quality reporting purposes. However, this aspect of the rulemaking will be scheduled for a later date when we will intend to issue a proposal.

The Commission's pending Interim Decision Establishing Rules Governing Telecommunications Consumer Protection in R.00-02-004 intends to establish and consolidate its consumer protection rules under a new General Order. As stated above, this instant proceeding is not intended to replace or modify those rules. Rather, we intend to establish reporting requirements that will help the Commission measure the effectiveness of its consumer protection rules, and assist the Commission in determining if and when its consumer protection rules need modification. Therefore, the scope of this instant rulemaking will include prescribing a definition of customer complaint for service quality reporting purposes, and may be further revised if and when we issue a decision in R.00-02-004 (Establishing Rules Governing Telecommunications Consumer Protection).

However, we are prepared at this time to begin our effort toward establishing measures related to consumer protection. Specifically, we propose to adopt requirements addressing carrier compliance with consumers' right to have their service connection or repair appointment scheduled within a four-hour period.

Utilities are required under current law to "inform their subscribers of their right to service connection or repair within a four-hour period, if the presence of the subscriber is required, by offering the four-hour period at the time the subscriber calls for service connection or repair, or by notifying the subscriber by mail three times a year of this service."81 In deciding C.00-11-018, the Commission found that Pacific failed to expressly notify customers that call its 611 repair service of the availability of a four-hour appointment window, and ordered Pacific to provide customers who call for repairs with an opportunity to request a four-hour appointment period.82

C.00-11-018 was not the first time issues concerning compliance with California Civil Code §1722 (c) have been brought before the Commission. In fact, NRF utilities' compliance with their obligation to offer a four-hour appointment opportunity has been an area of concern to customers for more than a decade.83 Even though the four-hour appointment opportunity is currently state law, the pending interim decision in R.00-02-004 on telecommunications consumer protection rules proposes a similar rule requiring all telecommunications carriers to provide customers an opportunity to request a four-hour appointment period for installation and repair services.

Also, as mentioned above, the Commission has already adopted a service performance guarantee credit program that requires SDG&E to credit customer accounts $50 if SDG&E fails to meet its scheduled appointment commitment.84

Therefore, we propose to establish requirements that telecommunications carriers report their performance in meeting their four-hour appointment obligations. The rules we propose will require carriers to report the frequency of four-hour appointment requests (i.e., percentage of four-hour appointment requests as a percentage of total installation and repair service requests), and carriers' performance in successfully meeting the four-hour appointment window (i.e., four-hour appointment commitments met as a percentage of total four-hour appointments scheduled).

We also propose a SQAM requiring a carrier to credit customers $50 if the carrier fails to meet its scheduled appointment commitment. We seek comment on whether the proposed measures for four-hour appointment commitments are adequate, and whether the proposed SQAM will ensure that carriers consistently meet the appointment commitments. Where commenters contend that the proposed SQAM is insufficient, we ask for specific changes to the proposed SQAM that will ensure compliance.

63 The Commission is responsible for requiring telephone corporations to provide customer service to telecommunication customers that includes, but is not limited to... "reasonable statewide service quality standards, including standards regarding network technical quality, customer service, installation, repair, and billing." P.U. Code § 2896 (c). 64 G.O. 133-B, Section 3.2.

65 NARUC Service Quality White Paper. Available at http://www.fcc.gov/Bureaus/Common_Carrier/Public_Notices/1999/da992441.doc

66 R.01-09-001/I.01-09-002, TR. 2493 67 P.U. Code § 451 68 October 5, 1977 Memorandum from Ermet Macario, Chief - Surveillance Branch. 69 See, for example, Service Interruption Report P.A.-02-00 and Summary of Major Service Interruptions Report P.A.-02-01. 70 Section 3.3. 71 Reports made before the initial or first customer trouble report has been cleared are called "subsequent reports." 72 See Filename RE2.pdf at http://www.fcc.gov/wcb/mcot/SBC_AIT/service_quality/ 73 See Filename RE2.pdf at http://www.fcc.gov/wcb/mcot/BA_GTE/service_quality/ 74 R.01-09-001/I.01-09-002, TR 2479. 75 Response to D.R. 02-01-001, TD 003178 (Designated "Proprietary"). 76 SBC response to D.R. 02-01-001, TD 003178 (Designated "Proprietary"). 77 Verizon response to D.R. 02-01-001, P.24. 78 Chapter 4901:1-5-20(C)(1). 79 Part 603.3(e). 80 Rule T-21 (M)(1). 81 California Civil Code § 1722 (c ). 82 D.01-12-021. 83 D.94-06-011, 55 CPUC 2nd 1 at 55. 84 D.99-05-030.

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