VI. Methods For Measuring Applicable Standards

The existing G.O. 133-B rules apply to "all telephone utilities providing service within the State of California."⁸⁵ Even though G.O. 133-B applies to all telephone utilities in California, staff reports that only ILECs have ever filed any G.O. 133-B reports with the Commission. Given the absence of sufficiently precise rules governing the methods and procedures that ensure uniformity in measuring and reporting service quality measures, the Commission is concerned that some carriers may have established procedures which minimize the possibility that G.O. 133-B reports will ever need to be filed with the Commission. Other carriers may simply not file the required reports.

We cited above an example of how one carrier's procedures understate held orders and another example of how that carrier's methods overstate its BOAT performance. We believe there exist numerous other ways carriers can perform sampling or devise procedures that reduce or eliminate carriers' obligation to report service quality information to the Commission.

For example, G.O. 133-B permits carriers to base TOAT, DAOAT, TRSAT and BOAT results on a sample "that is representative of the measurement period", but does not otherwise require a carrier's sampling procedures to satisfy any particular criteria.⁸⁶ Thus, a carrier can generate TOAT, DAOAT, TRSAT and BOAT results that will not trigger the reporting threshold, either intentionally or inadvertently, merely by changing sample size, time of day/week/month for sampling, etc. Widely differing methods undermine the usefulness of service quality information. Therefore, we intend to adopt more specific criteria and procedures for producing service quality results. We propose that sampling be performed either, 1) daily and continuously throughout the 24-hour period in at least one-hour intervals, or 2) during the busy-hour of each day.

We seek comment on whether the proposed sampling procedures will ensure accurate and consistent TOAT, DAOAT, TRSAT and BOAT results. Where commenters contend the proposed methods are inadequate, we ask for specific step-by- step procedures that achieve accurate and consistent information.