Telecom Decision
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Ottawa, 24 July 1997
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Telecom Decision CRTC 97-16
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QUALITY OF SERVICE INDICATORS FOR USE IN TELEPHONE COMPANY
REGULATION
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- I INTRODUCTION
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- In Review of Regulatory Framework,
Telecom Decision CRTC 94-19, 16 September 1994
(Decision 94-19), the Commission stated that, under the new regulatory framework:
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- (a) as in the past, a proper determination
of just and reasonable telephone rates will continue to involve an assessment of the
service quality provided by telephone companies to their subscribers;
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- (b) the Commission will continue to monitor
the quality of service of all telephone companies under its jurisdiction, with respect to
essential Utility services, bottleneck facilities, and toll service in regions where the
telephone company is the sole provider actively marketing such service;
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- (c) in regions where the telephone company
is the sole provider actively marketing toll service, the Commission will continue to take
into account the dependence of remote and rural communities on long distance service, due
to population dispersal and distance from essential services; and
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- (d) the Commission will ensure that carriers
continue to maintain the quality of the above-noted services.
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- In Decision 94-19,
the Commission also stated its intention to initiate a general proceeding on quality of
service regulation. The Commission stated that it would use the four points noted above as
guidelines, taking into account the particular circumstances of individual companies, in
considering quality of service indicators, standards and other related matters.
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- Consistent with the above, the Commission
issued Review of the Quality of Service Indicators, Telecom Public Notice CRTC 94-50, 21 October 1994 (PN 94-50),
initiating a proceeding (the Quality of Service proceeding) to consider issues related to
the quality of service of BC TEL, Bell Canada (Bell), The Island Telephone Company
Limited (Island Tel), Maritime Tel & Tel Limited (MT&T), The New Brunswick
Telephone Company, Limited (NBTel), NewTel Communications Inc. (NewTel) (formerly
Newfoundland Telephone Company Limited) and TELUS Communications Inc. (TCI) (formerly AGT
Limited).
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- The Commission also included in the
proceeding consideration of appropriate quality of service regulation for MTS NetCom Inc.
(MTS) (formerly Manitoba Telephone System), Northwestel Inc. (Northwestel) and the largest
of the independent telephone companies that came under its jurisdiction as a result of the
Supreme Court of Canada's Decision in Attorney-General of Quebec et al. v. Téléphone
Guèvremont Inc., specifically, TELUS Communications (Edmonton) Inc. (TCEI) (formerly
Edmonton Telephones Corporation), Northern Telephone Limited (Northern),
Québec-Téléphone, Télébec ltée (Télébec) and The Corporation of the City of
Thunder Bay - Telephone Division (Thunder Bay Telephone), i.e., those with 25,000 or more
Network Access Services (NAS). In Regulatory Framework for the Independent Telephone
Companies in Quebec and Ontario (Except Ontario Northland Transportation Commission,
Québec-Téléphone and Télébec ltée), Telecom Decision CRTC 96-6, 7 August 1996, the Commission dealt with the
quality of service regulation of the independent telephone companies with less than 25,000
NAS.
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- In PN 94-50, the Commission identified a number of
issues upon which it invited proposals and comments. BC TEL, Bell, Island Tel,
MT&T, NBTel, NewTel, MTS, Northwestel, Northern, Québec-Téléphone, Télébec,
Thunder Bay Telephone, TCI and TCEI (the telephone companies) were made parties to the
proceeding and were directed to file, among other things, submissions with respect to the
issues set out in PN 94-50. These issues are
discussed below in Parts II and IV.
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- In response to PN 94-50, the telephone companies filed submissions
by 7 April 1995.
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- By 2 June 1995, the following interveners
filed comments on the telephone companies' submissions: AT&T Canada Long Distance
Services Company (AT&T Canada LDS) (formerly Unitel Communications Inc.); the
Government of British Columbia (B.C.); The Canadian Association of the Deaf;
Consumers Association of Canada, Alberta Branch (CACAlta); Consumers
Association of Canada, Fédération nationale des associations de consommateurs du Québec
and the National Anti-Poverty Organization (CAC/FNACQ/NAPO); Public Interest Advocacy
Centre (PIAC) Ottawa and The British Columbia Old Age Pensioners' Organization, Council of
Senior Citizens' Organizations West End Seniors Network, Senior Citizens'
Association, Federated Anti-Poverty Groups of B.C., Local 1-217 IWA Seniors (collectively,
BCOAPO et al.) represented by B.C. PIAC; Rogers Cantel Inc. (Cantel); the
Telecommunications Workers Union (TWU) and Yukon Government.
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- By 28 July 1995, TWU and Stentor Resource
Centre Inc. (Stentor), on behalf of the telephone companies, filed reply comments.
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- By letter dated 6 November 1995, the
Commission stated that it considered it essential to the development and functioning of an
effective price cap regime that quality of service be maintained. The Commission stated
that some method of providing credits or rebates to customers may be appropriate to ensure
that rates for service received are just and reasonable where the quality of service fails
to meet an acceptable standard. Accordingly, the Commission directed the telephone
companies to file further submissions with respect to a scheme of credits and rebates. The
telephone companies filed their submissions on 16 February 1996 in response to the
Commissions letter of 6 November 1995. On 12 March 1996, AT&T Canada LDS,
BCOAPO et al. and PIAC filed comments.
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- In the proceeding initiated by Price Cap
Regulation and Related Issues, Telecom Public Notice CRTC 96-8, 12 March 1996 (the price caps
proceeding), TWU, the Communications Energy and Paperworkers Union of Canada, the Atlantic
Communications and Technical Workers Union, the International Brotherhood of Electrical
Workers and the Telecommunications Employees Association of Manitoba (TWU et al.) and CAC
filed evidence relating to quality of service.
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- On 29 August 1996, the Commission received a
letter from Stentor requesting confirmation that the issue of quality of service,
including proposals to include a service quality index in the price cap formula, was not
being addressed in the price cap proceeding, and that any evidence in relation to that
issue would not be considered in that proceeding.
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- By letter dated 12 September 1996, the
Commission ruled on Stentors application, stating that it would be more appropriate
to deal with all matters relating to mechanisms for the maintenance of quality of service
under a price cap regime (including penalties, rebates and the inclusion of a quality of
service factor in the price cap formula) in the Quality of Service proceeding.
Accordingly, the Commission ruled that it would not consider in the price cap proceeding
the evidence of TWU et al. or CAC relating to quality of service mechanisms. By letter
dated 25 September 1996, as amended by letter dated 17 October 1996, the
Commission modified the procedure for the Quality of Service proceeding to permit the
filing of additional submissions by TWU and CAC, as well as all parties to the proceeding,
with respect to mechanisms for the maintenance of a quality of service in a price cap
regime (including penalties, rebates and the inclusion of a quality of service factor in
the price cap formula).
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- By 16 October 1996, AT&T Canada LDS,
CACAlta, CAC/FNACQ/NAPO and TWU et al., and by 24 October 1996, the telephone companies
filed submissions with respect to mechanisms for the maintenance of quality of service in
a price cap regime. By 13 December 1996, AT&T Canada LDS, BC TEL, Bell,
B.C., BCOAPO et al., CACAlta, CAC/FNACQ/NAPO, MTS, TCI, TCEI and TWU et al. filed reply
comments.
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- On 19 December 1996, the Commission received
a letter from TCI objecting to the introduction of new evidence by CAC/ FNACQ/NAPO in
their reply comments of 13 December 1996, namely a copy of a draft report from the
National Regulatory Research Institute (NRRI) Report 96-11, March 1996, entitled
"Telecommunications Service Quality". TCI noted that CAC/FNACQ/NAPO had
contended that the draft NRRI report was filed earlier in this proceeding by PIAC.
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- By letter dated 20 December 1996, PIAC
responded to TCIs letter stating that it had originally referred to the report in
question in its 12 March 1996 submission. PIAC stated that shortly thereafter it provided
a copy of the report to Bell (in response to Bells request) and to the Commission,
but did not copy other parties due to the length of the report and the fact that no other
party requested copies. PIAC stated that, if its references to the NRRI report and
subsequent filing with Bell and the Commission were not considered as "filing on the
record of this proceeding", then CAC/ FNACQ/NAPO could withdraw their references to
the report in question.
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- Because all parties to the Quality of
Service proceeding were not provided a copy of the NRRI report, the Commission has not
considered the NRRI report as part of the record of this proceeding.
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- II Q-FACTOR IN THE PRICE CAP INDEX
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- In Price Cap Regulation and Related
Issues, Telecom Decision CRTC 97-9, 1 May 1997 (Decision
97-9), the Commission announced that it had decided not to include a quality of service
factor, i.e., Q-factor, in the price cap index and that the determination would be
addressed more fully in the decision to be issued in the Quality of Service proceeding.
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- A Q-factor is a discrete numerical value
built into the price cap index formula, designed to reflect a telephone companys
performance in respect of a set of objective quality of service indicators. Its principal
purpose is to act as a deterrent to the telephone companies from downgrading service
quality to increase profits under a price cap regime. A Q-factor could be designed such
that an adjustment triggered by sub-standard service would be calculated and the price cap
lowered. Alternatively, an increase in the price cap could result if quality exceeds
pre-set thresholds.
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- The telephone companies were opposed to a
Q-factor. However, in case the Commission decided to include a Q-factor in the price cap
formula, BC TEL and Bell submitted proposed models for a Q-factor. Both models
focused on two service interfaces: Provisioning and Repairs. For Provisioning, BC TEL
and Bell proposed to measure the interval within which new services can be furnished,
business office access and appointments missed. For Repairs, BC TEL and Bell measured
the length of service outages, the accessibility of repair bureau and appointments missed.
Under BC TELs model, the Q-factor would be adjusted in every month of
below-standard or above-standard performance. The sum of these monthly adjustments, if
any, calculated over a 12-month period would be totalled, resulting in the operative
Q-factor in the price cap index for the subsequent year. Unlike BC TEL, Bells
proposal provided for a three-month grace period, which would have resulted in a monthly
deduction only if below quality of service in a month had been preceded by three
consecutive sub-standard months of service.
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- TWU proposed a Q-factor which involved,
among other things, elements that would trigger credits for billing rebates.
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- The Commission notes that the implementation
of a Q-factor is based on the presumption that telephone companies will sacrifice service
quality to increase profits, especially in an increasingly competitive marketplace.
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- The Commission considers that there are a
number of shortcomings associated with a Q-factor, among them that a Q-factor does not
address the "injured party" specifically but affects all subscribers by lowering
the price cap and that a Q-factor would result in a time lag between the period in which
service quality was below standard, and the imposition of the Q-factor penalty.
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- Based on the experience with reporting under
the Quality of Service Indicators for Use in Telephone Company Regulation, Telecom
Decision CRTC 82-13, 9 November 1982 (Decision
82-13), the Commission further
considers that its close monitoring of key service indicators and its ability to deal with
problems on a case by case basis as they arise have proven to be a sufficient safeguard of
service quality in the past.
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- The Commission notes that the monitoring
model, which is set out in Part IV of this Decision and which is based in part on the
reporting requirements of Decision 82-13, is intended to ensure that quality of service is
maintained. Accordingly, as stated in Decision 97-9, a Q-factor
will not be included in the price cap index.
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- III COMMISSION MANDATED REBATES
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- In its letter of 25 September 1996, the
Commission directed the telephone companies to file submissions with respect to mechanisms
for the maintenance of quality of service in a price cap regime including, among other
things, rebates.
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- The telephone companies were opposed to
Commission mandated rebates, but in response to interrogatory (CRTC)25Sept96-101, proposed
that, if there must be rebates, only objective quality of service indicators, rather than
customer satisfaction indicators, should be used for rebate considerations. In addition,
the telephone companies addressed possible rebate mechanisms.
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- AT&T Canada LDS proposed various rebates
for customers that are also competitors.
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- With respect to AT&T Canada LDS
proposal, the Commission agrees with the telephone companies that rebates for customers
that are also competitors are a matter that is more appropriately dealt with in the
proceeding to be initiated to consider whether current tariff provisions require change
with respect to providing rebates to competitors, as stated in the Commissions
letter of 19 December 1995 to Sprint Canada.
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- Based on the submissions of parties, the
Commission notes that a mandated rebate scheme would provide direct compensation to
specific customers affected by poor service quality.
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- The Commission notes, however, that a
mandated rebate scheme is difficult to administer fairly in that what is deemed just
compensation to one individual may not be sufficient to another. In addition, a telephone
company may decide that providing rebates is less expensive than maintaining good service
quality.
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- Moreover, as stated in Part II above, the
monitoring model set out in Part IV is intended to ensure that quality of service is
maintained.
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- In the circumstances, the Commission is of
the view that mandated rebates are not warranted at this time.
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- In Telecom Order CRTC 96-940, 24 August 1996, the Commission
approved the introduction by MTS of a service guarantee for individual and party-line
customers when the company does not meet scheduled installation or repair appointments.
Under the service guarantee, MTS can offer, among other things, as compensation for
installation or repair appointments missed two calling features for two months or one
calling feature for four months at no charge (e.g., call forwarding, call waiting, voice
messaging, etc.). In addition, in Telecom Order CRTC
97-748, 4 June 1997, the Commission approved the introduction by BC TEL of a
market trial involving service guarantees and automatic customer rebates to certain
individual business line customers. The Commission stated that, should BC TEL file,
in the future, a similar application for permanent service offering it would be
appropriate for BC TEL to address the extension of service guarantees to both
business and residence subscribers.
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- The Commission, therefore, would entertain
voluntary rebate proposals. Such proposals should be uniformly applied to customers in a
manner that would not result in unjust discrimination.
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- IV QUALITY OF SERVICE MONITORING
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- A. Monitoring Model
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- In Decision 82-13, the Commission
established a set of quality of service indicators. Pursuant to Decision
82-13,
BC TEL, Bell and Northwestel, the telephone companies that were under the
Commission's jurisdiction at the time of the Decision, are required to report details of
their performance, on a quarterly basis, for a number of indicators dealing with eight
service interfaces.
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- In their initial submissions in this
proceeding, Island Tel, MT&T, NBTel, NewTel and TCI (which were not under the
Commissions jurisdiction at the time that Decision
82-13 was issued and were
therefore not required to file reports pursuant to Decision
82-13), requested that they be
exempted from reporting on quality of service and that market forces be relied on to
provide incentives to ensure that quality of service is maintained.
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- As noted earlier, the Commission stated in
the regulatory framework Decision (Decision 94-19) that
it would monitor the quality of service of all telephone companies under its jurisdiction
with respect to essential Utility services, bottleneck facilities, and toll service in
regions where the telephone company is the sole provider actively marketing such services.
The Commission remains of the view, stated in its letter of 6 November 1995, that market
forces are not sufficient incentives to ensure that quality of service with respect to
essential Utility segment services and bottleneck facilities does not deteriorate under a
price cap regime. The Commission also notes that the effects of local competition, if any,
on quality of service are not known at this time. Therefore, the request of Island Tel,
MT&T, NBTel, NewTel and TCI to be exempted from reporting on quality of service is
denied.
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- The Commission notes that, under the current
monitoring model, the service quality standards required for the three reporting telephone
companies, i.e., BC TEL, Bell and Northwestel, have generally been met or exceeded.
On this basis, the Commission is satisfied that the current monitoring model has worked
reasonably well in safeguarding service quality and provides an appropriate framework upon
which to develop a monitoring model for the telephone companies that are parties to this
proceeding. Therefore, in Appendix A to this Decision, the Commission has determined a set
of interfaces, indicators and standards based on those established in Decision
82-13 and
modified them to reflect the issues raised in this proceeding as discussed in Section B
below. The telephone companies are directed to use the new monitoring model in Appendix A
to file quality of service reports on a quarterly basis commencing with the year 1998. The
reports are to be filed within 45 days of the end of each quarter.
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- With respect to indicators, the Commission
notes that the current reporting requirements use a number of subjective indicators based
on regular surveys of customer satisfaction.
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- The Commission notes that the telephone
companies preferred the use of subjective indicators but, with respect to rebates,
indicated that they were in favour of using objective criteria. Interveners generally
favoured the use of objective indicators.
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- The Commission notes that, with the use of
subjective indicators, the results of customer surveys may be distorted simply by
customers being dissatisfied with other factors, such as a rate increase, rather than with
an actual change in the service quality of a specific indicator.
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- Accordingly, the Commission is of the view
that subjective indicators are not appropriate and directs the telephone companies to
employ indicators based on objective criteria in the new monitoring model.
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- Currently, BC TEL, Bell and Northwestel
report quality of service performance using company-specific standards. Under the new
monitoring model, the 14 telephone companies will be reporting on service quality using
uniform national standards. In the Commissions view, it would be appropriate to
obtain actual data before finalizing a set of national quality of service standards.
Therefore, the standards for the monitoring model set out in Appendix A for the telephone
companies are established on an interim basis until 31 December 1998.
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- BC TEL, Bell and Northwestel are
directed to continue to report under the Decision
82-13 requirements as well as the new
monitoring model in Appendix A. The Commission has set out in Part V of this Decision
directions for a process to finalize a set of national quality of service standards, to be
effective 1 January 1999. At that time, BC TEL, Bell and Northwestel will no
longer be required to report under the indicators set out in Decision
82-13.
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- B. Key Issues Raised in PN 94-50
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- 1. Uniformity of Quality of Service
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- The first issue was whether there should be
different approaches to quality of service regulation to reflect any differing
circumstances of the various telephone companies.
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- The telephone companies generally favoured
uniformity in principles.
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- Interveners generally favoured uniformity
for comparison purposes.
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- The Commission agrees that uniformity and
consistency should be encouraged to the greatest extent possible, so that all Canadians
can be assured of having a similar high quality of service, consistent with the objectives
set out in section 7 of the Telecommunications Act.
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- 2. Urban/Rural Reporting
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- The second issue was whether there should be
separate reporting of rural and urban quality of service indicator performance.
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- The telephone companies generally agreed to
report separately on provisioning and repair interfaces for urban and rural subscribers
but opposed separate reporting for indicators which have common delivery systems, such as
Operator Services and Billing, arguing there would be no difference in the quality of
service provided to urban versus rural areas.
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- TCI opposed separate reporting for urban and
rural subscribers on the basis that service to both customer sectors should be the same.
TCI stated that it provides the same service to all areas of its serving territory.
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- MTS proposed a separate category called
"remote" for areas not accessible by road year-round.
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- Interveners supported disaggregated
reporting for rural and urban areas based on a concern that the telephone companies would
lower the quality of service in high cost areas in order to cut costs and maximize
profits.
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- The Commission notes that the cost of
maintaining quality of service is greater in rural areas than in urban areas because of
the distances that have to be travelled and the human resources required to provide and
repair service. The Commission also notes that persistent problems with rural service
quality would not be as noticeable under a company-wide reporting system because the
number of quality of service problems reported would be spread over the total base of
urban and rural subscribers. Further, competitive market forces are less likely to be a
disciplining factor in rural areas. Accordingly, the Commission considers separate
reporting of rural and urban service indicators to be appropriate. The Commission notes,
however, that there is a common delivery system for Operator Services and Billing.
Therefore, the telephone companies will be required to report separately for Provisioning
and Repair service.
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- With regard to establishing an appropriate
delineation between urban and rural areas, the Commission notes that in Local
Competition, Telecom Decision CRTC 97-8, 1 May 1997 (Decision
97-8), it approved, on an interim basis, Stentors proposed rate bands for local
loops based on length and density. The Commission noted that the smaller, less dense
exchanges were generally characterized as constituting Bands C and D by Stentor in the
proceeding leading to Decision 97-8, but that some exceptions exist, for instance, for
NBTel.
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- The Commission notes that eight telephone
companies (i.e., BC TEL, Bell, Island Tel, MT&T, MTS, NBTel, NewTel and TCI) that
will be subject to price caps will have their territories delineated by rate bands.
Further, the bands will be finalized in the proceeding established by Implementation of
Price Cap Regulation, 1997 Contribution Charges and Related Issues, Telecom Public
Notice CRTC 97-11, 25 March 1997. The
Commission considers, therefore, that for BC TEL, Bell, Island Tel, MT&T, MTS,
NBTel, NewTel and TCI the use of the rate bands is an appropriate classification for the
reporting of rural and urban subscribers, i.e., Bands A and B, considered to be urban
areas, and Bands C and D, considered to represent both rural and remote areas.
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- With respect to Northern, Northwestel,
Québec-Téléphone, TCEI, Télébec and Thunder Bay Telephone, the Commission notes that
these companies are not subject to the rate band designation established in Decision 97-8. Therefore, the Commission considers that, based on the
population and density of subscribers in their respective territories, Northern,
Northwestel, Québec-Téléphone, Télébec and Thunder Bay Telephone can be regarded as
rural and TCEI can be regarded as urban for reporting purposes.
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- 3. Service Interfaces
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- The third issue was whether the eight
service interfaces (i.e., Provision of Service, Repair Service, Local Service, Long
Distance Service, Operator Services, Directory Service, Billing and Complaints) set out in
Decision 82-13 are still appropriate, and whether new service interfaces such as network
reliability should now be included in the new regulatory framework.
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- Most of the telephone companies agreed to
maintain the eight interfaces, with the exception of Long Distance Service which they
proposed be discontinued.
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- Several telephone companies proposed to
measure the quality of service provided to competitors under a new separate interface
called Access to Essential Utility Services (Interconnection Services).
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- Interveners were generally in favour of
retaining the eight service interfaces as well as the addition of a new interface for
Interconnection Services.
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- Both Cantel and AT&T Canada LDS proposed
additional indicators for Interconnection Services.
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- While the Commission finds that the
interfaces established in Decision 82-13 continue to be a valid framework upon which to
measure quality of service, the Commission considers that interfaces that have been
rendered superfluous due to technological and market developments over the past 15 years
should be phased out, specifically Interface #4: Long Distance Service; Interface #5:
Operator Services and Interface #7: Billing.
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- With respect to Interface #4: Long Distance
Service, the Commission notes that, with the proliferation of optical fibre, carrying
capacity of the intertoll telephone network has substantially exceeded current usage.
Also, excellent voice quality is attained with digital technology. Tone dialing, common
channel signalling (CCS7) and digital switches provide almost instant dial tone.
Therefore, the Commission concludes that the Interface dealing with Long Distance Service
no longer needs to be monitored, except in areas without competitive service providers.
For those areas, the Commission will track the number of complaints under the Interface:
Complaints, where Long Distance is reported as a separate category.
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- With respect to Interface #5: Operator
Services, the Commission notes that since Direct Distance Dial became popular, very few
customers use toll operators compared to a decade ago. Further, the convenience of calling
cards has further reduced the need to use Operator Services. For those customers
requesting Operator Services, the interface is for the most part handled by Voice
Interactive Recording. In light of the above, the Commission concludes that the Interface
dealing with Operator Services no longer needs to be monitored. The Commission will,
however, track the number of complaints under the Interface: Complaints, where Operator
Services is reported as a separate category.
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- With respect to Interface #7: Billing, the
Commission notes that with the high degree of computerization, billing errors are not
expected to be a serious problem with consistent 99% to 100% accuracy reported by the
telephone companies. On the other hand, customer caused adjustments are becoming
increasingly frequent as more and more enhanced services are tried and cancelled by
subscribers. Because the percentage of bills showing adjustments are no longer indicative
of the telephone companies faulty accounting, the Commission concludes that the
Interface dealing with Billing no longer needs to be monitored. The Commission will,
however, track the number of complaints under the Interface: Complaints, where Billing is
reported as a separate category.
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- With respect to whether new service
interfaces such as network reliability should now be included in the new regulatory
framework, the Commission considers network reliability to be covered under the Repair
Service Interface.
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- With respect to the proposal for new
interfaces for Interconnection Services (i.e., for competitors), the Commission
considers that such interfaces are not necessary as the new indicators for competitors are
included under Provisioning and Repair Interfaces.
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- 4. Maintaining Quality of Service under
Price Caps
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- The fourth issue raised in PN 94-50 has been
dealt with under Parts II and III above.
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- 5. Regulatory Responses to Below-Standard
Performance
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- The fifth issue was what regulatory
responses should be considered when actual measured performance falls below the standard
performance level.
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- The telephone companies took the position
that market forces obviated the need for regulatory action. In the alternative, the
telephone companies generally argued that an explanatory report with an action plan, when
needed, would be sufficient response to below standard service.
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- Interveners disagreed with the telephone
companies on the basis that market forces would not develop fast enough nor operate evenly
throughout the telephone companies territories. Interveners were of the view that
continued regulatory oversight was therefore imperative to safeguard the public interest.
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- The Commission notes that, depending on the
severity of quality deterioration, regulatory responses could range from increasing the
frequency of reporting from quarterly to monthly and demanding a plan of action, to
progressively severe measures, such as requiring customer-specific rebates, a general
rebate, or a downward adjustment to the price cap index as contemplated in a Q-factor. The
Commission is of the view that no change in regulatory treatment is needed at this time,
except that an explanation of below-standard performance, if necessary, is to be filed
concurrent with, rather than 15 days after, the filing of a quarterly report which is
filed 45 days after the end of the quarter.
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- 6. Sub-Standard Threshold Rebates
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- The sixth issue was, as a means to ensure
that rates to subscribers appropriately reflect the service quality provided to them,
whether rebates or rate reductions are appropriate when actual measured performance for
certain specified indicators (e.g., dial tone delay, repair, operator answer) falls below
a pre-set threshold lower than the standard performance level.
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- This issue has been addressed in
Part III above.
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- 7. New Indicators
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- The seventh issue was whether certain
quality of service indicators should be provided as a sub-set of other quality of service
indicators, for example:
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- (a) Provisioning of Bottleneck Facilities
for competitors as a sub-set of customer provisioning or business customer provisioning;
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- (b) Message Relay Service (MRS) as a sub-set
of Operator Services quality;
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- (c) Average Installation Interval (in days)
from receipt of order to available for service as a sub-set of held orders; and
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- (d) Average Repair Interval (in hours) from
receipt of trouble report to available for service as a sub-set of repair.
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- With respect to the provisioning of
bottleneck facilities, both the telephone companies and interveners generally supported
the introduction of indicators measuring the provision and repair of interconnected
services provided to competitors. As well, AT&T Canada LDS and Cantel proposed
additional indicators.
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- On the basis of parties proposals, the
Commission directs the addition of three new indicators: (1) percentage of competitors'
installation appointments met; (2) on time Primary Interexchange Carrier (PIC) activation;
and (3) percentage of competitors' repair appointments met.
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- As to the other indicators proposed by
AT&T Canada LDS and Cantel, the Commission notes that some of those proposed by
AT&T Canada LDS were subjective indicators and are therefore not appropriate as
previously stated. For the remaining proposed indicators, because interconnection service
agreements are approved by the Commission and the terms and conditions under which
interconnection services are offered are subject to supervision by the Commission
(including its Competitive Dispute Resolution process), the Commission considers that the
monitoring of the remaining proposed indicators is not necessary.
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- With respect to MRS, the Canadian
Association of the Deaf (CAD) proposed that it be included as a new indicator.
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- The telephone companies stated that MRS
already is subject to sufficient scrutiny from various organizations and that the
telephone companies have co-operated extensively with various agencies to facilitate
service for persons with disabilities.
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- The Commission notes that CAD acknowledged
the labour and cost-intensive nature of MRS, the dedication of the telephone companies in
providing this service and the great benefits this service has brought to deaf and hearing
people alike. Given that there is no evidence of poor service, the Commission is of the
view that a separate indicator for MRS is not required at this time.
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- With respect to average installation
interval, the telephone companies were opposed to reporting on this indicator.
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- The Commission considers that it is
appropriate to include an indicator for average installation interval in order to
determine how long it takes to provide service from the date of the initial request.
Average installation interval is shown as indicator 1.1 - Provisioning Interval in
Appendix A.
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- With respect to average repair interval, the
telephone companies stated that they currently report on out-of-service trouble cleared
within 24 hours and that they preferred to retain this indicator.
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- The Commission is of the view that the
current indicator for out-of-service trouble reports cleared within 24 hours remains
appropriate.
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- The Commission notes that NBTel proposed to
report on a new set of indicators. In view of the monitoring model set out in
Appendix A, NBTels proposal is denied.
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- 8. Below-Standard Reporting Rules
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- The eighth issue was whether the current
requirement for a telephone company to report below-standard service quality, where it
occurs over three consecutive months or over seven months in a 12-month period, should
remain the same. In particular, the Commission sought comments on, or proposed
alternatives to, the following possible reporting requirements:
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- (a) where service quality falls below
standard for three consecutive months, the affected indicator should be reported to the
Commission monthly until its performance level is at or above standard; and
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- (b) where service quality falls below
standard for seven out of 12 consecutive months, the affected indicator should be reported
immediately to the Commission, rather than on the regularly scheduled quarterly report due
date.
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- Parties generally agreed that it would be
appropriate to continue the current practice of requiring telephone companies that report
below-standard performance with respect to any indicator for three consecutive months or
seven out of 12 consecutive months, to provide the Commission (a) with an explanation of
the cause of quality degradation; and (b) with an action plan describing how the telephone
company intends to rectify and prevent the situation from recurring.
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- The Commission agrees with parties and
directs that in circumstances where a telephone company reports an indicator with
below-standard quality for three consecutive months, or seven out of 12 consecutive
months, it is to file for that indicator monthly reports within 15 days of the end of the
month, rather than quarterly reports, until quality meets or exceeds the standard for
three consecutive months, and provide an explanation of the cause of quality degradation
and an action plan describing how it intends to rectify and prevent the situation from
recurring.
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- 9. Basis for Standards
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- The ninth issue was whether the 90%
satisfaction objective stated in Decision 82-13 is still appropriate, or whether an
alternative objective should be considered.
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- The Commission concurs with both the
telephone companies and interveners that the 90% customer satisfaction objective is still
appropriate.
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- 10. Reporting of Internal Measures
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- The tenth issue was whether all telephone
companies should employ network measurements and adjust, on a periodic basis, their
respective service quality standards based on their impact upon customer satisfaction and,
if so, for which service quality standards.
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- The telephone companies indicated that they
employ internal measures to meet customers expectations.
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- The Commission considers that the telephone
companies approach is appropriate.
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- 11. Service Guarantees
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- The eleventh issue was whether a
"Customer Service Guarantee Policy" for utility service subscribers should be
considered, for example, one similar to that offered by the Georgia Power Company, shown
in Attachment 1 to PN 94-50.
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- The telephone companies took the position
that service guarantees were an operational and marketing strategy and that they should
have the freedom to consider these options at their discretion. They submitted that, where
service guarantees are offered, quality of service reporting should cease in that the
service guarantee itself would ensure that an adequate level of service quality is
provided; if it is not, the customer would be compensated in accordance with the service
guarantee.
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- TWU was of the view that such a guarantee is
appropriate.
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- As noted in Part III above, the
Commission is of the view that mandated rebates are not warranted at this time. Similarly,
the Commission is of the view that mandated service guarantees are not warranted at this
time. However, the Commission would entertain proposals for voluntary service guarantees.
Such proposals should be uniformly applied to customers in a manner that would not result
in unjust discrimination.
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- 12. Quality Management Programs
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- The twelfth issue was whether quality
management programs such as the International Standards Organization ISO 9000 (ISO 9000),
or certain aspects thereof, should be considered in developing quality of service
indicators to be reported to the Commission.
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- The telephone companies generally considered
quality management programs, such as ISO 9000, as tools more suitable for management
purposes than for regulatory oversight.
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- The Commission concurs with the telephone
companies that internal management tools are not the purview of the regulator unless
serious problems arise as a direct result.
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- 13. Company Employee Compensation Plans
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- The thirteenth issue was, where telephone
companies employ internal management systems (e.g., total quality management) or tie
Commission reported quality of service indicator performance to compensation plans for
management, whether quality-versus-compensation results of such systems should be provided
to the Commission on an annual basis.
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- The telephone companies were opposed to
identifying service elements used in a companys compensation plan, arguing that how
a company achieves desired performance levels is an internal matter.
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- TWU argued that the quality of service
components utilized in BC TELs company compensation plan have failed to attain
the desired quality of service levels. In TWUs view, such elements could not serve
as a substitute for Commission oversight.
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- The Commission agrees with the telephone
companies that compensation plans are properly within the purview of company management.
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- 14. Common Report Format
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- The fourteenth issue was whether the quality
of service periodic reports filed by the telephone companies should have a uniform format
and, if so, what format should be appropriate.
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- The telephone companies considered desirable
a common report format across all telephone companies.
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- The telephone companies proposed that the
administrative details of submissions would be best determined following a decision in
this proceeding and, at that time, that meetings between the telephone companies and
Commission staff could be held to determine the administrative details regarding the
reporting format.
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- PIAC and TWU supported a uniform format for
the quality of service reports.
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- The Commission is of the view that details
on a common reporting format should be developed through consultations with Commission
staff subsequent to the release of this Decision. The telephone companies and other
interested parties are therefore directed to notify the Commission, within 10 days of
this Decision, of the name of the person to contact with respect to this matter. The
format should be finalized by 31 December 1997.
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- 15. Machine-Readable Filings
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- The fifteenth issue was whether procedures
should be developed that would eventually enable the telephone companies to file the
periodic quality of service reports in electronic format.
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- In general, the telephone companies were of
the view that the use of an electronic media format for filing quality of service results
would be appropriate.
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- PIAC was supportive of electronic filings as
a way of reducing costs for the companies and the Commission.
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- The Commission notes that it began receiving
electronic filings with respect to its telecommunications activities on 1 January 1996 and
since then has successfully received over 22,000 documents filed electronically mostly by
Stentor and its members. The Commission further notes that Commission staff is available
to assist all telephone companies, that have not used electronic filing, on the process
involved. The Commission considers that, once all telephone companies are familiar with
the process, they will be able to file the first quality of service reports, as set out in
Part IV, in electronic format.
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- C. Other Issues - Changing Indicators and
Standards
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- To streamline the process of changing
indicators and standards, Bell and BC TEL, with the concurrence of the other
telephone companies, proposed a process for introducing changes.
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- Under the proposed process, the telephone
companies would file, 90 days before implementing changes, a proposal with the Commission
providing details and a rationale for the change. Before the end of the 90 days, if
the Commission does not respond, the changes would be implemented by the telephone
companies. Following implementation of the change, the telephone companies would report
for two consecutive quarters both old and new indicators or standards so that users would
be able to compare the changes. At the end of the two quarters, the old indicator would be
discarded.
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- The Commission considers the proposed
process for changing indicators and standards to be generally appropriate. The Commission
considers, however, that interested parties should have an opportunity to comment on any
proposed changes. In view of this, the Commission, therefore, directs the telephone
companies to use the following procedure when changes to indicators and standards are
proposed:
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- (a) 90 days before implementing any proposed
change, the telephone companies are to file a proposal with the Commission, providing
details and a rationale for the change, serving a copy on interested parties to this
proceeding and any other interested parties. The submission should include data for the
two most recent quarters showing results for both old and new indicators, in order to
allow interested parties to compare the effects of the change and comment;
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- (b) Interested parties will have 30 days to
comment and telephone companies will have 10 days to reply to any comments; and
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- (c) If there is no other impediment, the
Commission should be able to render its determinations before the proposed implementation
date.
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- V PROCESS TO FINALIZE THE STANDARDS
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- BC TEL, Bell, Island Tel, MT&T,
NBTel, NewTel, MTS, Northwestel, Northern, Québec-Téléphone, Télébec, Thunder Bay
Telephone, TCI and TCEI (the telephone companies) are made parties to this proceeding.
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- Other parties wishing to participate in this
proceeding must notify the Commission of their intention to do so by writing to
Mrs. Laura M. Talbot-Allan, Secretary General, CRTC, Ottawa, Ontario, K1A 0N2, fax:
819-953-0795, by 30 June 1998. Parties are to indicate in their notice their Internet
email address, if available. If parties do not have access to the Internet, they are to
indicate in their notice whether they wish to receive disk versions of hard copy filings.
The Commission will issue a complete list of parties and their mailing addresses
(including Internet email addresses if available), identifying those parties who wish to
receive disk versions.
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- The telephone companies are directed (1) to
file submissions to finalize the standards, (2) for those telephone companies unable
to meet the national standard, to provide a company-specific standard proposal with
supporting rationale, and (3) to provide any other proposals that the companies may wish
to put before the Commission. All such material is to be filed with the Commission and
served on all parties by 14 August 1998.
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- All other parties may file comments on the
telephone companies proposed standards and submissions, serving copies on all
parties, by 15 September 1998.
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- The telephone companies may file reply
comments serving copies on all parties by 25 September 1998.
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- Where a document is to be filed or served by
a specific date, the document must be actually received, not merely sent, by that date.
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- In addition to hard copy filings, parties
are encouraged to file with the Commission electronic versions of their submissions in
accordance with the Commission's Interim Telecom Guidelines for the Handling of
Machine-Readable Files, dated 30 November 1995. The Commission's Internet email
address for electronically filed documents is public.telecom@crtc.gc.ca.
Electronically filed documents can be accessed at the Commission's Internet site at http://www.crtc.gc.ca .
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- Laura M. Talbot-Allan
Secretary General
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- This document is available in alternative
format upon request.
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