Decision CRTC 2000-24
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Ottawa, 20 January 2000
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Final standards for quality of service indicators for
use in telephone company regulation and other related matters
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File No.: 8660-C12-05/99
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The Commission has concluded it will not relax the existing quality
of service standards that Canadian telephone companies are required to meet.
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Although some telephone companies have asked to have certain quality
standards made less stringent, they will be required to maintain the same standards the
Commission adopted on an interim basis in July 1997. Telephone companies have been
responsible for maintaining specific service standards since 1982.
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Among the 16 indicators that telephone companies must monitor and
report, some new indicators have been created. For example, the Commission is seeking
comment on how telephone companies should report the amount of time it takes to field
customer requests and inquiries. The telephone companies should indicate if they prefer
either a service indicator based on the total length of time it takes to handle a customer
inquiry, how long a customer was placed on hold, or a combination of the two.
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There is also a new provision to report the percentage of customer
complaints which have not been satisfied within 10 working days. Telephone companies
should also provide comment on what standards should be used to monitor the speed and
accuracy of directory assistance.
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The indicators will not override any time frames negotiated by the
CRTC Interconnection Steering Committee (CISC). Those service intervals and standards have
already been approved by the Commission for transferring customers' local service from the
telephone companies to their competitors.
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The alternative service providers that compete with the telephone
companies are also customers when they use portions of the existing network. The
Commission wants to monitor the quality of service the telephone companies provide to
their competitors who are also customers. Within 90 days of this decision, the telephone
companies are required to propose how this can best be accomplished.
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In recognition of the unique business environment in the far north,
Northwestel will be required to report certain service indicators at a community level.
Northwestel's special status as a rural service provider will be examined in the coming
months as the Commission creates a custom-made, competitive framework for the far north.
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Introduction
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1. In Quality of Service
Indicators for Use in Telephone Company Regulation, Telecom Decision CRTC 97-16, 24 July 1997 (Decision 97-16),
the Commission provided interim standards for quality of service indicators. The
Commission expressed the view that it would be appropriate to obtain actual data before
finalizing a set of national quality of service standards. The Commission directed the
telephone companies subject to the decision, i.e., TELUS Communications (B.C.) Inc.
(formerly BC TEL) referred hereafter as TCBC, Bell Canada (Bell), Island Telecom Inc.,
(formerly The Island Telephone Company Limited), Maritime Tel & Tel Limited, MTS
Communications Inc., NBTel Inc. (formerly The New Brunswick Telephone Company, Limited),
NewTel Communications Inc., Northern Telephone Limited (Northern), Northwestel Inc.
(Northwestel), Québec-Téléphone, Télébec ltée, TELUS Communications Inc. (TCI) and
The Corporation of the City of Thunder Bay - Telephone Division, (collectively the
telephone companies), to file quarterly (45 days after the end of each quarter), quality
of service monthly performance reports commencing with the year 1998, for each of the
indicators using the monitoring model in Appendix A of the decision.
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2. The Commission also directed the
telephone companies:
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(1) to file submissions to finalize the standards;
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(2) for those telephone companies unable to meet the national standard,
to provide a company-specific standard proposal with supporting rationale; and
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(3) to provide any other proposals that the companies may wish to put
before the Commission.
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3. Appendix 1 to this decision
contains a list of parties that participated in this proceeding.
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4. This decision deals with the
standards for the service indicators that will be required by the Commission from the
larger telephone companies in Canada for their quarterly quality of service reports. The
Commission relies upon these reports to ensure that subscribers receive acceptable service
from their respective carriers, to isolate service quality problems as they arise and to
work with the telephone companies to implement corrective actions where needed.
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5. While the Commission will use
objective service indicators as a measure of company performance, it recognizes that good
customer service involves many subjective factors such as courtesy, timely resolution of
real or perceived problems, and generally good rapport between a customer and the
supplying telephone company. The Commission encourages all companies to monitor their
total customer service performance and to consider the objective measurements as required
by the Commission as only one part of their responsibility to provide a high level of
quality of service.
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Final standards
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6. In this proceeding, several of the
telephone companies proposed changes to the interim standards for the following service
indicators:
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1.1 - Provisioning Interval Urban and Rural
1.3 - Held Orders Urban and Rural
1.5 - Access to Business Office
2.1 - Out of Service Troubles Cleared Urban and Rural
2.3 - Initial Customer Trouble Reports per 100 NAS Urban and Rural
2.5 - Access to Repair Bureau
4.1 - Directory Accuracy
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7. In general, the changes would have
reduced the standards for these indicators.
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8. The Commission has considered the
telephone companies' proposals and the comments from interested parties and is of the view
that changes to the standards are not required at this time. The Commission is satisfied
that the standards set on an interim basis in Decision 97-16
have worked reasonably well for the purpose of monitoring the quality of service of the
telephone companies and considers that these standards continue to be appropriate.
Therefore, the Commission denies the telephone companies' requests to change any of the
interim standards set in Decision 97-16, and approves,
on a final basis, all of the standards for the quality of service indicators approved on
an interim basis in Decision 97-16. The final standards
for monitoring quality of service indicators are set out in Appendix 3 to this Decision.
The standards approved in this Decision will be considered the minimum level of quality of
service performance for each telephone company.
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Proposals regarding other aspects of service indicators and new
service indicators
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A. General
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9. In addition to proposals to change
the standards for certain indicators, as noted in Paragraph 6 of this decision, the
telephone companies also proposed a number of changes related to other aspects of the
indicators. These proposed changes are discussed below as are the Commission's conclusions
regarding new indicators.
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B. Indicator 1.4 Held Upgrades
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10. With respect to Indicator 1.4
Held Upgrades, Northwestel stated that it currently has less than 100 multi-party
lines in service and therefore, this statistic is no longer meaningful in assessing the
demand for service upgrades. The company suggested that this statistic be reported only
when the number of party lines is 200 or more for a telephone company.
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11. Northern requested a reporting
exemption for Indicator 1.4 on the basis that it cannot meet the interim standard because
its current offering for basic service is four-party service. Northern stated that it
would resume reporting if and when the company has completed its individual line service
program and is therefore able to offer individual line service as part of its basic
service.
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12. The Commission notes that the
issue of establishing a monitoring program to track service improvement plans has been
addressed in Telephone Service to High-Cost Serving Areas, Telecom Decision CRTC
99-16, 19 October 1999 (Decision 99-16). The Commission concludes that if a telephone
company's service improvement program is to be tracked by a monitoring program established
by the Commission as a result of Decision 99-16, the quarterly reporting of this indicator
would no longer be required. However, the Commission is of the view that the progress
report resulting from monitoring the program to track service improvement plans as set out
in Decision 99-16 should be filed as part of the quality of service quarterly report
filing.
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13. The Commission considers that,
subject to the above, the status quo is appropriate. The Commission denies Northwestel's
request to report only when the number of party lines is 200 or more and Northern's
request to be exempted from reporting Indicator 1.4.
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C. Indicator 1.7 On-time Activation of PIC
Alternate Providers of Long Distance Service
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14. With respect to Indicator 1.7
On-time Activation of Primary Interexchange Carrier (PIC) Alternate Providers of
Long Distance Service, TCI submitted that this indicator should be reported on an
exception-only, complaint basis given that all companies have consistently met standards.
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15. The Commission notes that only
TCI proposed to discontinue the regular filings for this indicator. The Commission notes
that this indicator monitors the quality of service performance provided to competitors.
Given the importance placed by competitors on timely installation of facilities, and the
possibility of anti-competitive behaviour in this regard, the Commission is of the view
that data on the on-time activation of PICs should be collected. Therefore, the Commission
denies TCI's proposal to discontinue the reporting of Indicator 1.7.
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D. Indicator 2.1 Out-of-Service Trouble Reports
Cleared Within 24 Hours
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16. With respect to Indicator 2.1 Out-of-Service Trouble Reports
Cleared Within 24 Hours, Northwestel stated that it serves a large geographic area, many
of the communities it serves are remote, and the facilities in those communities may be
unmanned and accessible by technicians only by air. The company proposed that for purposes
of setting quality of service standards for this indicator, a third classification called
"remote" should be created (in addition to urban and rural), which would be
defined as any community with less than 500 Network Access Services (NAS) and where access
to the community from a larger centre is either by aircraft or by road with more than
three hours of normal driving. For this category, the company proposed a standard of 70%
of out-of-service troubles cleared in 10 working days.
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17. The Government of the Northwest
Territories (GNWT) objected to a separate indicator for remote areas on the basis that it
would fail to satisfy 90% of customers, and that by any criteria, this would be considered
very poor service.
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18. The Commission notes that the
"remote" category was also proposed by Northwestel in the proceeding which led
to the issuance of Decision 99-16. The Commission also notes that quality of service in
Northwestel's territory is an issue to be dealt with in the proceeding initiated by Northwestel
Inc.
Implementation of Toll Competition and Review of Regulatory Framework, Quality of Service
and Related Matters, Telecom Public Notice CRTC 99-21, 1 October 1999 (PN 99-21).
The Commission considers that the PN 99-21 proceeding is the appropriate venue to deal
with Northwestel's request for a "remote" category and will not address it here.
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E. Indicator 2.6 Competitor Repair
Appointments Met and Indicator 2.2 Repair Appointments
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19. TCI noted that it does not have
methods in place to separate data for Indicator 2.6 Competitor Repair Appointments Met and Indicator 2.2 Repair Appointments, and submitted that the
standard should be the same for both, and that a company-specific indicator should be
established for this indicator by subsuming it within Indicator 2.2.
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20. The Commission notes that the
same problem is being experienced by some of the other telephone companies. The Commission
also notes that both Indicators 2.6 and 2.2 already have the same standards. At this time,
the Commission considers that the telephone companies may report the combined data in
Indicator 2.2 and show N/A (not available) in the reporting of Indicator 2.6. However, the
telephone companies are to report progress on their efforts to separate data for Indicator
2.6 from Indicator 2.2 as part of the fourth quarter quality of service quarterly report
filed with the Commission.
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F. Indicator 3.1 Dial Tone Delay
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21. With regard to Indicator 3.1 Dial Tone Delay, TCI submitted
that this indicator should be reported on an exception-only, complaint basis given that
all companies have consistently met the standard.
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22. In Decision 97-16, the Commission stated that while the telephone
companies have consistently reported scores well above the standard, the Commission is
concerned that widespread use of Internet services may cause congestion in the future. On
this basis, the Commission remains of the view that this indicator should continue to be
monitored. Therefore, the Commission denies TCI's proposal to discontinue the reporting of
Indicator 3.1.
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G. Indicator 4.1 Directory Accuracy
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23. With respect to Indicator 4.1 Directory Accuracy, Northwestel
stated that competitive directories exist in its two major markets Yellowknife and Whitehorse.
Given the high directory accuracy maintained by Northwestel and the competitive nature of
directory advertising, the company proposed that Indicator 4.1 is no longer required.
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24. GNWT opposed Northwestel's
request to eliminate Indicator 4.1 stating that the company's rationale is only applicable
in two of over 90 communities served by Northwestel.
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25. The Commission concurs with GNWT
and denies Northwestel's request to discontinue reporting the quality of service
performance of this indicator.
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26. TCI provided a variation on the
reporting procedure for Indicator 4.1. TCI noted that it was unable to provide the
required information due to problems in implementing a process to gather the data. TCI
also stated that implementing the required procedure would be extremely expensive,
labour-intensive and arduous and would yield only questionable results. On this basis, TCI
proposed to gather the information by way of random samples of customers, and that a
company-specific indicator which would require the reporting of the survey results on a
quarterly basis with the standard being 90% should be implemented.
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27. In Decision 97-16, the Commission was of the view that subjective
indicators are not appropriate and directed the telephone companies to employ indicators
based on objective criteria. The Commission also notes that only TCI is unable to report
on this indicator and accepting TCI's proposed reporting procedure would not allow the
Commission to compare TCI's quality of service performance for this indicator against the
other telephone companies. The Commission directs TCI to report within 60 days of
this decision, on the feasibility, cost and earliest implementation date of adapting the
TCBC procedure for its reporting of Indicator 4.1.
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H. Additional Indicator On hold time or total
call duration
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28. The Commission is of the view
that Indicator 1.5 Access
to Business Office alone may not accurately depict the interaction between the customer
and the telephone company business office. For example, the customer's call may be
answered within 20 seconds but the customer could be put on hold for a long time. The
Commission is of the preliminary view that an additional indicator should be established
for measuring either the total length of time customers are placed on hold or the duration
of the call when they call a telephone company business office. The Commission directs the
telephone companies to file proposals, within 45 days of this decision, for a standard for
a new indicator to measure either on hold time or duration of call.
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I. Indicator 5.1 Customer Complaints, Additional
Reporting Requirements
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29. With respect to Indicator 5.1 Customer Complaints, MTS
requested that verbal complaints no longer be included in this measure. In MTS's view,
eliminating the verbal component of this indicator would ensure that complaints are of a
serious nature and would eliminate or reduce the likelihood of a single complainant being
counted more than once.
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30. The Public Interest Advocacy
Centre (PIAC) opposed MTS's submission for a number of reasons including that for many
customers, there is an expectation that verbal complaints will be treated in the same
manner as written complaints, and the fact that many people do not have the time or energy
to submit written complaints. PIAC noted that MTS's position was not supported by any of
the other telephone companies.
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31. Northwestel submitted that only
complaints referred by the Commission should be counted because there may be different
interpretations as to what constitutes a complaint.
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32. Northwestel's position was
opposed by GNWT on the basis that a further definition of what constitutes a complaint
could resolve the problem. GNWT noted that failure to achieve perfect uniformity on how
different companies report indicator results should not prevent the use of an indicator.
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33. The Commission notes that the
recording of both verbal and written complaints addressed to the Commission and the
companies has been ongoing since Quality of Service Indicators for Use in Telephone
Company Regulation, Telecom Decision CRTC
82-13, 9 November 1982. The Commission
further notes that complaints per 1000 NAS was adopted by all the telephone companies to
facilitate comparison between them. The Commission continues to believe that this
measurement is a useful tool for monitoring quality of service. The Commission concludes
that in the interest of uniformity in reporting complaints and to continue to facilitate
comparison between telephone companies, the process of recording of both verbal and
written complaints to the Commission and to the company will remain unchanged.
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34. However, the Commission is also
concerned that the number of complaints reported under Indicator 5.1 by itself does not
give as full a picture as possible of the quality of service being provided. The
Commission is of the preliminary view that, in addition to the above, the telephone
companies should also report the percentage of complaints not resolved within
10 working days with a standard of 90% being acceptable. The Commission directs the
telephone companies to file comments, within 45 days of this decision, on the above-noted
reporting requirement and standard.
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J. Directory Assistance
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35. In Decision 97-16, the Commission noted 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 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. The Commission concluded that the interface dealing with
operator services no longer needed to be monitored. However, the Commission stated that it
would track the number of complaints under the Interface: Complaints, where Operator
Services is reported as a separate category.
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36. The Commission notes that
Directory Assistance is now a tariffed item and customers are required to pay for the use
of this service. The Commission is of the preliminary view that an additional indicator
should be established to measure the speed and accuracy of directory assistance. The
telephone companies are to file within 45 days of this decision proposals for the
definition, methods of measurement and the standard for an indicator for directory
assistance.
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Other related issues
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A. Impact of the final standards on standards developed
by the CRTC Interconnection Steering Committee
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37. Call-Net Enterprises Inc.
(Call-Net) stated that various members of the Ordering and Billing Sub-Working Group of
CISC have worked diligently to reach an agreement on the interval for loop migration
between an incumbent local exchange carrier (ILEC) and a competitive local exchange
carrier (CLEC). Furthermore, work continues on the intervals for other carrier requests
such as loop provisioning and repair. Call-Net requested that the Commission ensure that
the approved quality of service indicators do not impact the ratified intervals developed
in CISC and that the indicators are not used by the ILECs as a baseline when deliberating
service intervals with other parties participating in CISC.
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38. The Commission notes that all
parties who addressed this issue are in agreement. The Commission notes that the quality
of service indicator standards approved in this proceeding should not impact the ratified
intervals developed in Commission-approved committees such as the CISC.
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B. Request for additional indicators for customers who
are also competitors
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39. AT&T Canada Long Distance
Services Company, now AT&T Canada Corp. (AT&T Canada), maintained that the public
interest would be best served by the expansion of the current indicators to include
specific measures of the quality of service to customers who are also competitors.
AT&T Canada requested, among other things, separate indicators and standards for a
number of items including:
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(1) unbundled network elements, in particular, unbundled loops by types;
(2) Local Number Portability porting;
(3) co-location; and
(4) interconnecting circuits with trunk side access.
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40. TCBC, Bell and TCI submitted that
AT&T Canada's request is beyond the scope of the procedure set out in Decision 97-16, and AT&T Canada is attempting to re-argue many
of the issues which have already been dealt with in that decision.
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41. The Commission agrees with TCBC,
Bell and TCI that the request by AT&T Canada for other quality of service indicators
has been dealt with in paragraph 79 of Decision 97-16.
It states that "because interconnection service agreements are approved by the
Commission and the terms and conditions under which interconnection services are offered
subject to supervision by the Commission (including its Competitive Dispute Resolution
process), the Commission considers that the monitoring of the (specific competitor's)
indicators is not necessary."
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42. The Commission also notes
Call-Net's request that the Commission ensure that the finalized standards do not affect
the agreed to intervals developed in the CISC working group. Therefore, the Commission
denies AT&T Canada's request for additional quality of service indicators. However, in
order to confirm that the actual quality of service performance vis-a-vis competitors is
in compliance with the standards negotiated in CISC and approved by the Commission, the
Commission directs the telephone companies to file within 90 days of this decision for
inclusion in the quarterly quality of service report a methodology for reporting
compliance with any intervals and standards negotiated in CISC and approved by the
Commission. The proposal should include the actual quality of service performance,
including definitions, methods of measurements and standards concerning the relevant
indicators negotiated under the sanction of the Commission.
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C. Need for community-level indicators
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43. GNWT expressed its concern that
reporting of quality of service data only on a company-wide basis can mask severe problems
that may be faced with respect to service quality in particular communities. GNWT further
stated that while establishing separate reporting of quality of service results for rural
and urban areas addresses this problem to some extent for companies serving rural and
urban areas, it does not address the situation at all for companies such as Northwestel
which are classified as serving wholly rural areas. GNWT requested that Northwestel, in
addition to providing aggregate service quality results, be required to continue to report
its service quality results on an individual community basis as done in the past.
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44. Northwestel stated that tracking
quality of service along community lines has, due to the large number of communities
involved, proven to be an increasingly burdensome task from an administrative perspective
and that community level quality of service reporting has been discontinued in other parts
of Canada. The company suggested that community-level quality of service issues be
addressed through complaints sent to the CRTC by customers.
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45. The Commission is of the view that
it would be appropriate for Northwestel to report quality of service indicators at the
community level. Northwestel is directed to file within 60 days of this decision a
proposal for community level reporting for quality of service.
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D. Need for continued standards monitoring
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46. TCI argued that because the local
market is now open to competition, the reporting of local service results should be
discontinued. None of the other telephone companies proposed this approach.
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47. PIAC noted that the Commission
has stated 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 has noted that the effects of
local competition, if any, on quality of service are not yet known. PIAC also stated that
there has been no material change in circumstances since Decision 97-16 to justify reversal of this determination by the
Commission. In PIAC's submission, the Commission would be in breach of its duties under
the Telecommunications Act if it were to discontinue monitoring quality of service
in telecommunications at this point.
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48. The Commission concurs with PIAC
that it is premature to allow TCI or the other companies to discontinue reporting local
service results at this time. Therefore, the Commission denies TCI's request to
discontinue the reporting of its local service results at this time.
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E. Proposals re: Quality of service reporting made in
high-cost serving areas
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49. PIAC stated that a number of
parties in the proceeding dealing with service to high-cost serving areas have emphasized
the ongoing need for regulatory measures designed to ensure an acceptable level of quality
of service in rural and remote communities and that this should be considered in this
proceeding as well.
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50. The Commission notes that
Decision 97-16 only covers the telephone companies
previously identified, whereas the high-cost decision covers all telecommunications
service providers serving in high-cost serving areas. The Commission also notes that in
the re-banding proceeding (announced in Decision 99-16) the
Commission will consider the regulatory treatment of quality of service in high-cost
serving areas. Accordingly, the Commission will not deal with that issue in this decision.
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F. Acceptance of comments from non-registered parties
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51. A Chronology of Interested
Parties' Submissions appears in Appendix 2. The telephone companies noted in their
reply comments, that more than half of the comments received were from organizations that
failed to register as interested parties in this proceeding. Although some of the
telephone companies addressed items they considered of substance, Bell requested that the
Commission serve notice that such an abuse of process will not be tolerated in the future.
The company further stated that continuing to accept comments filed out of process signals
to organizations that registration as an interested party is purely optional. The company
further submitted that in the future, any such comments should be denied status by the
Commission.
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52. The Commission considers that the
telephone companies are not prejudiced by the addition of these comments to the record of
this proceeding as they had the opportunity to address the comments in their reply
comments, and in fact did so. In these circumstances, the Commission is of the view that
the comments should be accepted. However, the Commission wants to remind these interested
parties that in future they should register in accordance with the Commission's
procedures, and that failure to do so could result in the exclusion of their comments from
the record of a proceeding.
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Process to include additional new indicators
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53. The telephone companies are
directed to file submissions with respect to new indicators for call completion for access
to the business office (paragraph 28), directory assistance (paragraph 36) and the
reporting of complaints outstanding after 10 working days (paragraph 34). All such
material is to be filed with the Commission by 6 March 2000, serving copies on
all other parties to this proceeding.
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54. Interested parties may file
comments on the telephone companies' submissions, serving copies on all parties, by 5
April 2000.
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55. The telephone companies may file
reply comments serving copies on all parties by 20 April 2000.
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56. 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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57. 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
e-mail address for electronically filed documents is procedure.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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Secretary General
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This decision is available in alternative format upon request, and
may also be viewed at the following Internet site: http://www.crtc.gc.ca
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