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					CANADIAN RADIO-TELEVISION AND TELECOMMUNICATIONS COMMISSION

TELECOM DECISION CRTC 2000-24

FINAL STANDARDS FOR QUALITY OF SERVICE INDICATORS FOR USE IN TELEPHONE COMPANY REGULATION AND OTHER RELATED MATTERS

REPLY COMMENTS OF TELUS Communications (BC) Inc. and TELUS Communications Inc.

APRIL 20, 2000

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TABLE OF CONTENTS INTRODUCTION ........................................................................................................................................ 3 GENERAL COMMENTS ........................................................................................................................... 3 BUSINESS OFFICE HOLD TIME AND/OR CALL DURATION ......................................................... 6 CUSTOMER COMPLAINTS ..................................................................................................................... 6 DIRECTORY ASSISTANCE – ACCESS AND ACCURACY ................................................................ 7 CONCLUSION ............................................................................................................................................10

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Introduction
1. In accordance with the procedures set out in Decision CRTC 2000-24, Final Standards for Quality of Service Indicators for Use in Telephone Company Regulation and Other Related Matters (“Decision 2000-24”), TELUS Communications (BC) Inc. and TELUS Communications Inc. (collectively, the "Companies") submit the following reply to comments submitted by the Public Interest Advocacy Centre (“PIAC”), on behalf of Action Reseau Consommateur, the Consumers’ Association of Canada, and the National Anti-Poverty Organization (“ARC/CAC/NAPO”), and by the British Columbia Public Advocacy Centre (“BCPIAC”) on behalf of the BC Old Age Pensioners’ Organization, Consumers’ Association of Canada (BC Branch), Council of Senior Citizens’ Organizations of BC, federated anti-poverty groups of BC, Senior Citizens’ Association of BC, West End Seniors’ Network, End Legislated Poverty, BC Coalition for Information Access and the Tenants Rights Action Coalition. 2. Failure by the Companies to address any comments or position taken with respect to any matter raised in any submission by parties to this proceeding should not be construed as agreement with that position, to the extent that it is inconsistent with the interests of the Companies.

General Comments
3. As BCPIAC’s comments were limited to adopting the whole of

ARC/CAC/NAPO’s comments, these reply comments will refer only to ARC/CAC/NAPO’s comments. 4. As a preliminary matter, the Companies observe that the general approach and perspective of ARC/CAC/NAPO seems to be that every time there is a measurement or administrative problem with a proposed Quality of Service indicator, ARC/CAC/NAPO proposes an alternative indicator which is equally

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unworkable. The underlying presumption in ARC/CAC/NAPO’s comments to this proceeding is that TELUS is prepared to willingly sacrifice service quality and customer satisfaction and, more specifically, discriminate against lower income customers in the delivery of service. This presumption is completely baseless. 5. In the Companies’ comments to this proceeding, TELUS argued that competition (including potential competition) is serving to achieve the Commission’s quality objectives better than any indicator that might be devised to monitor the Companies’ performance. 6. In prefacing its comments, ARC/CAC/NAPO states that: In an environment in which all but a select few local residential customers have any alternative to their incumbent local carrier for local service, and thus for the services in question here, TELUS’s assertion that competition is sufficient to ensure the delivery of adequate service quality is astonishing.1 7. ARC/CAC/NAPO is presupposing, without providing any evidence to that effect, that the incumbent local exchange carriers (“ILECs”) still enjoy a monopoly in the provision of local services even though that monopoly is disappearing. A review of the Commission’s website2 reveals that there are currently twelve competitive local exchange carriers (“CLECs”) and twenty-six proposed CLECs. The territories of the CLECs and proposed CLECs are far-reaching, extending from Halifax to Vancouver. In addition, the Commission’s website lists sixteen wireless service providers. Accordingly, TELUS submits that the market for local services is indeed open to competition and if the Companies fail to maintain the satisfaction of customers, new entrants will be better able to attract them away from TELUS. 8. ARC/CAC/NAPO states that:

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ARC/CAC/NAPO Comments, April 4, 2000, paragraph 3. See http://www.crtc.gc.ca/ENG/public/8180-8.htm

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The fact that customers now have alternatives for other services is proving to be of little solace to those who have experienced poor quality of service from their incumbent and who are eager for an alternative to local service. The fact is that residential customers are still largely captive to their incumbent local carriers. At the same time, competition in other service areas draws company resources away from non-competitive services.3 9. This comment misses the point completely. The Companies’ local service

customers, even in areas which may not yet present alternatives to TELUS, must be satisfied with the TELUS services they purchase or TELUS will lose them as customers for other services for which they do have a choice, including alternative long distance services, cellular services and internet access, to name a few. Customers can and do switch service providers for such services. Even if, as ARC/CAC/NAPO erroneously assumes, local services are non-competitive, the Companies are still compelled to provide high quality local services to every customer. The presumption that certain customers will be discriminated against is without foundation. With respect to the services that are the subject of this proceeding (business office access and directory assistance), even if the Companies were so unethical as to choose to discriminate against certain customer groups, there would be no means by which to identify a business office caller or a directory customer as one of those to which the alleged discrimination might apply. With respect to the argument that competitive services draw

resources away from non-competitive services, again there is no foundation for this assertion. With respect to business office access and directory assistance, TELUS has no way of knowing whether a caller to either of these services is, or potentially might be, a purchaser of a full array of TELUS services beyond local access. In a competitive environment the Companies have no choice but to allocate sufficient resources to every service and to treat all customers equally and impartially. 10. The Companies are long-term players in the telecommunications industry, committed to providing a full suite of telecommunications services to their
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ARC/CAC/NAPO Comments, April 4, 2000, paragraph 3.

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customers. All services are equally important and the statement that “competition in other service areas draws company resources away from non-competitive services” is neither intuitively nor factually supportable. To permit the quality of local service to erode in any service or for any customer makes absolutely no sense from a strategic or business perspective.

Business Office Hold Time and/or Call Duration
11. ARC/CAC/NAPO submits that “The existing indicator for Business Office Access, Indicator 1.5, only measures the time taken to answer a call; it can be easily circumvented by answering, then putting the customer on hold for an extended period of time”4 and that therefore “a new indicator should be established to measure hold time before the customer is connected to the appropriate service representative”5. 12. However the Companies have demonstrated that the proposed new indicator is naively unreasonable and administratively unworkable. 13. Furthermore, ARC/CAC/NAPO’s concern about Indicator 1.5 being easily circumvented is unfounded. Arguably, a customer service representative, by answering the call immediately but indicating that the customer will be called back, could circumvent any indicator. However, it makes no sense from a

business or operational perspective to conduct business in a manner that irritates and alienates customers. TELUS submits that the existing indicator for Business Office Access, Indicator 1.5 is sufficient to provide the Commission with a measure of service quality in business office access.

Customer Complaints
14. ARC/CAC/NAPO, in rejecting the Companies’ and other parties’ proposal that section 56(3) of the CRTC Rules of Procedure (the “Rules”) already provides the
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Ibid., paragraph 5. Ibid., paragraph 7.

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customer with the opportunity to forward any complaint to the Commission and have it addressed on a timely basis, states that: …consumers usually make complaints directly to the company, and only if they are not satisfied with the company’s response, do they take their complaint to the Commission. Not only is this the most efficient and logical approach for consumers to take, but it reflects the fact that the local telephone company is far better known the consumers than is the CRTC. Even those complainants who are aware of the CRTC may have difficulty finding an address to which to send their complaint.6 15. The Companies submit that, at best, the foregoing statement misrepresents an unsubstantiated claim as being a “fact” and at worst, it underestimates the sophistication of customers. Information regarding the Commission is in the front of every TELUS telephone book along with precise instructions on how to lodge a complaint. The Companies also acknowledge that the Commission has recently enhanced its website and initiated a series of cross-Canada informal round table consultations with the public, directed towards increasing public participation and heightening public awareness and understanding of the Commission’s role and mandate. The Companies submit that these efforts will result in the Commission becoming increasingly more accessible to the general public. 16. Therefore, the Companies reiterate that the Rules already provide every customer with the opportunity to forward any complaint to the Commission and no further quality of service indicator is required.

Directory Assistance – Access and Accuracy
17. ARC/CAC/NAPO acknowledges that “neither of the two measures proposed (speed of answer and accuracy of listing provided) addresses this problem”7, the problem being that “there is little incentive for companies to take the time and trouble to correctly understand the customer’s request and to find the number

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Ibid., paragraph 11. Ibid., paragraph 17.

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requested”8 because the Commission permits companies to charge for directory assistance calls that are unsuccessful. Accordingly, ARC/CAC/NAPO proposes “a new standard measuring unsuccessful requests be applied to those companies who charge for such requests.”9 18. ARC/CAC/NAPO then goes on to state that: In its submission, TELUS argues that the telephone companies should only be accountable for directory assistance inaccuracy that (is) caused by the errors of the telephone companies’ service representatives and databases, but not for the potential inaccuracy of other telephone companies’ databases or the potential inaccuracy of the customer’s request. In response, ARC/CAC/NAPO submit: a. that these concerns are adequately addressed through (a) standard which permits less-than-100% accuracy; that if technically possible and desirable in the circumstances, the measures could be designed so as to attribute results in respect of long distance DA to the appropriate company database; that companies who choose to rely on third parties for their directory databases nevertheless bear responsibility for the service that they deliver to their clients; and that it is unclear haw customer error would enter into a measure of accuracy, since customer error would presumably result in failure to provide the requested information rather than inaccuracy.10

b.

c.

d.

19.

TELUS submits that from an administrative perspective, the ambiguity in the meaning of the term “unsuccessful requests” in the proposed standard would make it extremely difficult for the Companies and the ILECs to effectively and consistently implement such a standard. The standard cannot be adequately

defined and cannot be effectively implemented.
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Ibid., paragraph 16. Ibid paragraph 17. 10 Ibid., paragraph 19.

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20.

Moreover, the Companies reiterate that the telephone companies should only be accountable for directory assistance inaccuracy caused by the errors of the telephone companies’ customer service representatives and databases. The

statement by ARC/CAC/NAPO, that this concern is addressed through a standard that permits less-than-100% accuracy, makes absolutely no sense. How much less than 100% is the right measure to allow for inaccuracies over which the Companies have no control. Similarly, ARC/CAC/NAPO’s statement that if “technically possible and desirable in the circumstances” measures could be designed to attribute results, begs the question of what is meant by “technically possible and desirable in the circumstances” and, indeed, if any such measures are currently capable of being designed. ARC/CAC/NAPO is engaging in wishful speculation here. 21. ARC/CAC/NAPO’s next suggestion, absent any underlying rationale, that the companies should bear responsibility for a service over which they have no control, defies all reason. The suggestion is that the Companies are somehow contracting-out the provision of directory services outside their operating territories and that TELUS should take responsibility for its contractors. This is simply not the case. The Company has no control over the accuracy of an unaffiliated carrier’s directory. The Companies simply relay the information provided to them by another carrier. Finally, an explanation of how customer error would enter into a measure of accuracy is found in paragraph 26 of the Companies March 6, 2000 Submission, where the Companies stated: For example, if a customer requests information regarding a telephone number for Bill Smith, who resides outside of TELUS’ territory, TELUS will access a third party’s database to obtain that information. To the extent that the third party’s database is inaccurate, TELUS would be unfairly penalized by the Commission’s proposed indicator for a performance element that is not within its direct control. If the customer service representative provided a telephone number for a Bill Smith, as requested by the customer, but the person whom the customer is seeking is actually listed as William smith, the accuracy of the customer service representative cannot be called into question because the information provided by the customer is not accurate. Again, a

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measure cannot be designed that will adjust for inaccuracies in customer requests.11 22. The Companies reiterate that an additional indicator to measure the speed and accuracy of directory assistance should not be established.

Conclusion
23. The Companies submit that, based on the record of this proceeding, new quality of service indicators for call completion for access to the business office, directory assistance and the reporting of complaints outstanding after ten working days should not be established. should be dismissed. ALL OF WHICH IS RESPECTFULLY SUBMITTED, April 20, 2000. Accordingly, ARC/CAC/NAPO’s comments

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The Companies’ Comments, March 6, 2000, paragraph 26.

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