PULP does not believe these changes are necessary, but does support extending the service standards to wireless and the voice services offered by the cable companies.
The New York State Public Service Commission (“PSC”) heeded Verizon’s request and released a notice inviting comments on Verizon’s proposals on February 24th. Specifically, Verizon asked that the following changes be made to the PSC’s Uniform Measurement Guidelines:
No Access: Under the current Guidelines, when Verizon cannot gain access to a customer’s premises to clear an out-of-service or service-affecting condition, the 24 or 48 hour clock runs until the trouble condition is cleared. As a result, “No Access” situations cleared after 24 or 48 hours would count as a trouble not cleared and, therefore, would count against the company in its measurements. Verizon requested that the Guidelines be changed so that if it appears at the customer’s premises within the 24 or 48 hour window and is unable to enter the premises or obtain access, such situations would not be included in the calculations since it would not reflect any failure by Verizon to take timely action. Verizon added that in these situations it calls the customer back to try to schedule a new appointment and this second appointment could be treated as a separate, reportable incident for metrics reporting purposes.PSC Staff tentatively supported Verizon’s request to exclude customer “requests” beyond the 24 hour or 48 hour window from the calculation of both the out-of-service and service affecting metrics, citing to “[t]he increasingly prevalent use of cell phones as an alternative means of communications . . . not contemplated when the Uniform Measurement Guidelines were adopted in 2000 . . . [which] may lessen the need for a repair within the mandated window.” It reasoned that Verizon should not be penalized if it is “merely complying with a customer’s request.” PSC Staff does not support the exclusion of instances when a customer “accepts” a company-offered repair appointment outside the mandated 24 or 48 windows. “In such cases,” Staff reasoned, “it would appear to be difficult to judge whether or not a customer’s ‘acceptance’ is full-hearted or if it is a mere acquiescence due to a perceived lack of alternatives.”
Request or Accept: Verizon argued that it does not make sense to apply a 24 or 48 hour clock to a customer-requested appointment that falls beyond the 24 hour or 48 hour window. Instead, where Verizon offers the customer an appointment that would enable it to make the repair within the 24 or 48 hour window and the customer requests or accepts an alternative appointment outside the 24 or 48 hour window, it should not count against the company. Verizon proposed that one of two alternatives should be adopted: (1) the metric would not apply at all to the appointment; or (2) the 24 or 48 hour “clock” could be deemed to begin running at 8 AM on the day of the scheduled appointment.
PSC Staff also does not support altering the Guidelines to exclude “no access” situations, stating: “The reason the OOS>24 and SA>48 metric thresholds were originally set at 20%, rather than 0%, is to recognize that there are circumstances such as no-access to customer premises, that will cause not every repair to be cleared within the mandated windows. The company has not offered any to reason treat no-access situations differently than they have always been treated. To the extent that “no-access” has already been factored into the 20% thresholds, excluding them now without adjusting the thresholds would skew the results in a manner that would make it easier for a company to achieve the threshold without any actual improvement to the company’s performance.”
Accordingly, while all of Verizon’s proposals are on the table, Commission Staff is only lending its support to the situation where the customer requests an appointment outside the 24 or 48 hour window, presumably due to the availability of wireless phones. This position ignores the fact that accessing emergency services through 911 does not work the same for wireless phones as it does for Verizon, if it works at all. PULP understands Commission Staff’s concerns with the other points raised by Verizon and is, therefore, not inclined to support altering the Uniform Measurement Guidelines at this time, other than making them applicable to all telephone service providers (including wireless and the voice services offered by the cable companies). The current arrangement unfairly skews the marketplace because these standards only apply to half of the players.
Comments are due by March 23rd.