Tuesday, April 17, 2007
Adding clarity to quality: CQoS

Of course, you are asking yourself, "Why would the CRTC consider exceptions? Either they beat the numbers or they don't." Well, long before CQoS was considered as a forbearance criterion, the 14 indicators were used to determine if rebates should be paid to competitors when the ILECs provide inadequate service levels. As part of the rebate plan, in Decision 2005-20, the CRTC created a mechanism for considering exclusions from CQoS results where an ILEC might have failed to meet a performance standard due to circumstances beyond its control.
So, the CRTC is now calling for comments on whether that 'get out of jail free card' for rebates should apply for the local forbearance test as well.
The clock is ticking quickly on this file; comments are due on April 27 and replies are due just one week later. It has to be an expedited process. After all, the first applications for forbearance have to be answered in 120 days from last week's applications.
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As I remarked to you privately last week, all the press stories about the Telus and Bell forebearance applications make it seem that applying for it and getting it approved is a simple process with a foregone conclusion. In fact, one or two of them suggested that competition in the local service market will be in effect in Toronto by this summer. There was hardly any mention, if any, about the 9 CQoS standards that the incumbents have to meet and that supposedly, I thought, until that's achieved there's no forebearance.
At the time, I wondered if the incumbents are currently meeting the CQoS standards? Now, I read in today's entry that exceptions have been made and are going on and that refunds for non-compliance are the order of the day.
This confirms everything what was said to the INDU Committee during their hearings into telecom deregulation by the cablecos and other providers of local telephone service. So if the ILECs are not meeting the standards now, what likelihood is there that they'll be met in the future, especially if the CRTC ends up continuing to operate under their current practice of exceptions.
As you noted, either you have standards or you don't. If you're going to allow exceptions on an ongoing basis, then why have them at all?
I presume that it might be too expensive and time-consuming for the ILECs to get to the standards and continue to stay at that level of performance if they're continually meeting them now. One has to ask if they're just taking the easy route and looking at the refunds as a cost of doing business. If the refunds aren't that onerous and have less impact on on the bottom line than the capital and operating costs involved in getting to the standarts and staying there in a regulated market, what likelihood is there that the ILECs will ever move off of that behaviour in a deregulated market when they can adjust prices whenever they want?
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At the time, I wondered if the incumbents are currently meeting the CQoS standards? Now, I read in today's entry that exceptions have been made and are going on and that refunds for non-compliance are the order of the day.
This confirms everything what was said to the INDU Committee during their hearings into telecom deregulation by the cablecos and other providers of local telephone service. So if the ILECs are not meeting the standards now, what likelihood is there that they'll be met in the future, especially if the CRTC ends up continuing to operate under their current practice of exceptions.
As you noted, either you have standards or you don't. If you're going to allow exceptions on an ongoing basis, then why have them at all?
I presume that it might be too expensive and time-consuming for the ILECs to get to the standards and continue to stay at that level of performance if they're continually meeting them now. One has to ask if they're just taking the easy route and looking at the refunds as a cost of doing business. If the refunds aren't that onerous and have less impact on on the bottom line than the capital and operating costs involved in getting to the standarts and staying there in a regulated market, what likelihood is there that the ILECs will ever move off of that behaviour in a deregulated market when they can adjust prices whenever they want?
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