adhere to the service quality standards in GO 133-D, and that the Commission adopt the penalty mechanism to ensure that the telephone corporations comply.” While the Commission did not adopt the specific penalty mechanisms and designs proposed by TURN, it did implement a penalty mechanism in GO 133 where none existed before. Moreover, some elements of TURN’s proposal are incorporated into the adopted mechanism that is designed to address a carrier’s failure “chronic status” and is calculated using the relative number of access lines the carrier has in California. For example, the fines cover Out of Service, Answer Time and Trouble Report rate. These are all elements of the proposal put forth by TURN’s expert Dr. Roycroft. OIR, p.10, 13 Verified. 4. Performance Metrics Throughout the proceeding, most of the TURN/NCLC/CforAT Opening largest carriers in the state argued that Comments on OIR, January 31, 2012, the Commission should impose p. 3-5 fewer service quality metrics or eliminate the TURN/NCLC/CforAT Joint Reply metrics all together. Indeed, in Comments on OIR, March 1, 2012, p. comments on the OIR early in the 3-9 proceeding AT&T argued it should not AT&T Opening Comments on OIR, be subject to any service quality January 31, 2012, p. 6-7, 14-15 regulations and Verizon proposed a massive weakening of the current SureWest Telephone Reply requirements in GO 133-C. The carriers Comments on OIR, March 1, 2012, p. argued that competition and technology 1-3 protects consumers without need for Verizon Reply Comments on OIR, regulatory intervention. For support of March 1, 2012, p. 17-26 their argument, they pointed to other states that purported to eliminate or AT&T Reply Comments on Sept weaken their own service quality 2014 Scoping Memo, p. 2-4. standards. The carriers urged the Joint Consumers Reply Comments on Commission to take a similar path. Sept 2014 Scoping Memo, November TURN, along with other consumer 13, 2014, Roycroft Declaration p. groups and intervenors not only 19-20 opposed the carriers’ attempts to Final Decision at p. 23 weaken G.O. 133 standards, but provided expert testimony and detailed
adhere to the service quality standards in GO 133-D, and that the Commission adopt the penalty mechanism to ensure that the telephone corporations comply.” While the Commission did not adopt the specific penalty mechanisms and designs proposed by TURN, it did implement a penalty mechanism in GO 133 where none existed before. Moreover, some elements of TURN’s proposal are incorporated into the adopted mechanism that is designed to address a carrier’s “chronic failure status” and is calculated using the relative number of access lines the carrier has in California. For example, the fines cover Out of Service, Answer Time and Trouble Report rate. These are all elements of the proposal put forth by TURN’s expert Dr. Roycroft. 4. Performance Metrics Throughout the proceeding, most of the largest carriers in the state argued that the Commission should impose fewer service quality metrics or eliminate the metrics all together. Indeed, in comments on the OIR early in the proceeding AT&T argued it should not be subject to any service quality regulations and Verizon proposed a massive weakening of the current requirements in GO 133-C. The carriers argued that competition and technology protects consumers without need for regulatory intervention. For support of their argument, they pointed to other states that purported to eliminate or weaken their own service quality standards. The carriers urged the Commission to take a similar path. TURN, along with other consumer groups and intervenors not only opposed the carriers’ attempts to weaken G.O. 133 standards, but provided expert testimony and detailed OIR, p.10, 13 TURN/NCLC/CforAT Opening Comments on OIR, January 31, 2012, p. 3-5 TURN/NCLC/CforAT Joint Reply Comments on OIR, March 1, 2012, p. 3-9 AT&T Opening Comments on OIR, January 31, 2012, p. 6-7, 14-15 SureWest Telephone Reply Comments on OIR, March 1, 2012, p. 1-3 Verizon Reply Comments on OIR, March 1, 2012, p. 17-26 AT&T Reply Comments on Sept 2014 Scoping Memo, p. 2-4. Joint Consumers Reply Comments on Sept 2014 Scoping Memo, November 13, 2014, Roycroft Declaration p. 19-20 Final Decision at p. 23 Verified.
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