Brian T. Grogan Presentation to Washington Association of Telecommunications Officers and Advisors (WATOA) Spring Conference

1. 1
Customer Service Standards
Washington Association of Telecommunications Officers and Advisors
Spring Conference – Chelan, WA
May 1-2, 2014
Brian T. Grogan, Esq.
612-877-5340
brian.grogan@lawmoss.com

2. 2
Customer Service
Many jurisdictions have adopted the FCC’s
customer service obligations (47 C.F.R. § 76.309)
Two main issues:
1. Telephone Response Time
2. Installations and Service Calls

3. 3
Customer Service
1. Telephone Response Time
– 24/7 customer service
– Answer time within 30 secs (90%)
• Under “Normal Operating Conditions (NOC)”
– Busy signal less than 3%
– Call received by automated response unit (ARU)
• Or live human being
2. Installations and Service Calls
– Within 7 days of request
– 4 hour time block (during Normal Business Hours)
– Within 24 hours of interruption
– Begin corrections next business day

4. 4
Regional Call Centers
• Combining customer service operations to
serve 100,000+ subscribers
– Has resulted in loss of local presence/office
• Many call centers handle multiple services
– Cable Service
– High-speed data (cable modem)
– Local telephony

5. 5
Call Center Performance
• Some centers struggle handling voice, video
and data service calls
– Historical difficulty meeting 90% compliance
• Industry has history of blaming poor telephone
responsiveness on:
– Voice and data service calls
• Rollout of new services
• Time consuming calls

6. Service Level Performance
• TSL - Telephone Service Level TSL: HWSL / NCH
– Calls answered in 30 seconds
– NCO - Number of calls offered to the call center
– NCH - Number of calls handled by the call center
– HWSL - Number of calls handled within service
level by call center
– ASA - Average Speed of answer for all calls
• Should be less than 30 seconds
– % ATB - percentage all trunks busy > 3%
6

7. Month NCO NCH HWSL TSL ASA %ATB
2011-4 15795 15684 14769 94.2% 11.64 0%
2011-5 11867 11812 11332 95.9% 9.55 0.1%
2011-6 9203 9151 8659 94.6% 13.23 0.0%
Q2-QTD 36865 36647 34760 94.9% 11.30 0%
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8. 8
Normal Operating Conditions
• Defined by FCC
• Within the control of operator
– Upgrades
– Rate increases
– Peak demand
• Not within the control of operator
– Power outages
– Weather
– Telephone network outages
• Operators often argue that their call centers are not
under NOC

9. 9
Normal Operating Conditions
Example: Your system is served by regional call
center covering entire state
– Storm 100 miles away results in heavy call volume
– Subscribers in your City can’t get through on
telephone
– Is operator relieved of compliance because it was
not under NOC in part of their region?
Between line cuts, weather, telephone & power outages will
call center ever be under NOC?

10. 10
Normal Operating Conditions
• The larger the call center the bigger the problem
• How can cities verify compliance with customer
service standards?
– Will objective local data be available?
– If no local data will operator rely on regional data?
• Scrubbed data v. raw data
– Scrubbed data excludes time when operator is not
under NOC
– How is this calculated?
– Does your franchise permit access to data?

11. 11
City of Savage Case
• City of Savage v. Triax Midwest Associates, L.P.
– unpublished MN Court of Appeals decision 9/29/98
• City adopted FCC’s Customer Service Standards
(CSS)
– By providing Triax 90 days written notice
• City also had CSS in Franchise Agreement
• City requested info to verify compliance
• Triax failed / refused to provide info

12. 12
City of Savage Case
• City found Triax in violation of franchise for its
failure to:
– open customer service center during normal
business hours
– provide monthly compliant log
– answer phones within 30 seconds
– ensure busy signal less than 3% under normal
operating conditions
– provide 4 hour appointment window for installations
and service calls
– provide written information to subscribers

13. 13
City of Savage Case
• Triax challenged to MN Court of Appeals
• Court found City’s record
– Contained substantial evidence supporting non-
compliance
• Record consisting of numerous subscriber
complaints
– Found to be sufficient despite lack of telephone
records which Triax never produced
• After decision Triax settled with City

14. 14
City of Savage – Part II
• City found new operator in violation of franchise on
October 15, 2001
– Failure to provide quarterly telephone answering
reports “specific to the system serving the city.”
• In early 2002, City drew $26,250 from security fund
under franchise

15. 15
City of Savage – Part II
• Parties entered into Settlement Agreement in
October 2002.
• Operator agreed to the following:
1. Special 800 # for customer service inquiries
exclusively for Savage residents
2. Separate and dedicated trunk capacity to handle
traffic on 800 Savage line
3. Separate 4 person staff of CSRs assigned
exclusively to handle incoming calls from Savage
residents

16. 16
City of Savage – Part II
4. Designed customized software to track Savage only
call information
5. Deploy roll-over lines for 24/7 live CSR assistance
6. Savage specific report format (14 days from end of
quarter)
• Daily ACD report printouts
• Providing half hour by half hour call data
6. Financial settlement addressing City’s costs

17. Future??
• Are the FCC standards obsolete?
– Email inquiries
– iPad applications
– On-line bill handling
– Self install kits
• Local office
– Will there be local offices in the next few years?
• Without local regulation
– Will industry be governed by competition, or
– Will cities have single provider and limited service
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18. 18
Thank You
Brian T. Grogan, Esq.
Moss & Barnett, A Professional Association
4800 Wells Fargo Center, 90 South Seventh Street
Minneapolis, MN 55402-4129
(612) 877-5340 phone / (612) 877-5999 facsimile
E-mail: brian.grogan@lawmoss.com
Web site: www.lawmoss.com