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It is important to clearly define the instants marking opening and closure for the purposes of measuring fault repair times.

When to start counting the fault repair time

There is consensus, given the analysis of the various reference offers and the conclusions of PwC's audit, that fault repair time commences from the instant that the beneficiary reports the occurrence of a valid fault to PTC (i.e., when PTC receives the request).

D 1. The measurement of fault repair time commences from the instant that PTC receives notification that a valid fault has occurred.

In the RUO, PTC distinguishes situations where fault repairs are scheduled with the beneficiary (in particular in the case of joint interventions ¹) defining that, in this case, measurement of the time shall commence from the scheduled date/time (although stating that the time elapsing between "date/time that the fault is reported" and "date/time scheduled for repair" is nil).

Whereas, according to PTC, the time elapsing between "date/time that the fault is reported" and "date/time scheduled for repair" is measured as nil, and in order to simplify the rule establishing the instant from which measurement of the time taken to repair should commence, it is considered, as referenced above, that this instant shall correspond to the instant when the beneficiary reports the occurrence of a valid fault to PTC.

Instant that fault repair time is closed

According to Optimus, determination of this instant has greater impact in terms of the discrepancies between the times recorded by PTC and by Optimus.

This is because PTC considers that measurement of fault repair times concludes at the instant that the fault is resolved, regardless of whether or not the beneficiary is informed at the instant that the fault has been resolved.

In the RUO, the concepts associated with the measurement of repair times are not clearly aligned. In accordance with Section 5.1.1 of Annex 12 of this wholesale offer, loop repair time is defined as the "time, in working hours, elapsing between the instant that occurrence of a valid fault is reported and complete restoration of service" (emphasis added by ICP-ANACOM). Meanwhile, in section 7.2.4 of Annex II, it is set out that the duration of a fault "commences - from the instant that it is reported by the OLO" and "concludes - when the owner of the fault informs the owner of the problem that the fault has been resolved" (emphasis added by ICP-ANACOM).

The practice adopted by PTC means that the beneficiary cannot verify that the fault has in fact been resolved as at the moment which PTC reports it as being resolved, since, for example, PTC may give notice of resolution with a significant delay in relation to the date/time of actual resolution.

Measuring fault repair time as concluding at the instant that PTC informs the beneficiary that the fault has been resolved provides PTC with an incentive to inform the beneficiary promptly, ensuring that the beneficiary has opportunity to confirm proper repair more quickly and, simultaneously, ensures better protection of end-users. Moreover, this is an objective definition which is not subject to question - for example, if notification of the fault's repair is made on day x, at y hours, there can be no question from any party that this is indeed the actual time to be used to measure closure of fault, since it can be proved by both parties and it can be confirmed whether, in fact, the fault has been resolved. This is not the case if, for example, on day x+2, PTC informs the beneficiary that the fault has been repaired on day x at y hours (while not informing the beneficiary on day x at y hours, which therefore has no way of confirming that the service was indeed restored at that time).

In this respect, note should be made of the procedure adopted in the LLRO and the RUO on the restoration of the service.

For example, in the LLRO, it is stated that "upon conclusion of the [fault repair] process, PTC shall inform the OSP accordingly, requesting confirmation. The OSP has a period of 4 working hours for said purpose, after which period PTC shall consider the reported fault closed, unless the OSP reports that the problem persists." ²

In the RUO, a similar procedure was also agreed between PTC and one of the beneficiaries, applicable to all fault occurrences (except in the case of joint interventions) where:

(a) PTC notifies the beneficiary, immediately following repair of the fault, by telephone and through an IVR system.

(b) the beneficiary, after receiving this notification, is given a period of 10 minutes in which to report to the PTC technician, via IVR, that the loop remains faulty, describing the fault/problem on the loop.

(c) where, within the prescribed period, the beneficiary reports that the fault persists, the PTC technician will undertake examination/resolution and report resolution of the fault/problem on the loop to the beneficiary.

(d) unless the beneficiary reports otherwise, within a period of 10 minutes and in accordance with point b), the fault is considered as closed.

As seen above, the procedures adopted under the LLRO and RUO are similar, differing mainly as regards the period that the beneficiary is given to confirm that the fault has in fact been resolved.

It is considered that such a procedure contributes to:

(a) a reduction in the number of improperly closed faults;

(b) providing both parties with greater control over the date and time of fault closures.

Meanwhile, the period given to the beneficiary to confirm that the fault has in fact been resolved should act to promote efficiency in both parties. On the one hand, and for example with regard to the RUO, it is unreasonable that PTC's technicians are called on to remain at the intervention site for too long a period while waiting for the beneficiary to respond; on the other hand, the beneficiary must be given a reasonable amount of time to perform the required tests to confirm resolution of the fault.

In this case, the period of 10 minutes agreed between PTC and the beneficiaries of the RUO appears to have constituted a reasonable balance, with one of beneficiaries agreeing with this period.

In other offers, such as LLRO, longer periods are specified, possibly since the tests are more complex.

Therefore, the period given to beneficiary to confirm that the fault has been resolved will depend on the offer in question, whereas it falls first to PTC to establish a reasonable period for each offer, having consulted the beneficiaries.

If, within the time limit established for confirming resolution of the fault, the beneficiary:

(a) confirms that the fault has been resolved or does not report any information, the instant that the fault repair time is closed is the instant when PTC notified the beneficiary, immediately following repair of the fault, by phone and through the IVR system (whereas the period provided to the beneficiary to confirm the resolution may be included).

(b) reports that the fault persists, the fault remains open, whereas the time period elapsing between PTC's notification of the fault's resolution and the instant that the beneficiary reports to PTC that the fault persists should be considered for the purpose of calculating the fault repair times, provided that the beneficiary reports within the period prescribed for confirming resolution of the fault.

Following closure of the fault, according to PTC, its technician records the fault's resolution in the relevant information system, whereby this information is immediately available on the geographical CCO for confirmation. Upon confirmation, the information system automatically notifies the beneficiary by e-mail as to the fault's resolution. It is therefore made clear that the instant of closure is not the instant of notification by e-mail, but the moment that PTC notifies the beneficiary, immediately after repair of the fault, by phone and through the IVR system (and where the fault has indeed been closed).

Nevertheless, it is accepted that different procedures may be agreed upon in view of the specificity of the offers or the beneficiaries, which, for the sake of transparency, should also be included in the applicable offers.

As such:

D 2. The closure of the fault repair time corresponds to the instant that PTC informs the beneficiary (immediately following the fault's repair, by phone and through an IVR system) that the fault has been resolved (whereas the period of time made available to the beneficiary to confirm said resolution may be included), notwithstanding subsequent notification by e-mail and without prejudice to D 3. It is accepted that different procedures may be agreed upon in view of the specificity of the offers or the beneficiaries, which, for the sake of transparency, should be included in the applicable offers.

D 3. The beneficiary, after being informed by PTC, in accordance with D 2, shall have a determined period (depending on the reference offer in question and taking into account the practice already followed by PTC) to report to PTC, via IVR, that the fault persists, describing the fault/problem, whereby the fault shall remain open. Where, within the specified period, the beneficiary fails to report that the fault persists, the fault may be considered as closed from the instant of PTC's communication, as referred to in D 2.

D 4. The period of time that elapses between the instant of notification by PTC, as referred to in D 2, and the instant that the recipient informs PTC that the fault persists is to be considered for purposes of calculating the fault repair time, provided that the information communicated by the beneficiary is communicated within the maximum period as may be defined pursuant to D 3.

 
¹ Joint interventions are fault repairs scheduled at the request of the beneficiary with joint intervention by technicians from PTC and the beneficiary - Section 7.2.3.2 of Annex 12 of the RUO.
² See section 4.2 of Annex 6 of the LLRO.