Customer Service NOI Unnecessary and Duplicative, Industry Groups Claim
Competition is a better guarantor of good customer service than FCC rules, multiple industry groups said as they pushed back against proposals floated in the FCC's customer service NOI. The NOI was adopted 3-2 in October along party lines (see 2410230036). In comments in docket 24-472, which were due Friday, some industry groups also argued that the agency lacks legal standing on customer service rules. "Careful consideration will confirm that the Commission lacks anything like the plenary authority" to adopt a single set of customer service rules, CTIA said. Disability advocacy organizations, meanwhile, made suggestions for customer service requirements.
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Customer service rules "would be both unnecessary and inappropriate," ACA Connects said, noting cable operators and broadband providers "incur tremendous costs" to build their networks and are motivated to give subscribers a good experience. Those incentives are enough to ensure providers continuously improve their customer service standards, ACA said. It warned against "one-size-fits-all rule," saying the best practice for a giant broadband provider "may not be the best practice for a provider with two hundred customers, and there may be multiple possible solutions to any given customer service issue." Similarly, arguing that such rules are unnecessary, NCTA said extending customer service rules to cable-provided broadband and voice services is outside FCC authority.
Not resolving a problem risks losing a customer not only for that service but also for all bundled services offered to that customer, as well as any prospective customer who reads a negative online review, USTelecom said. "Broadband providers know that their success is dependent upon providing and maintaining excellent customer service."
Along with in-store and voice call support to subscribers, wireless providers also commonly offer chat and other online and app-based tools, CTIA said. Customer support for people with disabilities includes dedicated accessibility customer service call operators and specialized training for customer service representatives, it said. Moreover, wireless providers are considering AI options for enhancing those offerings. CTIA said customer service rules would be duplicative of the FCC's truth in billing, accessibility and porting requirements; its broadband labeling regulations; and the FTC's negative option billing rule.
NTCA said if any agency should address such customer service issues, the FTC is the more logical home. The FCC has "uncertain at best" jurisdiction when it comes to broadband services, while the FTC Act, which prohibits unfair or deceptive business practices, including a common carrier exemption, is a better vehicle. NTCA said the FCC should pause consideration of customer service requirements pending the outcome of litigation over the FCC's Title II net neutrality rules.
The interconnected VoIP marketplace is rife with competition, but if the FCC goes forward with a rulemaking, then it should carve out an exemption for enterprise customers of voice service providers whose contracts specifically address customer service standards, said Voice on the Net Coalition.
Noting the necessity of people with visual disabilities having access to a live telephone operator, the American Foundation for the Blind said the FCC must maintain and maybe even strengthen customer service requirements of a live operator being available during and after business hours. AI and other means of chatbots don't make live human operators unnecessary, it said.
Disability groups urged that the commission mandate provision of direct video calling for American Sign Language users, along with other accessible communication options such as live chat and text-based support, in their customer call centers. Signers of the filing included Communication Service for the Deaf, National Association of the Deaf, American Association of the Deaf/Blind, Gallaudet University Alumni Association and the National Association of State Agencies for the Deaf and Hard of Hearing.
The International Brotherhood of Electrical Workers said decades of telecommunications deregulation at the federal, state and local level have left customers without customer service protection. Meanwhile, customer service employment has plummeted, it added. IBEW urged such rules as installation of a customer's order within three days of submission, service outages being dealt with within 24 hours of a customer reporting them, and appointment windows not wider than four hours.
Automated customer service software company MosaicX said the FCC should avoid requirements that would preclude use or development of AI-based customer service tools.