Oheinen loppuraportti perustuu London Economicsin Energiamarkkinaviraston toimeksiannosta tekemään selvitykseen, jonka tavoitteena on ollut selvittää asiakaspalvelun laadun mittaamista ja sen huomioon ottamista sähkön jakeluverkkotoiminnan valvonnassa. Selvitystyön on tehnyt London Economics yhdessä professori Jarmo Partasen kanssa.
Selvitystyön perusteella asiakaspalvelun laatuun liityvät asiat voidaan jakaa seuraaviin ryhmiin:
- vastaaminen asiakkaden yhteydenottoihin (puhelin, kirje, henkilökohtainen, Internet)
- tietojen oikeellisuus (laskutus, mittaus, yhteystiedot)
- tiedotus (suunnittelemattomien vikojen aikana, suunnitelluista töistä, hinnoissa tai ehdoissa tapahtuvat muutokset)
- palvelutoimenpiteet (sovitut tapaamiset, vikojen korjaus, myyjänvaihto, liittymien toimitus)
- reklmaatioiden käsittely
Selvityksessä suositellaan, että asiakaspalvelun laatua tulisi valvoa ja valvontaan sisältyä kannustimia, joiden perusteella verkonhaltijaa joko palkitaan tai rangaistaan sen mukaan, onko yritys mittauksen perusteella saavuttanut tavoitetason. Raportti sisältää suosituksia eri osa-alueiden tavoitetasoiksi ja miten tavoitetasojen ylittäminen tai alittaminen tulisi otettaa huomioon verkonhaltijan taloudellisessa valvonnassa ja/tai tulisiko asiakkaille maksaa suora korvaus, mikäli asiakaspalvelu ei ole ollut tavoitetason mukaista.
Raportti (englanninkielinen) on kokonaisuudessaan oheisena liitteenä. Alla on raportin englanninkielinen tiivistelmä
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Regulation of quality of service is generally necessary in Finland. This is because the firms face true and potentially binding incentives to reduce costs and improve efficiency, and can keep profits from achieving measured efficiencies. There is the possibility of profiting from lowering quality of service levels. Competitive forces are evolving for some parts of the country and service. Some elements will remain natural monopoly (pure DNO) and some will become or are potentially competitive (supply). Regardless of the true state of competition, competition and the profit motive cannot be relied upon to provide socially optimal levels of service quality. This is for a number of reasons, but depends mostly on how demand changes when quality of service changes. This has been recognised internationally, and the international evidence points to a wide range of quality of service regulatory measures. Further, consumers and DNOs surveyed in Finland, indicate a high importance for a variety of service measures. These conclusions are robust for whatever type of quality of service is being considered.
Quality of service in electricity DNO and supply operations can be divided logically into three broad categories: quality of supply, technical quality, and customer quality. The focus of this report is on the third, but in general, some form of quality monitoring or regulation is needed for all three.
Quality of customer service regulation needs to be straightforward, easy to measure, track, and verify. There are numerous measures important to customers, but a sub-set of these that covers the major aspects of customer quality of service should suffice. Broadly speaking, they fall into some main categories:
- Customer contacts (Telephne, Agent, Machine, Letter/written, In person)
- Record keeping accuracy (Billing, Metering, Address, personal, other)
- Information (Information during unplanned outage, Information in advance of planned work, Information about changes in commercial operations)
- Physical service on the premises (Keeping appointments, Calling to fix problems within certain period, Switching within certain period, Connections within the regulated time period)
- Dispute resolution
In the very general sense, we recommend that customer quality of service be regulated and that the regulation include some form of incentives that result in rewards or penalties if measured targets are not met. Only in this way will quality of service have any rational meaning in terms of companies taking the regulation seriously. We note however, that the regulator should be careful not to implicitly attempt to maximise service quality in and of itself, as this is not likely to be optimal. The optimal regulation is the one that incentivises the companies to provide the level of service quality that equates the marginal costs with the marginal benefits.
A number of options are available to Finland in terms of regulation of customer quality of service. Difficulties however arise in Finland in terms of recommending very specific methods for regulation such as monetary values for each service category.
We propose that specific regulations be enacted for each of the broad service categories listed above. More detailed regulations and actions for the sub-categories can be enacted with more flexibility. These recommendations are as follows.
First, each company should be required to track data on the broad categories. The data should be measured in common units and be verifiable. It is suggested that the data not be audited annually, but perhaps spot-checked by the regulator. In general, the data should be kept to allow the regulator to determine the distribution of the data, e.g., the percentage of call-responses taking more than a certain amount of time (we propose more specific standards for each item later).
Each company should propose a company customer charter. The charter should be made public before being finalised to allow consumer groups to comment or have inputs into the process. The regulator should check that the companies’ proposals are of a minimum standard.
We propose a range of possible standards and penalties for the elements that will be monitored by both the regulator and consumers below. We propose that the period for monitoring should be annual. This will preclude the possibility of once-off events influencing the results significantly. While we propose these ranges, we wish to note that these ranges are indicative judgements from our experience and from the international research. Consultation with the industry and consumer representatives would likely be necessary before formal binding standards and penalties would be required. We also note that in general, the principles of the economics of penalties and incentives suggest that the penalty should be proportional to the costs and benefits of the transgression/improvement in service quality. This may need to be weighed or rebalanced by the cost of compliance and the probability of being caught, among other things.
It is proposed and suggested that the timing and implementation of the above would take between 1 and 2 years. A first step is to allow stakeholders to comment on the proposals. A second step is to collect and estimate the relevant data and indicators. It is further suggested that a one-year “trial” period be run where the estimated impacts on revenues be calculated by the companies. This will give the companies a chance to secure systems, ascertain methods of improvements, and perhaps appeal if penalties appear too harsh. We believe, however, that as the proposed penalties are limited, there is limited risk in the proposed regime in general for companies.
The report makes proposals for an indicative way forward for quality of service regulation of customer commercial quality elements in Finland. The section proposes elements that companies should collect data on and that the regulator should track. Total revenues allowed are proposed to be adjusted by between 0.25% and 0.5% for hitting a set of service quality standards. If two or more of five customer contact standards are not met, a 0.25% penalty is proposed. If one or more of three customer record keeping accuracy standards are not met, a 0.5% penalty is proposed. If two or more of the customer switching and connection standards are not met, then a 0.25% revenue adjustment is proposed. Companies complying with all the standards for customer contacts should get a 0.2% reward and those complying with all the standards for accuracy should get a 0.3% reward, while a reward of 0.2% for appointments and switching compliance is suggested.
Individual customers who receive poor service for written contacts, inaccurate bills, or failure to meet appointments, switches or connections, can receive direct payments of between €5 and €25. It is noteworthy that the system effectively employs a dead-band where no adjustment is made if the company fails to hit one of either customer contact standards or customer record keeping accuracy standards. It is also noteworthy that the penalties are effectively capped at 1% of revenues (notwithstanding direct payments to customers) and rewards are capped at 0.7% of revenues.