Archive for October, 2006

It was my birthday a few days ago, and every birthday I tend to wonder what the heck I am doing with my life. Another year goes by, and somehow I find myself engaged in trench warfare with the most absurd people in the world. And losing. Usually I find myself losing the battle very slowly. But this year the common sense gang suffered its biggest defeat ever, and paranoid as I am, I missed the whole thing.

So Hong Kong woke up to reality and ditched their metering and billing scheme as a waste of time. Australia rewrote theirs, and proved that industry does a much better job of writing technical regulations than government appointees. Combined populations of HK + Aus = 27m. Two small victories for the forces of common sense. After those two victories, I must have got complacent. Luckily, Nitin Patel tipped me off about what was happening in the sub-continent from his safe haven at C&W – thanks to him for keeping an eye on the enemy. India has fallen; leaving a population of 1.08bn victim to the most ill-conceived piece of telecommunications regulation ever.

I should have seen it coming. There was an Indian guy in the UK last year looking for advice on how to regulate bill accuracy. I told him what I thought. He obviously did not like my advice, because the Indian regulator TRAI has employed some “international consultants” and come up with a new metering and billing code. However much the Indian taxpayer contributed towards these international consultants they were robbed – the new Indian code is a word-for-word take of the UK Direction. They should have just downloaded it for free from Ofcom and changed the name on the front. All round, this is a crushing defeat for the forces of common sense.

The Indian code is funny because it has even copied the words that nobody knows the meaning of. For example, they copied the product materiality threshold that never gets applied in the UK – because the Approval Bodies established it was not their responsibility to check it. They copied it right down to applying materiality to 5% of the “target” market. Unfortunately, nobody ever volunteers to have a target market smaller than the whole market (why would they? don’t they want to sell to everyone?). Luckily, there is some audit guidance to sort out that rule. What does it say about how to audit this? Ah yes, the test to be performed to determine if all the material products were covered is “observations, if any”. Then that’s all clear, then.

But, it gets better. To be fair, they did not copy every word. Because, per the new Indian code, when you implement a Canadian switch in India it presumably cannot keep time the same way as it does in the UK. A switch accurate to measure duration within 0.5s in the UK is only accurate to 1s in India. Its clock is less accurate in India. Obviously. Must be something to do with the electricity supply. Or the temperature. Something like that. Not that something like ripping off 0.5s is a big consumer protection issue. Oh no. I mean how much can 0.5s*1,000,000,000 people be worth?

So our “international consultants” persuaded the Indian Regulator, TRAI, that some meaningless words had to be copied word for word, but trivial things like the expectations for design and operating specs of technology sold and implemented world-wide should be tailored to the local market. All those telcos outsourcing to India better be careful – seems like the Indian watches are going to run slow compared to UK standards.

It is no wonder the Indian regulator did not make a fuss about the odd half second here and there. They made it clear why they introduced the regulation. Apparently, people complain about bills. Could this be a worldwide phenomenon we ask? Could it be that there are people all over the world who when asked to pay for something do not like paying so complain instead? The solution seems so obvious: audit the telco, and then you will see a demonstrable reduction in billing complaints. Except for one thing: the demonstrable reduction in billing complaints. Because they are not going down in the UK after many years of regulation. That is a bit of an inconvenient truth if you are a regulator wanting to act tough, so Ofcom generally avoids drawing attention to it. Is it just me, or is there a pattern forming here?

Of course, if you are worried about complaints, what do you focus on? Yes, the need to regulate to prevent undercharging. At least that is what TRAI has done by copying that bit of the UK rules too. Doubtless they bought the argument that there is a demonstrable, ahem, I mean totally unproven connection that customers lose “confidence” in their bill if they get undercharged. As opposed to just not noticing. After all, the supposed reason why telco bill accuracy needs to be regulated to standards 100 times more stringent than any other sector is because phone bills are complicated and customers cannot check them. Until you walk through the looking glass and find that an argument that customers are unable to check their bills supposedly in no way contradicts arguments that customers are checking their bills and complaining and losing confidence all the time. No doublethink there, it must just be me who struggles to believe both can be true at the same time. The funny thing is that one regulator now does agree with me and sees a contradiction – the UK regulator. After spawning the worst ever telco regulation, even the UK is starting to own up to its mistakes. Which is why Ofcom has said it is going to scrap the rules to audit undercharging. Perhaps those “international consultants” forgot to mention this to TRAI? So TRAI not only copied the UK, they even copied the rules that are now considered to be excessive regulation in the UK.

There is an unholy alliance between regulators and niche audit firms. One gets to boast of being tough on telcos. The other gets to play at being tough, independent and a friend to telcos and customers all at the same time, whilst earning a splendid constant revenue stream, in a controlled market with hardly any competition and no real supervision over the quality of their work. Better still, they even get to lever their regulatory stranglehold into markets that need no regulator intervention – preventing revenue loss – and get to play at being international consultants! Of course I am paranoid. Everyone knows that. But take a quick look at the half-a-dozen firms given a concession by TRAI to do the metering and billing audits in India. 5 companies I have not heared of, and 1 that I have. TUV, parent to BABT, can look forward to increasing metering and billing audit revenue flows from the Indian subcontinent to compensate its gradual decline in the UK market. And where will that money come from? From the pockets of Indian customers of course. Let us keep our fingers crossed and hope that the Indian customer keeps doing the one thing that may actually protect them – complain, complain and complain again.

Bookmark and Share

Anyone who knows me must sometimes hear me wittering on about the TeleManagement Forum. Over on their site, there has been an interesting debate recently, about what the expected returns from revenue assurance should be. This got me thinking.

Well, revenue assurance is much like drilling for oil; thanks to Clare Patterson for originally suggesting that metaphor to me. You may strike it lucky, you may not. RA is fairly speculative and you have to suffer a fair bit of cost on faith before you start making returns. The value of the oil industry goes up and down, but the value of a oil company is linked to the value of oil.

So if you assume a rational market, it should be easy to calculate the average returns from RA – just work out the average returns of the average RA vendor. Why has nobody ever calculated this? Partly because the sector is too small, I suspect, but partly because it would give us an unpalatable truth – the expected returns are rarely the huge “oil strikes” that so often get used to make a sales pitch for RA. Even if you conclude there is a high premium for risk in RA projects – the risk of getting nothing instead of a big pay off – and that this is all taken by the telcos rather than being shared with the vendors, then returns enjoyed by vendors still look lower than most of the estimates of the benefits would suggest.

No matter how well you pitch the benefits of a product, and you can think of revenue assurance as a product too, the value is probably best determined by its customers, not by salesmen….

Bookmark and Share

Just getting back from Informa’s revenue assurance conference in Prague, I was surprised by two things: the very warm weather for the time of year, and how well the debate around revenue assurance has moved on.

Whilst packing, I was suffering from my usual pre-conference fear that I would be hearing the same old content as previous years, but just packaged differently. As chair for the first day I decided to keep my opening remarks to a minimum (sometimes the conference is half an hour behind schedule before the first speaker opens their mouth) so focused on my usual pleas to audiences – that debate is good, we need to talk to each other (not just to listen quietly to the speakers) and that we all learn a lot more by being honest. Perhaps it worked or perhaps I had no need to make these comments. I found a surprising blend of people – some even from vendors – making refreshingly honest statements about where RA is both within their own organization and in general, and not just in quiet corners but in front of the whole audience. We were witness to the GBA’s spokesperson playing down how reliable their benchmark data is, a vendor admitting that they had yet to see credible metrics of revenue assurance performance, an operator admitting that there is good and bad with working with peers in a group, a consultant who wanted to talk about the alternatives and limits of using automated tools, and another operator referring to the necessary soft skills that RA people need – including empathy!

So, I am back in the UK and wishing I was still out there enjoying a beer and chatting with these very frank and rather clever people. If there can be some straightforward discussion about the weaknesses of revenue assurance, and not just the strengths, then maybe we can do something about them. At the very least, I will be trying to keep in touch with the new friends I met, as well as the familiar faces, in the hope not just of hearing about them succeeding in meeting the challenges they identified, but also learning how to copy their success!

Bookmark and Share

I took some bottles to be recycled last week. I must be a revenue assurance zealot because it got me thinking about revenue assurance.

Most people get the idea behind recycling, even if they are too lazy to do it. Recycle existing materials, and you save having to mine for new raw materials, save energy in producing new things, reduce the problem of waste disposal. Think global, act local, saving the world one tin can at a time. Recycling is obvious because it involves something physical, something tangible, but people also get the idea that waste in general is bad – like wasting energy or wasting water. What intrigues me is that people may be able to think coherently about these kinds of waste, but feel differently about the waste implied in a business that is inefficient or sloppy. Not only is the business wasteful in terms of money, but it wastes the human skills and abilities of its people on avoidable and unnecessary activities, and wastes the time and resources of customers when expecting them to challenge poor services, inaccurate capture of their orders, and invalid bills. If everything worked efficiently, and was correct first time, then not only money but also the time of people inside and outside the business would be released for more productive activities. Given the purpose of revenue assurance, and claims made about the size of errors it addresses, surely this makes RA a force for good?

Of course, we can go even further. If RA is a force for good, then it becomes an ethical duty to not only do it, but to do it well, and to encourage others to do it well. If some kinds of waste are obvious, and the steps to reduce them simple – like switching off the lights in an empty room – we can expect all to feel obliged and take action. But if other kinds of waste are harder to understand and to eliminate, the responsibility falls on a more select group. So RA is not just a job in the conventional sense, and not one for oriented purely for commercial gains. At least, RA is ethically equivalent to a recycling business, which also earn a profit but do something good that may not happen without the profit motive. There must have been a time when people who recycled tin cans seemed like zealots. But slowly they are converting the world, and I wish them well. They successfully persuaded me to join their cause. So, as a zealot, I am asking you to join me in spreading the good news of RA. We may be few in numbers now, but we can grow our numbers, and maybe that is our duty.

Bookmark and Share

I’ve been looking for years for likeminded souls who think the way I do about RA. If life’s a journey, and a good chunk of our lives is spent at work, then for most revenue assurance must be a grubby truck stop. It is somewhere they find themselves, not on any map, just hoping to refuel, grab a coffee, take a break. However long they stay, it is a nowhere-place, just a place on the way, not the destination.

Looking around, I cannot blame them for not wanting to stay. For a start, it isn’t exclusive. Anyone can drop in anytime they like, whatever their qualifications or background. Many of them are a little shady. And if there is any excitement it’s a fight. The fights are mostly about who can boss who around and who has the biggest RA engine, who is going somewhere faster, who has the most admirers. Then there is the hospitality, which is atrocious. Everyone is impatient. Most people stare blankly at you when you speak to them – some look right through you. Nobody has a smile for you. You get cussed at and treated like scum most of the time, unless you act really nice in which case you get barely tolerated. And finally you get ripped off. However much you money you give them, the hand stays outstretched expecting more. So it is no wonder people don’t plan to stay.

It must be hard to get people to work in truck stops for any length of time, especially if they have a tiny amount of ambition. The same is true for revenue assurance. But the thing that drives me crazy is that to be good at RA you need to be a smarty-pants or ultra-keen or have some kind of visionary faith in what you do. RA is detective work, not flipping burgers. It needs an enquiring mind, not one that switches off and goes into auto-pilot. If it doesn’t engage people like that, then it is nothing. Because it all boils down to finding out what when wrong when a lot of other smarty-pants were trusted to run a telco.

So here’s my blog manifesto. I want to smarten up the truck stop and to do that I need the help of the others who have stopped by this way. We need to move up-market, discourage some of the riff-raff who visit, and make it a more pleasant place to stay – maybe even turn it into somewhere people want to stay for a long time, maybe even a lifetime. Striking up a little intelligent conversation might be a good place to start. So I see you, sat at your table on your own, with your coffee and stale sandwich. And I’m coming over to talk to you. What you going to do? Will you assume I am a psycho and try to leave at the first opportunity? Just keep your head down, act dumb and hope I go away? Be entertained by my stories but choose to not share your own? Or are you going to respond, share an anecdote, a joke, some tips, and generally make this stop a nicer place? The truth is, you would much rather visit a place where everybody knows your name and wants to engage in conversation. So this is me talking. If you talk, I will listen. Are you listening to this?

Bookmark and Share