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Mr. Jonathan Daniels
Vice-President ‒ Regulatory Law
Bell Canada
160 Elgin Street, 19th Floor
Ottawa, Ontario K2P 2C4
bell.regulatory@bell.ca

Mr. Denis E. Henry
Vice-President
Regulatory, Government Affairs and Public Law
Bell Aliant Regional Communications
160 Elgin Street, 19th Floor
Ottawa, Ontario K2P 2C4
regulatory@bell.aliant.ca

Re: Communication to consumers regarding options to opt out of $2 charge for paper bills

Dear Sirs:

This is further to Commission staff’s letter dated 7 December 2012 , and the response from Bell Aliant Regional Communications, L.P. and Bell Canada (the Companies) dated 21 December 2012, about the monthly fee that the Companies are charging certain customers that wish to continue to receive paper bills.

In the 21 December 2012 response, the Companies stated that:

[T]he Companies will contact all their PES customers that are subject to the $2 paper bill fee and do not purchase Internet from the Companies (i.e. vulnerable customers and other customers who do have access to the Internet, but from another broadband supplier) to inform them of how to contact the Companies regarding their options to avoid paying the $2 fee, including by subscribing to standalone PES. The Companies will do this through a message printed on customers' bills, which ensures that customers can see they are being charged for the fee when they see the message. The Companies will also make such information available on their website which will allow Commission Staff to refer to this site in response to future complaints.

Commission staff notes that the Companies have created a Web page designed to inform customers as described above, at www.bell.ca/paperbillfee or www.bell.ca/fraisfacturepapier.

As well, Commission staff understands that the Companies’ intent is to proceed with an insert on customers' bills in April or May of this year.

Commission staff’s goal is to ensure that consumers, including consumers with disabilities, can easily find information about the possibility of opting out of paying the $2 charge for paper bills by subscribing to basic residential telephone service on its own or in conjunction with other services, such as calling features. This information should be easily accessible, searchable, and well highlighted, both at the time the consumer is shopping for or selecting a Bell Aliant or Bell Canada Home Phone service that will trigger the application of the charge or when the consumer sees the charge on the bill. Based on a review of Bell Canada’s website, Commission staff does not believe that this goal is presently met.

In Commission staff’s view, adjustments to the online information are required to:
i) make the information concerning the possibility of opting out of paying the $2 charge for paper bills by subscribing to basic residential service, on a standalone basis or in conjunction with other services, including calling features, more visible on the above referenced Web page, by including a heading in bold text and/or moving the text higher up on the page;
ii) ensure that the enhanced Web page can be accessed directly from those pages that a customer would be most inclined to visit while in the process of shopping for or selecting new Home Phone service; and
iii) ensure that the page appears among the top results when a customer conducts a search for information on the Companies’ websites about the $2 charge for paper bills using intuitive keywords.

With respect to the Companies’ planned bill insert, Commission staff is of the view that in order to be helpful to the Companies’ customers, the wording on the bill itself must make specific reference to the option of opting out of paying the $2 charge for paper bills by subscribing to basic residential service on a standalone basis or in conjunction with other telecommunications services, including calling features.

Commission staff requests that the Companies adjust the website information in order to make the option to opt out of the $2 charge easier to find, from the perspective of a current or prospective customer, and searchable. Commission staff also requests that the wording on the Companies’ planned bill insert be specific about this same option. Further, Commission staff considers that the online information should be accessible to persons with disabilities (i.e. be W3C compliant) and that the bill insert should be available in alternative formats for consumers with disabilities.

Yours sincerely,

Original signed by

Chris Seidl
Executive Director
Telecommunications Directorate

c.c.: Barbara Motzney, CRTC, barbara.motzney@crtc.gc.ca
Michel Murray, CRTC, michel.murray@crtc.gc.ca

Date modified:

2013-03-28