|
|
Telecom Decision CRTC 2003-86
|
|
|
Ottawa, 23 December 2003
|
|
|
Bell Canada and Aliant Telecom Inc. − Show Cause on the issuance of monthly itemized billing statements − Follow-up to Decision 2002-34
|
|
|
Reference: 8638-C12-60/02
|
|
|
In this decision, the Commission directs Bell Canada and Aliant Telecom Inc. (Aliant Telecom) to commence providing all customers with monthly itemized billing statements within six months of the date of this decision. The Commission denies the request of Bell Canada and Aliant Telecom to recover any costs associated with the introduction of monthly itemized billing statements.
|
|
1.
|
In Regulatory framework for second price cap period, Telecom Decision CRTC 2002-34, 30 May 2002 (Decision 2002-34), the Commission directed Bell Canada and Aliant Telecom Inc. (Aliant Telecom) to show cause why they should not be directed to provide their customers monthly itemized billing statements at the same level of detail as is currently provided on an annual basis.
|
|
2.
|
The Commission received submissions from Bell Canada and Aliant Telecom on 2 July 2002 and comments from the Public Interest Advocacy Centre, on behalf of the Consumers' Association of Canada, the National Anti-Poverty Organization and l'Union des consommateurs (the Consumer Groups) on 12 July 2002. The Commission received reply comments from Aliant Telecom on 19 July 2002 and from Bell Canada on 22 July 2002. The Consumer Groups filed further comments on 9 September 2002. On 18 October 2002, Commission staff requested further information from Bell Canada and Aliant Telecom. The Commission received responses from Bell Canada and Aliant Telecom on 4 November 2002. The Commission received further comments from the Consumer Groups on 14 November 2002 and further reply comments from Bell Canada and Aliant Telecom on 25 November 2002.
|
|
|
Background
|
|
3.
|
The Commission notes that incumbent local exchange carriers (ILECs) have varying policies with respect to the frequency with which itemized statements are sent to customers.
|
|
4.
|
TELUS Communications Inc. (TELUS), MTS Communications Inc. (MTS) and Saskatchewan Telecommunications (SaskTel) send itemized billing statements to their customers monthly.
|
|
5.
|
Pursuant to Review of the general regulations of the federally regulated terrestrial telecommunications common carriers, Telecom Decision CRTC 86-7, 26 March 1986 (Decision 86-7), Bell Canada currently provides its single-line customers with a detailed itemization of service and equipment charges at service commencement, after any service and equipment changes and, at a minimum, once a year.
|
|
6.
|
Similarly, Aliant Telecom currently provides customers in New Brunswick and in Newfoundland and Labrador with itemized billing statements, on request as well as at service commencement, after any service and equipment changes and, at a minimum, once a year. Aliant Telecom currently provides monthly itemized billing statements to all customers in Prince Edward Island and Nova Scotia.
|
|
7.
|
In Decision 2002-34, the Commission noted statements of Aliant Telecom, Bell Canada, MTS and SaskTel (the Companies) that their subscribers were generally satisfied with current billing policies. However, the Commission also noted that the Companies reported focus group results indicating a preference for "consolidated" statements, similar to the itemized statements provided annually.
|
|
8.
|
In light of the policy implemented by TELUS, SaskTel and MTS in their territories to provide monthly itemized billing statements, and in view of subscriber preference for "consolidated" statements, the Commission indicated in Decision 2002-34 its preliminary view that such a policy should be extended to Bell Canada and Aliant Telecom.
|
|
9.
|
Accordingly, the Commission directed Bell Canada and Aliant Telecom to show cause why they should not be directed to provide their customers monthly itemized billing statements at the same level of detail as is currently provided on an annual basis.
|
|
|
Positions of the parties
|
|
|
Bell Canada's initial comments
|
|
10.
|
Bell Canada stated its understanding that customers were satisfied with the existing billing statement format and content, based on informal customer feedback and on quality of service results evidencing a low number of customer complaints regarding Bell Canada's billing service. Bell Canada noted that its customers could verbally request and receive detailed billing information at any time. Bell Canada submitted that it would therefore be unnecessary and inefficient to provide all of its customers with an itemized billing statement more frequently than at present. Nonetheless, Bell Canada indicated that it would be prepared to provide a monthly itemized billing statement to customers who indicated a preference for such a monthly statement (opt-in approach).
|
|
11.
|
Further, Bell Canada argued that should the company be directed to provide monthly itemized billing statements, Bell Canada should be allowed to draw down any related incremental expenses and/or capital costs from the deferral account identified in Decision 2002-34. Bell Canada argued that such additional expenses would be incurred as a direct result of a regulatory requirement implemented solely for the benefit of customers.
|
|
|
Aliant Telecom's initial comments
|
|
12.
|
Aliant Telecom noted that monthly itemized billing statements have been provided to its customers located in Nova Scotia and Prince Edward Island since early in 2001. Aliant Telecom submitted that after more than a year of providing monthly itemized billing statements to these customers, there were no identifiable customer benefits to justify the additional cost of extending the provision of monthly itemized billing statements to all customers.
|
|
13.
|
Aliant Telecom indicated that it provided itemized billing statements to its customers located in New Brunswick and in Newfoundland and Labrador whenever there was a change to any of the services subscribed to by a customer, whenever there was a change to a service rate, whenever there was a customer-initiated request such as the cancellation of a service, and at least once a year. Aliant Telecom indicated that it also provided monthly itemized billing statements to its customers located in New Brunswick and in Newfoundland and Labrador upon request. Furthermore, Aliant Telecom noted that all of its customers have electronic access to their billing details over the Internet. Aliant Telecom stated that in Newfoundland and Labrador, residential customers with limited optional services received an average of four itemized billing statements during 2001.
|
|
14.
|
Aliant Telecom submitted that it had no reason to believe that its New Brunswick and Newfoundland and Labrador customers were dissatisfied with the existing billing format. Aliant Telecom noted that customers in New Brunswick had previously received monthly itemized billing statements, but that the practice had been withdrawn in the face of customer concerns over the amount of paper consumed to provide billing statements. Aliant Telecom further reported low rates of customer complaints with respect to billing services.
|
|
15.
|
Accordingly, Aliant Telecom argued that the approach currently taken in New Brunswick and in Newfoundland and Labrador to itemized billing statements was preferable to the automatic provision of monthly itemized billing statements. Aliant Telecom proposed to implement an opt-in approach throughout its territory.
|
|
16.
|
Finally, Aliant Telecom submitted that should the Commission require Aliant Telecom to provide monthly itemized billing statements to customers throughout its territory, Aliant Telecom should be allowed to recover any and all associated costs.
|
|
|
The Consumer Groups' initial comments
|
|
17.
|
The Consumer Groups supported the Commission's preliminary view that Bell Canada and Aliant Telecom should provide customers with monthly itemized billing statements. The Consumer Groups noted that most telephone companies in Canada provide monthly itemized billing statements to their customers. The Consumer Groups submitted that SaskTel had begun to implement monthly itemized billing statements and submitted that MTS used to follow the practice currently followed by Bell Canada and Aliant Telecom, but reverted to monthly itemization.
|
|
18.
|
The Consumer Groups submitted that all billing statements should be sufficiently detailed so that customers can determine from each billing statement the services to which they subscribe and how much they are paying for each service. The Consumer Groups argued that as long as services are billed on a monthly basis, each monthly billing statement should include the minimum level of detail considered adequate by the Commission.
|
|
19.
|
The Consumer Groups argued that without monthly itemized billing statements, customers could lose track of the various optional services to which they subscribe, and end up paying for services that they neither want nor need. The Consumer Groups further submitted that without monthly itemized billing statements, customers may believe that they have ceased subscribing to a given service, such as an optional service provided free of charge for a limited period of time, when in fact they are still being charged for the service.
|
|
20.
|
The Consumer Groups argued that merely because customers have not formally complained in large numbers about the lack of detail they receive on their monthly billing statements does not mean that they are satisfied with the monthly billing statements. The Consumer Groups submitted that the results of Bell Canada's focus group testing, filed by the Companies in the proceeding leading to Decision 2002-34, indicated that customers prefer the level of detail provided by Bell Canada on its annual itemized billing statement.
|
|
21.
|
The Consumer Groups submitted that the context has changed since the Commission issued Decision 86-7, ordering the ILECs to provide customers with detailed itemized billing statements, at a minimum, once a year. The Consumer Groups submitted that many new optional services are now available to customers and that the ILECs now aggressively market these optional services. The Consumer Groups argued that, consequently, the fact that annual itemized billing statements were considered appropriate in 1986 does not suggest that annual itemized billing statements are now sufficient. The Consumer Groups further noted that the U.S. Federal Communications Commission (FCC) requires telephone companies to provide full and non-misleading descriptions of all charges on all billing statements.
|
|
22.
|
With respect to the issue of customer concerns regarding the consumption of paper, the Consumer Groups submitted that the goal of minimizing unnecessary paper must be weighed against the goal of providing adequate billing information. The Consumer Groups further suggested that the length of billing statements could be reduced while still providing monthly itemized billing statements by instead minimizing other, less important information that appears on billing statements.
|
|
23.
|
The Consumer Groups objected to Bell Canada's and Aliant Telecom's proposal to offer monthly itemized billing statements under an opt-in approach and argued that customers would be denied meaningful choice under such an approach. The Consumer Groups submitted that the results of opt-in processes are always biased towards the default as a result of customer inertia. The Consumer Groups further submitted that using bill inserts to inform customers of the option of monthly itemized billing statements would be ineffective as most bill inserts consist of marketing material and many customers never or only rarely read bill inserts. The Consumer Groups argued that under an opt-in approach, Bell Canada and Aliant Telecom would be in a position to treat the option of more frequent itemized billing statements as a value-added service, for which a charge may apply.
|
|
24.
|
The Consumer Groups argued that Bell Canada and Aliant Telecom should therefore provide customers with monthly itemized billing statements as the default and should offer customers the choice of opting-out of monthly itemized billing statements (opt-out approach).
|
|
25.
|
Finally, the Consumer Groups argued that Bell Canada and Aliant Telecom should not be allowed to draw down from the deferral account any incremental expenses and/or capital costs attributable to the provision of monthly itemized billing statements. The Consumer Groups argued that such a policy would be unfair to those ILECs that have already implemented monthly itemized billing statements without any such cost recovery. The Consumer Groups further argued that the ILECs benefited from a lack of scrutiny of their reduced costs for specific services under the new price cap regime and that it would therefore be inappropriate for Bell Canada and Aliant Telecom to recover increased costs from the deferral account stemming from a directive to provide monthly itemized billing statements.
|
|
|
Bell Canada's reply comments
|
|
26.
|
Bell Canada submitted that the lack of customer complaints regarding Bell Canada's billing service indicates that customers are generally satisfied with Bell Canada's current billing practices and contradicts the position advanced by the Consumer Groups that Bell Canada's customers may not be satisfied with its current billing practices.
|
|
27.
|
Bell Canada submitted that it would not be onerous for a customer to contact Bell Canada to request monthly itemized billing statements under an opt-in approach and that the use of a bill insert would be sufficient notice to all customers of this option. Bell Canada rejected the Consumer Groups' position that without monthly itemized billing statements, customers would be denied the billing detail they need to make informed choices on an ongoing basis, given that customers can receive detailed billing information verbally at any time and given that Bell Canada provided itemized billing statements for all services on an annual basis, as well as whenever there is a change to the customer's services.
|
|
28.
|
Bell Canada indicated that it had no current plans to eliminate paper billing statements or to charge its customers for the provision of an itemized billing statement.
|
|
29.
|
Bell Canada opposed the Consumer Groups' submission that it would be inappropriate to recover increased costs stemming from the provision of monthly itemized billing statements through the deferral account, noting that businesses, in general, recover the normal costs of business from customers.
|
|
30.
|
Finally, Bell Canada stated that MTS and SaskTel commenced providing monthly itemized billing when they came under the jurisdiction of the Commission and were required to implement significant changes to their billing systems in order to comply with Decision 86-7. Bell Canada noted that its billing practices already complied with Decision 86-7.
|
|
|
Aliant Telecom's reply comments
|
|
31.
|
Aliant Telecom submitted that the American experience with the issue of itemized billing statements was very different than the Canadian situation and that the FCC's imposition of billing statement guidelines was based on customer complaints to the FCC, whereas Aliant Telecom's evidence showed a minimal number of billing related complaints within its territory. Aliant Telecom further noted that the FCC imposed billing statement guidelines on all carriers under its jurisdiction and not just the ILECs. Aliant Telecom further argued that the Consumer Groups did not analyze the billing format used by Aliant Telecom and did not provide any evidence that information contained on the Aliant Telecom billing statement is unimportant or that a different format could reduce the amount of paper used in providing billing statements to customers. Aliant Telecom noted that it does not charge customers who currently receive monthly itemized billing statements for the service.
|
|
|
The Consumer Groups' supplementary comments
|
|
32.
|
The Consumer Groups submitted that Aliant Telecom's recent notice on its monthly billing statements that the rates for optional services were being changed provided an example of why monthly itemized billing statements are required. The Consumer Groups submitted that the notice provided new monthly rates but did not provide the previous monthly rates and that customers were therefore unable to determine whether the monthly rates were being increased.
|
|
|
Bell Canada's reply to the Commission's interrogatories
|
|
33.
|
Bell Canada submitted that if it were required to provide monthly itemized billing statements to all customers, it would incur estimated incremental and recurring costs of 1.6 cents per network access service (NAS) per month, which would amount to a present worth of annual costs of $5.9 million. Bell Canada noted that under its existing itemized billing statement policy, customers received an itemized billing statement on average 2.2 times per year.
|
|
34.
|
Bell Canada estimated that its incremental and recurring costs under an opt-in approach would be 2.7 cents per NAS per month, or a present worth of annual costs of $9.8 million, while its incremental and recurring costs under the opt-out approach would be 3.7 cents per NAS per month, or a present worth of annual costs of $13.3 million. Bell Canada estimated that approximately 10% of its affected customers would opt in to receive a detailed monthly bill, while approximately 1% of its affected customers would opt out of receiving a detailed monthly bill.
|
|
35.
|
Bell Canada proposed that it be allowed to draw down the Phase II costs associated with monthly itemized billing statements from the deferral account. Bell Canada estimated that if it were required to provide monthly itemized billing statements to all customers, the associated Phase II costs would be $1.4 million per year. Bell Canada estimated that the Phase II draw down amounts under the opt-in and opt-out approaches would be $2.4 million and $3.2 million per year, respectively. Bell Canada noted that these proposed draw downs from the deferral account would recur each year.
|
|
36.
|
Bell Canada indicated that, on average, it printed 20 additional lines of information when it produced an itemized billing statement, which equated to approximately a half page of bill space. Bell Canada indicated that it was not aware of any changes which it could make to the existing billing statement layout or template that could offset the need for additional paper costs on an ongoing basis. Bell Canada noted that there were many design considerations that impacted any modifications to the layout of a residential customer billing statement.
|
|
37.
|
Bell Canada further provided information regarding the percentage of customers who subscribe to optional services and the number of customers who use Internet billing, and provided lists of the optional services available in 1985 and in 2002 and sample itemized and non-itemized billing statements.
|
|
|
Aliant Telecom's reply to the Commission's interrogatories
|
|
38.
|
Aliant Telecom indicated that the start-up costs of the conversion to monthly itemized billing statements in Nova Scotia and Prince Edward Island in 2001 was negligible and estimated that the annual incremental costs related to the increase in the number of printed pages required in the 2001 conversion amounted to $1.24 per residential NAS or a total of $529,000.
|
|
39.
|
Aliant Telecom submitted that if it were required to provide monthly itemized billing statements to all customers in New Brunswick and in Newfoundland and Labrador, it would incur an annual estimated incremental cost of $1.24 per residential NAS or a total of $637,000. Aliant Telecom estimated that if it were directed to provide monthly itemized billing statements to all customers in New Brunswick and in Newfoundland and Labrador, it could expect a substantial number of calls to its customer contact centres, resulting in an estimated one-time cost of $334,000.
|
|
40.
|
Aliant Telecom submitted that, under the opt-in approach to monthly itemized billing statements, with the resulting reduction in the number of monthly itemized billing statements delivered in Nova Scotia and Prince Edward Island and the increase in the number of monthly billing statements delivered in New Brunswick and in Newfoundland and Labrador,there would be an annual net cost savings of $415,000 in relation to the number of pages that would be printed. However, Aliant Telecom estimated that there would also be $596,000 in call centre costs as a result of an assumed 10% of customers that would opt in to receiving monthly itemized billing statements.
|
|
41.
|
Aliant Telecom submitted that, under the opt-out approach to monthly itemized billing statements, there would be an annual incremental cost of $986,000 related to the increased number of pages that would be printed, and an estimated $596,000 in call centre costs as a result of an assumed 10% of customers that would opt out of receiving monthly itemized billing statements.
|
|
42.
|
Aliant Telecom indicated that it had no documented records or studies concerning the volume or nature of the concerns customers expressed subsequent to the introduction of monthly itemized billing statements in New Brunswick in 1992, but noted that management personnel involved in the introduction of the service estimated the volume of customer complaints to be in the thousands.
|
|
43.
|
Aliant Telecom indicated that, on average, it printed 20 additional lines of information when it produced an itemized residential billing statement. Aliant Telecom estimated that it would be necessary to print additional billing statement pages for approximately 95% of its residential customers if it were required to provide all of its customers with monthly itemized billing statements. Aliant Telecom submitted that its existing billing statement layout was the most efficient and understandable design option.
|
|
44.
|
Aliant Telecom indicated that approximately 0.2% of its residential customers access their billing information via the Internet and that customers accessing their billing information via the Internet receive the same level of itemization on a monthly basis that is provided on the paper format of Aliant Telecom's billing statements.
|
|
45.
|
Aliant Telecom further provided information regarding the percentage of customers who subscribe to optional services and filed examples of itemized and non-itemized billing statements and a list of the optional services available in 2002.
|
|
|
The Consumer Groups' further comments
|
|
46.
|
The Consumer Groups noted that of the three approaches to providing monthly itemized billing statements, namely (i) mandatory for all subscribers, (ii) opt in, and (iii) opt out, the mandatory approach would be the least costly option according to Bell Canada's calculations, while the opt-in approach favoured by Bell Canada would be significantly more costly. Further, the Consumer Groups argued that the mandatory approach would cost even less than Bell Canada calculated because Bell Canada had failed to account for the recurring cost savings that would be achieved due to fewer billing-related inquiries.
|
|
47.
|
The Consumer Groups argued that Aliant Telecom's cost estimates did not take into account recurring call centre-related costs and challenged Aliant Telecom's assumption that it would be required to print additional billing statement pages for approximately 95% of Aliant Telecom's residential customers.
|
|
48.
|
With respect to the length of billing statements, the Consumer Groups submitted that an itemized billing statement does not require all items to be broken down to their constituent parts, as described by Bell Canada, and that Bell Canada and Aliant Telecom could further reduce the length of their billing statements by reducing the use of the billing statements to advertize optional services.
|
|
|
Bell Canada's further reply comments
|
|
49.
|
Bell Canada noted that of all the possible approaches to providing itemized billing statements, its existing policy of only providing itemized billing statements at service commencement, after any service changes and, at minimum, once a year, would be the least expensive. Bell Canada submitted that even the second least expensive option, the mandatory approach to monthly itemized billing statements, would still result in incremental costs of 2.7 cents per NAS per month. Bell Canada submitted that the opt-out approach promoted by the Consumer Groups was the most expensive option, at an incremental cost of 3.7 cents per NAS per month, and was undesirable from a financial and operational perspective.
|
|
50.
|
Bell Canada further submitted that the number of optional and other tariffed services that could have appeared on a residential itemized billing statement as of 1 May 1985 was very similar to the number of optional and other tariffed services that could have appeared on a residential itemized billing statement as of 1 October 2002. Bell Canada argued that, consequently, there was currently no greater need for monthly itemized billing statements than there was in 1985.
|
|
51.
|
Bell Canada also submitted that it had accurately described the service items that would be included in an itemized billing statement. Bell Canada further argued that it only placed promotions for optional services on the billing statement when there were few factual information messages in that month.
|
|
52.
|
Finally, Bell Canada submitted that the Consumer Groups had provided no evidence to support their submission that the level of billing detail currently provided by Bell Canada to its customers was insufficient or that Bell Canada customers were dissatisfied with Bell Canada's current billing practices.
|
|
|
Aliant Telecom's further reply comments
|
|
53.
|
Aliant Telecom indicated that its estimated incremental costs under the mandatory approach of providing monthly itemized billing statements to all residential customers was 10 cents per residential NAS per month. Aliant Telecom indicated that there would be a further, one-time estimated cost of 65 cents per residential NAS to implement monthly itemized billing statements in New Brunswick and in Newfoundland and Labrador.
|
|
54.
|
Aliant Telecom submitted that the opt-in approach would result in a monthly net saving of 4 cents per residential NAS per month, and in a one-time estimated cost of 65 cents per residential NAS to remove monthly itemized billing statements in Nova Scotia and Prince Edward Island. Aliant Telecom further stated that the opt-out approach would result in an incremental cost of 9 cents per residential NAS per month, plus the one-time cost of 65 cents per residential NAS to activate the opt-out approach.
|
|
55.
|
Aliant Telecom clarified that its estimated $596,000 one-time cost took account of call centre-related costs, assuming a 10% take rate for either an opt-in or opt-out approach.
|
|
56.
|
Aliant Telecom submitted that the mandatory approach to monthly itemized billing statements would not result in lower call centre costs, as demonstrated by Aliant Telecom's experience in Nova Scotia and Prince Edward Island, where monthly itemized billing statements were provided without a measurable reduction in the number of calls to Aliant Telecom's call centres. Aliant Telecom reiterated that the experience of management personnel involved with the introduction of monthly itemized billing statements in New Brunswick in 1992 was that customer calls to call centres increased substantially with the provision of billing detail.
|
|
57.
|
Aliant Telecom indicated that its printing cost estimates were based on the need to print additional pages for approximately 95% of its residential customers, based on the current billing statement design. Aliant Telecom submitted that its current billing statement format was designed and structured to achieve optimum readability and efficiency and that any redesign of the billing statement format would have to consider many issues.
|
|
58.
|
With respect to the Consumer Groups' supplementary submissions, Aliant Telecom indicated that all of its customers in Nova Scotia, Prince Edward Island and in Newfoundland and Labrador affected by the rate changes to optional services referred to by the Consumer Groups received itemized billing statements. Aliant Telecom noted that, inadvertently, New Brunswick customers subscribing to the optional services that had not selected to receive monthly itemized billing statements did not receive the itemized billing statement. Aliant Telecom indicated that it had since re-established the process to provide itemized billing statements to all customers affected by any change in rates for services subject to monthly recurring rates.
|
|
|
Commission analysis and determination
|
|
59.
|
The Commission notes that in Decision 2002-34, it expressed the preliminary view that the policy of providing monthly itemized billing statements to all customers should be extended to Bell Canada and Aliant Telecom.
|
|
60.
|
The Commission notes that Bell Canada and Aliant Telecom submitted that they should not be directed to provide monthly itemized billing statements to their customers because their customers appeared to be satisfied with existing billing practices. The Commission notes that Bell Canada and Aliant Telecom submitted that quality of service results indicated consumer satisfaction with existing billing policies. In this regard, the Commission notes that quality of service indicators relate to billing measure only the accuracy and timeliness of billing statements. The Commission does not consider the quality of service indicators to offer a clear indication of customers' preference regarding the frequency with which they would wish to receive itemized billing statements, or the extent of detail contained in billing statements. Furthermore, in Decision 2002-34 the Commission noted that, while the Companies stated that their customers were generally satisfied with current billing policies, the Bell Canada focus group results reported by them indicated a preference for "consolidated" statements, similar to the itemized statements sent annually.
|
|
61.
|
The Commission further notes the Consumer Groups' opinion that without monthly itemized billing statements, customers could:
|
|
|
- lose track of the various optional services they subscribe to;
|
|
|
- end up paying for services they neither want nor need; and
|
|
|
- assume that the amalgamated local charge shown on a billing statement was entirely mandatory.
|
|
62.
|
The Commission considers these to be valid concerns and considers further that requiring Bell Canada and Aliant Telecom to issue monthly itemized billing statements would be consistent with the Commission's policy of encouraging the implementation of means to assist consumers in understanding and managing their accounts and maintaining basic service.
|
|
63.
|
To that effect, the Commission notes that in Local service pricing options, Telecom Decision CRTC 96-10, 15 November 1996, and in Commission modifies reporting requirements for affordability, Order CRTC 2000-393, 10 May 2000, the Commission introduced bill management tools as important means to facilitate consumer access to telephone service and consumer management of their telephone services. The Commission considers that monthly itemized billing statements would provide customers with the level of detail needed to permit more informed account management and would assist those customers experiencing financial difficulty to better manage their account and payments in order to maintain primary exchange service. The Commission further considers that monthly itemized billing statements would enable customers to verify the accuracy of their billing statements on an on-going basis and dispute any errors more promptly.
|
|
64.
|
In light of the above, the Commission considers that Bell Canada and Aliant Telecom should provide monthly itemized billing statements to their customers.
|
|
65.
|
The Commission notes that Bell Canada and Aliant Telecom indicated that they would be prepared to provide monthly itemized billing statements to every customer who indicates its preference for such a bill under an opt-in approach.
|
|
66.
|
The Commission notes that under an opt-in approach, Aliant Telecom's customers in Nova Scotia and Prince Edward Island would no longer automatically receive monthly itemized billing statements.
|
|
67.
|
The Commission notes that Bell Canada and Aliant Telecom estimate that only 10% of customers would opt in to receive monthly itemized billing statements under the opt-in approach. The Commission also notes the Consumer Groups' view that customer inertia would prevent any significant customer take-up of monthly itemized billing statements under the opt-in approach. The Commission further notes that the Consumer Groups supported this view by providing survey results indicating that the methods proposed to communicate the opt-in approach to customers would not be effective. The Commission considers that the estimated low take-up rate of monthly itemized billing statements under the opt-in approach would be attributable to customer inertia. The Commission considers that it would be inappropriate if inertia precluded customers from receiving monthly itemized billing statements when the issuance of monthly itemized billing statements would benefit customers.
|
|
68.
|
The Commission further considers that the mandatory issuance of monthly itemized billing statements to all customers would achieve the following objectives and results:
|
|
|
- customers would be able to verify the accuracy of their billing statements on an ongoing basis; and
|
|
|
|
|
|
- responsive to customer preference for itemized billing statements;
|
|
|
- consistent with Commission policy initiatives to assist customers in managing their telephone services by ensuring that they can determine from their monthly bills the individual services for which they are being charged and what each costs; and
|
|
|
- consistent with the practice already employed by other ILECs.
|
|
69.
|
Accordingly, the Commission considers the mandatory issuance of monthly itemized billing statements to be a preferable approach to the opt-in approach proposed by Bell Canada or the opt-out approach.
|
|
70.
|
In light of the above, the Commission directsBell Canada and Aliant Telecom to commence providing their customers with monthly itemized billing statements, at the same level of detail as is currently provided on an annual basis within six months of the date of this decision. Bell Canada and Aliant Telecom may utilize a phased-in implementation process so long as all customers are receiving detailed monthly bills by the end of the six month period.
|
|
71.
|
In regard to Aliant Telecom's request that it be allowed to recover any costs associated with the introduction of monthly itemized billing statements and Bell Canada's request that it be allowed to draw down from the deferral account any incremental expenses and/or capital costs related to the introduction of monthly itemized billing statements, the Commission notes that it set out the conditions under which adjustments would be made to the deferral account in Decision 2002-34. The Commission notes that it indicated that an adjustment to the account would be made whenever the Commission approves rate reductions for residential local services that are proposed by the ILECs as a result of competitive pressures or to mitigate certain rate increases for residential services. The Commission also noted in Decision 2002-34 that other draw downs could occur, for example, through subscriber rebates or the funding of initiatives that would benefit residential customers in other ways.
|
|
72.
|
In this regard, the Commission agrees with Bell Canada's submission that the issuance of monthly itemized billing statements is a policy decision that would primarily benefit residential customers. However, the Commission notes that TELUS, MTS and SaskTel already issue monthly itemized billing statements, as does Aliant Telecom with respect to its customers located in Nova Scotia and Prince Edward Island. Accordingly, the Commission considers that the provision of itemized billing statements on a monthly basis should be considered to be an ordinary business practice.
|
|
73.
|
In light of the above, the Commission denies Aliant Telecom's request that it be allowed to recover any costs associated with the introduction of monthly itemized billing statements and denies Bell Canada's request that it be allowed to draw down from the deferral account any incremental expenses and/or capital costs related to the introduction of monthly itemized billing statements.
|
|
|
Secretary General
|
|
|
This document is available in alternative format upon request and may also be examined at the following Internet site: www.crtc.gc.ca
|
Date Modified: 2003-12-23