ARCHIVED -  Letter

Ottawa, 7 December 2012

Our reference: 8495-1 8480-B54-X
8492-B54

By EMAIL

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: Consumer complaints regarding fee for paper bills and Bell Canada’s response

Dear Mr. Daniels and Mr. Henry:

This is further to a Commission staff letter to Bell Canada, dated 23 April 2012¹, about the monthly fee that Bell Canada and Bell Aliant Regional Communications, Limited Partnership (Bell Aliant) (the Companies) are charging their customers who wish to receive paper bills.

The Commission continues to receive complaints from consumers and concerned Members of Parliament about the Companies’ decision to charge $2 per month for paper bills.

Many consumers have written to the Commission to oppose the fee and to express their concern that e-billing is not a viable option for them, for example, due to lack of Internet access at home or at other locations.

Commission staff notes that in response to a request for information,² Bell Canada indicated that:

• the Companies were implementing e-billing as a standard practice in their serving territories in Ontario and Québec and would charge customers an additional $2 per month if they wished to continue to receive paper bills;
• however, customers who subscribe to only a basic residential telephone service³ on its own or in conjunction with other telephone services on an unbundled basis in regulated and forborne areas, and those registered to receive bills in alternate formats, were exempt from the $2 per month fee for paper bills; and
• Bell Canada and Bell Aliant had notified their customers of the option to arrange for e billing at no charge.

The Commission supports innovation and considers that e-billing may have a positive impact on many consumers and the environment. However, Commission staff is concerned that the approach that the Companies have taken to encourage consumers to choose e-billing over paper billing may be having a negative impact on vulnerable consumers.

Specifically, Commission staff is concerned that the decision to charge consumers a fee of $2 per bill if they wish to receive paper bills puts an increased burden on consumers on limited incomes. Commission staff notes that as a result of this approach, consumers who, for a variety of reasons, have limited access to Internet services will be paying more than other customers for the same service that they were receiving previously.

Commission staff encourages Bell Canada and Bell Aliant to consider an approach to moving to e-billing whereby the incentive will not create an undue burden on vulnerable consumers. To ensure that consumers can make informed decisions about their service and service providers, Commission staff requests that Bell Canada and Bell Aliant inform all their customers about all possible ways to avoid or opt out of the charge for paper bills, including by subscribing to a basic residential telephone service on its own or in conjunction with other telephone services on an unbundled basis.

Commission staff further requests that the Companies respond by 19 December 2012 and confirm details of the specific actions that they either may have already taken, or will be taking, on this issue.

Yours sincerely,

Original signed by John Macri
for

Chris Seidl
Executive Director
Telecommunications Directorate

c.c.: Barbara Motzney, CRTC, barbara.motzney@crtc.gc.ca
Lynne Fancy, CRTC, lynne.fancy@crtc.gc.ca
Michel Murray, CRTC, michel.murray@crtc.gc.ca
Bob Martin, CRTC, robert.martin@crtc.gc.ca

[1] Commission staff letter to Mr. Philippe Gauvin, Senior Counsel, Regulatory Law and Policy at Bell Canada.

[2] In its 23 April 2012 letter, Commission staff requested that Bell Canada respond to interrogatories about the types of services for which a charge would be applied for paper bills, the regulatory authority for applying such a charge, and how customers were being notified of the charge.

[3] Stand-alone residential Primary Exchange Service.

Date modified:

2012-12-07