Telecom - Commission letter addressed to the Distribution List

Ottawa, 30 November 2020

Our reference: 1011-NOC2020-0081


To: Distribution List

Subject: Broadcasting and Telecom Notice of Consultation (“BTNC”) CRTC 2020-81, Call for Comments - Provision of paper bills by communications service providers, (CRTC File No. 1011-NOC2020-0081) – Request for information

Madams, Sirs,

The Commission initiated a proceeding, Broadcasting and Telecom Notice of Consultation CRTC 2020-81, (the Notice), to examine the issue of the provision of paper bills. Since (i) the Commission has addressed issues with respect to billing in similar ways for both telecommunications and broadcasting services, and (ii) section 27.2 of the Telecommunications Act and section 34.1 of the Broadcasting Act set out similar prohibitions against charging for paper bills, the scope of this proceeding includes both telecommunications and broadcasting services.

Commission staff has reviewed the interventions, responses to the request for information, and replies and considers that additional information is required on the record of the proceeding.

In order to ensure that the Commission has the factual record necessary to make a determination, Commission staff is requesting more information from the communications service providers in the Canadian market, namely Bell Canada, Bragg Communications Incorporated, Cogeco Communications inc., Quebecor Media Inc., Rogers Communications Canada Inc., Saskatchewan Telecommunications, Shaw Communications Inc., TBayTel, TekSavvy Solutions Inc., TELUS Communications Inc., and Xplornet Communications Inc..

Each of the above-noted companies’ responses must address its practices as a telecommunications service provider (TSP) and/or a broadcasting distribution undertaking (BDU), as well as the practices of any brands and subsidiaries Footnote1 .

As set out in Broadcasting and Telecom Information Bulletin 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, service providers may designate certain information as confidential. Service providers must provide an abridged version of the document involved, accompanied by a detailed rationale to explain why the disclosure of the information is not in the public interest. All submissions are to be made in accordance with the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, SOR/2010-277.

Responses to the request for information in the Appendix are to be filed with the Commission, by 14 December 2020. All responses are to be received, and not merely sent, by that date. Responses will be posted on the Commission website shortly after they are received and can be found at the following link 1011-NOC2020-0081.

Any party to this proceeding may file final replies on the responses by no later than 15 January 2021.

A copy of this letter and all related correspondence will be added to the public record of the proceeding.

If you have any questions, please contact Patrick Arseneau, Senior Analyst, Social and Consumer Policy, at 819 994-7993 or


Original signed by

Nanao Kachi
Director, Social and Consumer Policy
Consumer Affairs and Strategic Policy 

cc: Distribution List

Appendix: Request for information

New customers

  1. Can new customers request paper billing as part of subscribing to any of your services? If so, which services?
  2. Are new customers made aware of their billing options, if any?

Pre-migration to e-billing

  1. Are you planning to migrate customers to e-billing in the next year? If applicable, please provide
    1. a specific timeline and,
    2. copies of the documentation that will be used to inform customers of the planned migration.

Post-migration to e-billing

Have you migrated customers from paper bills to e-billing? Specifically, have you initiated a process to switch customers to e-billing without customers explicitly requesting this change? If so, respond to questions 4 to 7

  1. Provide copies of each type of notification sent to customers in all formats used (including but not limited to hardcopy paper correspondence, email, and SMS) advising them of a mandatory transition to e-billing.
    1. Were customers notified that they could still request paper bills?  If yes, were they informed using one of the notification methods noted above or by another means? Why was this approach chosen?
    2. If no, why was this decision made?
  2. What was the procedure for handling inquiries or complaints from customers who contacted you to indicate that they did not want to be migrated to e-billing?
  3. Provide call centre scripts, online support scripts, and any training documents regarding the mandatory transition to e-billing and responding to customer requests for paper bills.
  4. Once transitioned to e-billing, are the previous bills available online? If so,
    1. for how many months?
    2. what level of detail is available for these past bills?


  1. How did you handle any non-payment of bills in the billing cycles following the transition to e-billing for customers? Specifically
    1. Explain how your transition plan included consideration for any customers who may have remained unaware that they were migrated to e-billing, despite notifications, and did not know how to access their e-bills. 
    2. If a customer failed to pay their bill following this transition, how were customers notified of this non-payment?  Were the notifications sent only by email or via the billing portal or did you reach out to any such customers using other methods such as by telephone?
    3. Did you take steps to monitor nonpayment in such circumstances to identify customers who might not be aware that they were no longer receiving paper bills?  If so, what were they?
  2. In instances where customers appear to have stopped paying their bills in the billing cycles following the transition to e-billing, how do you ensure that customers are notified of a potential disconnection?
  3. Did you receive any complaints regarding disconnections that may have stemmed from customers being unaware of the fact that they were moved to e-billing? If so, how many?
    1. What was your standard process in handling these complaints?
  4. If you provided email notifications to a customer that they were being transitioned to e-billing and/ or you provided billing notifications via email following the transition, was there an option provided to the customer to confirm receipt/acknowledge receipt, which would indicate that the email had been successfully? 
    1. If yes, in the case where no such receipt was received, what steps did you take to follow-up with the customer? 
    2. If no, how did you ensure that the email address used to contact such a customer was valid and actively used or monitored by that customer? 

Instances where paper billing is available after the migration to e-billing

  1. In light of your response and/or intervention, in which you indicated that paper bills are available to customers who want them:
    1. Do you provide information about the availability of paper bills on your website? Is it provided through any other means?
    2. Explain the processes through which customers can switch back to paper billing, including every step on the customers’ part.
    3. Is there an option available in your online portal or other self-serve mechanism where customers can select paper billing? 
    4. If customers require the assistance of your client services to do so (by phone or online chat) is there a fee to do so?  If yes, what is that fee? 
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