Thank you, Mr. Chair.
My name's John Lawford. I'm the executive director of Public Interest Advocacy Centre. We're a non-profit charity that specializes in representing consumer interests, and in particular vulnerable consumer interests concerning important public services. We're commenting today on Bill C-43 and notably on the power to levy administrative fines and monetary penalties for non-compliance with the Broadcasting Act, Radiocommunication Act, and Telecommunications Act.
Our message today is that it is necessary to have such penalties, and the amounts proposed are appropriate. However, the bill also does away with paper bill fees for telecommunications and broadcasting invoices, and that is a matter on which PIAC wrote a report and a result we have worked very hard to achieve, first through the CRTC and now here before you. We'll also speak briefly to the other two points that Mr. Seidl raised.
The AMPs provisions in the bill are proportionate to the job to be done and are necessary. On the CRTC side, this addition is necessary as the regulator transitions from price regulation towards policy-based framework regulation. In short, the CRTC has forborne price regulation and relies upon market competition. It no longer has the enforcement stick of denying requested price increases until a certain regulatory outcome is achieved. In addition, other legislation has already provided the CRTC with AMPs power in the national do-not-call list enforcement and now Canada's anti-spam legislation. So it is incongruous that the CRTC does not have a monetary penalty power for its core jurisdiction of setting conditions of service.
One of the framework measures that the CRTC is now tasked with overseeing and that is close to our heart is the wireless code. At the moment, should a company take a systematic and wrong interpretation of the code to heart, the CRTC can only make an order to stop that conduct in the future and perhaps register it with the Federal Court of Canada for enforcement. However, the telecommunications provider in question can reap any monetary gain from such a breach of the code until such time as it is asked to stop, with no monetary downside. The AMPs provide the CRTC with both the power and the appropriate tool—a monetary fine—to quickly discourage such behaviour.
We note the amounts in question—up to $10 million for a corporation and $15 million for a repeat offence—are identical to the CASL penalties and also the false advertising penalties under the Competition Act. This level of fine is necessary to deter very large corporate service providers that may make many millions more by ignoring a CRTC or Industry Canada interpretation of statutes.
Our second point is about paper bills. PIAC's report on paper bill fees estimated that the cost of only telecommunications and broadcasting service fees to consumers was nearly half a billion dollars a year. As part of this report, PIAC collected the views of consumers through an analysis of a telephone survey. Of Canadians asked, 74% disapproved of the practice of charging people extra for paper bills, 71% approved of offering consumers a discount for electronic billing, and 83% believed receiving a paper bill in the mail is part of the cost of a company doing business.
This legislation became necessary when the CRTC was unable to convince the telecommunication and broadcasting providers to do the right thing and stop charging such fees. We fully support it and we do not support any delays of the kind Mr. Eby has mentioned.
We wanted to note that the information sharing between the CRTC and the Competition Bureau during formal and less formal proceedings will, in our opinion, assist the Competition Bureau in its advocacy work and allow the CRTC to make better decisions in a competitive marketplace.
Lastly, we just wanted to point out that the addition of the new reseller provision Mr. Seidl referred to, while welcome, does hide a jurisdictional issue that this committee should at least publicly air. We'd be happy to answer questions about that.
Thank you.