Thank you, Mr. Chairman.
I'm Kurt Eby. I'm the director of regulatory affairs and government relations at CWTA. Bernard sends his regrets.
I'll be brief. I'm here to talk about one specific aspect of Bill C-43, and that is the amendments to the telecom act that would impose a prohibition on charging for paper bills. We just have a couple of things we wanted to talk about on that and answer questions.
Basically, this industry has been trying to move to electronic billing like many other industries. The government, for example, is phasing out paper cheques by April 2016. It's the same kind of principle, and we're facing the same challenges that were faced when companies went to direct deposit payments and we implemented automated teller machines. A number of practices have been tried to entice people to move to electronic billing. These include credits, discounts, offering reward miles, donations to charitable causes, and of course, charging to receive a paper bill. Bill C-43 proposes to remove that particular option, of course, and we just have a couple of comments and requests for the committee regarding some amendments to the bill in that respect.
The first one is about to whom this prohibition would apply. We think, as the government has stated publicly, that this should apply to individual consumers and not to businesses. Our request is that particular clause, clause 194 in the bill, be amended to read:
Any person who provides telecommunication services shall not charge an individual or small business subscriber for providing the subscriber with a paper bill.
Right now, it just says “subscriber”.
That definition of “small business” is already used by the commissioner for complaints about telecommunications services, and is used in the wireless code by the CRTC. The definition is that a small business is a business whose average monthly telecommunications bill is under $2,500. Businesses above that, corporate accounts, we think have the power and the ability to negotiate the full extent of their agreement, which would include how they receive a bill or invoice, and what goes on in that manner. We think this bill, as the government has stated, this proposal, which is to put more money back in the pockets of hard-working Canadian families, should be limited to families and individual accounts.
Our second request is regarding the coming into force period. A couple of weeks ago Industry Canada told this committee it had not undertaken consultation with the telecommunications industry with respect to how ready they would be to implement this. Our members have confirmed to us that it would be difficult if not impossible to effectively coordinate all of the IT system changes necessary to comply with this by, basically, January, when it could come into force. They have indicated that March 31, 2015, which is slightly more than five months from when the bill was introduced, would be an appropriate time to make sure that everything came into effect effectively and reasonably, and everyone would see that change uniformly.
That's all. I'm happy to answer any questions on that.