Is there really a difference between charging $2 for a paper bill and providing a $2 discount to those who opt for electronic billing?
In the minds of parliamentarians there is.
Either way, consumers who opt for e-billing pay $2 less than those who still get a paper bill.
But proposed legislation only bans the explicit paper charge, not the e-billing discount. The Broadcast Act is proposed to be amended with:
34.1 No person who carries on a broadcasting undertaking shall charge a subscriber for providing the subscriber with a paper bill.
The Telecom Act is proposed to have a similar amendment, covering telecom services providers, wireless and wireline and including internet service providers. large and small:
27.2 Any person who provides telecommunications services shall not charge a subscriber for providing the subscriber with a paper bill.
These are amendments to the Acts with questionable value for consumers. There are two ways around the proposed law. One is to raise the base price for everyone and then provide a discount for the e-billing customers. The other is for the company to simply not offer paper billing as an option. How many internet service providers or new entrant companies offer only e-billing options?
My member of parliament started a Twitter defense of the new legislation even before the omnibus bill was introduced:
@Mark_Goldberg Paper billing penalty discriminates against long-time older and lower income clients who may not be e-capable
— Peter Kent, MP (@KentThornhillMP) October 16, 2014
He was concerned about seniors and low income Canadians who may not have digital skills or even on-line capabilities. My regular readers know that I share concerns about the failure in leadership to deal with digital literacy and connectivity for disadvantaged groups.
But the reality is that the industry already indicated that it would look after these groups.
The CRTC held a meeting on August 28 to try to get industry wide consensus on such charges for paper bills – in effect, trying to get a competitive industry to collude on whether they would all agree on charges to consumers. The CRTC Vice-Chairs reported:
those companies that charge paper bill fees have agreed to provide exemptions for customers who have no personal or home broadband connection, persons with disabilities who need a paper bill, seniors aged 65 and over and veterans of the Canadian Armed Forces.
So – there goes that rationale for the legislation.
In the meantime, we know that incentives for e-billing lead to dramatically higher adoption of such services. One would have thought that the government would have wanted to encourage the adoption of e-billing. Once again, we see a failure to maintain consistency with a national digital agenda. As I wrote before (in “Don’t do stupid stuff“):
Increasingly, it appears that Canada needs a digital conscience in Ottawa to teach the Obama doctrine: stop doing stupid stuff.
Threatening to introduce legislation to ban charges for paper bills is another in a growing list of actions that are at cross purposes with achieving policy objectives.
I have also written in the past: “it has sometimes been difficult to determine what the government would like to achieve.” It should be simple: Set clear objectives. Align activities with the achievement of those objectives. Stop doing things that are contrary to the objectives.
Years from now, will people look back at the proposed paper billing law and put it in the category of Canada’s Criminal Code ban on crime comics and other strange artifacts of a different era?