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Telecom Order CRTC 2025-216

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Gatineau, 26 August 2025

File numbers: 1011-NOC2025-0020 and 4754-786

Determination of costs award with respect to the participation of the Deaf Wireless Canada Consultative Committee in the proceeding initiated by Telecom Notice of Consultation 2025-20

Application

  1. By letter dated 12 May 2025, the Deaf Wireless Canada Consultative Committee (DWCC) applied for costs with respect to its participation in the proceeding initiated by Telecom Notice of Consultation 2025-20 (the proceeding). In the proceeding, the Commission sought comments on how to improve the routing of 9-8-8 calls and texts.
  2. The Commission did not receive any interventions in response to the application for costs.
  3. The DWCC submitted that it had met the criteria for an award of costs set out in section 68 of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure (the Rules of Procedure) because it represented a group or class of subscribers that had an interest in the outcome of the proceeding, it had assisted the Commission in developing a better understanding of the matters that were considered, and it had participated in a responsible way.
  4. In particular, the DWCC submitted that it represents the interests of a particular, specific, and distinct group of Deaf, Deaf-Blind, and Hard of Hearing (DDBHH) Canadians. The DWCC also submitted that its contribution did not duplicate that of the other public interest parties because it represents this distinct group of DDBHH Canadians.
  5. With respect to the group or class of subscribers that the DWCC has submitted it represents, the DWCC explained that this group or class consists of DDBHH individuals from intersectional backgrounds, and that their primary languages are American Sign Language and Langue des signes québécoise. With respect to the specific methods by which the DWCC has submitted that it represents this group or class, the DWCC explained that it brought together responses from team members who contributed their perspectives and experiences. Additionally, the DWCC conducted a nationwide survey to gather insights on the lived experiences of DDBHH Canadians in receiving customer notifications from their wireless phone and Internet services provider on a daily basis.
  6. The DWCC requested that the Commission fix its costs at $36,373.21, consisting of $30,150 for consultant fees and $6,223.21 for disbursements. The DWCC filed a bill of costs with its application.
  7. The DWCC claimed 134 hours at a rate of $225 per hour for consultant fees, consisting of work to review the file; prepare the application, interventions, evidence, reply comments, and costs application; and procedural letters. The DWCC also claimed $6,223.21 for disbursements. This includes $565 and $358.21 for work by CB Linguistic Services, $4,100 for accessibility-focused media production, and $1,200 for a 9-8-8 social media campaign.
  8. The DWCC made no submission as to the appropriate parties to be required to pay any costs awarded by the Commission (the costs respondents).

Commission’s analysis

  1. The criteria for an award of costs are set out in section 68 of the Rules of Procedure, which reads as follows:
    1. The Commission must determine whether to award final costs and the maximum percentage of costs that is to be awarded on the basis of the following criteria:


      (a) whether the applicant had, or was the representative of a group or a class of subscribers that had, an interest in the outcome of the proceeding;

      (b) the extent to which the applicant assisted the Commission in developing a better understanding of the matters that were considered; and

      (c) whether the applicant participated in the proceeding in a responsible way.

  2. In Telecom Information Bulletin 2016-188, the Commission provided guidance regarding how an applicant may demonstrate that it satisfies the first criterion with respect to its representation of interested subscribers. In the present case, the DWCC has demonstrated that it meets this requirement. The DWCC conducted a nationwide survey to gather insights on the lived experiences of DDBHH Canadians in receiving customer notifications from their wireless phone and Internet services provider on a daily basis.
  3. The DWCC has also satisfied the remaining criteria through its participation in the proceeding. In particular, the DWCC played a key role in helping the Commission’s understanding of the accessibility needs of DDBHH Canadians regarding the future provision of 9-8-8 services. This included contributions to the public record that offered realistic, practical, and culturally grounded recommendations. These recommendations were aimed at ensuring that 9-8-8 services are fully accessible and responsive to the linguistic and communication needs of DDBHH individuals across Canada. Accordingly, the Commission finds that the applicant meets the criteria for an award of costs under section 68 of the Rules of Procedure.
  4. The rates claimed in respect of consultant fees are in accordance with the rates established in the Guidelines for the Assessment of Costs, as set out in Telecom Regulatory Policy 2010-963. The Commission finds that the total amount claimed by the DWCC was necessarily and reasonably incurred and should be allowed.
  5. This is an appropriate case in which to fix the costs and dispense with taxation, in accordance with the streamlined procedure set out in Telecom Public Notice 2002-5.
  6. The Commission has generally determined that the appropriate costs respondents to an award of costs are the parties that have a significant interest in the outcome of the proceeding in question and have participated actively in that proceeding. The Commission considers that the following parties had a significant interest in the outcome of the proceeding and participated actively in the proceeding: Bell Canada, including Bell Mobility Inc.; Bragg Communications Inc., carrying on business as Eastlink; Quebecor Media Inc., on behalf of its affiliates Videotron Ltd. and Freedom Mobile Inc. and their brands Fizz and VMedia (Quebecor); Rogers Communications Canada Inc., including Shaw Cablesystems G.P. and Groupe Shaw Group (Rogers);Footnote 1 Saskatchewan Telecommunications; TBayTel; and TELUS Communications Inc. (TELUS).
  7. The Commission considers that, consistent with its practice, it is appropriate to allocate the responsibility for payment of costs among costs respondents based on their telecommunications operating revenues (TORs) as an indicator of the relative size and interest of the parties involved in the proceeding.Footnote 2
  8. However, as set out in Telecom Order 2015-160, the Commission considers $1,000 to be the minimum amount that a costs respondent should be required to pay, due to the administrative burden that small costs awards impose on both the applicant and costs respondents.
  9. Accordingly, the Commission finds that the responsibility for payment of costs should be allocated as follows:Footnote 3
    Company Proportion Amount
    Bell Canada    35.86% $13,043.43
    Rogers 30.52% $11,101.11
    TELUS 25.78% $9,377.01
    Quebecor 7.84% $2,851.66

Directions regarding costs

  1. The Commission approves the application by the DWCC for costs with respect to its participation in the proceeding.
  2. Pursuant to subsection 56(1) of the Telecommunications Act, the Commission fixes the costs to be paid to the DWCC at $36,373.21.
  3. The Commission directs that the award of costs to the DWCC be paid forthwith by Bell Canada, Rogers Communications Canada Inc., TELUS Communications Inc., and Quebecor Media Inc. according to the proportions set out in paragraph 17.

Secretary General

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