Telecom Order CRTC 2025-219

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Gatineau, 27 August 2025

File numbers: 1011-NOC2025-0094 and 4754-793

Determination of interim costs award with respect to the participation of the Canadian Anti-Monopoly Project in the proceeding initiated by Broadcasting and Telecom Notice of Consultation 2025-94

Summary

The Commission is an administrative tribunal with quasi-judicial functions responsible for regulating the Canadian communications sector. To make decisions in the public interest, the Commission encourages people with a diversity of perspectives to participate in its proceedings.

In this order, the Commission approves interim costs for the Canadian Anti-Monopoly Project to support its participation in Broadcasting and Telecom Notice of Consultation 2025-94. In that proceeding, the Commission is gathering views on how it can better support people, including public interest groups, to participate in its proceedings. Any applicants that receive interim costs will still be required to file for final costs to confirm that the amounts were spent.

Awarding interim costs provides groups who represent the public interest with funding up front, which can help support their participation and encourage broader participation from those who might otherwise not participate.

Background

1. In Broadcasting and Telecom Notice of Consultation 2025-94, the Commission created a simplified process for awarding costs to encourage broader participation. All costs applications are being reviewed and processed using the telecommunications costs process.
2. Applicants must demonstrate that they meet most of the criteria for interim costs awards set out in section 63 of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure. Specifically, they must show that they will represent a group or class of subscribers that has an interest in the outcome of the proceeding and that they can assist the Commission in developing a better understanding of the matters to be considered. They must also undertake to participate in the proceeding in a responsible way. However, applicants do not need to show that they have insufficient financial resources to participate effectively in the proceeding without these costs.
3. The Commission named the following parties as the most likely parties to be required to pay any interim costs awarded by the Commission (costs respondents):
   • Bell Canada;
   • Cogeco Connexion Inc.;
   • Quebecor Media Inc.;
   • Rogers Communications Canada Inc. (Rogers);
   • Saskatchewan Telecommunications; and
   • TELUS Communications Inc. (TELUS).

Application

4. The Canadian Anti-Monopoly Project (CAMP) applied for interim costs with respect to its participation in Broadcasting and Telecom Notice of Consultation 2025-94 (the proceeding). In the proceeding, the Commission is gathering views on how it can better support people, including public interest groups, to participate in its proceedings.
5. CAMP submitted that it meets the simplified criteria for interim costs set out in Broadcasting and Telecom Notice of Consultation 2025-94.
6. CAMP submitted that it represents the interests of the general public because it helps ensure that Canada’s communications sector is fair, competitive, and democratic. CAMP also outlined that its mandate and research agenda, which focus on market concentration and how that impacts consumers, innovation, and public discourse, are intrinsically linked to the public’s ability to engage meaningfully with the Commission.
7. CAMP submitted that it will represent the public interest by drawing from its anti-monopoly research and advocacy perspective to assist the Commission in diversifying public engagement, particularly among groups with limited resources. More specifically, CAMP plans to research and identify participation structures that are skewed by market power imbalances and examine how funding rules can either promote more equitable participation or favour participation by parties with more resources.
8. CAMP requested that the Commission fix its interim costs at $6,915.60, which includes the Ontario Harmonized Sales Tax (HST) and consists of consultant fees. CAMP filed an estimated bill of costs with its application.
9. CAMP claimed that its submission will take approximately 51 hours of work at a rate of $120 per hour for a consultant to review the record, conduct research, analyze issues, and prepare initial and reply comments.
10. CAMP submitted that telecommunications service providers, broadcasting distribution undertakings, and potentially online streaming services are likely respondents.

Answer

11. TELUS filed an intervention, dated 23 June 2025, in response to applications submitted by CAMP, the Deaf Wireless Canada Consultative Committee, and the Public Interest Advocacy Centre. TELUS did not object to CAMP’s eligibility for interim costs payments or the amount CAMP claimed. It did, however, argue that the Commission should call on the Broadcasting Participation Fund (BPF) to review the costs and provide up to 50% of the claimed amount because the proceeding concerns both telecommunications and broadcasting.
12. Rogers also intervened, objecting to CAMP’s interim costs application. Rogers argued that CAMP failed to meet the Commission’s subscriber representation requirement since CAMP operates as a policy advocacy organization representing broad ideological interests rather than a specific group or class of subscribers. Rogers also disagreed with the Commission’s decision to waive the requirement for interim costs applicants to demonstrate that they lack sufficient resources for effective participation in the proceeding. According to Rogers, this consideration is highly relevant, especially because CAMP appears to be well-resourced.

Reply

13. CAMP argued that Rogers’ objections are without merit given that telecommunications services are essential for anyone to participate in economic, social, and civic life; in other words, every Canadian is effectively a telecommunication service subscriber or potential subscriber. CAMP also noted that it represents an identifiable group of subscribers who are concerned with the state of competition, namely the 1,100 Canadians who subscribe to its newsletter and the 1,400 who follow its professional analysis. CAMP emphasized that costs awards enable organizations to participate in specific and resource-intensive proceedings without forcing them to abandon their other essential work. As CAMP’s operational funding is fully allocated, its participation in the proceeding is contingent on an award of costs. Without such an award, CAMP would simply lack sufficient resources to participate fully and meaningfully in the proceeding.

Commission’s analysis

14. The Commission considers that CAMP demonstrated that it meets the streamlined criteria set out in Broadcasting and Telecom Notice of Consultation 2025-94. More specifically, CAMP represents a broad range of views and the subscribers who support its research and advocacy in market concentration and anti-monopoly issues. The Commission considers that this will contribute to a better understanding of the matters being considered by the Commission.
15. Moreover, CAMP proposed to use the interim funds it receives to hire a consultant in policy communications who will review the record, conduct research, and prepare its submissions.
16. The rates claimed for interim costs are generally 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 interim amount claimed by CAMP should be allowed.
17. The Commission notes that CAMP must be able to collect any awarded interim costs in a timely manner to participate effectively in the proceeding. Given the circumstances, the Commission considers it appropriate to limit the interim costs respondents to those previously identified in paragraph 3.
18. Regarding TELUS’s proposal to have BPF provide 50% of the costs in the proceeding, the Commission determined that it would be more efficient from an administrative standpoint to rely exclusively on the telecom costs regime to determine how to award interim costs. While the Commission has split costs between the BPF and its own telecom costs award process for combined proceedings in the past, it is not necessary to do so in the proceeding because the issues are so intertwined.
19. In response to Rogers’ submission outlining their objections to CAMP’s costs application, the Commission notes that it intentionally removed its own requirement to have costs applicants demonstrate that they lack sufficient resources to reduce barriers to participation in the proceeding. Consequently, the Commission considers that CAMP met the eligibility criteria for interim costs awards: first, CAMP adequately described the subscribers it represents, and second, CAMP clarified in its reply that its existing funding is fully committed elsewhere, specifying that any interim costs awarded would be used exclusively for preparing its intervention in the proceeding. The Commission therefore considers that this is sufficient to justify an interim award of costs in the proceeding.
20. Consistent with its practice, the Commission considers it 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 1}
21. 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.
22. Accordingly, the Commission finds that the responsibility for payment of interim costs should be allocated as follows:^{Footnote 2}

    Company	Proportion	Amount
    RogersFootnote 3	41.43%	$2,865.39
    TELUS	35.17%	$2,431.95
    Bell Canada	23.40%	$1,618.26

23. CAMP will need to apply for final costs at the end of the proceeding. This means that CAMP will be required to demonstrate how it assisted the Commission in developing a better understanding of the matters to be considered, account for the amount claimed using written documentation, and demonstrate that its group spent the funds provided responsibly. At that time, the Commission will be able to consider how to allocate costs amongst costs respondents most appropriately. The costs respondents will bear the costs of any reallocation as appropriate.

Directions regarding costs

24. The Commission approves the application by CAMP for interim costs with respect to its participation in the proceeding.
25. Pursuant to subsection 56(1) of the Telecommunications Act, the Commission fixes the costs to be paid to CAMP at $6,915.60.
26. The Commission directs that the award of interim costs to CAMP be paid forthwith by Rogers Communications Canada Inc., TELUS Communications Inc., and Bell Canada according to the proportions set out in paragraph 22.
27. CAMP is directed to file an application for final costs no later than 30 days after the close of the record in the proceeding.

Secretary General

Related documents

• Call for comments – A new approach to funding public interest participation in Commission proceedings, Broadcasting and Telecom Notice of Consultation CRTC 2025-94, 12 May 2025
• Determination of costs award with respect to the participation of the Ontario Video Relay Service Committee in the proceeding initiated by Telecom Notice of Consultation 2014-188, Telecom Order CRTC 2015-160, 23 April 2015
• Revision of CRTC costs award practices and procedures, Telecom Regulatory Policy CRTC 2010-963, 23 December 2010

Date modified:

2025-08-27