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Telecom Order CRTC 2025-356

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Gatineau, 18 December 2025

File numbers: 1011-NOC2024-0293 and 4754-765

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 2024-293

Application

  1. By letter dated 11 April 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 2024-293 (the proceeding). In the proceeding, the Commission sought comments on how to improve the information Canadians receive from their wireless and Internet service providers when their current contract is about to end through the 90-day notice period and when roaming internationally. The proceeding was launched to address certain amendments to the Telecommunications Act (the Act) set out in Division 37 of An Act to implement certain provisions of the budget tabled in Parliament on April 16, 2024.
  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. 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 Deaf, Deaf-Blind, and Hard of Hearing (DDBHH) Canadians who face accessibility challenges, particularly in relation to broadcasting and telecommunications. With respect to the specific methods by which the DWCC has submitted that it represents this group or class, the DWCC explained that it conducted a nationwide survey and researched issues in a fully accessible manner whenever possible.
  5. The DWCC requested that the Commission fix its costs at $54,680, consisting of consultant and analyst fees. The DWCC filed a bill of costs with its application.
  6. The DWCC claimed 167 hours for senior external consultants at a rate of $225 per hour for work on reviewing the file, preparing interventions and comments, preparing evidence, preparing reply comments, case management, preparing procedural letters, and preparing the costs application ($37,575). The DWCC also claimed 121 hours for a junior external analyst at a rate of $110 per hour to review the file, prepare interventions and comments, prepare evidence, prepare reply comments, and prepare the costs application ($13,310), as well as 23 hours at a rate of $165 per hour for an intermediate external analyst to prepare evidence ($3,795).
  7. The DWCC submitted that the telecommunications service providers who have an interest in the proceeding are the appropriate parties to be required to pay any costs awarded by the Commission (the costs respondents).
  8. The DWCC suggested that the responsibility for payment of costs should be divided among the costs respondents on the basis of their telecommunications operating revenues.

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 represents the interests of DDBHH Canadians who face accessibility challenges, particularly in relation to broadcasting and telecommunications. This group has an interest in the proceeding because they could be affected by the adequacy and formats of the information included in customer notifications and wireless accessibility plans.
  3. The DWCC also satisfied the remaining criteria through its participation in the proceeding. In particular, the DWCC’s submissions, including a nationwide survey and an infographic poster which visually summarized key points of DDBHH Canadians’ experiences on receiving customer notifications from wireless phone and Internet service providers, assisted the Commission in developing a better understanding of the matters that were considered. The DWCC further assisted the Commission by providing a unique viewpoint on the consumers’ need for information and accessibility plans, and proposing recommendations aimed at enhancing the customer notification experience of DDBHH Canadians. The DWCC also participated in a responsible way by being actively engaged throughout the proceeding and submitting comprehensive intervention documents.
  4. The rates claimed in respect of consultant and analyst 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;Footnote 1 Bragg Communications Inc., carrying on business as Eastlink; Cogeco Communications Inc., on behalf of its subsidiary Cogeco Connexion Inc.; Iristel Inc.; 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 Groupe Shaw Group and Shaw Telecom G.P. (Rogers); Saskatchewan Telecommunications (SaskTel); SSi Micro Ltd., doing business as SSi Canada; TBayTel; TekSavvy Solutions Inc.; TELUS Communications Inc. (TELUS); and Xplore Inc.
  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 35.83% $19,591.84
    Rogers 29.42% $16,086.86
    TELUS 24.97% $13,653.60
    Quebecor 7.60% $4,155.68
    SaskTel 2.18% $1,192.02

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 Act, the Commission fixes the costs to be paid to the DWCC at $54,680.
  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., Quebecor Media Inc., and Saskatchewan Telecommunications according to the proportions set out in paragraph 17.

Secretary General

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