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Telecom Order CRTC 2025-359

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Gatineau, 18 December 2025

File numbers: 1011-NOC2024-0294 and 4754-773

Determination of costs award with respect to the participation of Canada Deaf Grassroots Movement in the proceeding initiated by Telecom Notice of Consultation 2024-294

Application

  1. By letter dated 21 April 2025, the Canada Deaf Grassroots Movement (CDGM) applied for costs with respect to its participation in the proceeding initiated by Telecom Notice of Consultation 2024-294 (the proceeding). In the proceeding, the Commission called for comments to determine how it can amend the Wireless Code and the Internet Code (the Consumer Protection Codes) to ensure that Canadians can modify or cancel their plans without fees acting as a barrier. The Commission also addressed the amendments to the Telecommunications Act (the Act) set out in An Act to implement certain provisions of the budget tabled in Parliament on April 16, 2024, which require the Commission to prohibit fees whose main purpose is to discourage subscribers from modifying or cancelling their plans.
  2. The Commission did not receive any interventions in response to the application for costs.
  3. The CDGM 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 CDGM has submitted it represents, the CDGM explained that this group or class consists of Deaf, Deaf Indigenous, Hard of Hearing and Deaf-Blind (DDIHHDB) consumers across Canada. The CDGM also submitted that it contributed to a better understanding of the matters under consideration by providing a distinct and unique point of view, especially concerning the impact on persons with disabilities who are directly affected by how service fees, billing practices, and communication methods are designed and delivered by telecommunications service providers (TSPs). In particular, it highlighted the importance of using tools like Video Relay Service (VRS) or texting to support direct and equitable communication with service providers. Further, the CDGM indicated that it participated in the proceeding in a responsible way by submitting comments that were active, focused, and structured, and that its contribution did not duplicate that of the other parties.
  5. The CDGM requested that the Commission fix its costs at $2,887.50, consisting entirely of external consultant fees. The CDGM filed a bill of costs with its application.
  6. The CDGM claimed 20.5 hours for an external consultant at a rate of $110 per hour for work preparing for the proceeding, such as interventions and replies, and the costs application ($2,255). The CDGM also claimed 5.75 hours for another external consultant at a rate of $110 per hour for the same type of work ($632.50).
  7. The CDGM submitted that the TSPs that participated in the proceeding are 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 CDGM has demonstrated that it meets this requirement. The CDGM represented the interests of DDIHHDB consumers who are directly affected by how service fees, billing practices, and communication methods are designed and delivered by TSPs.
  3. The CDGM has also satisfied the remaining criteria through its participation in the proceeding. Its submissions, especially regarding how Canadians with accessibility needs often face additional challenges in accessing and managing their communication services, assisted the Commission in developing a better understanding of the matters that were considered. The CDGM further assisted the Commission by providing a unique point of view as its contribution did not duplicate that of the other parties. The CDGM also participated in the proceeding in a responsible way.
  4. The rates claimed in respect of consultant fees are in accordance with the rates established in the Guidelines for the Assessment of Costs (the Guidelines), as set out in Telecom Regulatory Policy 2010-963. The Commission finds that the total amount claimed by the CDGM was necessarily and reasonably incurred and should be allowed.
  5. 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; Bravo Telecom; 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; Rogers Communications Canada Inc., including Groupe Shaw Group and Shaw Telecom G.P. (Rogers); Saskatchewan Telecommunications; SSi Micro Ltd., carrying on business as SSi Canada; TekSavvy Solutions Inc.; TELUS Communications Inc.; and Xplore Inc.
  6. 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
  7. 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.

  8. Accordingly, the Commission finds that the responsibility for payment of costs should be allocated as follows:Footnote 3

    Company Proportion Amount
    Bell Canada 54.91% $1,585.58
    Rogers 45.09% $1,301.92

Directions regarding costs

  1. The Commission approves the application by CDGM 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 CDGM at $2,887.50.
  3. The Commission directs that the award of costs to CDGM be paid forthwith by Bell Canada and Rogers Communications Canada Inc. according to the proportions set out in paragraph 15.

Secretary General

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