Search

Telecom Order CRTC 2025-364

PDF version

Gatineau, 18 December 2025

File numbers: 1101-NOC2024-0295 and 4754-783

Determination of costs award with respect to the participation of l’Union des consommateurs in the proceeding initiated by Telecom Notice of Consultation 2024-295

Application

  1. By letter dated 25 April 2025, l’Union des consommateurs (l’Union) applied for costs with respect to its participation in the proceeding initiated by Telecom Notice of Consultation 2024-295 (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) by requiring the provision of self-service mechanisms in a way that would be useful to Canadians. 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 impose the provision of self-service mechanisms that allow Canadians to cancel or modify their plans.
  2. The Commission did not receive any interventions in response to the application for costs.
  3. L’Union 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 l’Union has submitted it represents, l’Union explained that this group or class consists of 15 groups that defend consumer rights, especially low-income consumers, mainly in the province of Quebec. L’Union also submitted that it contributed to a better understanding of the matters under consideration by providing submissions that included comments focusing on, among other things, the importance of standardizing how cellphone plan information is presented in self-service mechanisms to help consumers compare offered plans. L’Union also submitted that affordable cellphone plans should be displayed prominently and be easy to find, and that discounted or promotional prices should never be displayed on their own without the regular price. Furthermore, l’Union submitted that it participated in the proceeding in a responsible way by complying with the Commission’s Rules of Procedure.
  5. L’Union requested that the Commission fix its costs at $1,410, consisting entirely of in-house analyst fees. L’Union filed a bill of costs with its application.
  6. L’Union claimed two days for an in-house analyst at a rate of $470 per day to review the file, prepare interventions and comments, and conduct research ($940). L’Union also claimed one day for another in-house analyst at a rate of $470 per day to prepare interventions and comments ($470).
  7. L’Union submitted that all telecommunications service providers that participated in the proceeding are the appropriate parties to be required to pay any costs awarded by the Commission (the costs respondents) because they had the most significant interest in the outcome of the proceeding.
  8. L’Union suggested that the responsibility for payment of costs should be divided among the costs respondents on the basis of their gross 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, l’Union has demonstrated that it meets this requirement. L’Union represents the interests of consumers, in particular those in Quebec and in low-income households. This group has an interest in the proceeding because the vast majority of Quebec consumers have wireless or Internet plans and could be affected by the adoption of self-service mechanisms and the way the prices and plans are presented on these mechanisms, the way they can be accessed, and the costs that are associated with them.
  3. L’Union has also satisfied the remaining criteria through its participation in the proceeding. In particular, l’Union’s submissions, especially regarding the importance of standardizing how cellphone plan information is presented in self-service mechanisms so that consumers can more easily compare offered plans, ensuring that affordable cellphone plans are displayed prominently and conveniently, and displaying discounted or promotional prices together with regular prices so that they are never displayed on their own, assisted the Commission in developing a better understanding of the matters that were considered. Furthermore, l’Union participated in the proceeding in a responsible way.
  4. The rates claimed in respect of analyst 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 l’Union 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; 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.; Saskatchewan Telecommunications; SSi Micro Ltd., carrying on business as SSi Canada; TBayTel; 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 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 100% $1,410

Directions regarding costs

  1. The Commission approves the application by l’Union 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 l’Union at $1,410.
  3. The Commission directs that the award of costs to l’Union be paid forthwith by Bell Canada according to the proportions set out in paragraph 16.

Secretary General

Related documents

Date modified: