Telecom Order CRTC 2026-49

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Gatineau, 24 March 2026

File numbers: 1011-NOC2025-0020 and 4754-805

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

Application

1. By letter dated 15 September 2025, the Deaf Wireless Canada Consultative Committee (DWCC) applied for costs with respect to its participation in the additional process initiated by Telecom Notice of Consultation 2025-20 (the proceeding). In that notice of consultation, the Commission sought comments on how to improve the routing of 9-8-8 calls and texts. The additional process was introduced by a Commission staff letter requesting the Centre for Addiction and Mental Health (CAMH) to file responses to questions and seeking replies to CAMH’s responses. The DWCC filed a reply to CAMH’s responses.
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 four consultants, each of whom provided unique expertise in psychology and mental health. The DWCC further highlighted that its reply was necessary to ensure that accessibility issues affecting DDBHH Canadians were fully considered in the Commission’s assessment of CAMH’s proposal.
6. The DWCC requested that the Commission fix its costs at $12,000, consisting entirely of consultant fees. The DWCC filed a bill of costs with its application.
7. The DWCC claimed 46 hours at a rate of $225 per hour and 15 hours at a rate of $110 per hour for consultant fees, consisting of work to review the file and prepare the reply comments ($10,350 and $1,650, respectively) to respond to CAMH’s answer to the Commission’s request for information (RFI).
8. The DWCC submitted that the 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).
9. 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 (TORs). Footnote 1

RFI

1. On 8 December 2025, an RFI was sent to the DWCC seeking to gather more detailed information on the exact work undertaken by each consultant and how that work contributed to the DWCC’s reply.
2. The RFI also asked for further justification as to why four consultants were needed to prepare the reply, and how the work undertaken by each consultant differed.

Answer

1. In its answer to the 8 December 2025 RFI, the DWCC provided detailed hourly records for the work undertaken by each consultant who worked on the reply.
2. The DWCC also submitted that the use of three senior consultants and one junior consultant was reasonable and proportionate given the complexity, sensitivity, and interdisciplinary nature of the issues raised in CAMH’s response to the previous RFI.
3. The DWCC outlined how CAMH’s response raised clinical, operational, and policy considerations that required expert review from different perspectives. The DWCC submitted that its reply therefore needed to address technical feasibility along with risk, safety, lived experiences, and systemic accessibility impacts.
4. To provide an extensive reply, the DWCC indicated that it relied on each consultant to provide distinct, non-duplicative expertise that was essential to the reply. The DWCC submitted that this group of consultants reflected the most efficient and reasonable allocation of work, ensuring that tasks were performed at the lowest level of seniority while maintaining the quality and integrity of the reply.

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 ensured that accessibility issues affecting DDBHH Canadians were placed on the record for the Commission’s assessment of CAMH’s proposal.
3. The DWCC has also satisfied the remaining criteria through its participation in the proceeding. The DWCC incurred costs in replying to CAMH’s responses that specifically related to the unique psychological and mental health needs of DDBHH Canadians in relation to 9-8-8 services, and its submissions assisted the Commission in developing a better understanding of the matters that were considered. The DWCC also participated responsibly in the proceeding.
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 is of the view that the DWCC’s rationale for the number of consultants provided in its answer to the RFI is reasonable and recognizes the unique knowledge and background each brought forward when preparing the reply. In the Commission’s view, the explanation as to why there was a delineation between senior and junior consultants is sufficient given the more limited role undertaken by the junior consultant in the preparation of the reply. Accordingly, 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 Groupe Shaw Group and Shaw Telecom G.P. (Rogers); 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 TORs as an indicator of the relative size and interest of the parties involved in the proceeding.
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 2

| Company | Proportion | Amount |
| --- | --- | --- |
| Bell Canada | 35.10% | $4,212.00 |
| Rogers | 29.57% | $3,548.40 |
| TELUS | 25.59% | $3,070.80 |
| Quebecor | 9.74% | $1,168.80 |

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 $12,000.
3. The Commission directs that the award of costs to the DWCC be paid forthwith by Bell Canada, Quebecor Media Inc., Rogers Communications Canada Inc., and TELUS Communications Inc. according to the proportions set out in paragraph 24. Secretary General

Related documents

• Call for comments – Improving the routing of 9-8-8 calls and texts, Telecom Notice of Consultation CRTC 2025-20, 27 January 2025, as amended by Telecom Notice of Consultation CRTC 2025-20-1, 7 March 2025
• Guidance for costs award applicants regarding representation of a group or a class of subscribers, Telecom Information Bulletin CRTC 2016-188, 17 May 2016
• 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
• New procedure for Telecom costs awards, Telecom Public Notice CRTC 2002-5, 7 November 2002

Footnotes

Footnote 1 TORs consist of Canadian telecommunications revenues from local and access, long distance, data, private line, Internet, and wireless services.

Return to footnote 1 referrer

Footnote 2 In this order, the Commission has used the TORs of the costs respondents based on their most recent audited financial statements.

Return to footnote 2 referrer

Date modified:

2026-03-24