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Telecom - Staff Letter addressed to Jeffrey Beatty (Deaf Wireless Canada Consultative Committee)

Gatineau, 8 December 2025

Our reference: 1011-NOC2025-0020; 2025-20

BY EMAIL

Jeffrey Beatty
Chairperson
Deaf Wireless Canada Consultative Committee
405-15 Wellington Dr.,
Picton, Ontario, K0K 2T0
regulatory@deafwireless.ca

Subject: Request for information – Application for costs award with respect to supplemental participation in Call for comments – Improving the routing of 9-8-8 calls and texts

Dear Jeffrey Beatty:

On 15 September 2025, the Canadian Radio-television and Telecommunications Commission received an application for costs from the Deaf Wireless Canada Consultative Committee (DWCC) with respect to its supplemental participation in Telecom Notice of Consultation CRTC 2025-20 (TNC 2025-20) regarding improving the routing of 9-8-8 calls and texts.

The purpose of this letter is to request information from DWCC regarding its application for supplemental costs. Commission staff sends Requests for Information such as this one in an effort to gather all information required to process cost applications.

DWCC is requested to provide the information requested below no later than January 5th, 2026.

A copy of this letter and all related correspondence will be added to the public record of the proceeding.

Yours sincerely,

Originally signed by

Galen Teschner-Weaver
Legal Counsel

Requests for Information

  1. Time records

    In its initial cost application filed on 12 May 2025, the DWCC included a detailed breakdown of the work undertaken by each consultant to prepare the initial intervention and reply in TNC 2025-20. However, in the supplemental cost application, the DWCC does not include this more detailed breakdown of the work undertaken. Commission staff requests that the DWCC provide more detailed hourly records for each of the consultants who worked on the DWCC’s supplemental reply. This information is requested pursuant to paragraph 16 of Telecom Regulatory Policy CRTC 2010-963 – Revision of CRTC costs award practices and procedures (TRP 2010-963), which states as follows:

    16. If the applicant is claiming costs which are to be calculated on an hourly basis, all persons for whom work is being so claimed must keep hourly records which may be requested by the Commission. Hourly records must contain at least the following information: the date on which the work was done, the amount of time spent on the work and a brief description of that work. In the event that the Commission requests such records and they are not available, the applicant’s claim in respect of that work will generally be disallowed in its entirety.
    1. Please provide detailed copies of your hourly records, detailing the work completed and time spent on tasks in the same format as the first cost application filed on 12 May 2025. These records should clearly outline the specific work undertaken by each consultant and how that work contributed to the reply.

  2. Preparation of Reply

    TRP 2010-963 states that when evaluating whether or not the time expended by a claimant is excessive under the circumstances, the considerations that the Commission will generally take into account include:

    1. The extent of the applicant’s participation, the degrees of complexity of the issues to which that participation related, and the amount of documentation involved in the proceeding;
    2. The degree of responsibility assumed by the claimant;
    3. The duplication of substantive submissions among claimants;
    4. The experience and expertise of the claimant; and
    5. The time claimed and awarded in the proceeding or in other similar proceedings.

    The considerations listed above are not exhaustive and the factors considered are entirely within the discretion of the Commission, depending on the circumstances of each case.

    In your cost application, you indicate that three senior consultants prepared the reply comments amounting to a total of 34 hours while the junior consultant prepared the response to the CAMH answer to the CRTC RFI for 12 hours.

    1. Please provide further justification as to why three senior consultants and one junior consultant were needed to prepare the DWCCs reply.
    2. Please clarify why the work undertaken by the junior consultant is categorized differently than the work undertaken by the other three consultants.
    3. Please provide more details on how the work undertaken differed between the junior and senior consultants when preparing the DWCCs reply.

c.c.:
Bell Canada: bell.regulatory@bell.ca
Bragg Communications: regulatory.matters@corp.eastlink.ca
Quebecor Media Inc. : regaffairs@quebecor.com
Rogers Communications Canada Inc.: regulatory@rci.rogers.com
Saskatchewan Telecommunications : document.control@sasktel.com
TBayTel: laura.foulds@tbaytel.com
TELUS Communications Inc. : regulatory.affairs@telus.com

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