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

Gatineau, 26 March 2026

Our reference: 1011-NOC2024-0318; 1011-NOC2025-0227; 1011-NOC2025-0094; 1011-NOC2025-0180

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 – Costs applications submitted by the Deaf Wireless Canada Consultative Committee

Dear Jeffrey Beatty:

The purpose of this letter is to request information from the Deaf Wireless Canada Consultative Committee (DWCC) regarding certain commonalities in its approach to cost applications in the above noted proceedings. Commission staff understands the distinct accessibility considerations of the DWCC as it represents Deaf, Deaf-Blind and Hard of Hearing (DDBHH) communities across Canada. Furthermore, Commission staff recognizes how this representation of DDBHH Canadians may impact the preparation of interventions and other submissions to the Commission.

Costs applications must be examined with rigour to ensure that they align with the legislation and applicable guidelines. In fixing costs, the Commission must, among other things: 1) review the costs that will ultimately be paid by costs respondents to ensure that the total amount of the costs does not exceed the costs necessarily and reasonably incurred by the cost applicant (DWCC); and 2) avoid circumstances in which the cost applicant (DWCC) incurs costs that would not be recoverable under the costs awards regime.

To gain a better understanding of the common questions that arise in relation to the above noted costs applications, Commission staff is seeking a better understanding of how the DWCC develops its interventions and replies to inform the analysis of current and any future costs applications that are brought forward to the Commission for determination.

DWCC is asked to provide the information requested below no later than 9 April 2026.

A copy of this letter and all related correspondence will be added to the public record of the following proceedings: 1011-NOC2024-0318; 1011-NOC2025-0227; 1011-NOC2025-0094; 1011-NOC2025-0180

Yours sincerely,

Originally signed by

Galen Teschner-Weaver
Legal Counsel

Requests for Information

  1. DWCC often relies on several different consultants and/or analysts when preparing its interventions in a given proceeding. For example, in the open costs applications, DWCC claims the following:

    Proceeding Number of Consultants
    1011-NOC2025-0094 6 consultants (4 senior and 2 junior)
    1 analyst
    1011-NOC2025-0227 2 consultants (2 senior)
    1011-NOC2024-0318 3 consultants (2 senior and 1 junior)
    1011-NOC2025-0180 4 consultants (3 senior, 1 junior)
    2 analysts (1 intermediate, 1 junior)
    1. Please explain how the DWCC assesses the consultant assistance that is reasonable and necessary for its participation in a given proceeding.
    2. Please explain why and in what scenarios the DWCC relies on senior or junior consultants to complete certain tasks.

  2. DWCC claims all of its fees at the applicable rates for external consultants and external analysts.

    1. Please explain whether DWCC has any in-house consultants or analysts. If it does, explain why inside resources are not used to work on Commission files. In formulating your response, please refer to paragraph 20 of the Guidelines for the Assessment of Costs and the factors set out by the Commission at paragraphs 11 and 12 of Telecom Order CRTC 2014-351.

    2. How does DWCC account for work already done or knowledge already held when it assesses time spent on preparing a submission? For instance, how does DWCC calculate time spent on preparing reply submissions that restate initial submissions, or how does DWCC account for existing knowledge of Commission rules and practices when it calculates time spent on submissions?

      • For example, in its costs application for the proceeding initiated by NoC 2025-180, DWCC claimed costs for 4 consultants and 2 analysts, but stated in its intervention that DWCC members bring extensive expertise, experience, and involvement in CRTC proceedings. Similarly, in a second example, in its costs application for the proceeding initiated by NoC 2025-94, the DWCC claimed costs for 6 consultants and one analyst but in its intervention highlighted its extensive experience in CRTC participation that helped to inform the submissions.
    3. Please comment on the possibility that the Commission may reduce the claimed hours by the DWCC, should the Commission find that the number of consultants used, and the amount of time required to prepare a submission is excessive considering the expertise that the DWCC already has developed in Commission processes.

  3. DWCC relies on infographics and other similar visuals in many of its submissionsFootnote 1. In the proceeding initiated by NoC 2025-94, DWCC claimed 29 hours of work by a senior consultant and an analyst on infographics, many of which appear to be duplicative in their format and content, totaling $3,305. This represents 6.5% of the total amount claimed for consultants and analysts' fees for final costs.

    1. Please provide further clarification as to how these infographics and other visuals, in general, contribute to the accessibility of the DWCC’s submissions while also helping to better inform the Commission.
    2. Should the Commission find that the time spent on the creation of these infographics is excessive considering the potential duplicative output they provide, please comment on the possibility that the Commission may reduce the claimed hours by the DWCC.

  4. In the event that the Commission were to reduce the claimed hours by the DWCC and without limiting the Commission's discretion, please comment on these potential approaches:

    1. Limiting the number of hours recoverable for certain consultants depending on work undertaken by each consultant;
    2. Restricting the number of hours that can be claimed based on whether they are attributed to senior or junior consultants;
    3. Applying an appropriate percentage reduction across the total hours claimed with consideration of the work undertaken; or
    4. Reducing the hours claimed that appear to the Commission to be duplicative, excessive, or insufficiently documented.

c.c.:
Access Communications Co-operative Limited: documents@myaccess.coop
Bell Canada: bell.regulatory@bell.ca
Bragg Communications Inc. (Eastlink): regulatory.matters@corp.eastlink.ca
Cogeco Connexion Inc.: telecom.regulatory@cogeco.com
Eeyou Communications Network: alfred.loon@cngov.ca
Iristel Inc.: regulatory@iristel.com
Québecor Media Inc.: Regulatory regaffairs@quebecor.com
Rogers Communications Canada Inc.: regulatory@rci.rogers.com
Saskatchewan Telecommunications: document.control@sasktel.com
TekSavvy Solutions Inc.: regulatory@teksavvy.ca
TELUS Communications Inc.: regulatory.affairs@telus.com
Terrestar Solutions Inc.: reglementaire-regulatory@terrestar.ca
Xplore Inc.: legal@xplore.ca

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