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Telecom - Staff Letter addressed to the Deaf and Hard of Hearing Coalition

Gatineau, 21 January 2026

Our reference: 8665-D112-202502708; 8665-C423-202502723; 2025-54

BY EMAIL

Donald Prong
Executive Director, Ontario Association of the Deaf
dprong@deafontario.ca

Myles Murphy
Executive Director, Newfoundland and Labrador Association of the Deaf
myles.murphy@nf.sympatico.ca

Elliot Richman
Consultant
richmanelliott@gmail.com

Subject: Request for information – Application for costs award with respect to participation in two applications to review and vary Telecom Regulatory Policy CRTC 2025-54.

Dear representatives of the Deaf and Hard of Hearing Coalition (DHHC):

On August 8, 2025, the Canadian Radio-television and Telecommunications Commission received applications for costs from the Ontario Association of the Deaf (OAD) and the Newfoundland and Labrador Association of the Deaf (NLAD). These applications related to their joint participation as the DHHC in:

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

As representatives of the DHHC members OAD and NLAD, you are requested to provide the information requested below no later than 4 February 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

Chris Irwin
Articling Student

Requests for Information

In the Guidelines for the Assessment of Costs included in Telecom Regulatory Policy 2010-963, the Commission indicated that costs awarded shall not exceed those necessarily and reasonably incurred by the applicant in connection with its participation in the proceeding. Commission staff are requesting that the OAD and the NLAD provide more information to demonstrate that the costs they have claimed for their participation in these proceedings were necessarily and reasonably incurred.

In Bell Canada’s answer to the costs applications filed by the OAD and NLAD, it claimed that there was substantial duplication and repetition between the submissions for which costs are claimed, as well as between these submissions and previous submissions by the DHHC in the proceeding that led to Telecom Regulatory Policy CRTC 2025-54. Further, Bell Canada submitted that claiming costs related to two proceedings through a single costs application risks double-counting and overcompensation.

In their joint response to Bell Canada, the DHHC members indicated that references to previous comments were necessary to support their arguments that the application to Review and Vary should be granted. Regarding the combined cost applications, the DHHC members indicated that they had announced their intention to proceed in this way and submitted that it reduced regulatory burden. The DHHC members did not address Bell Canada’s submissions on double-counting or overcompensation.

Commission staff needs to understand the time the DHHC members spent on their submissions and whether or not there is double counting of costs resulting from overlap in the substance of the submissions.

  1. Time records for the OAD’s external consultant hours submitted

    As outlined in paragraph 16 of the Guidelines for Assessment of Costs included in CRTC 2010-963, an applicant claiming costs that are calculated on an hourly basis must keep hourly records which may be requested by the Commission. These must contain at least the date on which the work was done, the amount of time spent on the work and a brief description of that work. When such records are requested and not provided, the applicant’s claim for the relevant work will generally be disallowed in its entirety.

    Please provide these hourly records for the external consultant hours that OAD submitted in its costs applications. If there is any overlap in the time spent on the application, intervention, and final comments that OAD filed, please explain and make clear how this time was claimed.

  2. Time allocation for internal consultants

    For both OAD and NLAD please provide the following information:

    1. The amount of time spent by each internal consultant on the application to Review and Vary Telecom Regulatory Policy CRTC 2025-54 (“the Review and Vary application”);
    2. The amount of time spent by each internal consultant on the intervention into the application filed by CDGM to Review and Vary Telecom Regulatory Policy CRTC 2025-54;
    3. The amount of time spent by each internal consultant on the final comments filed in the Review and Vary application; and
    4. If there is any overlap in the time spent on the application, intervention and final comments, please explain and make clear how this time split between the two proceedings.

  3. Necessary and reasonable time across the different submissions.

    1. To the extent that DHHC’s submissions either quoted from previous submissions or repeated arguments from a similar application, explain how this was taken into account when claiming time for these submissions. Was there new research or analysis required to adapt these positions to the new application or intervention?

cc:
Bell Canada: bell.regulatory@bell.ca
Quebecor Media Inc. : regaffairs@quebecor.com
Rogers Communications Canada Inc.: regulatory@rci.rogers.com
TELUS Communications Inc. : regulatory.affairs@telus.com

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