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Broadcasting and Telecom - Staff Letter addressed to Joan Jenkinson (Black Screen Office)

Gatineau, 9 February 2026

Reference(s): 1011-NOC2025-0094, 4754-816

BY EMAIL

Joan Jenkinson, CEO
Black Screen Office
25 John St., Ste. 6C300
Toronto, Ontario, M5V 3G8
info@bso-ben.ca; operations@bso-ben.ca

Subject: Application for costs award with respect to Broadcasting and Telecom Notice of Consultation CRTC 2025-94 – Call for comments – A new approach to funding public interest participation in Commission proceedings

Dear Joan Jenkinson:

On 21 November 2025, the Canadian Radio-television and Telecommunications Commission received an application for costs from the Black Screen Office (BSO) with respect to its participation in Broadcasting and Telecom Notice of Consultation CRTC 2025-94 - Call for comments – A new approach to funding public interest participation in Commission proceedings (CRTC 2025-94). As noted in paragraph 50 of CRTC 2025-94, cost applications will be treated under the telecommunications costs process for this proceeding.

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

BSO is requested to provide the information requested below no later than 16 February 2026. Please confirm your initial receipt of this request.

A copy of this letter and all related correspondence will be added to the public record of the proceeding. Please repeat each question in your responses.

Requests for Information

  1. Time Records

    Commission staff requests that the BSO provide more detailed hourly records for the external consultant, Kelly Lynne Ashton. 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:

    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.

    Please provide detailed copies of Kelly Lynne Ashton’s hourly records, detailing the date on which the work was done, the amount of time spent on tasks for the BSO and a brief description of the work. These records should clearly outline the specific work undertaken by the consultant for the BSO.

  2. Clarifying a Distinct Point of View

    Pursuant to TRP 2010-963, in evaluating whether an applicant has contributed to a better understanding of the issues, the Commission will generally take into account:

    1. whether the applicant filed evidence;
    2. whether the contribution was focus and structured; and
    3. whether the contribution offered a distinct point of view.

    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.

    Since a large portion of BSO’s intervention and reply appears to be substantially similar to that of the Disability Screen Office (DSO)’s intervention and reply in the proceeding, including duplicated paragraphs and sentences. Please compare the interventions and reply of both organizations and indicate how your application offered a distinct point of view on the issues.

  3. Explanation of Substantive Submissions among Claimants

    Further, pursuant to TRP 2010-963, 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.

    Considering that both BSO’s intervention and reply in CRTC 2025-94 appear to be substantially similar to DSO’s intervention and reply, please compare the interventions and replies between the two organizations and explain the duplication of the substantive submissions. If BSO was aware of the similar content of DSO’s submissions, please explain why the BSO did not coordinate their submission with the DSO. In addition, please explain why the time spent on these submissions should not be considered as excessive under the circumstances.

    In the event that the Commission decides to reduce costs for the reasons mentioned above, please comment on the possibility of a 50% costs reduction. If you disagree with a potential 50% costs reduction, please explain why and propose an alternative solution that would be acceptable to you. Please explain why the Commission should adopt this solution.

  4. Completion of Application

    As required under paragraph 66 (1)(a) of the Canadian Radio-television Commission Rules of Practice and Procedure (the Rules of Practice and Procedure), in an application for final costs, the applicant must demonstrate that they:

    1. have, or represent a group or a class of subscribers that has, an interest in the outcome of the proceeding,
    2. assisted the Commission in developing a better understanding of the maters that were considered, and
    3. participated in the proceeding in a responsible way;

Please complete your costs application by explaining why the DSO meets the criteria for (ii) and (iii).

Paragraph 66(1)(b) of the Rules of Practice and Procedure requires that an applicant for costs identify the respondents that should pay the costs, please indicate who these respondents should be for the public record.

As required by subsection 66(2) of the Rules of Practice and Procedure, please submit Form V (Summary of Fees and Disbursements) to complete your application or explain why you are unable to do so.

Yours sincerely,

Originally signed by

Deborah Ring
Articling Student

Cc:

Black Screen Office: info@bso-ben.ca; operations@bso-ben.ca
Bell Canada: bell.regulatory@bell.ca
Bragg Communications: regulatory.matters@corp.eastlink.ca
Cogeco Connexion Inc.: telecom.regulatory@cogeco.com
Rogers Communications Canada Inc.: regulatory@rci.rogers.com
TELUS Communications Inc.: regulatory.affairs@telus.com
Véronique Lehoux (CRTC): veronique.lehoux@crtc.gc.ca
Bianka Lauzon (CRTC): bianka.lauzon@crtc.gc.ca

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