ARCHIVED - Telecom Commission Letter addressed to Megan McHugh (Canadian National Society of the Deaf-Blind)

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Ottawa, 21 August 2019

Our reference: 1011-NOC2018-0422& 4754-625


Megan McHugh, President
Canadian National Society of the Deaf-Blind

Re: Proceeding to establish a mandatory code for Internet Services, Telecom Notice of Consultation CRTC 2018-422 – Request for information concerning certain disbursements

Dear Ms. McHugh,

In its application for costs filed with the Commission on 25 June 2019, the Canadian National Society of the Deaf-Blind (CNSDB) included an invoice from the Deaf Wireless Canada Consultative Committee (DWCC) in the amount of $9,130.00. This invoice included work related to “set-up, formatting, enlarge fonts, editing, writing, and editing assistance of all Deaf-Blind related sections of documents, reports, providing technical and visual orientation assistance for CRTC TNC 2018-422 [bold text in original]”.

Commission staff are of the preliminary view that the work undertaken by DWCC on behalf of CNSDB is more properly characterized as the work of external consultants, rather than as a disbursement. Commission staff note that a disbursement is generally an out-of-pocket expense necessarily incurred in connection with the applicant’s participation in the proceeding such as travel, meals, accommodation, or photocopying. In this case, the expenses DWCC has billed for appear to be for the work of persons who participated in the proceeding to put forward the views of the Deaf-Blind community on CNSDB’s behalf.

Accordingly, Commission staff request information from CNSDB concerning the nature of DWCC’s work and whether Commission staff’s preliminary view is accurate. If so, Commission staff request further information from CNSDB addressing the following two points:

  1. the number of completed years DWCC’s staff have been acting as consultants;
  2. whether the $110.00 claimed by CNSDB is in error, as the recoverable rates (as laid out in the Commission’s Guidelines for the Assessment of Costs, Telecom Regulatory Policy 2010-963) vary based on the years of experience a consultant has. Commission staff remind CNSDB that the number of years provided shall be calculated based on the date of the commencement of the proceeding giving rise to this application for costs.

Commission staff request this information by 28 August 2019. Any interested parties may file a response by 30 August 2019, after which CNSDB may file a reply by 4 September 2019.

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


Original signed by

Jean-Sébastien Gagnon –  
Legal Counsel


Scott Hutton –
Nanao Kachi –
Salahuddin Rafiquddin –

Distribution List
Canadian Association of the Deaf-Association des Sourds du Canada –
Deaf Wireless Canada Consultative Committee –
Deafness Advocacy Association of Nova Scotia –
Bell Canada –
Bragg Communications Inc., carrying on business as “Eastlink” –
Canadian Communication Systems Alliance –
Canadian Network Operators Consortium Inc. –
Canwisp –; 
Cogeco Communications Inc. –
Commission for Complaints for Telecom-television Services –;;;
Competition Bureau of Canada –; 
Conseil provincial du secteur des communications (CPSC) du Syndicat canadien de la fonction publique –;
Distributel Communications Limited –
Government of Yukon –
Independent Telecommunications Providers Association –
Ministère de la Culture et des Communications et l'Office de la protection du Consommateur
du Québec –
Primus Management ULC –
Québecor Média Inc. –;
Réseau FADOQ –;  
Rogers Communications Inc. –;;  
Rothschild & Co. –
Saskatchewan Telecommunications (SaskTel) –
Shaw Communications Inc. –
TekSavvy Solutions Inc. –;
TELUS Communications Inc. –;; 
Union des consommateurs –;  
Xplornet Communications Inc. –;

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