Telecom and Broadcasting - Commission letter addressed to Kenneth Whitehurst (Consumers Council of Canada)

Ottawa, 7 December 2020

Our reference: 1011-NOC2020-0081


Kenneth Whitehurst
Executive Director
Consumers Council of Canada

RE: Call for comments – Provision of paper bills by communications service providers CRTC 2020-81 – Request for information

Dear Kenneth Whitehurst,

On 24 August 2020, Consumers Council of Canada (CCC) submitted an application for final costs in the above-noted proceeding.

According to section 66(1) of the CRTC Rules of Practice and Procedure, in their application for final costs, applicants must demonstrate that they

(i) have, or represent a group or a class of subscribers that has, an interest in the outcome of the proceeding,

(ii) assisted the Commission in developing a better understanding of the matters that were considered, and

(iii) participated in the proceeding in a responsible way;

In Telecom Information Bulletin 2016-188, the Commission provided guidance regarding how an applicant may demonstrate that it satisfies the first criterion with respect to its representation of interested subscribers. In particular, the Commission stated that blanket statements that a costs applicant represents a group or a class of subscribers, without further elaboration, will generally be insufficient for the Commission to conclude that a costs applicant satisfies this criterion.

In its application for final costs, Commission staff finds that CCC has not met the content requirements of section 66 of the Rules of Procedure. Accordingly, Commission staff requests information from CCC concerning how it represented a group or class of subscribers that had an interest in the outcome of the proceeding, the extent to which it had assisted the Commission in developing a better understanding of the matters considered, and whether it had participated in the proceeding in a responsible way.

Commission staff requests this information by 15 December 2020. Any interested parties may file a response by 17 December 2020, after which CCC may file a reply by 8 January 2020.

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


Feyisayo Oni
Legal Counsel

cc: Julia Kelen -

cc: Distribution List

Canadian Association for the Deaf (CAD-ASC) -;
Manitoba Coalition -
Deaf Wireless Canada Committee -;;
Union des Consommateurs -
Canadian National Society of the Deaf-Blind (CNSDB) -
Deafness Advocacy Association Nova Scotia (DAANS) -
Bragg Communications Inc. -
Xplornet Communications Inc. -
TELUS Communications Inc. -
TekSavvy Solutions Inc. -
Shaw Communications Inc. -
Saskatchewan Telecommunications (SaskTel) -
Rogers Communications Canada Inc. (Rogers) -
Québecor Média inc. -
Bell Canada -

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