Telecom - Staff Letter addressed to the Distribution List

Ottawa, 12 December 2023

Our reference: 8665-C209-202304814

BY EMAIL

Distribution List

Subject: The Canada Deaf Grassroots Movement (CDGM) and Deaf and Hard of Hearing Coalition (DHH) Application for an award of costs related to their participation in the proceeding initiated by the Part 1 Application of the filing of Canadian Administrator of VRS (CAV). Inc 2024 Annual Budget

Dear recipients,

The Canada Deaf Grassroots Movement (CDGM), by letter dated 11 October 2023, applied for costs with respect to its participation in the proceeding # 8665-C209-202304814 with respect to the Part I Application of the Canadian Administrator of VRS (CAV) proposed 2024 budget. The CDGM requested that the Commission (CRTC) fix its costs at $2,200 for consulting services.

With respect to the same proceeding, the Deafness Advocacy Association Nova Scotia (DAANS), Newfoundland and Labrador Association of the Deaf (NLAD) and Ontario Association of the Deaf (OAD), collectively known as the Deaf and Hard of Hearing Coalition (DHH), submitted on 11 October 2023, their cost application for $3,717.40 for consulting services.

Section 37 of the Telecommunications Act (the Act) provides that the Commission may require Canadian carriers or any person to file information or documents that the Commission considers necessary for the administration of the Act.

Accordingly, Bell, Rogers and TELUS are required to provide complete responses to the attached request for information by 8 January 2024. CDGM and DHH will have until 19 January 2024 to comment on the information provided in the received responses.

Request for Information

In determining the appropriate costs respondents, the Commission has generally considered which parties are affected by the issues and have actively participated in the proceeding. However, in this case, no TSPs actively participated in the Part 1 application.

The CDGM submitted that it would be appropriate for Wireless Service Providers (WSP) to cover the costs. The DHH submitted that CRTC TRP 2014-187 mandated Telecommunications Service Providers (TSPs) to fund VRS nationally via existing National Contribution Fund. They submitted that the same TSPs were responsible to cover costs awards related to interested parties’ participation in TNC 2013-155 that led to TRP 2014-187 and in 2014-188, that led to 2014-659.

Should the Commission find CDGM and DHH eligible for their costs, comment on the possibility that the Commission would find that all TSPs that pay contributions had a significant interest in the outcome of the proceeding even if that they did not participate.  Applying the Commission’s established approach of allocating costs based on relative telecommunications operating revenues and limiting the number of cost respondents, such a conclusion would lead to the following cost allocation:

Cost allocation for CDGM

TSP's Proportion CDGM
Bell and subsidiaries Footnote1 100% $2,200.00

Cost allocation for DHH

TSPs Proportion DHH
Bell and subsidiaries Footnote2 49,34% $1,499.74
Rogers Footnote3 32,06% $1,191.71
Telus 27,60% $1,025.95

Should you need further information, please do not hesitate to contact me by email at imene.benaissa@crtc.gc.ca

Yours sincerely,

Original signé par

Imène Benaïssa
CRTC Legal Counsel

Distribution List

bell.regulatory@bell.ca
regulatory.affairs@telus.com
regulatory@rci.rogers.com
canadadeafgrassrootsmovement@gmail.com
daansregs@gmail.com

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