Telecom - Staff Letter addressed to the Deaf-Blind Planning Committee

Ottawa, 26 February 2024

Reference(s): 1011-NOC2021-0102

BY EMAIL

Deaf-Blind Planning Committee
227 Sixth Street
New Westminster, British Columbia
V3L 3A5
Terri Nolt dbpc2.0@gmail.com

Subject: Call for comments – Review of Video Relay Services, Telecom Notice of Consultation CRTC 2021-102 (Ottawa, March 11, 2021) – Request for Information to complete Cost Application

Introduction

The Deaf-Blind Planning Committee (DBPC) applied for recovery of costs with respect to its participation in the proceeding initiated by Telecom Notice of Consultation CRTC 2021-102. The DBPC requested that the Commission fix its costs at $119,941.96, consisting of consultant fees and disbursements.

This is a Request for Information (RFI) sent by Commission staff pursuant to Rule 28(1) of the CRTC Rules of Practice and Procedure, SOR/2010-277, and paragraph 12 of Telecom Regulatory Policy 2010-963. The purpose of this letter is to request additional information from your organization regarding its application for costs.

Commission staff sends Requests for Information such as this one in an effort to assist interested parties, and to gather all information required to process cost applications. Please note that other cost applicants also received an RFI, but each RFI sent by Commission staff has been personalized for each recipient to highlight the specific information and clarifications required by the Commission to process their cost application file.^Footnote1

Important Information

To facilitate the treatment of all interested parties’ submissions and a fulsome review of all relevant document, Commission Staff suspends the deadline by which Cost Applicants can file a Reply to the Answer filed by Telecommunications Service Providers (TSP’s) on 25 January 2024. In other words, the deadline to reply, which had previously been extended by Commission Staff to 1 March 2024, will now be postponed to 15 March 2024. As such, the deadline to Reply to the TSPs’ Answer will fall on the same day as the deadline to respond to this RFI.

Cost Applicants will be able to submit a Reply to the TSPs’ Answer and to file a Response to this RFI, by no later than 15 March 2024.

Upon receipt of the new information provided in response to this RFI, the Cost Respondents will be given the opportunity to file an Answer with regard to the new information provided in Response to the RFI, only. This Answer must be filed by no later than 22 March 2024.

Cost Applicants will subsequently have the opportunity to produce a final Reply to the new information contained in the Cost Respondents’ Answer. This Reply, if applicable, will need to be filed by Cost Applicants by no later than 1 April 2024.

When filing your response to this RFI with the Commission (via GC Key portal), please also send a copy of your reply (or its partially redacted version, if you designate information as confidential) by email to the following addresses :

Telus Regulatory kaitlin.mackenzie@telus.com
Rogers Regulatory regulatory@rci.rogers.com
Bell Regulatory bell.regulatory@bell.ca
Québecor Regulatory regaffairs@quebecor.com
Ursula Grant, CTA ugrant@cwta.ca

Requests for Information

Time records and ChatGPT
- The DBPC submitted time sheets which did not include details pertaining to file review time. The Commission requires documentation of your hourly records, pursuant to paragraph 16 of Telecom Regulatory Policy CRTC 2010-963 – Revision of CRTC costs award practices and procedures, to ensure that the fees claimed do not exceed the reasonable and necessary fees that have been incurred by your organization for its participation in the proceeding:
  
  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.
- As indicated in your cost application, your organization used ChatGPT to estimate its file review time, but documented other times, such as for meetings, case management and filming time, as they occurred.
  1. Please provide an explanation as to why it was necessary for your organization to use ChatGPT for file review time with respect to this portion of the work.
  2. If you did not keep hourly records of the work completed for which you are seeking to recover costs, please provide a detailed explanation as to why your organization was unable to keep hourly records of the work completed.
  3. What assurances can you give that using ChatGPT in the way your organization did to estimate file review time accurately reflects the number of hours actually worked? Please summarize the process followed by your organization to estimate file review time using ChatGPT, the questions, data, or prompts relied upon by your organization to generate estimates using Artificial Intelligence, and the information inputted into ChatGPT to arrive at your estimates.
- If you have confidentiality concerns about submitting this information
- Pursuant to sections 30 to 34 of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure (the Rules of Procedure), information filed with the Commission can be designated as confidential under certain circumstances. Broadcasting and Telecom Information Bulletin CRTC 2010-961, 23 December 2010 (the Information Bulletin), provides details on the steps for requesting information filed to the Commission to be designated as confidential. Should you with to designate a portion of your time records as confidential:
  1. Please provide an abridged version of the documents containing this information. The abridged version should redact only the specific information that is designated as confidential in accordance with the criteria outlined above; and
  2. Please explain how the specific information falls respectively into a category of information listed in section 31 of the Rules of Procedure.

Signature of Form III – Consultant / Analyst Fees
- Please note that the Commission requires a signed copy of each Form III submitted. We note that you only submitted a version of these forms with the typed names of the consultant or analyst instead of a signature.
  1. Please provide an unredacted v ersion of these signed forms, for the Commission’s review. Please note that electronic signatures, or personal marks used in lieu of a signature, are also accepted.

Possible duplication of work claimed for three (3) consultants
- Commission staff noticed a potential duplication of work hours claimed by the Deaf Wireless Canada Committee (DWCC), by the Canadian National Society of the Deaf-Blind (CNSDB), and by the Deaf-Blind Planning Committee (DBPC), who are each claiming costs for time spent by the same consultants and analyst on the proceeding initiated by Notice of Consultation (NOC) CRTC 2021-102. After a review of the time sheets provided, Commission staff noticed that certain meeting/training sessions overlap.
  1. Please provide clarifications for the below-noted hours claimed by your organization, and amend the corresponding timesheets and Forms III, as required. The signatures of the consultants/analysts concerned by such amendments must also be filed with the Commission, to confirm that they endorse the clarifications, information, and/or explanations provided by your organization in response to this RFI.

A. Consultant: Jessica Sergeant

Respond to Interrogatories
DBPC	DWCC
1 hour on 15 July 2022 “Writing for category 6 – QoS Standards and Metrics”	1 hour on 15 July 2022 “Responding to category 6 – QoS Standards and Metrics”
1 hour on 17 July 2022 “Writing for category 6 – QoS Standards and Metrics”	1 hour on 17 July 2022 “Responding to category 6 – QoS Standards and Metrics (overall category)”

Meeting/Training
DBPC	DWCC
2 hours on 5 June 2022 “CRTC 2021-102 group meeting for prep”	1 hour on 15 July 2022 “Responding to category 6 – QoS Standards and Metrics”

B. Consultant: Leanor Vlug

C. Consultant: Jeffrey Beatty

Meeting/Training
DBPC	DWCC	CNSDB
1 hour on 27 June 2021 “Meeting with Jeffrey Beatty and Meghan McHugh to prep for the CAD-ASC townhall”		1 hour on 27 June 2021 “Meeting with Leanor Vlug and Meghan McHugh to prep for the CAD-ASC townhall”
2 hours on 29 May 2022 “ Meeting/Training “CRTC 2021-102 group meeting for prep”	2 hours on 29 May 2022 Meeting/Training “Meeting – TNC 2021-102 Team Meeting”	2 hours on 29 May 2022 Meeting/Training “CRTC 2021-102 group meeting for prep”
2 hours on 5 June 2022 “CRTC 2021-102 group meeting for prep”	1 hour on 5 June 2022 “Meeting – task clarifications” (1hr) and “Meeting – TNC 2021-102 Team Meeting”	2 hours on 5 June 2022 “CRTC 2021-102 group meeting for prep”
2 hours on 30 June 2022 “Meeting with Jessica – progress report”	2 hours on 30 June 2022 “Meeting – delegations, task clarifications”
1 hour on 6 July 2022 “Meeting with Jeffrey and Jessica – progress report”		1 hour on 6 July 2022 “Meeting with Jeffrey and Jessica – progress report”
1 hour on 19 July 2022 “Meeting with Jessica – progress report”	1 hour on 19 July 2022 “Meeting – task clarifications”
1 hour on 20 July 2022 “Meeting with Jessica and Paula – discussion on intervention”	1 hour on 20 July 2022 “Meeting – task clarifications and delegations”	1 hour on 20 July 2022 “Meeting with Jessica and Paula – discussion on intervention”
1 hour on 23 July 2022 “Meeting with Jessica – progress report”	1 hour on 23 July 2022 “Meeting – task clarifications”
1 hour on 24 July 2022 “Meeting with Jessica and Paula – progress report”	2 hours on 24 July 2022 “Meeting – team meeting, delegations and clarifications”	1 hour on 24 July 2022 “Meeting with Jessica and Paula – progress report”

Review File
DBPC	DWCC	CNSDB
3 hours on 13 July 2022 “Reviewing CDBC.VRS’s Intervention (27 pages)”		3 hours on 10 July 2022 “Reviewing CDBC.VRS’s Intervention (27 pages)”

Case Management
DBPC	DWCC	CNSDB
	9 hours between 10 July 2022 and 17 July 2022 “Building Document Tracking Library, Setting up folders & file management” and 10 hours on 13 July 2022 “Building Document Tracking Library, Setting up folders & file management”	3 hours on 14 July 2022 “Fix/fiddle links and document locations in MASTER Document Library Spreadsheet” and 4 hours on 17 July 2022 “Fix/fiddle links and document locations in MASTER Document Library Spreadsheet” and 3 hours on 18 July 2022 “Fix/fiddle links and document locations in MASTER Document Library Spreadsheet”
	4 hours some time between 23 July and 24 July 2022, and from 1 August to 8 August 2022 “Building Document Tracking Library, Setting up folders & file management”	2 hours on 22 July 2022 “Fix/fiddle links and document locations in MASTER Document Library Spreadsheet” and 2 hours on 25 July 2022 “Fix/fiddle links and document locations in MASTER Document Library Spreadsheet”

Conclusion

If you have any questions regarding this Request for Information or the submission of your response to it, please contact me at stefanie.bedard@crtc.gc.ca.

Regards,

Stéfanie Bédard
Legal Counsel
Canadian Radio-television and Telecommunications Commission

Date modified:: 2024-02-26

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