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Telecom - Staff Letter addressed to the Canada Deaf Grossroots Movement

Ottawa, 26 February 2024

Reference(s): 1011-NOC2021-0102

BY EMAIL

Canada Deaf Grassroots Movement
11717-84 Street NW
Edmonton, Alberta
T5B 3C2
Kimberly Wood canadadeafgrassrootsmovement@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 Canada Deaf Grassroots Movement (CDGM) applied for recovery of costs with respect to its participation in the proceeding initiated by Telecom Notice of Consultation CRTC 2021-102. The CDGM requested that the Commission fix its costs at $31,375.50, 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

  1. Time records
    • The CDGM did not include time sheets in support of its cost application. Commission staff requests that you provide copies of your hourly records, pursuant to paragraph 16 of Telecom Regulatory Policy CRTC 2010-963 – Revision of CRTC costs award practices and procedures, which states as follows:

      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.

      1. Please provide copies of your hourly records (also known as time sheets), detailing the work completed and time spent on tasks.
      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.
    • If you have confidentiality concerns about providing 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.
  1. Time distribution: Hearing attendance
    • In the Forms III submitted by your organization for Anthony Cashin and Kimberly Wood, time was claimed for “Hearing Attendance” and/or “Prepare for Hearing”. Please note that there was no public hearing held in the course of this proceeding. However, virtual discussion sessions were held.
      1. Please clarify what you are referring to as “Hearing Attendance”.
      2. Please also specify the date(s) for which you are claiming this attendance time.
  1. Disbursements
    • In your application, you claimed $53.00 in disbursements, and provided invoices in support of this claim. These invoices are dated and time-stamped, and reflect costs paid for transportation by Uber on 7 May 2022 between two residential addresses. These invoices appear to have been paid by “Christopher”, who we assume refers to external consultant Christopher Polson.
    • Pursuant to paragraph 37 of Telecom Regulatory Policy 2010-963, taxi and Uber costs may be eligible for recovery, provided they are necessary and were reasonably incurred:

    37. In respect of intra-city travel, local taxi fares, parking expenses or other local travel disbursements may be claimed provided that such disbursements are necessarily and reasonably incurred, and provided that they would not otherwise normally have been incurred.

    1. Please provide an explanation for these disbursements, including a justification as to why these costs were necessarily and reasonably incurred.
    • Also, the first invoice was issued at 9:33 am (arrival), and the second costs were incurred starting at 3:59 pm (departure), approximately 6.5 hours later that same day. However, a total of 9 hours are claimed by the CDGM for this consultant’s fees.
    1. Please provide the date for which the remaining 2.5 hours were completed, and explain why transportation costs were not required on that separate work occasion.

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

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