Telecom - Staff Letter addressed to the Deaf and Hard-of-Hearing Coalition, Deafness Advocacy Association Nova Scotia and Newfoundland Association of the Deaf and Ontario Association of the Deaf
Ottawa, 26 February 2024
Reference(s): 1011-NOC2021-0102
BY EMAIL
Deaf and Hard-of-Hearing Coalition
Deafness Advocacy Association Nova Scotia
28 Redwood Avenue
Halifax, Nova Scotia
B3P 1Y6
Elliott Richman daansregs@gmail.com
Newfoundland Association of the Deaf
201-33 Pippy Place
St. John’s, Newfoundland
A1B 3X2
Myles Murphy myles.murphy@nf.sympatico.ca
Ontario Association of the Deaf
2395 Bayview Avenue
Toronto, Ontario
M2L 1A2
Donald Prong dprong@deafontario.ca
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 and Hard-of-Hearing Coalition (DHHC) applied for recovery of costs with respect to its participation in the proceeding initiated by Telecom Notice of Consultation CRTC 2021-102. The DHHC requested that the Commission fix its costs at $43,791.52, 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
- Employment status of consultant Elliott Richman
- Commission Staff notes that you have provided two Forms III for the consultant Elliott Richman, one of which is claiming time at the rate of an internal consultant, and the other claiming time at the rate of an external consultant.
- Please clarify whether the consultant Elliott Richman is a consultant that is internal to the DHHC (or the DAANS/NLAD/OAD), or external to the DHHC
- Please provide an amended version of the Form III submitted to this consultant, to reflect the appropriate employment status and rate.
- Commission Staff notes that you have provided two Forms III for the consultant Elliott Richman, one of which is claiming time at the rate of an internal consultant, and the other claiming time at the rate of an external consultant.
- Time records (if applicable)
- If – and only if – Elliott Richman is a consultant external to the DHHC, 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.
- Please provide copies of your hourly records (also known as time sheets), detailing the work completed and time spent on tasks.
- 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:
- 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
- Please explain how the specific information falls respectively into a category of information listed in section 31 of the Rules of Procedure.
- If – and only if – Elliott Richman is a consultant external to the DHHC, 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:
- Time distribution: Hearing attendance
- In the Forms III submitted by your organization, 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.
- Please clarify what you are referring to as “Hearing Attendance”.
- Please also specify the date(s) for which you are claiming this attendance time.
- In the Forms III submitted by your organization, 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.
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: