Telecom Order CRTC 2026-1

Gatineau, 8 January 2026

File numbers: 1011-NOC2025-0020 and 4754-804

Determination of costs award with respect to the participation of the Public Interest Advocacy Centre in the additional process initiated by Telecom Notice of Consultation 2025-20

Application

By letter dated 24 September 2025, the Public Interest Advocacy Centre (PIAC) applied for costs with respect to its participation in the additional process initiated by Telecom Notice of Consultation 2025-20 (the proceeding). In that notice of consultation, the Commission sought comments on how to improve the routing of 9-8-8 calls and texts. The additional process was introduced by a Commission staff letter requesting the Centre for Addiction and Mental Health (CAMH) to file responses to questions. In the proceeding, the Commission sought replies to CAMH’s responses.
The Commission did not receive any interventions in response to the application for costs.
PIAC submitted that it had met the criteria for an award of costs set out in section 68 of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure (the Rules of Procedure) because it represented a group or class of subscribers that had an interest in the outcome of the proceeding, it had assisted the Commission in developing a better understanding of the matters that were considered, and it had participated in a responsible way.
In particular, PIAC submitted that it represents the interests of consumers across Canada, including low-income and vulnerable consumers who are relatively more prone to mental health crisis and distress.
With respect to the group or class of subscribers that PIAC has submitted it represents, PIAC explained that this group or class consists of all consumers across Canada, with a particular focus on low-income consumers. PIAC represents a number of individual and organizational members and is held accountable for its representation of the public interest through a volunteer board of directors drawn from across Canada.
PIAC requested that the Commission fix its costs at $750, consisting entirely of legal fees. PIAC filed a bill of costs with its application.
PIAC claimed 1.25 days for in-house counsel at a rate of $600 per day for work reviewing the file and preparing reply comments ($750).
PIAC submitted that the telecommunications service providers that participated in the proceeding are the appropriate parties to be required to pay any costs awarded by the Commission (the costs respondents).
PIAC suggested that the responsibility for payment of costs should be divided among the costs respondents on the basis of the most recent data provided to the Commission.

Commission’s analysis

The criteria for an award of costs are set out in section 68 of the Rules of Procedure, which reads as follows:
1. The Commission must determine whether to award final costs and the maximum percentage of costs that is to be awarded on the basis of the following criteria:
  
  (a) whether the applicant had, or was the representative of a group or a class of subscribers that had, an interest in the outcome of the proceeding;
  
  (b) the extent to which the applicant assisted the Commission in developing a better understanding of the matters that were considered; and
  
  (c) whether the applicant 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 the present case, PIAC has demonstrated that it meets this requirement. PIAC represented the interests of all consumers across Canada with a particular focus on low-income consumers.
PIAC has also satisfied the remaining criteria through its participation in the proceeding. In its reply, PIAC emphasized the importance of prioritizing public safety when determining the most appropriate and reliable routing option for 9-8-8 calls. PIAC also submitted that the routing process for 9-8-8 should be reconsidered on an expedited basis while the existing process is still used and maintained, to ensure there is no disruption in access to the service. PIAC reaffirmed the need for resilient redundancies to ensure there is no disruption to the critical 9-8-8 service. As such, PIAC participated responsibly in the proceeding, and its reply submissions assisted the Commission in better understanding these issues.
The rates claimed in respect of legal fees are in accordance with the rates established in the Guidelines for the Assessment of Costs, as set out in Telecom Regulatory Policy 2010-963. The Commission finds that the total amount claimed by PIAC was necessarily and reasonably incurred and should be allowed.
This is an appropriate case in which to fix the costs and dispense with taxation, in accordance with the streamlined procedure set out in Telecom Public Notice 2002-5.
The Commission has generally determined that the appropriate costs respondents to an award of costs are the parties that have a significant interest in the outcome of the proceeding in question and have participated actively in that proceeding. The Commission considers that the following parties had a significant interest in the outcome of the proceeding and participated actively in the proceeding: Bell Canada, including Bell Mobility Inc.; Bragg Communications Inc., carrying on business as Eastlink; Quebecor Media Inc., on behalf of its affiliates Videotron Ltd. and Freedom Mobile Inc. and their brands Fizz and VMedia; Rogers Communications Canada Inc., including Shaw Cablesystems G.P. and Groupe Shaw Group; Saskatchewan Telecommunications; TBayTel; and TELUS Communications Inc.
The Commission considers that, consistent with its practice, it is appropriate to allocate the responsibility for payment of costs among costs respondents based on their telecommunications operating revenues (TORs) as an indicator of the relative size and interest of the parties involved in the proceeding.^{Footnote 1}

Accordingly, the Commission finds that the responsibility for payment of costs should be allocated as follows:^{Footnote 2}

Company	Proportion	Amount
Bell Canada	100%	$750

Directions regarding costs

The Commission approves the application by PIAC for costs with respect to its participation in the proceeding.
Pursuant to subsection 56(1) of the Telecommunications Act, the Commission fixes the costs to be paid to PIAC at $750.
The Commission directs that the award of costs to PIAC be paid forthwith by Bell Canada according to the proportions set out in paragraph 17.

Secretary General

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