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ASL – Filing submissions

Video Transcript

Whether you are making a complaint, participating in a proceeding, or filing an application, all written documents must be submitted to the CRTC following a specific set of rules and guidelines. These written documents are called submissions. On average, the CRTC receives 1,000 written submissions each week. During complex proceedings, however, they can receive over 10,000 submissions per week.

Any individual or organization that files a submission becomes a "party" to the proceeding. This Roadmap lists the basic rules for the most common types of documents. For more detailed information and the specific requirements for filing various submissions, please refer to this Roadmap's Submission Requirements Summary Table and the Guidelines on the CRTC Rules of Practice and Procedure. For more information on the electronic filing of an application and the use of CRTC forms see Broadcasting and Telecom Information Bulletin CRTC 2010-453 and 2010-453-1.

Where applicable, all submissions must be:

  • Addressed to the Secretary General
  • Sent to the required parties before the deadline (also known as to serve)
  • Submitted to the CRTC before the deadline
  • Written in either official language, English or French, or provided with a translation if submitted in another language
  • Separated into different parts and include headings and sub-headings
  • Include consecutively numbered paragraphs
  • Include an Executive Summary (if over ten (10) pages)
  • Submitted electronically using the available online form and your GCKey Account (applications and confidential documents), or by mail, fax, or in person (if electronic filing is not possible)

Further, the CRTC now expects all incorporated corporations and associations to file submissions in accessible formats and encourages all Canadians to do so as well. Please refer to Broadcasting and Telecom Information Bulletin CRTC 2015-242 for detailed information.

Many proceedings have a Notice of Consultation or a CRTC letter listing the specific procedures and requirements that you should use to ensure your submission is complete. These documents will be made available to the public on the CRTC website in the proceedings' electronic file, known as the public record. The proceeding's public record is the main place to find all the details and updates regarding a specific proceeding. Check it often. To view the public record visit the CRTC website, the Public Examination room during an oral hearing, or visit a local CRTC office.

Please refer to the Guidelines on the CRTC Rules of Practice and Procedure for more information on how to follow the public record in sections 52-53 and serving documents to other parties in section 83.

Confidential Information

During a proceeding, information submitted to the CRTC is generally posted on its website and placed on the public record. In your comment you can request that certain financial and corporate information be kept confidential between you and the CRTC. To do this you must identify what information you would like the CRTC to consider confidential and explain why. Some examples of confidential information are:

  • Trade secrets
  • Information about ongoing negotiations
  • Operating expenses
  • Employees' salaries

Keep in mind that any information that is available publicly cannot be designated confidential (e.g. a public company's financial statements; your name and contact information). For a complete list of typically accepted confidential information, please refer to the Broadcasting and Telecom Information Bulletin 2010-961.

Along with the document for which you are requesting confidentiality, you must submit an abridged version of your document to be made public. An abridged version is like the original version of the document that you submitted to the CRTC; however, it replaces the confidential sections with the pound symbol (#). Please note that unless stated otherwise by the CRTC, your information will be treated confidentially. In some cases, you may be requested to modify your abridged document following the CRTC's review.

Example:

Chart inside the video

This image shows how to transform a confidential document into an abridged version. It shows two pieces of paper: one being the confidential document and the second being the abridged version of the document. The confidential document shows the following sentences: Radio Inc.'s revenues for 2014 were $50,000. The salary of John Smith, the station manager, was $23,000. Radio Inc. is currently in negotiations to sell the station to New Radio Inc. The abridged document replaces the confidential sections by blank spaces, using the same amount of space as the words it replaces. These blank spaces each start with the symbol #, which is followed by a series of spaces that usually corresponds to the number of characters in the confidential section, and is closed by another # symbol. For example, to abridge the revenues of Radio Inc., one would proceed as follows: Radio Inc.'s revenues for 2014 were #+seven spaces+#.

Disclosure of Information

In some cases, the CRTC, or a party in the proceeding, may ask another party to have the information it has identified as confidential be made public, or in other words be disclosed. The party has ten (10) days to either disclose the information or explain why it will not. The CRTC then will decide if the information must become public, remain confidential, or be a part of the proceeding or not.

For more information on filing confidential information and requests for disclosure of information, please refer to Broadcasting and Telecom Information Bulletin 2010-961 and sections 102-107 of the Guidelines on the CRTC Rules of Practice and Procedure.

Alternative Format

The CRTC is committed to facilitating the full participation of persons with disabilities at proceedings. In the event a submission was not filed in an accessible format, you can ask for the documentation to be made available to you in an alternative format such as large print text or as rich text format (RTF format). To make this request the process is as follows:

  • The CRTC posts the original document on its All Public Proceedings Open for Comment webpage in the proceeding's file.
  • Contact the CRTC's Client Services to request the alternative format and indicate:
    • Which document(s) you wish to have provided to you by noting the title and the author
    • What proceeding it is part of by noting the process number
  • The CRTC will then contact the author to reply (with an explanation) and accept or deny the request.

The person requesting the document has to inform the CRTC if he/she is satisfied with the reply. The CRTC then will make a decision and may require the author to create the alternative format document.

For more information on requesting documents in alternative formats, please refer to section(s) 118-123 in the Guidelines on the CRTC Rules of Practice and Procedure.

Procedural Request

The needs of each proceeding are different and changes may be made during the process to increase the effectiveness of the proceeding. Changes may be made to allow parties more time to submit comments, to request documents to be made in an alternative formats, or to request disclosure of confidential information. When the CRTC makes this change it will post the information on the All Public Proceedings Open for Comment webpage either as a change to the Notice of Consultation or in a CRTC letter. When a party makes a request for a change to the CRTC they must:

  • Submit a formal letter to the CRTC, addressed to the Secretary General.
  • List reasons for the request and how the request will or will not affect other parties in the proceeding.

The CRTC will make a decision for or against the request, communicate the changes, if any, in a CRTC letter or in a change to the notice of consultation, and post it on the proceeding's public record.

For more information on making a procedural request please refer to sections 102-123 in the Guidelines on the CRTC Rules of Practice and Procedure.

Cost Applications

If you participate in a proceeding, it may be possible for some of your expenses to be reimbursed; this is called Applying for Costs. There are two streams of proceedings, (i) Telecommunications and (ii) Broadcasting. In general, the criteria, rates, policies, and forms are similar; however, some differences do exist and their cost applications are processed and administered separately.

(i) Telecommunications Proceedings

For Telecommunications Proceedings there are two categories of costs that parties can apply for: Interim and Final.

Interim costs can be awarded in special circumstances when your own funds are not readily available to you to attend the oral hearing during the proceeding. Funds can be provided for travel and accommodation expenses to attend the proceeding. When approving an application for interim costs, the CRTC will consider if the party has, or does not have, immediate and sufficient funds to participate effectively in the proceeding. Applications should be submitted as early as possible in the proceeding, to allow for processing to occur in time for your appearance at the oral hearing.

Final costs are expenses that you apply for after the proceeding has ended. These expenses can include remaining travel or accommodation costs to attend an oral public hearing and fees for professional services used to create your submission such as lawyers, expert witnesses, and professional consultants. If you were approved any interim costs and apply for final costs, you must list the interim costs in your application. Your application for final costs must be submitted to the CRTC within thirty (30) days after the proceeding's last date to file documents (known as "close of record"). Final costs are the most common type of cost awarded as part of a proceeding.

To make a cost application for a Telecommunication proceeding you must write a formal letter, complete the appropriate forms, and include proof of your expenses.

To qualify to apply for costs you must meet the following criteria:

  • Being a formal party in the proceeding
  • Helped the CRTC understand the issue
  • Participated responsibly

Your Cost Application letter must include:

  • How you meet the criteria
  • Which telecommunications company or companies that was party to the proceeding you view as responsible to pay your costs
  • The completed appropriate cost form(s)
  • Receipts or list of estimated expenses

When the CRTC does approve the repayment of costs, the funds do not come from the CRTC itself. The funds come from the companies (phone, Internet, and wireless) that also participated in the proceeding. Therefore, when you send your cost application to the CRTC you must also send a copy to the party or parties you view as responsible to pay your costs.

You must also complete and include the appropriate forms. All the required forms for Telecommunications Proceedings and additional information on cost applications can be found on the Telecommunications Cost Assessment Forms webpage.

Please note, if receipts are not provided with the application, the request for reimbursement will most likely be denied.

For more details and information regarding applying for costs for Telecommunications proceedings refer to sections 152-163 of the Guidelines on the CRTC Rules of Practice and Procedure and Telecom Regulatory Policy 2010-963.

(ii) Broadcasting Proceedings

During Broadcasting proceedings parties can also apply for cost reimbursement; however, the Broadcasting Participation Fund (BPF), not the CRTC, administers the process.

For more information regarding applying for reimbursement of costs for a Broadcasting proceeding please visit the BPF website or contact the BPF's Cost Officer.

This video is intended for Canadians that use American Sign Language (ASL) as their primary language. Whether you are making a complaint, participating in a proceeding, or filing an application, all written documents must follow a specific set of rules and guidelines.

For more information, see the ASL - Roadmap to CRTC processes

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