25% fee increase in one year

Last week, the CRTC announced (in 4 brief paragraphs) that it was raising its fees by 25% year over year.

No explanation. No justification. Just 4 pro-forma paragraphs, matching the same format as in previous years, with the exception that in 2021, the Commission only raised fees by less than 5% and by less than 1% in 2020.

Telecom Order CRTC 2022-177, Telecommunications Fees says

1. The Telecommunications Fees Regulations, 2010 (Fees Regulations) provide for the payment of annual telecommunications fees by certain telecommunications service providers, as set out in sections 2 and 3 of the Fees Regulations.
2. Pursuant to subsection 3(4) of the Fees Regulations, the Commission hereby announces that the estimated total telecommunications regulatory costs of the Commission for the 2022-2023 fiscal year (1 April 2022 to 31 March 2023) are $48.072 million. This includes additional funding to secure the necessary incremental increases to the Commission’s resources to address both current and future regulatory operational requirements.
3. The annual adjustment amount (credit) referred to in subsection 3(5) of the Fees Regulations for the 2021-2022 fiscal year is ($0.552) million.
4. Taking into account the annual adjustment above, the net billing for the Commission’s telecommunications fees for the 2022-2023 fiscal year is $47.520 million. This estimated net billing represents an increase of 24.17% compared to the amount for the 2021-2022 fiscal year ($38.271 million).

Secretary General

If we reach back to 2019, there was a 20% fee increase, but in that case, the Order included a justification, attributing the increase “to the implementation of the Broadband Fund project management function and to the ratification of collective agreements.” As an aside, that year’s $6M increase provided some visibility in the cost of having the CRTC’s duplicative broadband funding organization, independent of personnel at ISED performing a substantially similar function.

But, this year’s Order calls for increasing fees by another $9M with no explanation, no justification, nothing to allow Canadians to understand why we have to pay more. The CRTC simply says “This includes additional funding to secure the necessary incremental increases to the Commission’s resources to address both current and future regulatory operational requirements.”

What does that mean? “Additional funding to secure incremental increases to the Commission’s resources”? Who writes this way? It strikes me as a little bit redundant (and perhaps repetitive) without providing any meaningful disclosure? More money so we can get more and more? What are those incremental resources going to do?

The CRTC wrote up this fee increase, granting itself nine million dollars more, in just 4 short paragraphs. Contrast that with Telecom Order CRTC 2022-149, that took 22 paragraphs of discussion to award PIAC just over $1,300, 15 months after PIAC’s request, requiring 9 pages of filings, and opportunities for public comment on the appropriateness of the funding.

No public process exists for the CRTC’s unilateral funding order. Just 4 short paragraphs.

These Telecom Fees are part of the cost of regulation for Canadian telecom service providers, costs I have discussed before that ultimately impact the prices paid by consumers. Note that the budget is actually increasing by close to $10.25M, increasing from $37.821M last year to $48.072 this year. The CRTC had a half million dollars left over last year.

What kind of performance improvements will Canadians see as a result of this 27% budget increase? Will the Commission deliver Decisions and Orders that much faster? Where is our money going? Are there measurements of how the CRTC performed against last year’s objectives?

Where is the accountability?

Don’t Canadians deserve more of an explanation than the 4 boilerplate paragraphs in Telecom Order CRTC 2022-177?