Manitoba Legal Clinic Law Students Push For More Inclusive CRTC Proceedings
On August 21, 2025, the Manitoba Legal Clinic for the Arts and the L. Kerry Vickar Business Law Clinic jointly submitted formal comments including recommendations to the Canadian Radio-television and Telecommunications Commission (CRTC), in response to Broadcasting and Telecom Notice of Consultation CRTC 2025-94, Call for comments – A new approach to funding public interest participation in Commission proceedings.
Launched on May 12, 2025, this CRTC proceeding aims to improve how individuals and public interest groups can participate in its decision-making processes. The CRTC, an independent body regulating Canada’s communications sector, seeks to ensure a diversity of voices in its work. The current rules for public interest funding have not been reviewed in over a decade, prompting the CRTC to reevaluate how it supports participation — especially from underrepresented groups.
The submission by Emily Trottier [BA/23] and Donald Plant [BA/23], both JD Candidates 2027 who have been employed over the summer at the University of Manitoba’s Faculty of Law Clinics, emphasized in detail the importance of enhancing inclusivity and accessibility in CRTC processes, and strongly support funding revisions which promote public participation in CRTC proceedings. The Clinics provide free legal services to small businesses, start-ups, including family businesses, non-profits, charities, as well as artists, arts, cultural and community organizations and others who lack access to legal representation across Manitoba.
The Clinic students strongly believe in the importance of diverse perspectives and inclusivity, especially when various communities are impacted by CRTC proceedings.
“Ensuring that diverse voices are heard and that everyone can share their perspectives on issues that affect them is essential to building a CRTC that truly serves all Canadians,” said Trottier.
Plant added, “We are thankful for the opportunity to provide comments and recommendations that may reduce participation barriers and allow for a more inclusive process for all Canadians.”
Beyond offering direct legal support, both students saw the opportunity to contribute to long-term policy change as vital. Central to their recommendations is the creation of a unified, independent funding system to simplify how individuals and organizations can apply for financial support to participate in CRTC proceedings. Currently, the existence of separate funding processes for broadcasting and telecommunications proceedings complicates access and discourages participation, particularly among individuals, and underrepresented and equity-deserving communities.
The Clinics propose a consolidated single funding process that removes administrative complexity and fosters equitable participation across all proceedings, would create fewer barriers to participation. The Clinics further argue that funding eligibility should be broad, encompassing individuals and organizations including Indigenous communities, racialized groups, persons with disabilities, official language minority communities (OLMCs), legal clinics, grassroots organizations and others, so all may have an opportunity to participate and have their views heard. They stress that participation must go beyond formal written submissions. Funding should also cover and support outreach, consultation, translation, accessibility services, and other necessary and meaningful engagement activities.
Complementary procedural reforms are also recommended, such as:
- Public and regional hearings
- Hybrid engagement models (online and in-persons)
- Pre-hearing consultations
These steps are seen as essential for building trust and ensuring input from rural, Northern, and Indigenous communities and OLMCs. The Clinics emphasize the need for dedicated funding streams and culturally appropriate consultationpractices, including the availability of Indigenous and other non-official languages during proceedings, or broader translation services, if necessary, in official proceedings recognizing the English and French are not the only first languages of many Canadians.
The submission stresses the importance of inclusive practices that remove barriers to participation, specifically financial as well as other supports needed, reflecting a wider push for greater equity in regulatory processes. With their experience serving underserved populations, the law students are deeply committed to ensuring all Canadians can have a say in decisions affecting their lives.
By adopting these recommendations, the CRTC could position itself as a leader in regulatory inclusiveness, shaping a more accessible and representative communications landscape in Canada. These Clinic students view this consultation as a critical opportunity to develop a more accessible and representative communications landscape in Canada.
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The CRTC Call for Comments invited all interested persons to participate in this proceeding. The deadline for public comments is September 9, 2025, with replies due by October 9, 2025. Only those who submit initial comments may file replies.
The Clinics look forward to reviewing the submissions of others and to the outcome of this important proceeding.
The full submission by the Clinics is available and may be read online.