Telecom Commission Letter addressed to Mr. Simon-Pierre Olivier (Rogers Communications Canada Inc.)

Ottawa, 7 April 2020

Our reference: 8662-R28-201911694


Mr. Simon-Pierre Olivier
Director, Regulatory Affairs
Rogers Communications Canada Inc.
One Mount Pleasant Road, 10th Floor
Toronto, Ontario  M4Y 2Y5

RE: Internet Code implementation – Rogers Communications Canada Inc.’s Part 1 application for an extension of time for certain rules

Dear Sir:

This letter sets out the Canadian Radio-television and Telecommunications Commission’s determinations on Rogers Communications Canada Inc.’s (RCCI) Part 1 application seeking an extension of time to implement certain requirements of the Internet Code (the Code), set out in The Internet Code, Telecom Regulatory Policy CRTC 2019‑269, 31 July 2019 (the Internet Code Policy).

In its application, filed on 21 November 2019, RCCI stated that it and its affiliate brand, Fido Internet (Fido), were unable to comply with the rules set out in the following sections of the Code by the 31 January 2020 deadline:

For this reason, the company requested an extension to 30 April 2020 to implement these rules. RCCI stated that all other Code rules would be implemented by the 31 January 2020 deadline.

The application was posted to the Commission’s website on 25 November 2019. No interventions were filed.

Pursuant to the Internet Code Policy, an Internet service provider (ISP) may submit a Part 1 application to seek an extension of the deadline to implement certain rules of the Code. To obtain an extension, the ISP must demonstrate that it faces unique barriers that would make implementing the specific rule(s) of the Code technically impossible or financially unreasonable. RCCI submitted that it faces unique barriers making implementation of the affected rules by 31 January 2020 technically impossible.

Specifically, RCCI submitted the following:

The Commission finds that RCCI’s application meets the test for an extension set out in the Internet Code Policy, since it effectively demonstrates that the company faces unique barriers (i.e. the IT development freeze) that would make implementing rules C.1., E.1.i., and I.2.ii. and iii. of the Code (hereafter, the affected rules) before 30 April 2020 technically impossible. In particular, the Commission is satisfied that RCCI’s available IT release windows, which are planned up to a year in advance and include the IT development freeze, constitute a unique barrier that makes it technically impossible to implement the affected rules by 31 January 2020. The Commission also considers that granting RCCI’s request will have a limited impact on customers, in that it will affect a limited number of customers and for a relatively short duration.

Accordingly, the Commission approves RCCI’s request to extend the implementation deadline from 31 January 2020 to 30 April 2020 for the affected rules. The Commission encourages RCCI to further accelerate the implementation of its new system in order to comply with the affected rules as soon as possible.
The Commission reminds RCCI of the following:

The Commission directs RCCI to file a report within 30 days of implementing all aspects of the Code in full. This report should address any complaints received about the affected rules prior to their implementation.

The Commission intends to monitor consumer complaints to the CCTS for any systemic issues arising from the delay in implementing the Code.

Yours sincerely,

(Original signed by)

Claude Doucet
Secretary General

C.C: Nanao Kachi, CRTC, 819-997-4700,;
Tara Levine, CRTC, 819-997-4478,;
Commission for Complaints for Telecom-television Services,;;

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