Telecom Commission Letter addressed to Mr. Philippe Gauvin (Bell Canada)

Ottawa, 7 April 2020

Our reference: 8662-M59-201911363


Mr. Philippe Gauvin
Assistant General Counsel
Bell Canada
Floor 19
160 Elgin St.
Ottawa, Ontario K2P 2C4

RE: Internet Code implementation – Bell MTS’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 Bell MTS’s 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 30 October 2019, Bell MTS stated that it was 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 2021 to implement these rules. Bell MTS stated that it would implement them on a rolling basis to benefit customers as soon as possible and that all other Code rules would be implemented by the 31 January 2020 deadline.

The application was posted to the Commission’s website on 6 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. Bell MTS submitted that it faces unique barriers making implementation of the affected rules by 31 January 2020 both technically impossible and financially unreasonable, due to technical issues with migrating existing customers from legacy to new systems.


The Commission finds that Bell MTS’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 transition to new systems) that would make implementing rules B.1., 2., 3., and 5., C.1., D.2.i.(c), and I.1.i.a. and iii. of the Code (hereafter, the affected rules) before 30 April 2021 technically impossible and financially unreasonable. Specifically, Bell MTS has demonstrated that it would be technically impossible to advance the implementation date of the new systems, or the affected rules, without accepting an unreasonable degree of risk for the new systems, and ultimately, customers. Bell MTS has also demonstrated that it would be financially unreasonable to implement the affected rules in the legacy and end-of-life systems and then again in the new systems. In addition, the Commission considers that the impact on customers from the extension should be minimal, since Bell MTS offers only indeterminate, unlimited use Internet service contracts. Thus, customers (i) can cancel services at any time without being subject to early cancellation fees, (ii) are not subject to overage fees, and (iii) do not require usage notifications. Customers will also continue to receive written contracts in the existing format following the installation of Internet service.

Accordingly, the Commission approves Bell MTS’s request to extend the implementation deadline from 31 January 2020 to 30 April 2021 for the affected rules. The Commission notes Bell MTS’s commitment to implement the affected rules on a rolling basis, and encourages Bell MTS to further accelerate the implementation of its new systems in order to comply with the affected rules as soon as possible.

The Commission reminds Bell MTS of the following:

Given the duration of the extension, to ensure that Bell MTS’s customers are aware of the delay and can seek recourse where appropriate, the Commission directs Bell MTS to do the following:

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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