Network resilience

The Canadian Security Telecommunications Advisory Committee (CSTAC) released a report aimed at improving network resilience and reliability.

“Telecommunications Network Resiliency in Canada: A Path Forward” [pdf, 474KB] contains guidance for telecommunications services providers, not obligations. The report says, “recommendations contained in this document are neither directive nor mandatory.”

The report was prepared by the Canadian Telecommunications Network Resiliency Working Group (CTNR-WG). CTNR-WG represents 12 of Canada’s largest telecommunications services providers, including mobile carriers, telephone companies, cable companies and satellite services, with companies that cover urban and rural, business and consumer markets. The recommendations include items that address last July’s national network failure and the impact of Hurricane Fiona last September on networks in Atlantic Canada.

General Recommendations:

1. Seek to establish redundant pathways, in particular, facilities that support main fiber access should have physically diverse fiber routes between critical infrastructures, especially those routes with access to emergency services such as 911.
2. Attempt to identify and mitigate single points of failure and strive for geographic diversity of services and network elements. Where essential equipment is co-located, priority should be given to physical separation, such as a fire break, to reduce the possibility of common mode failure.
3. Design physical structures (both indoor and outdoor) to be as resilient as practicable, in the circumstances, to withstand extreme environmental conditions and weather events (e.g., wildfires, floods, windstorms, ice, etc.), as well as the loss of commercial utility (e.g. hydroelectric) power supplies. Further, CTSPs should strive to source their equipment and systems from reliable, capable, and reputable suppliers.
4. Strive to install communications cables underground to mitigate damage from possible structural degradation and/or natural disasters. Should communications cables be buried, known risks attributed to this design should be documented and mitigated to the extent practicable.
5. Endeavor to establish robust business practices that enable rapid assessment of network issues, along with service continuity plans that support strong communication and responsiveness when adverse events cause major outages to critical services.

The report also includes recommendations for certain government actions to help improve network resilience. First in that list is one that highlights the growing impact of vandalism and theft of critical infrastructure, such as the theft of copper cable.

Asks of the Government of Canada:

1. Create an article of federal law that specifically protects CTSPs’ critical and ancillary infrastructure and maximizes criminal penalties in the event of willful or negligent damage to, and/or acts of vandalism or theft of critical network infrastructure. As a reference, the US Criminal Code criminalizes such acts through financial penalties, imprisonment, or both. CTSPs will endeavour to provide data to ISED on a strictly confidential basis that could include information such as (but not specific to or limited to) the type of damage (e.g., a fiber cut) and/or the relevant details.
2. Implement a timely approval process by ISED for short-term emergency spectrum sharing in the event of a severe network outage, when it is jointly requested by the CTSPs involved. Such a process could be helpful when a “Triggering Event Declaration” is made under the September 9,2022 Memorandum of Understanding but also in other emergency circumstances which may not qualify as or rise to the level of a Triggering Event.
3. Liaise with provincial and territorial governments with a view to enhancing measures to enforce compliance with existing regulations related to “Dial Before You Dig” legislation or other similar underground infrastructure notification regulations, in order to minimize any potential damage to underground telecom facilities resulting from non-compliant or careless excavation practices.
4. Liaise with the telecom and electricity / hydro sector participants, including the Canadian Standards Association (CSA), to collaborate on improving critical infrastructure resiliency through changes to the Canadian Electrical Code or other construction standards.
5. Facilitate network construction and reliability access to public places and publicly owned passive infrastructure. Specifically, through amendments to the Telecommunications Act and Radiocommunication Act:
   1. Expand the CRTC’s authority over publicly-owned passive infrastructure to clearly include access to all public property capable of supporting [network] facilities, such as street furniture.
   2. Assert federal jurisdiction in the wireless tower siting and develop new site approval processes that avoid unnecessary delay and burden and expedite the delivery of wireless services to Canadians.
   3. Expand the scope of the CRTC’s authority over support structures to include CTSPs access to the support structures of provincially regulated utilities. 
6. Telecommunications networks are critical infrastructure that, while federally regulated, are highly dependent on provincial/territorial regulated utilities and services. The CTNR-WG asks that the federal government coordinate the following amongst both federal and provincial / territorial emergency management organizations:
   1. Priority access, at all times (including during emergencies) for CTSP technicians to their sites to effect repairs and fuel generators;
   2. Priority access for CTSPs to fuels during recovery efforts following major emergencies and consider reliable / resilient fuel dispensaries; and
   3. Priority restoration of utility power to CTSP sites by provincial / territorial utility companies.
7. Exemption from labour regulations and legislation that is fundamentally inconsistent with the Minister’s prioritization of network resiliency – specifically the legislation prohibiting the use of replacement workers, which, if applied to CTSPs, could result in outages during work stoppages and Hours of Work limitations under Part III of the Labour Code in the contexts of emergencies, which would limit the ability of CTSPs to respond to outages.
8. In regions where there is no wireless coverage, or where there exists service from only one CTSP, the federal government should provide funding or tax credits to bolster that CTSPs’ reliability. This will support the CTSP in supplying backup batteries, generators, diverse backhaul investments, etc.
9. Encourage and liaise with provincial, territorial and municipal governments to ensure that local processes support accelerated tower construction and other radio apparatus siting approval times.

There are more than 100 detailed recommendations to improve network resilience for telecom services providers to implement “to the extent commercially, operationally, technically and physically practicable”.

We’ll certainly be following these issues. But let me pause for a little story.

With all the best preparations in the world, networks will still sometimes go down. Just over a week ago, we saw the CRTC itself experienced a weather related outage:

When the Rogers network went down last July, I observed that it wasn’t even the worst outage that week: “KDDI, Japan’s number 2 carrier, had 40 million customers without service for 3 days.”

Thirty-two years ago, I attended TELECOM 91 in Geneva, a global gathering and trade show for industry professionals and government authorities. Together with my company CEO, we were being given a tour of the multi-storey Digital Equipment Corporation booth by the president of the company’s Canadian arm. He proudly stated that 100% of Digital’s Canadian communications network was on our company’s facilities. I responded by saying in that case, he should probably fire his IT manager. My CEO nearly swallowed his cigar.

Imagine if Canada’s Interac bank network had been built with multiple suppliers of services.

Instead of expecting that networks will never fail, network professionals have plans in place to manage and mitigate various risks of failure. Most of the time, network events aren’t noticed by customers because backup plans are invoked within milliseconds.

Every so often, something new comes along to test the networks and the advance planning. The Canadian Telecommunications Network Resiliency Working Group is working to minimize the customer impact of those events.