An article in Telecommunications Policy got me thinking more about how regulatory authorities should deal with network resilience in a competitive marketplace.
The paper notes that facilities-based competition, such as that promoted in Canada, fosters improved resilience, with “multiple independent networks operated by ILECs, cable providers, and wireless operators, creating a dense and diverse infrastructure.”
But the paper includes a warning.
However, the resilience benefits of competition can be undermined by poorly designed regulatory policies. Spectrum allocation without deployment requirements or mandated roaming and MVNO access without infrastructure obligations may reduce incentives for operators to build and maintain independent networks. In Canada, such policies risk concentrating traffic on fewer networks, thereby increasing systemic vulnerabilities. Policymakers must ensure that regulatory frameworks support infrastructure diversity and investment while maintaining competition.
The paper also noted that “market forces often fall short in two key contexts: remote and rural areas and regions requiring systematically hardened networks”.
In remote and rural areas, the low population density and high costs of deployment—such as building towers, transport infrastructure, and power generation—make it economically unviable to serve customers with even a single network, let alone multiple redundant networks or hardened infrastructure. Similarly, in regions facing extreme environmental risks, such as areas prone to wildfires, flooding, or hurricanes, the economic incentive to invest in layers of duplication and advanced hardening is often insufficient without external support.
Two months ago, I wrote that it is important to recognize that all networks will fail. Improving network resilience helps ameliorate the situation when a failure condition exists.
Increasingly complex network architectures, coupled with more extreme environmental conditions, will lead to the potential for more network failure events, with even greater impact.
How do service providers build more resilient networks? How does the industry collectively create a more resilient national infrastructure? What is the role of government regulatory authorities, policy makers, and emergency preparedness organizations?
Let’s look at how the CRTC, Canada’s telecommunications regulator, is dealing with resilience and survivability. The Commission’s approach appears to be largely reactive, emphasizing post-event reporting and compensation.
In early September, the CRTC issued a Decision requiring “Mandatory notification and reporting of major telecommunications service outages”. In the eyes of the regulator, “This decision will help improve coordination whenever a major outage happens by requiring TSPs to notify the Commission and other government authorities within specific timeframes. These notifications will help ensure that relevant authorities are aware of outages so that they can help manage them and their impact on Canadians.”
Personally, I’m not convinced there will be any meaningful help managing outages coming from the relevant authorities.
On that same date, the CRTC launched two additional public consultations:
- “Development of a regulatory policy on measures to improve the resiliency of telecommunications networks and the reliability of telecommunications services” [TNC CRTC 2025-226]; and
- “Consumer protections in the event of a service outage or disruption” [TNC CRTC 2025-227].
The latter is effectively examining what kinds of communications from service providers should be mandated during service disruptions and what kinds of refunds will be required. Initial comments were due a couple weeks ago. The reply phase closes December 15. Frankly, in my view, if the market is sufficiently competitive for the CRTC to forebear from price regulation, then we should ask why the CRTC is wading in on consumer refunds and communications.
I am more interested in the former, TNC CRTC 2025-226 which has initial comments due December 3 and replies due at a date still to be determined. It is a far more complex proceeding.
In this consultation, the Commission is developing a regulatory policy on measures that TSPs should take to help improve the resiliency of telecommunications networks and the reliability of telecommunications services. The Commission is gathering views on (i) what principles should guide the development and implementation of the regulatory policy, (ii) how TSPs should design and operate their networks to help make them more resilient, and (iii) how the regulatory policy can help support the safety of Canadians in all regions of the country, including rural, remote, and Indigenous communities.
Two and a half years ago, I wrote about a report issued by the Canadian Security Telecommunications Advisory Committee (CSTAC). That report [pdf, 474KB] is referenced in the CRTC’s Notice of Consultation. Notably, the CSTAC report says “recommendations contained in this document are neither directive nor mandatory”. That is why I get concerned when I read the CRTC consultation repeatedly asking “Which of these measures should be mandatory, and which should be considered best practices?”
The CSTAC report included more than 100 detailed recommendations to improve network resilience for telecom services providers to implement “to the extent commercially, operationally, technically and physically practicable”, and there were 9 specific requests from government.
As I have frequently observed, even with all the best preparations in the world, networks will still occasionally go down.
As the CRTC continues its examination of ways to improve network resilience, it should explore how the Commission can contribute to the proactive planning and coordination across all branches of government, including the identification of funding required in rural and remote areas where redundant facilities simply don’t exist.