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.

“There is no ‘magic number’ of mobile operators”.

That statement appeared, almost as a non-sequitur, in a press release from the UK Department for Science, Innovation & Technology. The department announced funding and support for the next evolution of 5G and “a national mission to connect all communities.”

But it then continued to say:

To help the mass adoption of 5G across the country, the strategy sets out a clear pro-investment framework for mobile network operators by driving down deployment costs and improving demand. The government has also reconfirmed that there is no ‘magic number’ of mobile operators, whilst noting all decisions on consolidation are for the Competition and Markets Authority.

The release noted that the UK expects to have gigabit broadband available to 75% of the population and expects to deliver 99% by 2030.

(According to figures from the CRTC, Canada had already reached 75% gigabit broadband coverage by year-end 2020, nearly two and a half years ahead of the UK.)

The UK announcement seems to be recognizing the importance of a developing a government policy environment to support investment in digital infrastructure. And as part of that, the government said there is no ‘magic number’ of operators, almost inviting consolidation if it will promote investment.

Promoting investment in high-quality networks is a key element of the Canadian Government’s Direction to the CRTC on a Renewed Approach to Telecommunications Policy.

It is an important factor as the new CRTC begins its review of a number of files.

Canada’s future depends on connectivity. And, connectivity depends on investment.

From the earliest days, regional networks have been a part of the North American telecom landscape, often plugging gaps in rural and remote regions.

Nearly 150 years later, regional networks still play an important role in bridging the digital divide.

A recent report by STL Partners describes “How Regional ISPs are Bridging the Digital Divide Through Innovation” [pdf, 740KB].

The report suggests that regional ISPs should explore new business models to close the digital divide.

Regional ISPs can overcome their unique challenges by developing business models that are not accessible by the larger carriers. Many smaller ISPs are formed by public entities, such as electric cooperatives and tribal governments, meaning that they operate locally and are more attuned to their community’s needs. In this report, we will highlight innovative business models that regional and rural ISPs are pursuing to bridge the digital divide, focusing on four key factors: technology, partnerships, financing models, and new services and customer segments.

Under technology, STL speaks of the role of wireless access, including TV White Space and LEO satellite, supplementing fibre that “can be impractically expensive for rural deployments, where population density is much lower.” I agree. We need to be technology agnostic as we bring broadband to unserved and underserved areas.

However, regional ISPs aren’t the only ones examining new services and customer segments to create business cases for rural investment. Mobile service providers will continue to explore the role of their networks in providing additional services, and can deploy fixed wireless access over 5G networks to deliver residential broadband.

It will take lots of industry participants, deploying a variety of technologies, to bring broadband to every Canadian household.

However, don’t confuse regional networks with municipally owned networks.

Frequent readers will recall that I am not a fan of municipally owned broadband networks. Unfortunately, too many ill-conceived and naive business plans result in squandered time and taxpayer dollars. ConnectTO was an example of a solution in search of a problem. Its proponents thought one of the world’s most fibred cities would benefit from the city building a new, government owned overlay network.

Beaumont, Alberta provides another example of when a smart city plan isn’t so smart.

As I wrote in “The Broadband Divide’s Little Secret”,

We have well-meaning advocates and academics in Canada pushing agendas for municipal broadband with no evidence, or in the case of ConnectTO, deeply flawed evidence, to support their assertions that gaps in adoption rates are all about price.

The mistake that emerges from a lack of good economic and social data analysis is that governments are tempted to apply the wrong solution to solve the wrong problem.

I wrote before that too many community networks are failing their constituents. I have also written that government programs to provide better broadband are failing underserved markets.

There is a role for municipal and regional governments in driving increased access to broadband in those underserved areas. Governments (at all levels) need to ensure that policies and programs stimulate investment in sustainable competitive network facilities. And, local and regional governments are uniquely suited to drive rates of digital adoption.

Investment drives connectivity. And, Canada’s future depends on connectivity.

A couple weeks ago, I saw a press release from HomeEquity Bank announcing a series of videos to help unmask the scams that are targeting Canadians. I think they are worth sharing.

The Canadian Anti-Fraud Centre (CAFC) says fraud and cybercrime cost Canadians more than $530m in 2022. A recent article by Christine Dobby (Toronto Star) says those annoying telephone scam calls represented more than 10% of that total, $57M.

HomeEquity Bank’s campaign shows how easy it is to create and run a convincing deepfake scam. Using readily accessible AI technology, the series has a deepfake impersonator appearing as actor Keanu Reeves. Thieves have used Reeves’s name in a frequently reported celebrity romance scam.

The HomeEquity Bank deepfake takes viewers through three common scams to raise awareness of some of the most frequent methods of fraud targeting Canadians.

The series demonstrates how simple it can be for almost anyone to be transformed into a convincing impersonator. “The deepfake impersonator recorded the videos virtually from his home, and didn’t need any special cameras or devices to create the effect.”

HomeEquity Bank’s target market skews toward more senior client base, with its reverse mortgage product. The elderly are a frequent target for these scams.

The bank created the series as a follow up to its 2020 “Catch the Scam” campaign with Frank W. Abagnale, the con man and imposter featured in the Stephen Spielberg film “Catch Me If You Can.”

That 2020 campaign featured 4 videos, highlighting:

• The Grandparent Scam
• The CRA Scam
• The Lottery Scam
• The Romance Scam

Better education helps to unmask the scams, making them less profitable. As HomeEquity Bank writes, “We should see sharing our own experiences with scams as a means of better protecting us all. That means breaking down the stigma that comes with being the target of a scam. The more scams we can recognize and share with others, the less successful scams will be.”

In the US and Canada, the telecom regulators are looking at satellite to mobile phone direct connectivity. Is there a space race underway between the FCC and CRTC?

In the past few weeks, each regulator has started to examine what the FCC is calling “innovative collaborations between satellite operators and wireless companies”.

On March 16, the FCC announced the launch of a new Notice of Proposed Rulemaking process, adding the file to the FCC’s International Bureau’s Docket 22-271. The FCC wants to establish “clear and transparent processes” to support supplemental coverage from space, such as connecting mobile consumers to emergency services via low earth orbit satellites, where no terrestrial mobile service is available.

The FCC has asked for comments on “how this framework might best support access to emergency response systems like 911 and Wireless Emergency Alerts when a consumer is connected via supplemental coverage from space.”

In early March, the CRTC sent a letter to Apple asking for information about its “Emergency SOS via satellite and Crash Detection services”. The CRTC was following up on a presentation from early last October. Rather than conducting a full public process, the CRTC targeted Apple to respond to 30 questions, including: “Explain why Apple does not consider the Crash Detection service as a telecommunications service, the provision of which in Canada could require Apple, among other things, to register with the Commission as a telecommunications service provider.”

It is interesting to see the different approaches by the Canadian and US regulators. In the US, the FCC “proposes a framework through which satellite operators collaborating with terrestrial service providers would be able to obtain FCC authorization to operate space stations on certain currently licensed, flexible-use spectrum allocated to terrestrial services.” The FCC is also looking at adding a satellite to mobile phone allocation on some terrestrial flexible-use spectrum bands.

The CRTC does not handle telecommunications spectrum allocations; that is the responsibility of ISED. As such, the CRTC is unable to consider the potential outcomes associated with satellite to terrestrial spectrum allocations. The CRTC’s interrogatories only looked at emergency access, while the FCC also plans to examine how such connectivity “can open up innovative opportunities for consumers and businesses.”

On the surface, the FCC approach appears to be more forward looking, contrasted with what I perceived to be a somewhat more challenging tone in the CRTC’s letter.

The CRTC asked Apple for a response by March 31. As a follow-up, perhaps the CRTC will work together with ISED to explore a progressive approach that advances mobile connectivity for Canadians when we are off the beaten path.