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Building resilience in telecommunications in Canada and Beyond. That is the topic for a workshop taking place in downtown Toronto on the afternoon of May 14, 2024. The event is hosted by the Ivey Business School.

Over the past couple of years, I have written about network resilience a few times:

• Reliable and resilient networks (January 23, 2024)
  I observed that weather-related service disruptions will likely be a bigger factor in coming years. In a competitive environment, I asked what is the role of regulators in setting standards or objectives for reliable and resilient networks?
• Network resilience (April 14, 2023)
  This post looked at the report released by The Canadian Security Telecommunications Advisory Committee (CSTAC), aimed at improving network resilience and reliability.
• Time to rethink resilience (October 11, 2022)
  While it is impossible for businesses to prepare for all potential disruptive events, mitigation strategies can dampen potential damages.

Network resilience was incorporated in the 2023 Policy Direction to the CRTC. The Canadian government oversaw the creation of a multilateral memorandum of understanding for mutual assistance in the Fall of 2022. The CRTC has not yet released its final determinations in its “Development of a regulatory framework to improve network reliability and resiliency – Mandatory notification and reporting about major telecommunications service outages”, launched a year ago. Regional governments have increasingly been concerned with the Emergency Management and Climate Readiness. Canadian consumer groups have raised concerns about network outages, prompting responses from both government and industry. The industry is investing heavily for resilience in wired infrastructure and wireless networks, including satellite.

In the Canadian context, discussions include examining the roles of government funding mechanisms, outage reporting, network access, and the role of layered and competing infrastructures. Internationally, both geopolitical and domestic concerns have brought resilience to the highest concerns among Canada’s main trading partners and allies. New initiatives are underway in the United States, the European Union, and South Korea, among others.

This workshop aims to explore policy, regulation, business strategy and institutional frameworks for an increasingly resilient Canada – in a world where threats to resilience (climate events, cyberattacks, war) surge forth without regard to national borders or government mandates, with digital ecosystems of international reach. Speakers from Canadian government, industry and consumer organizations will join with international experts for an engaging debate and important announcements. New initiatives, frameworks and concepts will be explored by an inquisitive debate and presentations.

Speakers from Canadian government, industry and consumer organizations will join with international experts for an engaging debate and important announcements. New initiatives, frameworks and concepts will be explored by an inquisitive debate and presentations.

Confirmed speakers include:

• Andre Arbour, Director General, Telecommunications and Internet Policy, ISED
• Erik Bohlin, Professor, Ivey Business School, and Ivey Chair in Telecommunication Economics, Policy and Regulation
• Seongcheol Kim, Professor, Korea University
• Phil Moore, VP, TELUS
• Romel Mostafa, Director, Lawrence National Centre for Policy and Management, Ivey Business School
• Eli Noam, Professor, Columbia University
• Jieun Park, Korea Institute of Science and Technology
• Adam Scott, Vice Chair, CRTC
• Georg Serentschy, Serentschy Advisory Services

This workshop, Building Resilience in Telecommunications – In Canada and Beyond, is funded in part by the Ivey Chair in Telecommunication Economics, Policy and Regulation, as well as the Lawrence National Centre for Policy and Management at the Ivey Business School. Registration includes lunch, all sessions, and a cocktail reception to wrap up the day. It all takes place at Ivey’s Donald K. Johnson Centre in the Exchange Tower at 130 King Street West in the heart of Toronto’s financial district.

The full agenda [pdf, 660KB] and registration information are available on the event website.

Over the past couple of years, I have been more assertive in defending my identity.

I am proudly a Jew (in case you didn’t already know). I have never hidden that fact. In university, I refused to write exams scheduled on Jewish holy days or on the Jewish Sabbath (Friday evenings and Saturdays). On my first day of work at Bell-Northern Research in early September in the late 80’s, I informed my boss that I would be missing work in a few weeks for the High Holy Days of Rosh Hashana and Yom Kippur. He responded that I wouldn’t have earned any vacation time by then. I made it clear that I wasn’t asking for time off. I wasn’t going to be at work those days; he and HR could figure out how to code it.

In the early 90’s, the CRTC was running behind schedule during a multi-week hearing. The Commission wanted to have sessions on Saturdays in order to catch up. I refused to testify on a Saturday. My boss pressured me, reminding me that I wasn’t “that” religious. I replied saying it is one thing for me to choose to do some work on Saturdays, but it is a different matter for my government to require me to work on my Sabbath. I held firm. Instead, the hearing ran later each day. An observant Jewish member of one of our competitors came up to me and thanked me for holding my ground.

And, that is why I am using this platform to write this post.

When I am publicly defending my identity, I am also standing up for those who don’t have a public persona. I get to raise my voice on social media, and often, some like-minded followers will amplify that message well beyond my customary reach. It is a network benefit.

Back when the Laith Marouf affair was percolating, the story gained traction when Jonathan Kay raised the profile of my complaints. It is for that reason that I believe it is important to write to you.

Followers of this website know that I frequently travel to Israel. Israel is an intrinsic part of my Jewish identity. When Jews pray, we face toward Jerusalem. Our prayers and our bible contain references to Israel. Major Jewish festivals are tied to agrarian timetables and practices in Israel. I am not an Israeli citizen, but I have family who are.

The events of October 7, 2023 have been deeply troubling to me. The response – or more correctly, the lack of moral leadership – by Canadian officials has been disturbing. The sacking of British Columbia’s NDP cabinet member Selina Robinson demonstrates a pervasive rot – or latent antisemitism – among many political leaders.

I am tired of politicians thinking that the way to respond to antisemitic acts is to write on Twitter that “This is not who we are” or claim that “Hatred and violence against Jewish communities have no place in Canada.”. Condemnations on social media are no match for intimidation by throngs calling “Death to the Jews”. Tweets are ineffective against firebombings and shots fired at synagogues and Jewish community centres.

In defending freedom of expression, I have frequently quoted Aaron Sorkin’s brilliant speech from The American President. “You want free speech? Let’s see you acknowledge a man whose words make your blood boil, who’s standing center stage and advocating at the top of his lungs that which you would spend a lifetime opposing at the top of yours.”

Still, there are limits to those speech rights. As CIJA said in its statement yesterday, “We cannot allow mob-driven demonstrations to obstruct our right to participate fully in society.”

Which brings me to how you fit in to help in defending my identity. In resigning from the NDP caucus, Ms. Robinson wrote, “I don’t need your hugs and your emojis. What my community needs however, is for you to stand up to antisemitism.”

Call out hate when you see it online. Tell your elected officials that antisemitism isn’t just a problem for Canada’s Jews. Demand action.

And every once in a while, I’d be OK with a hug.

Maybe I am the naive one for expecting delegates at national political convention to produce thoughtful policy resolutions.

Shame on me.

At the recent Liberal Party convention, there were 24 policy proposals that earned majority delegate support as an “official party policy”.

One of these, ranked tenth in priority, was entitled “Combatting Disinformation in Canada”. The policy requests “the Government explore options to hold on-line information services accountable for the veracity of material published on their platforms and to limit publication only to material whose sources can be traced.” Because it directly impacts press freedoms, the media had a field day with this one. A Globe and Mail editorial called it “nothing short of dreadful and dangerous”.

The resolution passed without debate. No one stood up to challenge it. And while the Prime Minister told journalists that the government “had no intention of acting on the party’s policy”, let’s remember that this same government is pushing through a suite of legislation to control internet content, generally treating committee review of the bills with hostility.

As the Globe editorial wrote, “the resolution reflects how the Liberal base, at least, thinks that control should be increased”.

This wasn’t the only resolution that should have attracted greater review. Number 17 caught my eye, entitled “Fairer Access to Telecommunications Infrastructure”. The leadoff recital begins “Whereas a 2017 OECD report found…”. And, that may be all you need to know about that first recital.

Should we actually care what a six year old OECD report reported? A 2017 OECD report, any 2017 OECD report, is based on data from 2016 or earlier. It is 2023. If there are no newer reports that support your resolution – the first recital of your resolution – that may be an important indicator. Contradictions in that policy resolution might bring comic relief to your day. For example, the policy calls for nationalization of telecom infrastructure in part of the resolution, while seeking more international carriers in the second part. What a welcome to doing business in Canada!

I am not just picking on the Liberal Party. Three years ago, I noted that more thoughful policy would be helpful for all of the political parties. At the time, the Conservatives had produced a telecom policy paper that read more like a rough draft of a first year college term paper, a hodgepodge of random thoughts.

Our parliamentary committees seem broken. Is there a sufficient depth of understanding of issues to help produce more thoughtful policy?

Last week, University of Calgary economist Dr. Jeffrey Church and NERA’s Managing Director Dr. Christian Dippon penned a detailed critique of the “junk science” approach to analysis of international price comparisons, published in the Financial Post. The article is a deeper analysis, but it is worth investing time and brain-power to read.

Notably, the authors write that “The quality of network service, availability of family plans, consumer preferences, income, availability and terms of handset provision, alternatives to wireless services, costs of provision, and the institutional / regulatory / legal environment all differ across countries.” These factors are all missing from more simplistic analysis of price comparisons, leading to a flawed conclusion that higher prices in Canada are to be blamed on market competitiveness. “The FCC assessment [pdf, 2.8MB] of effective competition in wireless services contrasted starkly with the emphasis on flawed international price comparisons by the CRTC and the Competition Bureau.”

Junk science market analysis contributes to the flawed resolution passed by the Liberal party at its convention. Such policies, based on overly simplistic price analysis, can lead to increased costs for Canadian carriers, ultimately raising prices for consumers and potentially harming the business case for investment in network upgrades.

What is the best way to facilitate development of more thoughtful policy?

The Canadian Wireless Telecommunications Association announced it is rebranding itself, dropping the ‘wireless’ qualifier, explicitly expanding its scope to include wireline communications. Its new Twitter tagline reads “Dedicated to building a better future for Canadians through connectivity”.

Welcome to the Canadian Telecommunications Association, a new name reflecting the organization’s broadened role. The Association promotes the “importance of both wireless and wireline telecommunications to Canada’s economic growth and social development, and the crucial role of ongoing investments by facilities-based service providers in delivering world-class internet and mobile-wireless services to Canadians.”

The rebranding represents the latest chapter in a nearly 50-year history for the organization. In many ways, the evolution of the Association’s name and branding over the decades reflects the changing nature of telecommunications in Canada. The association says it will continue to do more than advocate on behalf of its industry members. It facilitates industry-wide initiatives such as the Mobile Giving Foundation Canada, Canadian Common Short Codes, STAC and wirelessaccessibility.ca.

Technology evolution and consumer demands tend to blur lines between the capabilities and use of wired and wireless telecommunications. Many policy priorities overlap between wireline and wireless carriers.

“We remain dedicated to building a better future for Canadians through both wireline and wireless connectivity.”

Consumers want faster, more reliable internet connections, driven by streaming video and other bandwidth-intensive applications. So, service providers invest billions of dollars each year to expand and upgrade access and transport networks.

Canadian Telecommunications Association CEO Robert Ghiz said: “Our members are committed to ensuring that Canadians continue to enjoy world-class telecommunications services that are the cornerstone of Canada’s digital economy and an important contributor to the social fabric of our country. For this to happen, Canada must maintain a regulatory environment that incentivizes the high-level of private sector investment needed to connect all Canadians and build the next generation of connectivity infrastructure and services.”

“Canada’s future depends of connectivity” is a phrase that has appeared many times on these pages since it was used by former ISED Minister Navdeep Bains in August 2020.

The rebranding recognizes that connectivity can be delivered over wireline and wireless facilities, building digital infrastructure for a new era.

Canada’s innovation-based economy depends on connectivity – connectivity delivered by the investments made by members of the Canadian Telecommunications Association.

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.