Public safety authorities want lower thresholds for network outage reporting requirements

Provincial public safety agencies are requesting to the CRTC that they be included on the list of authorities that must be notified by carriers when a major network outage occurs and that the threshold which would trigger such an event be lowered. Wednesday, the commission posted the reply comments for its consultation on network reliability and resiliency and mandatory notification about major telecommunications service outages. The CRTC proposed that Canadian carriers be required to inform the Department of Innovation, Science and Economic Development (ISED), and other relevant authorities of major service outages, and to submit a comprehensive post-outage report to the commission. It issued an interim direction for all Canadian carriers to report major service outages (MSOs), including outages affecting only 911 networks, to the commission within two hours of when the carrier becomes aware of such an outage. The commission’s proposed definition of a major outage is established as “any outage affecting: more than 100,000 subscribers or a material portion of the carrier's subscribers for more than one hour, subscribers that are in a geographic area served only by the affected carrier, critical infrastructure, major transport facilities, a 911 network." “The threshold of 100,000 subscribers for more than one hour is an acceptable definition to notify the Commission and ISED. However, it is not sufficient for notifying PSAPs and EMOs,” the Nova Scotia Provincial 911 Service (NS911) of the Nova Scotia Emergency Management Office wrote to the CRTC in its Apr. 11 reply. NS911 noted that the Atlantic provinces have many rural communities where population and subscriber numbers are well below 100,000. The New Brunswick Department of Justice and Public Safety and the 911 department of Justice and Public Safety in Newfoundland and Labrador also filed similar concerns with the commission. In its March intervention, New Brunswick’s department suggested that carriers be forced to provide immediate reporting of any interruption to services that impacts the ability of the public to make 911 calls. EComm 911, in its initial intervention, argued that a loss of service for more than 30 minutes should constitute a major service outage. EComm and the Canadian NG9-1-1 Coalition argued that one or more mobile devices being unable to connect to 911 service would also be considered a major service outage. “Any time Canadians lose 911 access it should be considered a major service outage and all Canadian carriers should be required to report MSOs to PSAPs,” the coalition wrote in March. In its March intervention the Public Interest Advocacy Centre (PIAC) urged the CRTC to use the definition established by the United State’s telecom regulator, the Federal Communications Commission (FCC) . The FCC requires carriers to report an outage with a duration of at least 30 minutes that potentially affects at least 900,000 user-minutes. That threshold would trigger outage reporting where 30,000 users are affected by an outage for 30 minutes, which PIAC argued is more likely to occur in urban areas, or 10,000 users affected for 90 minutes, reflecting typical outages in rural and remote areas. Many emergency groups also called on the commission to add them to the list of authorities that should be notified in the event of an outage. PIAC noted “it would be impractical for carriers to themselves identify and notify the relevant agencies other than the commission” and the department of Innovation, Science and Economic Development. It proposed that the commission develop an online notification and reporting portal like the Network Outage Reporting System implemented by the FCC. The Competitive Network Operators of Canada (CNOC) supported PIAC’s proposal for an online portal in its reply comments. BCE Inc. and Telus Corp. on the other hand opposed the various proposals. “Some parties have displayed a fundamental misunderstanding of the differences and impacts of a 9-1-1 network outage versus an access service outage,” Telus wrote in its reply comments. “In the event of a voice access services outage, customers of the impacted carrier would experience no dial tone or be unable to complete calls to anyone, 911 or otherwise. In such an access services outage, the 911 network might not be affected at all because it is a separate network - normally operated by the in the geographic area - and processes all wireline and wireless 9-1-1 calls in a geographic area,” Telus wrote. Bell noted to the CRTC that the commission allows any 911 service outage to be considered as a major outage then every outage, no matter how small or localized, would qualify as a major outage because a subscriber typically cannot reach 911 if their underlying service does not function. “This does not seem to be the commission’s intention or to be reasonable. It makes more sense to consider that only 911 network outages rise to the level of a MSO,” Bell wrote. Bell, Telus and TBayTel urged the commission to use the definition it established in 2016 “that a 911 network should begin at the point of interconnection between the originating networks and the 911 network, and end at the demarcation point between the 911 network and the PSAPs.” Finally Bell disagreed with the proposal to include all PSAPs, police, fire, ambulance, and provincial, regional, local EMOs on the list of authorities to notify in the event of a major outage. Bell argued that the appropriate authorities to be notified of an outage is already appropriately defined in the memorandum of understanding (MOU), or the network sharing agreement, signed between telecom service providers (TSPs) in response to the July outage experienced by Rogers Communications Inc. “Critics of the MOU list of governmental authorities have not cited any evidence indicating there has been a change in circumstances since endorsed the list of notification addressees in that document,” Bell wrote. BCE Inc. in its initial March intervention said that the CRTC’s outage measures “are premature given the lack of supporting evidence as to their necessity, efficiency, and proportionality”. –Reporting by Jenna Cocullo at jcocullo@thewirereport.ca and editing by Paul Park at ppark@thewirereport.ca

Public safety authorities want lower thresholds for network outage reporting requirements

News | April 14, 2023

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Public safety authorities want lower thresholds for network outage reporting requirements

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