How to Make Telecoms More Resilient? For Starters, Better Internal Controls

A provocative way of thinking about infrastructure is to consider it as sociologists Susan Leigh Star and Karen Ruhleder have, as something that “remain[s] invisible until breakdown.” When Rogers Communications’ network went down on July 8, 2022, it became hard to unsee the depth of our dependence on telecommunications services, and the firms that provide them.

It’s one thing not to be able to email colleagues, phone friends or like their social media posts. It’s another matter altogether to go without emergency services, or payment services, or to miss a mandated court appearance because your internet is down. The dynamics of entire communities change when thousands of concertgoers are sent home, bike-share fleets blink offline, or doctors must remain at hospitals because they may be otherwise unreachable.

Given enough lifespan, every complex system must experience failures, despite the best efforts of individuals within those systems who work hard to prevent them. But that inevitability should be viewed as a conversation-starter, rather than an excuse for inaction.

Resiliency is bigger than any one individual or even any one company. It is systemic. How do we retrofit into our fraught telecom environment a reliability agenda that amounts to more than a telecom equivalent of poorly privatized health care, in which service is most accessible to the most fortunate? What does a reliability agenda for telecom look like — one that recognizes that we are all better off when we all are served by a critical communications infrastructure that we rarely need to notice?

The answer starts with understanding where existing public oversight fell down in the Rogers fiasco and the nature of those gaps. For nearly 30 years, the Canadian Radio-television and Telecommunications Commission (CRTC) has been charged by the Telecommunications Act with ensuring that markets render “reliable … telecommunications services of high quality accessible to Canadians in both urban and rural areas in all regions of Canada.” Its mandate is to steer telecom markets in ways that ensure they meet all the public policy expectations we have for them in view of their public role.

The CRTC is, of course, aware of telecom’s embeddedness as both a direct-use service and an essential ingredient in the services that businesses, public agencies and not-for-profits provide for Canadians’ everyday use. But following through on that awareness — even after the post-mortem the CRTC has initiated with its 54 pointed questions to Rogers is completed — should include more than better visibility, fewer redactions, or scrambling into action when news of an outage crackles over the transom. How, rather, should resilience become embedded in the way we oversee and regulate telecom markets systemically?

Reliability Lost in the Shuffle
A resilience agenda for Canadian telecom is easy to call for but hard to execute, especially when much else is afoot. Over the three decades since the Telecommunications Act came into force, the regulator has also presided over the progressive introduction of competition; the implementation, then general dismantling, of foreign ownership restrictions; and the complete, and ongoing, reworking of how communications services are delivered in light of digital technologies. It has worked to update its frameworks to both respect and respond to the once-central public switched telephone network’s long wind-down in favour of broadband and internet.

Somewhere along the way, however, the reliability expectations exemplified by responsibilities such as retail quality-of-service reporting, once required of rate-regulated monopolies by the CRTC, were replaced by the lesser outcome of “informal resilience.” That’s something that emanates from markets in which overlapping service providers compete on multiple platforms for the trust of consumers and businesses. For critical infrastructures, informal resilience is not enough.

Read the full publication here.