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Telecoms want CRTC to adjust service outage reporting, notification requirements
(Visual: Naomi Wildeboer/Hill Times Publishing)

Telecoms want CRTC to adjust service outage reporting, notification requirements

New requirements changing how telecom companies must notify the CRTC about service outages and report the specifics to the commission are going to be too burdensome for companies to take on, and in too short an amount of time, according to a group of service providers asking the commission to update its ruling. 

The group of applicants consists of BCE Inc.’s Bell Canada, Bragg Communications Inc.’s Eastlink, Cogeco Communications Inc., Quebecor Media Inc., Rogers Communications Inc., Saskatchewan Telecommunications Holding Corp. (SaskTel), and Telus Corp. While they say they are in full support of the CRTC’s intention behind the decision, they say it requires “practical, but necessary, adjustments.” 

“These minor changes aim to address operational challenges and reduce administrative burden for both the applicants and the commission, while still implementing increased notifications and reporting, ensuring effective implementation without compromising the decision’s core objectives, which we collectively support,” they write. 

The CRTC released its decision last month, ordering telecoms to notify the commission and other official bodies about outages, such as provincial emergency management crews. Companies will also have to file “comprehensive post-outage reports” explaining what caused the outage, as well as the effects of the incident and what was done to resolve it. Those requirements come into force in early November. 

Two years after it launched its consultation on the matter, the commission has defined a “major emergency services outages” as being:

– A major primary service outage (a complete loss of service to internet, cellphone, data services, landline phone and voice over internet protocol [VoIP] service);

– A major 911 service outage;

– A major wireless public alerting service outage.

According to the CRTC’s decision, major primary service outages could occur in two ways. For one, it would have to impact at least 600,000 user minutes, “calculated by multiplying the duration of an outage in minutes by the number of end-users affected.” It could also be an event where a rural or remote community is isolated by losing access to internet or phone services. 

There is not a required minimum number of end-users affected for the other types of major issues to count as a problem that must be reported. Once such outages have been ongoing for 30 minutes or more, they must be reported. 

The CRTC in early 2023 put in place interim reporting measures for major service outages which were slightly different. It required telecoms to notify it within two hours of an outage, and requested a comprehensive report within 14 days of an outage.

In their recent application, the telecoms’ suggestions for changes address the “aggressive implementation timeline,” of the newer decision, which they say is not enough time to prepare and deploy the required automated systems and staff training. 

Implementation deadline should be updated, telecoms say

The telecoms suggest the full implementation deadline for the new rules be extended until the regulator’s expected outage reporting portal is launched, and that the notification threshold be set at 50,000 users affected over an hour. 

They say all submitted outage notifications and related forms should be presumed to be confidential, and that detailed post-outage reports should only be required for major outages as defined under the interim regime or when explicitly requested by the commission. 

When it comes to notifications for outages that do not meet the interim threshold and trigger notification requirements outside of normal business hours, they want the deadline for notifying the commission extended to 11 a.m. the next business day.

“These revisions would enable carriers, during the transition, to allocate their resources most effectively during an outage – prioritizing service restoration – while still providing the commission and relevant authorities with timely and actionable information for major outages as defined in the interim decision,” the telecoms write in their application. 

There are also concerns about needing to make the reports publicly available. The CRTC had decided that the reports would be made public on its website, and would inform its resiliency policy. 

The telecoms compare the situation to the United States, where they say outage notifications and reports are “presumed confidential in their entirety.” They worry publicizing them will require administrative staff to assess what kind of information cannot be disclosed publicly. 

“Given the significant increase in reporting resulting from the new thresholds, there is a real possibility, as recognized by the [Federal Communications Commission], that a collection of outage data could reflect patterns that implicate national security, even when the filings taken individually may not. The first notification after the event (as opposed to the post-outage report) should be confidential. Any public disclosure should be limited to [the] post-outage report,” the telecoms wrote. 

 

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Expect a deluge of reports under new rules, telecoms warn

Under the new rules, the telecoms expect the CRTC would get reports on more than 1,000 outages per year compared to the approximately 20 they say it gets under the interim regime. 

“Considering the commission initially provided providers only two months to implement the new thresholds, clearly such a dramatic increase was not anticipated,” they wrote.

Fibre cuts are a daily problem for telecoms, the applicants note, caused by anything from vandalism and theft, to construction and car accidents. Cuts can take a “significant” amount of time to fix, depending on factors like waiting for police or hydro companies to secure a scene or getting permission from landlords. 

“Based on the newly-established thresholds, [service providers] would now have to report these minor events on a daily basis. These lower commission’s outage reporting thresholds add a disproportionate administrative burden on [service providers] at a time when they are urgently focused on repairs to restore service, and communicating with impacted customers as needed.”

Even if the commission were to find that the reporting thresholds it created is appropriate, it should still vary the decision because it failed to adequately explain the “practical and meaningful benefits that would result from such extensive reporting or to justify the very significant operational burdens of the new notification and reporting regime in comparison to these benefits, the telecoms write. 

“It is unclear, for example, whether the commission intends to staff the receipt of outage notifications 24/7 and what it intends to do with such notifications,” they note. 

“The commission has also failed to provide guidance on how carriers are expected to reconcile stringent immediate notification requirements with the primary objective of service restoration, given limited off-hours staffing and the time required to scope and tender out to vendors the necessary systems, process, and automation changes required to meet the newly imposed reporting requirements.”

The telecoms are looking for an expedited ruling on timing of when the changes must be implemented, or at least suspend the deadline for now, and decide on doing so before the end of October. 

hdaley@thewirereport.ca