Telecom - Procedural Letter addressed to the Distributon List
Ottawa, 12 April 2021
Our reference: 1011-NOC2021-0009
BY EMAIL
To: Distribution List
Re: Compliance and Enforcement and Telecom Notice of Consultation CRTC 2021-9 – Procedural request from the Communications Security Establishment
On 13 January 2021, the Commission published Compliance and Enforcement and Telecom Notice of Consultation CRTC 2021-9 (the NOC), soliciting comments on the development of a network-level blocking framework to limit botnet traffic and strengthen Canadians’ online safety. The deadline for interventions was 15 March 2021.
On 26 March 2021, the Communications Security Establishment (CSE) filed an intervention along with a procedural request asking the Commission to consider its late intervention. CSE is of the view that their intervention should be considered as part of the consultation given the particular cyber security expertise they can provide on the subject of the consultation. CSE claims that their mandate and experience provide them with insights on the issue of botnets and indicators of compromise that would be a valuable contribution to this consultation. They believe that it would be beneficial to add their views to the public record to inform the discussion as well as the decision-making process moving forward since several interventions submitted as part of this consultation have referenced CSE and the Canadian Centre for Cyber Security (CCCS), a division of CSE, and offered suggestions on the role they could play in a botnet blocking framework.
On 29 March 2021, Marc Nanni filed a response, requesting that the Commission refuse CSE’s procedural request and its late intervention. Mr. Nanni noted that CSE’s public-facing website likely provides sufficient information about botnets to which companies and the public can refer. Alternatively, Mr. Nanni requested changes to the timelines of the proceeding in order to ensure procedural fairness.
Commission’s analysis and determinations
CSE is Canada’s national lead agency for foreign signals intelligence and cyber operations, and the technical authority for cyber security. The CCCS defends Government of Canada networks from cyber threats, provides expert security advice, guidance, and services for other levels of government and critical infrastructure. It protects the systems and information that Canadians rely on every day.
In view of CSE’s important role as the Government of Canada’s authority on cyber security, the Commission considers that CSE’s intervention is important to ensuring a complete and robust record. The Commission considers that CSE’s submission would help to provide a balanced record that takes into account the interest of all stakeholders.
CSE’s expertise in cyber security would also help to provide valuable perspective on the technical components of the consultation and assist in validating claims made by other parties to the proceeding.
In light of the above, the Commission hereby grants CSE’s procedural request, and its intervention will be made part of the public record.
In order to provide all parties to the proceeding an opportunity to consider CSE’s submission before filing their reply submissions, the Commission finds that the deadline to reply to interventions should be extended to account for CSE’s late submission and to provide parties with an equal opportunity to reply to CSE’s submission. The deadline for replies to interventions initially set as of 14 April 2021 is therefore extended to 5 May 2021.
Original signed by
Claude Doucet
Secretary General
c.c. (1) Distribution list
Compliance and Enforcement and Telecom Notice of Consultation CRTC 2021-9
Distribution List:
ar6136128372@gmail.com
francois.roukoz@gmail.com
philiasvezina@gmail.com
graemesmith1551@gmail.com
ksales0617@outlook.com
bjames@snetworks.com
email@email.ca
benoit.dupont@umontreal.ca
buell@isoc.org
chris.lynam@rcmp-grc.gc.ca
vittorio.bertola@open-xchange.com
info@diacc.ca
Karine.uqo@gmail.com
slavoie3r@gmail.com
sxmpxr@gmail.com
don.mcdonald@superchannel.ca
m_nanni@hushmail.com
michalopulos@electricity.ca
amy@m3aawg.org
mike.mckeon@nokia.com
regulatory@cira.ca
scott.seab@lumen.com
fenwick.mckelvey@concordia.ca
document.control@sasktel.com
gloria@cacmanitoba.ca
Joe.LoBianco@CIBC.com
ksurette@telus.net
Jcurtis11@gmail.com
regulatory.matters@corp.eastlink.ca
regulatory@sjrb.ca
regulatory@teksavvy.ca
christopher.hickey@distributel.ca
carl.macquarrie@corp.xplornet.com
jonathan.holmes@itpa.ca
regulatory@rci.rogers.com
jlawford@piac.ca
bell.regulatory@bell.ca
leonard.eichel@cogeco.com
regaffairs@quebecor.com
regulatory.affairs@telus.com
jfmezei@vaxination.ca
tisrael@cippic.ca
info@infosecsw.ca
media@cse-cst.gc.ca
- Date modified: