Telecom - Staff Letter addressed to the Distribution List
Ottawa, 22 February 2023
Subject: Procedural Requests related to Rogers Canada-wide service outage of July 2022
This letter addresses procedural requests related to Rogers Communications Inc. (Rogers) network outage of 8 July 2022.
By letter dated 8 July 2022, the Public Interest Advocacy Centre (PIAC) requested that the Commission initiate an inquiry pursuant to its power under section 48 of the Act into Roger’s network outage and to launch a public process to consider a variety of regulatory measures regarding network resiliency for all telecommunications services providers (TSP) in Canada. By letter dated 12 July 2022, Vaxination Informatique also submitted that a public process should be initiated seeking information from all TSPs and allowing all parties to address requests for information (RFI). On 12 July 2022, Competitive Network Operators of Canada (CNOC) requested that the Commission address RFIs to Rogers and all primary internet service providers to put on the public record the terms and conditions associated with network outages.
PIAC’s request for a public process was supported by CNOC, the Deaf Wireless Canada Consultative Committee (DWCCC); the Deaf and Hard of Hearing Coalition (DHHC); and the Canada Deaf Grassroots Movement (CDGM). The DWCCC also submitted that the process should examine the impacts on persons with disabilities, including those who are Deaf, Hard of Hearing and Deaf-Blind (DHHDB). By letter dated 5 August 2022, the CDGM sought responses from Rogers to a number of questions regarding the effects of the outage on DHHDB consumers. By letter dated 12 August 2022, the DWCC included a set of RFIs regarding the effects of Rogers’ outage on persons with disabilities and requested that the Commission direct the RFIs to Rogers. DWCC’s request was supported by CNOC as well as PIAC.
Public process to consider regulatory measures regarding network resiliency for all Carriers telecommunications services providers in Canada
The Commission has today issued Telecom Notice of Consultation CRTC 2023-39Footnote1, which sets out the Commission’s approach to addressing the matter of network resiliency and reliability. As set out in that Notice, the Commission is taking action, building on the work of Innovation, Science and Economic Development Canada (ISED) and the Canadian Security Telecommunications Advisory Committee (CSTAC), to develop a framework to improve resiliency and reliability of telecommunication services for all Carriers, and not just Rogers.
As the first stage of the Commission’s process, the Notice of Consultation seeks comments on a proposal to require all Canadian carriers, on a going-forward basis and as a condition of service imposed pursuant to section 24 of the Telecommunications Act:
· to notify the Commission, ISED, and other relevant authorities of major service outages; and
· to submit a comprehensive post-outage report to the Commission.
On an interim basis pending the outcome of that process, the Commission has directed all Canadian carriers to report major service outages (including outages affecting only 9-1-1 networks) to the Commission within two hours of when the carrier becomes aware of such an outage and to file a comprehensive report with the Commission within 14 days following the outage.
In addition, the Commission will initiate additional public proceedings to address network resiliency in broader terms. Those proceedings will address network resiliency issues including resiliency principles, emergency services (9-1-1), public alerting, consumer communication, the impact of outages on accessibility of telecommunications services, consumer compensation, technical measures, and the imposition of administrative monetary penalties.
Inquiry into Rogers service outage of July 2022
In order to understand the cause of the service outage experienced by Rogers on 8 July 2022, the Commission addressed two RFIs to Rogers on 12 July 2022 and on 5 August 2022. The Commission also sent an RFI to Pelmorex, the operator of Canada’s National Alert Aggregation and Dissemination (NAAD) system to understand the impact of Rogers’ outage on Canada’s alerting system. In response to these RFIs, Rogers has provided extensive information about the events that led to the service outage on 8 July 2022. Rogers has also provided details about the service restoration process and its future investment plans to make its network more resilient and avoid such outages. The abridged versions of the responses are available to the public.
The Commission is currently in the process of analysing the information submitted by Rogers and intends to engage a third-party expert to provide a report with their analysis of the service outage and the adequacy of Rogers’ actions and planned network changes. This report will be published by the Commission in order to inform Canadians and stakeholders of the report’s findings.
Given the comprehensive public process relating to the resiliency and reliability of telecommunication networks of all Carriers including Rogers, as well as the Commission’s analysis of the service outage suffered by Rogers, the Commission has determined that an inquiry into Rogers service outage of July 2022 under section 48 of the Act is not necessary. The processes identified in this letter and set out in the Notice of Consultation will enable the Commission to determine and develop any regulatory measures that may be necessary in the public interest.
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