FRAMEWORK FOR A CANADIAN PSBN - Volume I - PSBN User Census
Volume I - PSBN User Census - Stakeholders in National Governance
Pre-Publication Release - February 3, 2024
By: Phil Crnko, MASc., P.Eng.
Principal Consultant - Black Castle Networks
INTRODUCTION & OVERVIEW
The Canadian Federal Ministry of Emergency Preparedness (“the Ministry”) is seeking input from in regard to optimally establishing a Public Safety Broadband (PSBN) governance in Canada, and in considering linked themes relating to governance of connectivity in rural and remote areas, including telecommunications service providers, communities, consumers, and consumer advocates.
Black Castle Networks – an independent design and engineering consultancy based in the Greater Toronto Area with over 25 years engineering experience, is pleased to provide this abridged version of our set of formal responses to Public Safety Canada (PS-Canada) and the Ministry of Emergency Preparedness (the Ministry).
This document is a pre-publication & abridged release of portions of Volume I of our overall five volume public-facing set of policy analyses, financial business case models, and policy recommendations pertaining to a cost effective, and reliable Public Safety Broadband Network (PSBN) for Canada.
In total, our series of publications on PSBN topics in February 2025 will comprise:
In this introductory pre-release extract from Volume I, we will discuss general themes of note for the Ministry to consider via an Open Source survey of stakeholder user populations that would be potential participants in a PSBN, helping the Federal Government to determine stakeholders that would be key to include in building a fair, effective and transparent PSBN Governance entity for Canada, and also some early thoughts on PSBN operational model (i.e., TNCO Model D) and how to build-out a PSBN across Canada in a cost-effective manner, and yet with optimal resiliency and reliability.
After this introduction, we proceed to provide a detailed view to our results from our 2024-2025 "Open Source" user stakeholder census, showcasing the quantities of users, and the relative size of key 911 emergency response communities and major voices that should make up PSBN participants in a Canadian PSBN Governance Entity.
A key finding from our user census is that Critical Infrastructure users (rail, utilities), are an outsized set of important stakeholders and potential investors in a PSBN given their user quantities and rapidly growing critical Internet of Things / Machine-to-Machine needs, however these users have been largely overlooked to date by Federal initiatives and Tri-Services organizations in considering PSBN strategy and business models.
When considered together, railways and electric utilities together tie for first rank alongside police agencies at total 34% out of the net user / subscriber population of primary emergency and disaster field responders. Coupled with their extensive pan-Canadian telecom infrastructure and possible PSBN tower mounting sites, these railway and utility critical infrastructure users – unfortunately often historically neglected in government investment in telecom and assignments of RF spectrum in Canada – are in fact very significant players and potential strategic partners for Public Safety Canada in building out a pan-Canadian PSBN.
Critical Infrastructure users can play a key part in reducing costs of PSBN CAPEX (capital expenses) and OPEX (operational expenses) for a PSBN telecom infrastructure build, and we recommend - backed up by our 2024-2025 open source census findings of user SIM and device count projections, that utilities and railways / transit users should be afforded a key voice and place at the table in any future governance model, and permitted to participate in shared RF spectrum deployments to help reduce costs over Canada's chronically high cost and vertically integrated status-quo telecom model (which we cost and discuss in detail in Volume III and Volume IV of our series).
In summary, stemming from our findings in our first bi-annual Open Source PSBN User Base Census, Black Castle Networks would like to propose 4 main policy considerations and requests for Public Safety Canada:
?In terms of implementation elements for a future operational Canadian PSBN, Black Castle Networks would like to propose 5 main policy considerations and requests for Public Safety Canada:
Key Benefits & Advantages of BCN's Proposals on PSBN Model
The Black Castle Networks (BCN) flexible P3 model for a Canadian PSBN can be seen as a type of “PSBN Investment Accelerator”, leveraging utility, railway, and optionally other P3 institutional investors as partners alongside incumbent MNO carriers, in order to move forward PSBN deployment more quickly, via a common-front investment and shared cost, and bottom line - at lower cost to government. We provide further detail of this model in the balance of this document.
Overall, the BCN proposals could potentially save the Federal Government and Canadian taxpayers Billions in Dollars in PSBN infrastructure and operations costs, due to infrastructure synergies with reliable utility telecom systems already in place today.
We now provide additional details in the following four main thematic areas in the balance of this abridged pre-publication release of Volume I - we refer the interested reader to our forthcoming full publications of Volumes I through Volume V coming later in February 2025:
Section 1 - PSBN User Census Results Overview
Section 2 - PSBN Infrastructure Accelerator
Section 3 - BCN Model Cost Savings for a PSBN vs. Status Quo
Section 4 - PSBN User Census Results 2024-2025
SECTION 1 - PSBN USER CENSUS RESULTS OVERVIEW
CRITICAL INFRASTRUCTURE ENTITIES AS KEY STAKEHOLDERS IN PSBN
Besides their key role in building and maintaining critical private telecom networks as a part of Green Energy initiatives and Electric Grid stability, and transportation control systems – electric utilities & railways also represent a significant number of the net user SIM-card population within the overall estimated PSBN subscriber population eligible to participate in a future Canadian PSBN.
The following summary charts help illustrates the importance of Electricity Utility and Railway / Transit operations members as major stakeholders in a Canadian PSBN – in terms of both current and future projected user quantities, per a recent Open-Source study being published in February 2025.
?As can be seen, railway and transit operations rank 3rd, and electric utilities rank 4th overall among all Canadian Tri-Services 911 emergency response agencies and Critical Infrastructure entities, in terms of net number of “human users’” SIM cards for voice and data features of a future Canadian national PSBN system.
When considered together, railways and electric utilities together tie for first rank alongside police agencies at total 34% out of the net user / subscriber population of primary emergency and disaster field responders. Coupled with their extensive pan-Canadian telecom infrastructure and possible PSBN tower mounting sites, these railway and utility critical infrastructure users – unfortunately often historically neglected in government investment in telecom and assignments of RF spectrum in Canada – are in fact very significant players and potential strategic partners for Public Safety Canada in building out a pan-Canadian PSBN.
Furthermore, when current and near-term IoT device deployments are included in the tally, electricity utilities rise to top rank among populations of all First Responder and Critical Infrastructure stakeholders in a Canadian PSBN system.
Given the importance of Electricity Utility and Railway / Transit members as potential PSBN users from a population and PSBN subscription stance, they also represent an important avenue of funding for both PSBN telecom operations (via the monthly subscription fees that would paid by electric utility and rail / transit users of a Canadian PSBN) and also via their role as potential capital investors and asset partners in PSBN infrastructure – a strategic partnership that would defray costs for the Federal Government as well.
The following charts offer a wider perspective and wider definition of a possible PSBN user population, and include users and agencies that are not primarily mobile field based (e.g., hospitals) and other secondary responder organizations and potential government users.
As can be seen in the above charts – Hospitals, Health & Social Services agencies – as a potential secondary user group in a PSBN – are a massive population of potential PSBN users, and top rank for net user and device count for “human users”. But again, when publicly committed IoT devices and M2M links are included, we see electric utilities rise again to top rank among all potential user classes for a future Canadian PSBN.
We provide additional illustrative plots and graphs of the extensive dataset in our upcoming Canadian PSBN User Census report, at the end of this abridged summary publication.
Another consideration to be made in regard to Canada’s critical infrastructure assets – is that they tend to follow human settlements, and given their co-deployment of telecom fiber-optic and wireless systems in support of their control-systems and operations, therefore there is a ready telecom infrastructure already built in many of Canada’s digital divide regions.
Given these geographic and investment synergies, we suggest it would be generational opportunity for the Federal Government to both save costs via utility & rail partnerships on PSBN + the opportunity to help solve the Digital Divide via an innovative P3 pooled resource approach. We see several good precedents to back this proposal – both in the UK with the SRN, but also in the USA with the example trend of utilities investing in regionalized Private 5G telecom operations – either fully private – or even as an outright MNO in the example of Southern Linc.
??We note here the precedent example of Southern Linc[4] in the United States, as an example of a major utility that also offers telecom services to First Responders in a regional PSBN. Another precedent related to the Southern Linc MNO is that it was recently awarded “primary communications” designation by the Georgia State Patrol[5] – over their legacy LMR systems – which highlights the confidence First Responders have in the US with Southern Linc as a specialized utility-owned and utility-maintained telecom service provider.[6]
?It is important to note, that the Southern Linc? bellwether[7] example also highlights that electric utilities in general - can indeed successfully maintain complex 5G wireless mobile broadband telecom infrastructure on par (if not better) than national incumbent cellular MNOs (mobile network operators) - and integrate that infrastructure successfully with incumbent national MNOs – to the point that Public Safety entrust their primary operations to that a utility-run carrier network in the South-Eastern United States regions that Southern Linc covers.
We also cite the trend of Private 5G municipal networks, such as CBRS systems in the USA, as also bellwether examples for Public Safety Canada – of the ability to integrate multi-carrier / multi-network systems and maintain roaming across these separate networks. This multi-carrier or “network of networks” vision is also at the core of our proposals – and our firm support of the Model D approach.
Therefore, given the Southern Linc, and CBRS examples, it is important for Public Safety Canada to note that there is no technology barrier today that would prevent potentially leveraging utility and railway assets – there are plenty of real-world precedent cases that speak to the ability to integrate a Model D style system with a number of Provincial infrastructure builders integrated into a common overall service.
Given that technology and utility and railway competency in maintaining telecom assets is not an issue – the benefit of allowing these critical infrastructure entities to participate in a PSBN build in Canada is significant, with potential savings on the order of Billions in capital costs that would not be necessary given existing fiber optic or tower-site assets in place across Canada.
Lastly, from a strategic vantage, there are of course also linked policy benefits in supporting the telecom needs of rail and utilities, including enhancement of Canada’s disaster reliability posture and Cybersecurity enhancement overall for the PSBN – and also synergies with Green Energy and Smart Grid initiatives of the Federal Government, which also require reliable, resilient and high-performing 5G networks. The “CSRN” approach and model of permitting P3 shared infrastructure investments - we suggest therefore, is a win-win for all participants.
Given these general observations and also the earlier PSBN user population statistics, we propose several clear conclusions for consideration by Public Safety Canada:
?
SECTION 2 - PSBN INFRASTRUCTURE "ACCELERATOR"
LEVERAGING CRITICAL INFRASTRUCTURE AS A “PSBN ACCELERATOR”
There are significant existing public assets, particularly within utility companies, that can be effectively integrated into a future Public Safety Broadband Network (PSBN). These assets offer a robust foundation for supporting emergency response and public safety communications, both in the interim and as part of a long-term solution.
Additionally, leveraging these assets will also a.) save costs versus a 100% greenfield build scenario for an incumbent MNO in rural regions, and b.) accelerates PSBN infrastructure build schedule significantly, given that most of the assets are already in place.
?Key benefits of Leveraging Utility & Railway Telecom Assets & Tower Structures for PSBN:
? Existing Infrastructure: Utilities Railways and Transit operators across Canada have already invested in extensive physical infrastructure, including towers, fiber optic cables, and other communication equipment. These assets are critical because they are often located in areas that are underserved by traditional telecom providers, particularly in rural and remote regions. By leveraging this infrastructure, the PSBN can achieve wider coverage without the need for significant new construction, saving time and resources;
? Supporting Interim Solutions: In the interim, these utility & railway assets can be used to enhance public safety communications. For example, the existing communication networks maintained by utilities can be integrated with public safety systems to provide fixed coverage, ensuring reliable communication during emergencies. While utilities may not offer mobile coverage, their fixed infrastructure can support essential communication links that are crucial during disaster recovery and emergency response operations;
? Pre-existing Ecosystem: The utility & railway sector already possesses the necessary equipment and expertise to support emergency communications. This ecosystem can be tapped into to provide immediate benefits to public safety communications, particularly in areas where current public safety networks are lacking. By integrating these assets, public safety agencies can benefit from an established, reliable communication network that has been designed to withstand extreme conditions;
? Collaborative Partnerships:? While utility & railway companies have the assets and infrastructure that can contribute significantly to the PSBN, it is essential to recognize that they cannot meet all the needs of public safety communications alone. A collaborative approach is needed, where utility & railway infrastructure is part of a broader package of support that includes mobile coverage and other critical communication services. Public safety agencies and utilities can work together to create a comprehensive network that leverages the strengths of both sectors;
Proposal for a “Canadian Shared Rural Network” as a PSBN Accelerator
We respectfully submit the following proposals on concrete elements to include for a flexible, reliable and cost-effective PSBN system. Based on our review of international PPDR organizations, including France’s ACMOSS?, Germany’s BDBOS, Finland’s Erillisverkot?, Korea’s SAFENET?, US FirstNet? and many other international partners and peers to Canada, we suggest that the following 5 main pillars should be included in Public Safety policies for a National PSBN, and which can help accelerate PSBN policy deployment for Public Safety Canada:
We provide a brief description of each of these main pillars in the proposal framework for a National PSBN:
? Canada Shared Rural Network (CSRN) & 700MHz PSBN RANs
In brief, the proposed CSRN is a new P3 (Public-Private-Partnership) fund consisting of institutional capital (Canada Infrastructure Bank, CDPQ, KKR, Brookfield, others), incumbent Mobile Network Operators (MNOs), private capital (TowerCo and InfraCo companies) in a $28 Billion+ seed fund. This model is based on successful international precedent with the UK's Shared Rural Network (UK SRN) model.
This approach helps to more rapidly build “common” or “neutral” shared last-mile RAN infrastructure in rural and First Nations areas that have difficult economics for telecom site deployments for any single carrier – but which can be economically viable when pooled resources are invested via shared “neutral-host” models.
In these “neutral host” CSRN sites, users from all MNO carriers would be able to roam onto the sites – and in turn a tender or negotiation for the award of given site-builds and tower builds, would be setup at the outset of the fund, to determine build distribution across the participating MNOs – aligned with the way the UK SRN was established with the 4 largest MNOs with active telecom assets.
In a similar approach as the successful UK SRN[8] precedent for this P3 (public-private-partnership) model for rural last-mile wireless infrastructure, we suggest that from an overall economic vantage, a pooled P3 capital investment model would bring the average capital cost for remote sites down for carriers, and thereby bring hundreds if not thousands of rural and First Nations cell tower sites in Canada – that were previously negative in terms of business case due to costs being borne by a single carrier – would now turn positive, due to the sharing of costs in the proposed CSRN “neutral host model”.
The net result therefore of cost sharing - would be a net faster closure of Canada’s Digital Divide versus the current status quo grant-based approach. Quite simply, the status quo approach of a “single carrier” shouldering all rural site build costs individually will always result in more challenging per-site ROI business case than our proposed shared infrastructure approach in the CSRN model.
It is important to note that this proposal for a Canadian “CSRN” model is based on the successful UK SRN[9] (Shared Rural Network) system, which has helped to bridge the UK Digital Divide[10] with a partnership consisting of 4 national MNOs[11] and the UK national government, building neutral host 4G & 5G sites in rural areas in a partnership approach.
Furthermore, by leveraging Canada’s extensive existing Electric Utility telecom assets, a PSBN last mile layer of access can be built much faster and at lower cost – due to synergies of existing infrastructure. Every dollar leveraged by existing Utility infrastructure is a dollar saved by the Government of Canada.
It should be noted in passing here, that in our proposed TNCO “Model D” implementation shown above, a Low-Earth Orbit (LEO) service overlay is included via tendered contract run by the PS-MVNO, to provide for a baseline access service across un-inhabited areas of Canada.
The LEO service (not shown in the diagram above) would also act as an overall added “satellite-based redundancy layer” for PSBN across urban-rural areas. We suggest that LEO will always at best be a secondary outdoor redundancy layer in urban, suburban and rural areas (due to building obstructions) and a possible primary communications layer in remote un-inhabited regions. For this reason, we suggest that LEO will not supplant the need to build terrestrial cellular tower sites – such as PSBN sites – as a primary communications access layer – especially given the high bandwidth of 5G and future anticipated 6G applications, and an ever-growing need for data bandwidth. We discuss this topic of service reliability and coverage reliability guarantees in our question-response section.
Therefore, BCN proposes that such a CSRN model would act as an PSBN Accelerator program, helping bridge digital divide in uneconomical remote areas, with new pooled resource sites build in collaboration with P3 investors, utilities, railways and Canada’s incumbent national Mobile Network Operators – helping build PSBN sites in difficult remote areas faster than any single carrier possibly could achieve by themselves. Simply put, the CSRN model accelerates deployment of PSBN nationally over any competing status-quo model
?? National Public Safety Mobile Virtual Network Operator (PS-MVNO)
A multi-carrier “network of networks” approach to primary PSBN services is the most resilient and cost-effective model for Canada. By building on the back of existing carrier networks, a multi-carrier model has more inherent reliability through leveraging all national MNO carriers, and at the same time permitting “mixing and matching” Private 5G RAN assets from utilities and railways – to build a holistic “network of networks” that meets both Public Safety needs for quality access everywhere, alongside Utility and Railway needs for Cybersecure and ultra-reliable, disaster-proof sites maintained in strategic areas by Critical Infrastructure stakeholders in a PSBN.
This flexible national PS-MVNO approach better addresses Critical Infrastructure needs for reliable PSBN communications and with more layers of infrastructure redundancy and resiliency than any single MNO carrier could possibly achieve by themselves.
As part of our proposals, and aligned with the Public Safety Canada TNCO “Model D” approach, we suggest that this national PS-MVNO entity
We propose a timeline for tendering for such a PS-MVNO service as part of our overall schedule proposals provided later in this document with our full responses to the Public Safety Canada consultation.
?? National Public Safety Center of Excellence (PS-CoE)
Based on our survey of international peer PPDR (Public Protection and Disaster Recovery) governance entities around the world, a holistic PSBN plan in Canada would benefit from a national Public Safety R&D facility, which would help in addressing specific technology challenges over the 30+ year lifecycle of a PSBN system. Furthermore, university R&D collaborations with Public Safety and Critical Infrastructure will help to solve the inevitable technology challenges that will arise over time for a PSBN, by providing a focused research facility with staff and university collaborations to develop new applications and devices that could be deployed on a PSBN.
We propose basing this PS-CoE concept on the good precedent seen with the USA’s FirstNet-NIST Public Safety Lab in Boulder, Colorado[12] – which helps fulfill these R&D roles in the USA. Canada would also benefit from such a dedicated facility, and would also benefit from R&D commercialization economic benefits stemming from this research.
??? National Cybersecure PSBN App-Store / Device-Store
An additional key element to a PSBN strategy which is essential for a future PSBN is the up-front setup of a cybersecurity vetting process for all apps and devices intended to be deployed on the PSBN system.
This critical step is essential to creating an ecosystem of “blessed” devices and apps – and locking down the network from 3rd party un-approved devices – in order to prevent cyber and network attack vectors related to poorly secured devices.
This activity could be tendered by the NPGE as a separate tendering stream from the PS-MVNO tender in 2025, or could be included in the terms of the tender for the PS-MVNO service provider as a sub-activity of that PSBN core network operational entity.
.? National PSBN Governance Entity (NPGE)
Last but not least – the NPGE listed in the diagram above is the national governance entity that is the subject of this consultation response.
In summary, we suggest that a holistic policy for PSBN deployment in Canada should consider these 5 main pillars of operations and governance listed above, as covering the set of key activities that would be included in a PSBN service.
SECTION 3 - BCN MODEL COST SAVINGS
COST SAVINGS FROM A "CRITICAL INFRASTRUCTURE ACCELERATOR"
Critical Infrastructure stakeholders in a PSBN - including the members of the Electricity Canada and the Railway Association of Canada – as electric utilities and critical infrastructure maintainers with presence across Canada - are uniquely positioned as both PSBN users and asset investment partners for Public Safety Canada and incumbent telecom carriers deploying PSBN services, given that their members have multiple key roles in a Canadian PSBN system, as both:
1.)?? User-stakeholders of a PSBN voice & data services as “secondary 911 emergency responders” and so an important user with utility staff as one of the voice and data users in a Canadian PSBN service. Electric utility workers are key partners in 911 interoperable communications and disaster recovery operations – and by extension as users we would also partially help fund the operations of the PSBN with our user and M2M device subscriptions, and;
?2.)?? Partners in the essential resiliency & reliability of Canada’s public telecom networks as - for instance - Electricity Canada members are not only providers of basic electric power to telecom RF sites that keep cellular services “on”, but also as users of telecom services that in-turn support electric grid control systems - which illustrates the very circular and symbiotic nature of utilities & telecom services, linked together in provision of basic and essential power + communications services to our modern industrialized Canadian society, and;
3.)?? Partners in infrastructure tower deployment & telecom maintenance - with Billions of dollars in existing critical infrastructure tower and telecom backhaul assets that span Canada’s urban and rural regions and First Nations Digital Divide regions that could be leveraged to help defray build-out costs of a PSBN in the P3 / co-investment approach proposed here, and help in building systems-level reliability in terms of geo-diverse RF site locations with our property assets, and also help with significant time savings for a PSBN build-out schedule, and;
?4.)?? Capital co-investors in net new greenfield PSBN infrastructure deployments, related to building new Private 4G and 5G telecom services within our service areas and on our properties and electric system towers – helping foster commercial service providers by defraying incumbent MNO investment costs (making it cheaper for the big cellular carriers), and defraying Federal tax-funded grants, while meeting our own capital investment needs for growth of electricity services and their underlying telecom systems, and;
?5.)?? Partners with cost-sharing -synergies via our existing Green Energy & Smart Grid projects underway, where our existing initiatives in support of Federal policies on Green Energy and distributed Smart Grid and Smart Metering / Smart Energy Demand Management initiatives, have investment timelines aligned with PSBN timelines and similar reliable 4G / 5G telecom service requirements. Therefore, Electricity Canada members have existing investment projects underway where some PSBN costs could be defrayed via cost-sharing – between PSBN and Canada’s Federal Smart Grid and Green Energy policy initiatives that have a telecom component (e.g., distributed wind-farm control systems, Smart Metering, low-voltage distributed energy projects, Electric Vehicle battery charging and energy storage initiatives, and more).
?Electricity Canada member & Railway Association of Canada tower sites and fiber lines - and their other supporting infrastructure assets and maintenance services for upkeep of these sites, are already in place – and could be immediately leveraged in the interim for a PSBN, through writing flexible RF spectrum policies via Conditions of License for Band 14 spectrum that would grant licenses on a Provincial basis, and which would offer optional Tier 4 / Tier 5 license subordination for critical infrastructure in key cases of national economic and security interest – such as electric utilities and rail infrastructure.
Also, we suggest a “modular” provincially-oriented RF spectrum licensing approach – with a national “clearinghouse” PS-MVNO selected federally by Public Safety Canada via tenders starting in 2025, to interconnect the regional PSBN infrastructure networks (as in TNCO Model D). We propose that the national PS-MVNO act as steward for national telecom reliability standards as part of its’ linked mission related to telecom reliability and resiliency for First Responders.
In summary, by incorporating assets from Railways and Utilities in a shared or pooled asset + capital investment model, Canada could deploy access faster than the status quo / highly centralized / single-winner-take-all model for telecom infrastructure, which has unfortunately suffered from Digital Divide coverage gaps, as chronic problems stemming from that existing centralized grant-based approach.
Instead, we suggest distributing PSBN last-mile infrastructure deployment and spectrum assignment to the Provinces, to either leverage the CSRN P3 fund, or tender for PSBN partnerships with carriers, and use the spectrum at zero cost as a negotiation asset with a selected incumbent MNO for the purpose of site builds.
Although this consultation by Public Safety Canada is not related to RF spectrum assignment (presumably the topic of a follow-on public consultation by the Ministry of Industry, Science and Economic Development), we nevertheless note for the record here that we strongly suggest against auctioning the PSBN Band 14 spectrum – as any fees recuperated from auction cost would simply be recuperated on the backs of First Responder rate payers.
Instead, we suggest that granting the spectrum at zero cost actually reduces the high-cost burden seen from auctions historically (and as noted by MNOs themselves in public statements).
In this way, the BCN model allows a measure of policy flexibility via Tier 2 licenses assigned to Provincial Governments who would setup regional infrastructure partnerships – as the Provinces are best placed with the knowledge of problem areas and local telecom failings and best placed with knowledge of local emergency response telecommunications investment priorities for local First Responder organizations and disaster response groups.
Using this provincially oriented licensing model - we gain the best of both worlds in terms of the cost and time-schedule benefits of a distributed build of infrastructure, with centralized standards and requirements for interoperability and operational timelines, via the national PS-MVNO service provider.
The proposed CSRN P3model can therefore be seen as a sort of flexible “PSBN Investment Accelerator”, leveraging utility, railway, incumbent MNO and other optional institutional investors as partners to incumbent carriers, in order to move forward PSBN deployment more quickly, and at lower cost to government.
Simply put, a “P3” approach that permits utility & critical infrastructure (e.g., rail & transit) co-investment wins on cost & time savings over the status quo. By leveraging the electric industry’s ready and available tower sites and fiber-optic backhaul would not only save the Federal Government Billions of dollars in lifetime infrastructure capital and operations costs, but also save years on schedule for infrastructure build-out – and furthermore gain synergies on operational maintenance costs given the electric grid’s interest in reliable telecom for Smart Grid and Green Energy initiatives.
Electricity Canada and Railway Association of Canada member assets, coupled with the proposed flexible P3 PSBN investment approach, would offer Public Safety Canada the following key strategic synergies and significant policy advantages over a status quo telecom model approach to infrastructure investment:
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1.?? Cost Savings Advantage via Shared Costs with existing Utility & Railway Assets
2.?? Schedule Compression / Time Savings Advantage via existing Infrastructure Assets
3.?? Network & Cybersecurity Reliability Advantage
4.?? Disaster Resiliency Advantage
5.?? First Nations & Rural / Regional Inclusion Advantage
6.?? More Net Capital Investment Sources & More Competitive Market Forces
7.?? Further Strategic Synergies with existing Smart Grid & Green Energy & Railway initiatives underway
We now briefly discuss each of these seven BCN model advantages and investment synergies for Canada’s PSBN:
? Critical Infrastructure Asset Synergy #1) - Cost Savings Advantage - There are significant strategic cost synergies in including electric utility infrastructure in a P3 model for PSBN build-out, which per recent independent studies have suggested potential savings of Billions of dollars in outright economic and financial savings, plus defrayed Federal tax-funded investment and grants, versus a status quo investment approach for a Canadian PSBN[13]. A PSBN asset investment model with a utility investment option or opt-in on a provincial or regional capital investment basis, would also build-out infrastructure faster than a status quo highly centralized and incumbent-cellular-carrier-only model.
Electricity Canada member synergies would consist of both utility tower assets and fiber optic backhaul assets that would defray the need for significant cost in any incumbent carrier PSBN deployment.
Furthermore, permitting electric utility involvement in PSBN deployment would more quickly connect rural regions, as Canada’s electric utility infrastructure tends to follow along with population centers – and so our members’ electric grid transmission lines, and pylon towers are already present in many rural and remote community cases, with electric lines traversing across rural and First Nations territories, and remote Canadian towns and settlements where Canada’s incumbent carriers have declined to invest – and yet where we have telecom systems presence in place today.
Electricity Canada has provided past public submissions to the Federal Government, highlighting these significant geographic telecom infrastructure synergies, with utility presence in many areas where Canada’s incumbent carriers decline to invest due to challenging costs related to spectrum auction, and costs related to low population density. By merging utility project needs for our Electricity Canada member transmission and distribution lines, coupled with telecom site investment plans for a PSBN and gap-filling of wireless 911 gaps, utility assets and co-investment could help make the ROI (return-on-investment) viable for many rural site locations that are otherwise unaffordable today – and at a cost savings to the Federal Government.
The following map is an extract for Electricity Canada’s 2019 submission and highlights the complementary geographic locations of utility assets, and the cellular coverage gap-filling potential of utility fiber assets in Ontario - as one illustrative provincial example:
Therefore, the flexible Electricity Canada P3 investment model offers Public Safety Canada a way to leverage this existing utility investment in telecom infrastructure, and potentially save the Federal Government Billions of dollars in greenfield construction in the status quo “incumbent-carrier-only” model, through shared PSBN infrastructure alongside utility control systems infrastructure.
In summary, by permitting electric utility firm investment and collaboration on PSBN spectrum, Public Safety Canada can generate a significant policy “win-win” case, which simultaneously helps incumbent carriers serve rural customers, through partnership or use of existing electric utility property tower assets and networks, which provide the ability to lower the per-site break-even cost for potentially thousands of currently unviable rural 4G or 5G RF site locations in low-population density regions. These utility cost synergies can amount to Billions in savings for the Federal government and incumbent carriers.
Electricity Canada would be pleased to provide further maps to Public Safety Canada affirming this advantage in partnering with and enabling electric utilities to advance PSBN rural infrastructure deployment, while gaining cost synergies with utility transmission line project investments underway.
? Critical Infrastructure Asset Synergy #2 - Schedule Compression & Time Savings – By permitting use of Electricity Canada’s member tower sites in TNCO Model D deployments with regional PSBN systems, and leveraging our member fiber backhaul systems and properties, Public Safety Canada would gain a significant deployment time / schedule savings to “leap-frog” forward in terms of PSBN deployment schedule.
Electric utility telecom tower sites and backhaul are ready assets that are already built – and which are in many of Canada’s digital divide areas as well – and which could be used in the interim now, with immediate utility-funded or co-funded PSBN spectrum and site deployments – as part of a proposed “Electricity Canada Accelerator” strategy for a Canadian PSBN.
PSBN investment timelines aligns with our Electricity Canada members’ existing project plans for build-out of Smart Grid and Green Energy initiatives, offering further investment synergies and strategic benefits for a PSBN build-out that includes consideration of utility needs, and potential for asset partnerships. Utility sites and infrastructure could be used in partnership with a Provincially designated MNO partner for Provincial PSBN services, or via County-level Private 5G regional utility deployments that integrate into the Provincial PS-MNO service provider. The flexible Electricity Canada P3 model permits a tailored approach for each Province – while meeting the needs for central coordination.
In all, if Public Safety Canada were to include Canada’s electrical utilities as co-investors and partners in a PSBN, the Federal Government would save years in deployment time – consisting of a.) the savings in terms of the time to build potentially thousands of greenfield RF sites across Canada to fill rural gaps, and b.) the savings to build thousands of kilometers of new greenfield fiber optic backhaul lines – all of which could be saved via a flexible PSBN infrastructure build model that permits electric utility partnerships in infrastructure deployments, with optional Private 4G/5G regional sites for critical utility needs.
Permitting utility co-investment for PSBN sites, and leveraging electricity grid sites – will result in significant savings and schedule time savings for Public Safety Canada.
? Critical Infrastructure Asset Synergy #3 - Network & Cybersecurity Reliability Advantage – By incorporating Canada’s electric utility site assets in the mix of PSBN infrastructure sites, and also by including utilities as potential co-investors for the building and architecting of Provincial and Regional PSBN systems, Canada will also gain a more reliable and resilient disaster posture, given that utility maintained sites are typically held to a higher standard of reliability due to stringent electricity Cybersecurity requirements, with more stringent disaster survivability requirements.
For example, utilities typically have hold-over times for critical network clock synchronization, and for critical battery and generator power sources, on the order of 7 days or more – while commercial cellular carriers have barely 4 hours at best.
This significant difference in the reliability of electric utility-maintained sites versus incumbent MNOs, means that by including Electricity Canada member assets as regionalized Private 5G PSBN sub-networks in a PSBN, or as Provincial PSBN partners – Public Safety Canada gains a “hardened PSBN backbone” of infrastructure that is significantly better – from day one - than any commercial carrier-grade reliability. For example, in the 2023 nation-wide Rogers outage, by using a PS-MVNO model with regional PSBN RAN systems – including regional utility PSBNs – Canada’s First Responders would have experienced lesser outage with an ability to maintain at least core utility networks on and available for First Responders (and for critical utility needs) during Rogers’ national outage.
This site reliability feature of a heterogeneous PSBN architecture – being able to better tolerate a national outage by commercial carriers by having utility networks using Band 14 held apparat from commercial sites - is another significant survivability advantage of the Electricity Canada approach over a status quo / monolithic alternative model with a single national carrier running all PSBN infrastructure.
Utility sites are also more geo-diverse with respect backhaul, as compared to commercial carrier sites, and also typically located at alternate physical sites and towers separate from commercial MNOs, thereby also adding a degree of better geo-redundancy in the event of flooding, forest fires, hurricanes or earthquake disasters that may take out infrastructure in a given region. This proposed utility role as another infrastructure investor therefore helps avoid the “all your eggs in one basket” issue seen in the status quo approach to telecom services, and underlined in the 2023 Roger outage, and previous national outages by Canada’s “Big 3” carriers.
Including utility sites and the option for regional utility “Private 5G” PSBN systems integrated within an overall National Model D PSBN “network of networks”, Public Safety Canada gains a key policy advantage and selling point – namely a policy approach that has a “Canadian Critical Infrastructure Wireless Backbone” as a policy feature and bonus advantage – with better disaster resiliency with a core set of utility-maintained PSBN sites – within an overall carrier-maintained network potentially – which can be considered as a last-layer of resiliency and Cyber-defense in the event of a disaster or Cyber-attack – offering a “skeleton” of always-on coverage in the event of major disasters (e.g., see lessons learned from Hurricane Dorian and Hurricane Fiona, or recent Huawei infrastructure concerns for commercial MNO security posture[14]).
? Critical Infrastructure Asset Synergy #4 – Disaster Resiliency Advantage – Another important consideration where Canada’s utilities can assist PSBN policy, is in the hardening of telecom infrastructure against natural disasters – underlined the recent experiences of lengthy power reconnection due to concurrent telecom failures during the 2024 Hurricane Helene disaster in the USA, and during previous Canadian experiences during Hurricane Dorian [14], Hurricane Fiona, and many other such examples.
Electric utilities have a longstanding record of service excellence for critical wireline and wireless telecom systems that underpin the control of the reliable Canadian electrical system, and utility systems are among the first that need reconnection after a disaster, where electricity continues to grow in societal importance as a necessary lifesaving and life-sustaining service, and as the digital and Green Economies continue to grow in importance as core to our modern society and lifestyle.
Indeed, Electricity Canada members’ field crews regularly travel to the USA to assist in mutual aid of electric power restoration during US disasters, and US electric crews likewise head up to Canada to regularly assist Canadian power and electric distribution companies to restore service during disaster outages. This mutual aid interoperability of “electricity bucket truck” field crews is another key role for PSBN in Canada – in facilitating Canada-USA utility fleets to communicate effectively via PSBN spectrum. This existing role in North American disaster response, is yet another reason for Canada’s electricity community to be at the table with Public Safety in helping decide PSBN system governance decisions.
Therefore, given all these disaster and interoperability roles for a common North American position on disaster preparedness, it is therefore essential for Public Safety Canada to ensure that Electric utilities have a critical role in PSBN governance, and a critical voice in how PSBN investment and maintenance of telecom infrastructure happen in Canada, in support of control systems that underpin our build-out of Canada’s Smart Grid, and also in the maintenance of essential electrical power service for all Canadians residents and businesses.
Utilities also have an added potential role, in also acting as possible partners for PSBN deployable site restoration services – where electric utilities’ existing large service fleets of utility “bucket trucks” and service vehicles, consisting of hundreds of such rugged vehicles across Canada, could easily be outfitted with PSBN spectrum “deployable radio masts” or tethered drones, and in combination with LEO backhaul – Electricity Canada’s members have a ready-made and distributed fleet of hundreds of “site on wheels” already spread across the country, and with existing service maintenance and asset support plans in place for this fleet of vehicles.
Utility “Bucket Truck” fleets are another ready-to-go utility asset - fleets of hundreds of utility vehicles that can act as an additional layer of PSBN deployable sites for Canada – already distributed across Canada. Electricity Canada members can help make this creative collaborative partnership related to PSBN deployable sites a reality for Public Safety Canada, as potential partners for deployable PSBN telecom site restoration services.
In this way, Canada’s utilities could help Public Safety Canada rapidly stand-up an “army” of deployable site on wheels to help fill-in coverage across Canada’s vast geography, during disaster outages, and that could rapidly converge on coverage outage spots to assist in telecom service restoration during outages.
? Critical Infrastructure Asset Synergy #5) - First Nations & Rural Inclusion Advantage - The flexible P3 Capital Investment Model and distributed “TNCO Model D” architecture at the core of the proposed model, also offers an inclusive approach for building out regional telecom carrier and First Nations co-investment for PSBN radio sites in rural regions, something that a monolithic incumbent-carrier-only spectrum grant, and an incumbent-carrier-only policy approach to PSBN investment approach would not permit.
Therefore, the BCN P3 investment model offers Federal a more flexible capital investment approach to addressing regional needs, with more net capital investment sources than the status quo carrier-only model, where our approach also offers First Nations the option for co-ownership rights in PSBN sites deployed in those regions, and also addresses energy grid security needs alongside Public Safety – as a holistic “Community Safety” oriented investment approach that addresses all stakeholders for a generational Canadian investment “win”. The Electricity Canada P3 investment partnership with both utilities and carriers together as joint stakeholders and investors in communications resiliency, can help finally bridge Canada’s chronic Rural & First Nations Digital Divide[15], [16].
In terms of technical feasibility, the telecom technology to build out regional private networks and integrate these PSBN private networks alongside a national or co-regional PSBN telecom service provider, is a well proven 3GPP technology model with decades of standards backing (i.e., namely MOCN technology, CBRS distributed network model, and looking forward we similarly see multi-network integration in upcoming 5G dynamic network slicing trends).
Therefore, Electricity Canada’s suggestions aligns with significant international real-world precedent including the success of distributed / regional CBRS private systems that integrate with commercial carriers, and with recent announcements by Ericsson related to the CAMARA network API initiative, and Samsung’s network slicing consortium[17] as but a few technology bellwether examples, all of which are aligned with and support our proposal to allow strategic regionalized PSBN networks for utilities, which double as linked partner networks for Public Safety and commercial cellular MNOs at the same time.
By building-in a degree of flexibility in the Public Safety PSBN investment model, and a degree of regional deployment rights for Canada’s electric utility stakeholders, we can simultaneously help guarantee that Canada’s First Nations have a say and an option to also build out regional telecom carrier networks to serve their localized jurisdictions.
Given Canada’s electric utilities are often already present in remote and First Nations jurisdictions with power system assets nearby or already on their premises, utilities are a natural co-investment partner, with common rural deployment interests, and assets that could help enable First Nations with wireless telecom services in areas of Canada that are underserved or neglected by commercial MNO carriers today.
The integration of existing public assets, particularly those held by utility companies, offers a practical and cost-effective way to enhance the development and speed the deployment of a future PSBN in rural and First Nations territories. These utility assets provide immediate benefits for Public Safety communications coverage, and can be leveraged to build a resilient, reliable network that meets the needs of emergency responders across Canada – while also incorporating First Nations as optional co-investors in a flexible investment business model.
By working in partnership instead of in isolation, Public Safety agencies and commercial MNO carriers should partner with utilities and First Nations, to bring more net capital investment to rural Digital Divide regions, and ensure that Canada’s future PSBN is inclusive in investments that assure wireless 911 services are also equitably available for First Nations and remote rural communities.
? Critical Infrastructure Asset Synergy #6 – More Net Capital Investment Sources & More Competitive Market Forces – The “TNCO Model D” architectural approach, and the Electricity Canada flexible P3 investment model, also help bring more net capital investment in play to help defray government tax-funded grants and telecom carrier costs, as a “win” versus the status quo approach.
Quite simply, by permitting utility co-investment alongside carriers – and other institutional investors – you ultimately bring net more capital dollars into play to potentially invest in solving Canada’s Digital Divide, than any single incumbent MNO carrier could ever achieve alone. The CSRN approach enables more total capital investment dollars, - which translates to more net telecom infrastructure investment in underserved rural regions.
From a financial lens, an important note is that Canada’s utility investors – and other potential 3rd party institutional investors in P3 PSBN fund, such as “TowerCos” could also have potentially better capital interest rate advantages for the cost of debt to finance the deployment of passive tower elements of a PSBN[6], and hence any Public Safety Canada PSBN model that permits electric utility co-investments alongside P3 institutional investors and incumbent carriers, will inevitably be in a better cost position based on better interest rates terms linked to capital investments – offering yet another significant and tangible cost savings in the Electricity Canada model versus the status quo.
Furthermore, as discussed earlier and in our Appendices, the “Disaggregated Telecom Model” for infrastructure investment, which splits “over-the-top” carrier services on a separated tower and backhaul infrastructure layer – creates more competitive forces and hence lower net cost for deployment than a vertically-integrated legacy approach to telecom capital investment as seen in the 1980s, and in Canada’s continued reliance on commercial MNOs for all aspects of telecom services – from towers to content to connectivity.[18], [19]
The lower cost of international telecom services speaks to the advantage of permitting more competitive forces into the telecom procurement model, and by extension a lowering of costs to the telecom subscriber as a result.[20] As proof of this competitive advantage on net telecom costs, we cite the cost differential and example of US telecom infrastructure, where in the USA over 90% of telecom infrastructure – including on the US FirstNet PSBN system – is not owned by incumbent commercial carriers. Instead, the vast bulk of telecom wireless tower infrastructure is owned by 3rd party “TowerCo” investors, and institutional players that specialize in economies of scale and operational efficiencies of tower assets, bringing economic specialization and efficiency to that telecom market – with reduced telecom costs as a proven benefit.[18]
In Canada, with our chronic high cost and relatively lower competitive forces per international studies on the topic, we instead see the inverse of the US tower infrastructure investment experience, with over 80% of all Canadian tower infrastructure held by the “Big 3” carriers in a vertically integrated model, and with high telecom subscriber fees as a side effect of this legacy Canadian approach.
Therefore, the PSBN investment model decision by Public Safety Canada, can potentially have a big impact on fostering competitive forces, and lower costs for telecom service in general for all Canadians. Canada’s electric utilities can have an important role in fostering those new competitive forces, as co-investors in tower site infrastructure, or as outright regional deployers of PSBN sites in Digital Divide areas.
Lastly, on this topic of the advantage of permitting new and “non-traditional” capital investment approaches into the mix of funding for PSBN radio sites, we also note the successful example of the UK’s Shared Rural Network.[22] As noted earlier in this submission, the UK SRN (Shared Rural Network) is a collaborative P3 investment model that combines the assets and capital investment of 4 national carriers, alongside UK national government capital, to create a set of “neutral 4G / 5G sites in rural Digital Divide jurisdictions in the UK.[11] The UK SRN has recently reported significant success with its’ collaborative deployment model.
Hundreds of new sites that would otherwise not have been economically possible by single carriers alone, have been made possible by the UK SRN initiative.[23]
In Electricity Canada’s policy suggestions for Canada’s PSBN rollout, we similarly propose the creation of a “Canadian Shared Rural Network” (or “CSRN”) as a new P3 fund under the umbrella of the Canada Infrastructure Bank (CIB), and as a and collaborative investment model along the lines of the UK model, but with utility co-investment and optional “TowerCo” and institutional capital investor participation (e.g., Canadian Infrastructure Bank, and other institutional Canadian investment funds) as an added Canadian twist.
P3 models for PSBN investment that permit Critical Infrastructure and other Private Institutional Capital and are ideal for a PSBN in that they can help to defray government investment (i.e., taxes), and bolster carrier investments by solving the investment problem in those rural areas where carriers have so far neglected to invest with these new entrant and P3 SRN style funds - freeing up carrier investment for other geographic areas where there is simply more profit interest to the carriers. Therefore, we suggest that there is ready interest from both utilities, and also institutional capital to help make a “Canadian Shared Rural Network” P3 investment model work – with all the benefits of cost savings for the Federal Government, and with added competitive forces as yet another side benefit to this P3 approach.
In summary, Electricity Canada suggests that by offering a similar P3 CSRN investment model for Canada, we would – just as the UK SRN has successfully proven – be able to garner hundreds of new PSBN site investments with carriers and utilities and institutional capital investors collaborating together on shared costs, which would help make hundreds if not thousands of new rural and First Nations telecom infrastructure sites.
By including Canada’s Electric Utilities as possible co-investors in a P3 rural fund model, Public Safety Canada would only help to further hasten the filling of Canada’s rural and First Nations digital divide, through collaborative PSBN spectrum and site infrastructure deployments.
? Critical Infrastructure Asset Synergy #7 – Utility partners have operational cost-sharing -synergies via our existing Green Energy & Smart Grid projects underway - Simply put, Canada’s Smart Energy and Green Energy initiatives depend on reliable, secure and resilient wireless & wireline communications systems.
By supporting utility asset involvement within a federated PSBN system, Public Safety Canada would also simultaneously be helping further the deployment of Canada’s national Smart Grid and Green Energy initiatives, by permitting PSBN spectrum to also serve utilities in their need for critical wireless synchronization control signaling for distributed windfarms, for closed loop control of Electric Vehicle and distributed regional Smart Grid battery systems, and for other future wireless control systems pertaining to Smart Grid and demand management.
Each of these current Green Energy initiatives would warrant an ability for utilities to work with Provincial governments and Public Safety to obtain localized private spectrum PSBN access, and with an ability to co-invest in strategic PSBN site infrastructure that would serve utility requirements for high security in support of these Green Energy initiatives, while seamlessly meshing utility deployments alongside any commercial deployments of PSBN spectrum – resulting in a seamless coverage experience for First Responders and commercial carriers that may be reselling excess PSBN spectrum bandwidth.
SECTION 4 - PSBN USER CENSUS RESULTS
PSBN 2024-2025 OPEN SOURCE USER BASE CENSUS - GRAPHS
In this section, we provide an exclusive sampling of a set of pre-print graphs and summary statistics from our upcoming Black Castle Networks (BCN) public report – slated to be released in February 2025, related to our comprehensive PSBN open-source user stakeholder census.
The BCN census report consists of an Open-Source survey of potential user device and SIM card quantities for major 911 Emergency Response agencies across Canada, and for linked Secondary Emergency Responder agencies and organizations.
Data for this electronic data set was collected using "Open Source" research, via government and corporate publications on staffing levels, and various public sourced documents that were independently researched in order to arrive at estimates for user quantities at eligible Fire, Police, EMS, Rail, Utility, Transit, Health Services & Hospitals, Municipal, Provincial and Federal government entities. This data set is considered accurate to within +/- 5% of true Total Addressable Market of users for a PSBN PS-MVNO or PS-MNO entity as of Q4-2024.
The following chart shown below summarizes the BCN 2024 Canadian PSBN User census findings per province – based on 2024 Open-Source data and government statistic surveyed. Values shown in this table include both hand-held SIMs for staff, and vehicular + fixed modem devices, and for Body Worn Cameras (BWC) devices. No IoT devices are included in the chart shown below.
On the following pages of this we provide a set of data set “drill downs” from the BCN 2025 PSBN Census, and with the following areas of focus:
REFERENCES
[2] Black Castle Networks Publication – “Canada’s PSBN User Base Survey 2024” – slated for release February 2025
[3] https://www.electricity.ca/files/reports/english/Final-CEA-response-to-CRTC-2019-57-May-15-2019.pdf
[13] Black Castle Networks – “A Canadian National PSBN Business Case & Costing Study” – for release February 2025
[14] Globe and Mail - https://www.theglobeandmail.com/canada/article-goodale-sajjan-to-visit-halifax-today-to-survey-dorian-recovery/
[18] ?Deloitte - https://www2.deloitte.com/de/de/pages/technology-media-and-telecommunications/articles/future-of-telco-business-model.html
[19] McKinsey - https://www.mckinsey.com/industries/technology-media-and-telecommunications/our-insights/can-telcos-create-more-value-by-breaking-up
Telecommunications Consultant
1 个月ìt is great that BCN acknowledge the important role organisations such as electricity, rail and general health services play in response and recovery of emergency situations. Ensuring access to communications in a disaster to these and others who assist should not be overlooked. My experience in NZ and Australia has shown the importance of maintaining communications for the whole community becomes critical in the first few hours of a disaster. I would recommend that any cellular coverage expansion (both permanent and temporary) is built with the whole community in mind and not just emergency services.
Great to see these insights and options being raised for hopefully inclusive debate and progress.