07 March 2024

Duncan Swan, chief operating officer, British APCO

British APCO is a founding member of the Collaborative Coalition for International Public Safety (CC:IPS). The partnership is currently looking at where critical communication networks are designated as critical national infrastructure.

The world is marching ever quicker towards an all-digital infrastructure – and this brings with it challenges that break the norm. The solutions and underlying business processes delivering business continuity and disaster recovery no longer hold water, and different approaches must be considered. Simple challenges include the migration from copper landlines to voice over IP for all UK telephone connections, which was paused once it became apparent that during bad weather conditions, when power was lost, many customers had no way of making an emergency 999/112 call; and users of health alarms are unable to call for help. The onus on protecting the vulnerable has switched to ensure all utility providers take this responsibility. Next generation communications help drive improved processes and opens new communication channels – but when we take these steps, we need to ensure that we are not alienating those in society who are unable to embrace this level of change.

Here in the UK, the move some 20+ years ago from each emergency service organisation having its own self-provisioned analogue radio communications infrastructure to sharing a national digital infrastructure providing critical communications as a service was a huge step. A key element of the service was the business continuity elements, not all of which had been fully considered at initial deployment; fully duplicated switches that supported hot-standby mode; several hundred key sites that had generator back-up capable of lasting several days; and the ability to alternate route infrastructure interconnectivity in case of outage and/or failure. There’s also off-network communications and the ability for nominated radio sites to act as a localised repeater in a major infrastructure outage, i.e. multiple layers of redundancy and fallback, and no need to consider this as part of – or relying upon – critical national infrastructure per se.

Fast forward and we are seeing a shift for the critical communication systems relied upon by our emergency services using commercial mobile network infrastructure to deliver next generation capability based upon 4G/5G – in particular radio sites, spectrum, and backhaul transmission networks which then feeds into a private, hardened, packet core network. This adds another obligation onto the network operators to ensure service availability – and move them ever closer to be classed as critical national infrastructure. So how do you justify the expense of protecting a significant subset of tens of thousands of radio sites and their corresponding transmission links?

In Australia they define critical national infrastructure as including ‘those physical facilities, supply chains, information technologies and communication networks, which if destroyed, degraded or rendered unavailable for an extended period, would significantly impact the social or economic wellbeing of the nation, or affect Australia’s ability to conduct national defence and ensure national security.’ In Canada they identify that ‘disruptions of critical infrastructure could result in catastrophic loss of life, adverse economic effects and significant harm to public confidence.’

Then across the members of the EU, Directive 2022/2557 sets out how countries need to ensure the resilience of critical services, with ‘critical infrastructure’ defined as ‘an asset, a facility, equipment, a network or a system, or a part of an asset, a facility, equipment, a network or a system, which is necessary for the provision of an essential service.’ In the same legislation, an essential service is ‘a service which is crucial for the maintenance of vital societal functions, economic activities, public health and safety, or the environment.’ The importance some countries place on public safety communications can be seen in Germany and the Netherlands where ‘communication with and between emergency services through the 112-emergency number and their emergency service mobile network falls under critical infrastructure.

Just a few days after the Optus network in Australia suffered an unplanned outage the Australian Minister for Home Affairs announced that ‘telecommunications’ will be recognised as ‘critical infrastructure’ – the Minister going on to say, “these rules, frankly, should have been in place years ago.” This starts to recognise the level to which society has become ever more dependent upon communication networks. Here in the UK, it is well documented that during an outage to the 999-emergency communication system a total of more than 11,000 unique calls were unable to be connected through to the emergency operator for onward connection to the emergency services.

The whole fabric of society has digital communications interwoven with heightened expectations and huge societal dependency. As in Australia, we can expect to see telecommunications being categorised more widely as critical national infrastructure. And whilst critical communications will rarely be classed as critical national infrastructure, the networks and infrastructure upon which they are built will be, because of the adverse economic impact; the harm to public confidence in the establishment; and the potential for significant loss of life with any prolonged unavailability.

Australia has taken the lead; let’s hope the UK is not slow to follow.