Telecoms emphasize concerns, support for CRTC’s botnet blocking proposal

Canada’s big-three telecoms are doubling down on their assertions that the CRTC does not need to implement a proposal that would require them to block malicious botnet traffic on their networks. In a reply to a public consultation on the proposal, filed this week following interventions on the issue, Rogers Communications Inc. stated it found most respondents agree that continuing with the existing voluntary approach for tackling cyber threats such as botnets is the best way forward. “The overwhelming consensus was that the proposal to mandate implementation of a single blocking framework by Telecommunication Service Providers (TSPs) to address the growing concern of botnets is not the most effective approach to protect Canadians,” Rogers stated. The CRTC had proposed blocking botnets, which it classifies as a network of malware-infected computers that are under the control of a command and control server operated by a malicious actor, at the network level. It stated botnets account for an “increasingly large proportion of malware and facilitate the most egregious forms of cyber threats.” BCE Inc. stated in its reply that a mandatory botnet blocking regime, perhaps with an independent body that would pre-determine whether particular domains or IP addresses should be approved for blocking, “would not provide the same flexibility and benefits as the current collaborative framework.” It stated after reviewing the first round of interventions it also found an “overwhelming consensus” that the most effective strategy to combat malicious botnets is to keep up collaboration between service providers and cyber security experts. “If the commission disagrees with the consensus and nonetheless mandates a network-level blocking regime, several interveners, including Rogers and (Shaw Communications Inc.), agreed with our position that it must be applied symmetrically to all TSPs to ensure that bad actors cannot circumvent mitigation solutions by targeting TSPs that are not subject to the mandate,” Bell stated in its reply. “Blocking is an extremely sensitive matter and potentially a prohibitively costly measure to implement. It should not be approached in isolation and should include the cyber experts to make any decisions about the best approach,” Rogers stated. Telus Corp. went further in its reply, saying the CRTC’s proposed framework “has many technical and process challenges that would make it inefficient, expensive and ultimately ineffective.” The company stated the best course of action is to allow service providers to keep coordinating their responses and adopting best practices for network security. Rogers asserted that the CRTC should perhaps let other agencies handle the issue, repeating its argument from its intervention. “The commission has a collaborative role to play in addressing the issue, however, any decisions about how to tackle botnets should be made by those government departments and agencies that have responsibility for cyber matters,” the company stated. “For example, there is an opportunity for the commission to proactively consult with the Canadian Security Telecommunications Advisory Committee (CSTAC) about the best approach to cyber issues impacting telecommunication networks. Consulting with CSTAC will ensure that this important public policy issue is addressed without fragmenting the oversight of cyber matters.” Previously, some telecoms echoed an earlier intervention from open internet advocacy group the Internet Society, expressing concerns that a network-level framework would overzealously restrict Canadians’ access to legitimate websites, possibly undermining the principle of net neutrality. In its reply, TekSavvy Solutions Inc. stated its “primary concern is that network-level blocking will ultimately lead to over-blocking, will be ineffective and, importantly, goes against the foundational principles of common carriage and network neutrality—core tenets of the free and open Internet.” In its call for comments, the CRTC repeated its support for the principle of net neutrality but also acknowledged that “a limited exception to net neutrality may be warranted in order to offer Canadians additional protections from these threats” as it proposed that internet service providers be required to block malicious botnet traffic. The Communications Security Establishment (CSE), which calls itself the national lead agency for foreign signals intelligence and cyber operations as well as the technical authority for cybersecurity, claimed in an intervention accepted after the CRTC’s original deadline that outright blocking results in fewer incidents and compromises from known threats. Though many of the telecoms who responded with interventions or replies are against the CRTC’s proposed framework, some are not. Saskatchewan Telecommunications Holding Corp. generally supported the idea in its intervention and reiterated this in its reply, saying “there is an opportunity, through CRTC involvement, for regulatory mechanisms to aid Telecommunications Service Providers (TSPs) in this joint quest of protecting consumers and protecting our networks.” “Implementing supporting regulations that provide a direct and clear – yet flexible – mandate, approve of methods used, and limit liability for TSPs acting reasonably in pursuit of the objectives would provide welcome regulatory support for TSPs who undertake the blocking of botnet and malicious traffic,” the company stated. Shaw has suggested that the commission lead the creation of a new and independent body that is a federally incorporated not-for-profit that would build and distribute a list of known botnets, making it available to all internet service providers. Rather than engaging in blocking activity itself, Shaw suggests in its reply that service providers would use the block list to protect their end users’ devices from unknowingly communicating with remote command and control servers. “The (body’s) list would include malicious domains to enable a domain name system (DNS) based blocking approach.” In the future, the list “could evolve to include ranges of malicious IP addresses; such a change might be necessary to keep pace with the growing use of encrypted DNS,” Shaw stated. Not all companies were in favour of that either. Telus deemed using a single owner of the block list to be “ill-advised” because it would reduce flexibility, cause delays and negate the benefits of industry collaboration. “It creates a bottleneck that results in delays in making changes to the list and it is not clear how a single entity will determine the threat vectors that appear on the blocklist, particularly in the case of conflicting information from various sources,” Telus stated. Like Rogers, Shaw also “proposed a limited and prescribed role for the commission” in its intervention. Shaw stated in its reply “beyond taking the legal steps necessary for the (independent body’s) inception at the conclusion of this proceeding and securing funding,” the commission would step aside to allow experts to determine the specific role of the organization. Then, its “continued operation and evolution would rely on guidance from ISPs, law enforcement, information technology companies, academics, and other experts.” “Regardless of its approach, if the commission decides to pursue a botnet blocking framework, it should apply to all ISPs. While our proposed approach will help ensure that the system is as cost effective as possible, any resulting framework should be universally applicable,” Shaw stated. — Reporting by Hannah Daley at hdaley@thewirereport.ca and editing by Jenna Cocullo at jcocullo@thewirereport.ca

Telecoms emphasize concerns, support for CRTC’s botnet blocking proposal

News | May 6, 2021

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