AurorA guests on RAG-TV

Timo appearing on RAGTV S2E1
Timo on RAGTV S2E1 with hosts Eric Priezkalns and Lee Scargall

On Wednesday, June 17, 2020 I had the honour of appearing on the opening episode of Season 2 of RAG-TV, the online streaming show of the Risk and Assurance Group. Their virtual conference in May was seen by over 2,000 telecom industry pros in over 93 countries ! Read more about that here and here.

RAG ia an association for telco professionals involved in all aspects of Revenue Assurance; fraud management, enterprise risk management, law enforcement liaison, credit risk, market assurance, capex analysis and security. Actually, association sounds too stuffy, a club is a better description. A club of like minded telecom fraud and risk managers wanting to get better and improve.

Commsrisk described the episode like this
“Telcos come in all shapes and sizes, from the hundreds of millions of customers served by an Indian mobile network like Jio, and the extensive multi-country operations and carrier function of a group like Vodafone, to telcos that serve tiny island nations and small, focused international carriers like AurorA International Telecom, based in Waterloo, Canada. They all need to work together in order to connect phone users whilst fighting the rouge elements that plague our industry.”

“AurorA’s Timo Vainionpää and LATRO Services’ Donald Reinhart were the guests for the first episode of the new season of RAG Television, giving me the opportunity to ask them about the factors that encourage bypass fraud and what can be done to identify and compete with gray routing. Watch the replay of the show below.”

Watch here !

Elon is not coming to rescue Canada’s remote broadband

Elon Musk and StarLink
Elon Musk, CEO of SpaceX and the StarLink constellation

The telecom press in Canada has been gushing over the news that Elon Musk and his company SpaceX has visions of coming to Canada to provide super-fast Internet service to rural and remote Canadians via their StarLink LEO (low Earth orbit) satellite constellation.

Please take a step back. Pause. Take a deep breath. Just stop it.

This is not imminent, it may never happen. In fact it probably will never happen.

First off, SpaceX only applied for a BITS licence. BITS is Basic International Telecom Service. AurorA has a BITS licence (in fact I believe AurorA had the first BITS licence provided to a non-facilities based carrier). This does not provide StarLink the spectrum required to operate in Canada. OneWeb had licensed Canadian spectrum (through 1021823 B.C. Ltd.) and so does Telesat for their proposed LEO constellation. SpaceX hasn’t yet applied for a Canadian spectrum licence (as far as I know).

The model of “connecting the unconnected”, providing broadband Internet service to the 3.5 billion people in the world that don’t have it has been around for decades. I remember the old Teledesic and Skybridge proposals, ICO, Iridium and GlobalStar who all went bankrupt. Iridium emerged from Chapter 11 eventually after a huge amount of drama (see my review of a great book on Iridium). More recently OneWeb who had already launched 74 satellites went bankrupt in March (read here) and before that LEOSat last November. As an aside, even Intelsat went into Chapter 11 bankruptcy protection in May.

Elon’s SpaceX has 362 satellites in orbit, but to actually provide service their plans call for 4,000 satellites just in the first phase deployment. To do this takes money; SpaceX need billions, and soon, to satisfy its high cash burn rate. It’s not making near enough revenue launching satellites (and astronauts) from others to cover the costs of it unpaid Starlink launches. This is also why they are desperately trying to be included in the FCC’s Rural Digital Opportunity Fund auction to get a piece of up to $16B in funding, even though they cant demonstrate that they can actually provide service (and may be fudging the latency numbers, hard to prove since you cant actually test it) !

There are very few investors that can write the cheques big enough to fund an LEO sat constellation. Even large investors like Softbank balked at committing additional risk capital to a single investment like OneWeb. The history of bankrupt constellations would bear that out. COVID-19 has made raising money for risky ventures even harder. Building the business case is difficult; it costs too much money to make money, even for a SpaceX that has re-invented rockets and dropped the price of launching satellites.

LEO satellite constellations, especially using small nano satellites can provide great services for many use cases; Earth observation, low data rate iOT or M2M, remote asset tracking, weather data and even imaging. GEO sats can provide great high throughput required for TV and telecommunications, but they provide poor connectivity at Northern latitudes like Canada’s Arctic. The use case of providing broadband Internet for the unconnected is just not suited for LEO.

To connect those 3.5 billion people to the Internet requires not only the huge investment in satellites and ground infrastructure (plus legal/regulatory, and non-trivial insurance costs) but also an inexpensive antenna/receiver for the consumer to be able to plug in themselves to access the service. Given that the terminals will be in remote areas they will need to be low power usage. By definition those places are off the grid. Since the LEO sats move quickly across the sky, the tracking antenna must be sophisticated, like a electronic phased array. No one has yet to produce such a low-cost, low power terminal device.

When the constellation is finally setup, the satellites would cover the entirety of the Earth’s surface. Ninety percent of the time this would be over open water, frozen tundra, wilderness and deserts devoid of people. So a business case dependent on a use case like consumer broadband would not generate revenue 90% of the time ! In areas like Africa or the Amazon, the surface is covered by jungle. The signal won’t penetrate through thick vegetation, limiting its usefulness. Finally, how much would people actually pay to use the service ? Has Elon gone out and talked to the people in emerging markets and asked them what they need and what they can afford ? What about when that area finally gets served via a cable or fixed wireless that can provide service for an order of magnitude less ? Eventually even Nunavut will get service by one or more sub-sea fiber optic cables.

So where exactly are the customers going to come from to justify the immense capital cost of building the constellation ?

The other problem that LEO sat constellations have to solve before we actually see this service launched is the one that they create themselves by launching thousands of satellites to do so. Space debris. Low Earth orbit is already crowded with dysfunctional satellites and space debris. What happens if, no when, a StarLink satellite malfunctions or becomes derelict or collides with other satellites or space debris. The attraction of low cost sats is that they are made with commercial off-the shelf components for a fraction of what traditional GEO sats cost. But given their disposability we are going to have a huge increase in space junk.

Without strict regulatory oversight (and who would be responsible for this in space ?) and the non-zero chance of failures and malfunctions, we could see a runaway feedback loop creating tons of space debris, called the Kessler syndrome. These concerns and liabilities have still not been fully addressed for the large volume LEO constellations.

Until StarLink (or any other LEO Sat constellation) actually builds and operates a constellation without going bankrupt, solves the physics of providing low cost-low power consumer terminal equipment and can guarantee they won’t destroy low Earth orbit with space debris for succeeding generations don’t hold your breath for cheap sat based broadband service in Canada’s rural and remote areas.

Instead of waiting for Elon, Canadians should take control of their own future and build more Arctic fiber optic cables.

RAG London Online: May 13-14, 2020

The compères Eric, Rachel and Tony

Today was the first day of the Risk and Assurance Group (RAG) London conference. Due to the ongoing global pandemic it was turned into a virtual online conference. The sessions began at 7:30 AM London time (2:30 AM in Waterloo, eek !) but I listened to the whole event from start to finish.

The conference covered revenue assurance, fraud management, cybersecurity, billing accuracy, enterprise risk management, margin optimization, cost management and other kinds of business assurance.

Revenue Assurance is a broad topic that can cover many issues in a telecom business. Many of the presentations highlighted the growth and evolution of revenue assurance from a simple audit type function to informal analytics to entire ecosystem tracking. RA professionals can not only increase the top line by preventing revenue leakage but also improve bottom line profits and cash flows, all without dampening demand. In fact
it can be said that business assurance is the only function that assures profit as it has the data to measure costs on a customer basis.

The near future for RA would be to embrace emerging technology such as Machine Learning and other for automating more and more processes. The skills of RA professionals in telecom will also find their way into other industries such as Finance, Utilities , Consumer and Tech.

There were discussions on the blockchain for telecom as well as specifically for battling Wangiri one-ring fraud. Other fraud management schemes such as STIR/SHAKEN, A&B # Handshake, and Seismic were discussed.

One of my favourite lines I heard today, reminded me of my sales philosophy with my own customers. “Trust is the biggest thing; it is about the relationship, it is not a transaction”. It was said in a discussion of RA working with internal partners such as network but it really did remind me of why I love my business and serving my customers.

Those are just some of the over-arching themes from over ten hours of superb content. If you missed it and are interested , some of the videos will be posted on the RAG website here.

Better yet, get yourself out of bed at 2:30 AM tomorrow and catch Day 2 of the conference live. That way you can participate in the Q & A sessions ! I am looking forward to it myself.

RAG – Risk and Assurance Group

You may have noticed a new logo on our home page and footer. AurorA, more specifically Timo, is a member of RAG, the Risk and Assurance Group.

I joined RAG back in June, 2019 after attending their conference in Toronto held at Telus Harbour. I wrote about that experience here.

RAG can be described as an association for telco professionals involved in all aspects of Revenue Assurance; fraud management, enterprise risk management, law enforcement liaison, credit risk, market assurance, capex analysis and security. Actually, association sounds too stuffy, a club is a better description. A club of like minded telecom fraud and risk managers wanting to get better and improve.

What makes it a club is the spirit of openness. The way to solve many of the issues in fraud and risk in the telecom industry is to work together. At RAG, people are encouraged to be open, to ask questions, provide answers and share, to share experiences and information and practices.

I have met many great people in the industry from all over the world through RAG. They have been kind enough to share their knowledge openly with me. You can find some of this online at the RAG website , where you will also find episodes of RAGTV and even online training courses under RAG learning. The conferences, such as the one I attended in Toronto, have been held around the world; London, Nairobi, Bahrain, Bonn, Johannesburg, Delhi and more. They are a great way to meet people face-to-face, network and interact directly.

With the global COVID-19 pandemic raging, the next scheduled conference on May 13-14, 2020 will be held online. Although the start times are pretty early for the Eastern Time Zone (2:30 AM EEEK) I still plan on getting up and watching some of the sessions live.

So know you know why many of my social media posts on Twitter and LinkedIn feature RAG. I am proud to be a member, and happy that they agreed to let me display the logo on my website. Membership in RAG really helps me stay on top of what is happening in the world of fraud and risk management so I can better serve you, my customers. Together, we can all help the telecom industry mitigate the hackers, cheats and criminals out there.

Origin Based Pricing

Wholesale telecom used to be simple. There was one rate per minute to call a country overseas from Canada. Then deregulation and liberalization came in the late 1990’s and early 2000’s and competition came to international telecom. We saw rates broken out for large cities within countries; then cellular came and we had breakouts for mobile phones, then for individual mobile carriers. The size of wholesale rate tables exploded.

Prices dropped dramatically over the years to where eventually calls to industrialized nations in North America, Europe and Asia were under a penny a minute for wholesale costs for landline AND for mobiles.

The one constant was that a country charged a rate for termination regardless of where the traffic came from. They didn’t discriminate. Then in late 2015 we started to see something new, coming out of France initially ; origin based pricing. Calls to France had different prices depending on where the call was coming from. For example a call to a mobile number in Paris might cost $0.03 per minute if called from Berlin, but cost $0.30 per minute if called from Hong Kong. Why ?

Well, telephony revenues had steadily declined for years all over the globe. New OTT players like Skype were taking huge market share. Then the EU began to mandate that roaming charges for calls within the EU be reduced to eventually zero (so that you could Roam Like Home all across the EU)
So the carriers were desperate for revenue, and they chose to find it from customers from outside of the EU.

The EU Commission initially fought Arcep (French regulator) over origin based pricing as the Commission sets European termination rates, but found that for calls originating outside of the EU it had no jurisdiction. The game was now on. Other European countries quickly followed suit. Austria , Belgium, Italy, Greece, the Netherlands, Portugal, Sweden and Switzerland were among the countries that introduced origin based pricing. Origin is determined by the caller ID of the calling party so the surcharge applies if it is outside the EU or if the caller ID is missing or blank.

Initially, these surcharges were mandated by the country regulators. To avoid trade disputes with countries that they had free trade agreements with, the surcharges were not charged for origination from Canada or the USA. Blank CLID still drew a hefty surcharge.

In January 2019 we saw a new phenomenon originating in Malta. It seems that all of the Maltese mobile carriers simultaneously saw the need to introduce surcharges for calls from outside of the EU. No longer was there an exemption for Canada or the USA. This has now been copied by other countries like Belgium and more recently Germany.

My complaints to the Canadian Trade Commissioners office generated this response

As the surcharge was a decision by the national operators in Malta, according to the TATA communication, and not a requirement of the telecommunications authority, there are no implications for the CETA. Our CETA commitments on telecommunications (like all services) apply specifically to government measures and do not affect the decisions of commercial service providers. So, nothing in the CETA would prevent a telecommunications service provider from raising its rates (or add a “surcharge”), including in a manner that discriminates on the basis of the origin of the call. If the additional surcharge had been a mandated requirement by the regulatory body, this would be considered a measure under the CETA and likely a violation of national treatment/most-favoured nation. But this does not seem to be the case here.

So where do we go from here ? Well, what we are seeing is that there is increased pressure on retail rates, driving customers to OTT providers such as WhatsApp and Skype. Carriers trying to circumvent the surcharges are seeking out grey route suppliers instead of premium quality suppliers like AurorA that will manipulate the CLI and route traffic through a third country like Ireland. The quality of these routes are often poor, and the manipulated CLI means the far end doesn’t know who is calling and reduces the ASR considerably (especially if the called party is a senior). Do you answer calls from a CLID you don’t recognize ?

Either way you are either losing revenue and customers to the OTT or providing poor service and then losing revenue and customers. That is not acceptable.

AurorA’s answer is to continue to fight these surcharges. The oligopoly won’t do it as they are perfectly happy to just add their 50% margin to these surcharges and reap the revenue bonus. AurorA will continue to show the Canadian Trade Commissioners and the staff at the ISED ministry that the EU telecom companies are violating MFN (most favoured nation) principles under the WTO, the CETA and FIPA (Foreign Investment Protection Acts).

Perhaps I am tilting at windmills; I think it is very important though. Calls that terminate in European countries make up nearly 20% of the world market. It is important for you, my wholesale customers, that we can return to the days where calls to the industrialized nations of the world were under a penny a minute , for landlines and for mobiles.

Cellphone Competition Coming ?

Left is MNO Rogers – right is the MVNO Ting – from Twitter user YOZZO

Last week the CRTC finished up two weeks of hearings as a Review of Mobile Wireless Services. The subject of the 9 days of hearings were whether to mandate (ie force) the current mobile network operators (ie Bell/Telus/Rogers, Big 3, Goliaths) to provide wholesale MVNO (Mobile Virtual Network Operator) access to their networks to smaller carriers (ie Davids). In short to open the market up to competition.

There were many parties giving evidence and opinions. The Big 3 are very against being forced to sell access to their networks. Very against. They cite that the market is already competitive, that mandating MVNO’s would curtail their ability to spend on network expansion (both to rural/remote areas and upgrading to 5G). And they point to a submission from the Competition Bureau that pro-MVNO regulation would harm smaller facilities based competitors like Videotron, Shaw, Eastlink and Xplornet. Telus CEO Darren Entwistle even threatened to cut $1 billion in network investment, 5,000 jobs and philanthropic giving if CRTC dared to mandate MVNOs.

Telus threatens to euthanize animals if CRTC approves mobile virtual network operators – from The Beaverton

Is the Canadian mobile market really competitive ? The reason this procedure was even going on was due to the outcry from Canadians about their cellphones! It seems self evident that Canadians view the current situation as unfair and that the Big 3 are acting as an oligopoly. They hate their current providers (see here) This came up more than once in various submissions, including co-ordinated rate plans (one moves they all move), the smoke-screen of flanker brands to confuse the market etc.

There were other parties like TekSavvy, Distributel, Tucows, CNOC, Ice Wireless (Iristel) and others arguing in favour of MVNO’s. They argued that as Full MVNO’s they would not own spectrum or operate their own radio access network, but purchase that from the Big 3 . Except for the operation of such a radio access network, they would be responsible for all other aspects of their operations such as sales, marketing, billing and the operation of a core network. From there they could increase competition in the marketplace to provide more services to Canadian consumers and businesses.

Twitter commentary on competition from MVNOs being more than “resale” or a free ride

We won’t know the outcome from these hearings for a while, maybe not until 2021. I am watching this process carefully; not because AurorA plans to become an MVNO. Almost my entire 35 year career has been on the competitive side of the industry, competing against the various incarnations of the Big 3. And they are formidable competitors indeed who do not cede an inch of any markets that they consider as theirs. My rooting interest naturally falls to the underdogs, the Davids competing against Goliaths.

If MVNO’s are mandated though, it could also open up a raft of new mobile competitors . Those competitors would need premium quality termination for their overseas calls. Mobile calls originate on cellphones and already undergo compression just to reach the core; from there you want to ensure premium quality so that the caller gets through perfectly. An LCR here makes zero sense; if the caller wanted a cheap call they would use a free app on their phone like Skype or WhatsApp. If they use the phone it has to be high quality. And I know just who has the best quality international voice termination !