Management Response and Action Plan: Audit of the Spectrum Compliance

For follow-up purposes - Detailed actions to address the recommendations in the report

Recommendation Planned Action on the Recommendation Responsible Official (position) Target Completion Date
Recommendation 1
(Low Risk):

DGSO should document and standardize roles and responsibilities to support the delivery of all compliance activities to ensure efficiency and consistency across the country.

1.1 ISED has current delegation charts that set out statutory powers and the levels to which authority is delegated. Within regions, many of the roles and responsibilities are consistently carried out although not fully documented for Spectrum Management Officers and Technical Spectrum Officer (TSO) for a core set of activities. DGSO agrees to standardize roles and responsibilities to support the delivery of compliance activities. In standardizing roles and responsibilities, care must be taken to balance the need for consistency with the efficient use of resources, where experienced staff may take on broader responsibilities than less experienced staff.

Director General, Spectrum Management Operations Branch -
1.2 In consultation with ISED’s regional offices, DGSO will develop a grid outlining high-level standardized roles and responsibilities for Spectrum Management Officers, Technical Spectrum Officers and Regional Engineers for compliance activities. Director General, Spectrum Management Operations Branch Q2, 2020-21
Recommendation 2
(Medium Risk):

DGSO should establish a standardized process for the issuance, management, and monitoring of inspector cards across all regions.
2.1 DGSO is updating the procedures to include specifics regarding the issuance, management and monitoring of inspector cards across all regions. This will include a standardized process to monitor inspector cards to ensure that they are issued and revoked in a timely fashion, taking into consideration procedures that were documented by Atlantic and Ontario Region. Director General, Spectrum Management Operations Branch Q3, 2019-20
Recommendation 3
(Medium Risk):

The DGSO should reassess the National Compliance Framework (NCF) to determine whether the compliance activities are aligned to the needs of the overall Spectrum program.
3.1 The DGSO National Compliance Framework was originally designed to bring together activities undertaken by the DGSO and was intended to encompass planned activities only. Other compliance activities are conducted by the Engineering, Planning and Standards Branch. - -
3.2 DGSO will consult with Engineering, Planning and Standards branch and the Assistant Deputy Minister to determine if their compliance activities should be merged into a compliance framework for the whole sector. Assistant Deputy Minister, Spectrum Telecommunications Sector Q4, 2019-20
3.3 DGSO will reassess the compliance framework in consultation with regional offices to determine whether the compliance activities are aligned to the needs of spectrum operations, and update the framework as required. Director General, Spectrum Management Operations Branch Q2, 2020-21
Recommendation 4
(High Risk):

The DGSO should formalize its risk-based methodology to support the annual planning for compliance activity targets, informed by resource requirements and constraints.
4.1 A methodology to cost program activities will be finalized and used to determine the resource and O&M costs of compliance activities in regions. It will be used to assist DGSO in setting national and regional targets. DG, Spectrum Management Operations Branch Q3, 2019-20
4.2 Using this tool, DGSO will formalize a risk-based methodology for the development of annual compliance activity targets, informed by resource requirements, constraints and historical program data. DG, Spectrum Management Operations Branch Q4, 2019-20
Recommendation 5
(Medium  Risk):

The DGSO should further standardize the remaining compliance activities by implementing national procedural guidelines with quality control practices to ensure compliance activities are delivered and documented consistently across regional offices.
5.1 As per the DGSO National Compliance Framework, there are two remaining items that DGSO is planning to standardize in year four: the Radio Licence Terms and Conditions Audits and Monitoring For Unlicensed Operations. The national procedures developed for these activities will include guidelines and quality assurance practices similar to those of the Western Region. DG, Spectrum Management Operations Branch -
5.2 DGSO will conclude the development of national procedures related to Radio Licence Terms and Conditions Audit. DG, Spectrum Management Operations Branch Q4, 2019-20
5.3 DGSO will conclude the development of national procedures related to Monitoring of Unlicensed Operations. DG, Spectrum Management Operations Branch Q4, 2020-21
5.4 Working with regions, DGSO will develop and document a common approach for the Prevention of Non-Compliance to determine priorities and to approach stakeholder engagement to support the outcomes of the Spectrum program. DG, Spectrum Management Operations Branch Q2, 2021-22
Recommendation 6
(High Risk):

The DGSO should implement quality control and assurance practices over SPECTRAPlus compliance activities to ensure all information entered in the system is accurate and appropriately coded. As a long-term solution, the DGSO should also consider implementing an information management capability that can guide the processes for each compliance activity, and accurately and efficiently capture the required information for analysis, decision-making and reporting.
6.1 DGSO will pilot and evolve quality assurance practices by examining monthly reports and identifying data quality issues to be resolved in collaboration with regions.DGSO will disseminate lessons learned throughout regional offices. DG, Spectrum Management Operations Branch Q3 2020-21
6.2 Drawing on the results of the pilot and in consultation with regional offices, DGSO will determine the best long-term plan, including the option to evolve or develop software. DG, Spectrum Management Operations Branch Q3, 2020-21
Recommendation 7
(High Risk):

The DGSO should implement a medium- and long-term investment plan to ensure the Spectrum compliance program can continue to meet its objectives, for both current technologies and those anticipated in the adoption of 5G services & technology.
7.1 Budget 2019 announced funding for DGSO to modernize the equipment used for Spectrum Management compliance activities. Director General, Spectrum Management Operations Branch -
7.2 DGSO appointed a Director of the Spectrum Management Innovation Directorate to lead the implementation of its equipment renewal program, Horizon. Director General, Spectrum Management Operations Branch Q3, 2018-19
7.3 DGSO will deliver a Treasury Board Submission to secure funding for the Horizon project. This includes for the initial investment and ongoing funding. Director General, Spectrum Management Operations Branch Q1, 2019-20
7.4 DGSO is developing a plan to modernize all spectrum management equipment nationwide. Director General, Spectrum Management Operations Branch Q3, 2019-20
7.5 In the short term, DGSO will develop and implement a maintenance schedule to ensure that a sufficient quantity of spectrum measurement equipment that requires calibration is available in the regions for activities that require calibrated measurements. This schedule will take into consideration operational requirements as well as the costs of calibration. Director General, Spectrum Management Operations Branch Q3, 2019-20
7.6 DGSO will hire a National Manager for spectrum monitoring infrastructure. Director General, Spectrum Management Operations Branch Q3, 2019-20
7.7 DGSO will hire a Modernization implementation team. Director General, Spectrum Management Operations Branch Q3, 2019-20
7.8 Define requirements and specifications, request information from vendors. Director General, Spectrum Management Operations Branch Q4, 2019-20
7.9 RFP, tendering and contract award process. Director General, Spectrum Management Operations Branch Q4 2020-21
7.10 Equipment deliveries. Director General, Spectrum Management Operations Branch Q4 2022-23
7.11 Equipment deployment. Director General, Spectrum Management Operations Branch Q4 2023-24
7.12 Training of personnel. Director General, Spectrum Management Operations Branch Q4 2023-24
Recommendation 8
(Medium Risk):

The DGSO should strengthen its annual reporting to include compliance rates for all standardized activities; year-over-year comparisons and trends; and performance against the established performance metrics.
8.1 DGSO will strengthen its annual reporting to include compliance rates for all standardized national activities, and year-over year trends. Director General, Spectrum Management Operations Branch Q2, 2020-21
8.2 DGSO will develop performance metrics to measure program performance in attaining the objectives of the DGSO National Compliance Framework. Director General, Spectrum Management Operations Branch Q4, 2020-21
Recommendation 9
(Low Risk):

The DGSO should strengthen its training program to include compliance activity training.
9.1 ISED currently has a strong training program in place for new Spectrum Management Officers. Supplementary to classroom training, training for compliance activities is provided on-the-job under the supervision of a more experienced employee. Director General, Spectrum Management Operations Branch -
9.2 DGSO will develop and implement a compliance training module in consultation with the regional offices and with the Spectrum Technical Training Committee. Director General, Spectrum Management Operations Branch Q2, 2020-21