[VoiceOps] CALEA for the small fry operator

Fri Jan 18 18:02:23 EST 2013

I read (and I think most people do) "Facilities-Based Broadband Internet Access Providers" and "Providers of Interconnected VoIP" in that paragraph as two distinct categories.  You don't need to be a CLEC to be an interconnected VoIP provider.  If that were the case, then we wouldn't have to file 499s and pay into USF, would we?  (Oh, if only...)

Furthermore, I don't think the section you quoted makes mention of LECs.  It says "Facilities-Based BROADBAND INTERNET ACCESS Providers".  So they aren't necessarily even talking about LECs here (although some LECs -- ones that have an ISP arm or division -- would be a subset of that group).  I don't think "facilities-based" is a term with a specific legal definition that means "telecom company with their own switch".  They are referencing "facilities-based" (that is, non-resellers/"white-labelers") ISPs (such as us), and "interconnected" VoIP providers (VoIP services that "interconnect" with the PSTN and use NANP TNs, such as Vonage, and now us).

I would love to be proven wrong.

--
Nathan Anderson
First Step Internet, LLC
nathana at fsr.com

-----Original Message-----
From: Joshua Goldbard [mailto:j at 2600hz.com] 
Sent: Friday, January 18, 2013 2:31 PM
To: Nathan Anderson
Cc: voiceops at voiceops.org
Subject: Re: [VoiceOps] CALEA for the small fry operator

From: http://transition.fcc.gov/pshs/services/calea/

CALEA Compliance for Packet Equipment, And Equipment for Facilities-Based Broadband Internet Access Providers and Providers of Interconnected VoIP

All facilities-based broadband Internet access providers and providers of interconnected VoIP service must ensure that their services comply with CALEA upon launch. In the May 12, 2006 Commission order, the Commission found that section 107(c)(1) may not be used by entities seeking extensions for equipment, facilities, and services deployed on or after October 25, 1998 (the effective date of the CALEA section 103 and 105 requirements).
I believe you aren't subject to CALEA unless you're a facilities-based CLEC/ILEC. I am not a lawyer, this is not legal advice, but I don't think this applies to you. (Someone please correct me if I'm mistaken).

Joshua Goldbard
VP of Marketing, 2600hz

116 Natoma Street, Floor 2
San Francisco, CA, 94104
415.886.7923 | j at 2600hz.com

On Jan 18, 2013, at 2:16 PM, Nathan Anderson <nathana at fsr.com>
 wrote:

	Nope.

	-- Nathan 

	-----Original Message-----
	From: Joshua Goldbard [mailto:j at 2600hz.com] 
	Sent: Friday, January 18, 2013 2:03 PM
	To: Nathan Anderson
	Cc: voiceops at voiceops.org
	Subject: Re: [VoiceOps] CALEA for the small fry operator

	Are you a CLEC? 

	Cheers,
	Joshua

	Joshua Goldbard
	VP of Marketing, 2600hz

	116 Natoma Street, Floor 2
	San Francisco, CA, 94104
	415.886.7923 | j at 2600hz.com

	On Jan 18, 2013, at 1:54 PM, Nathan Anderson <nathana at fsr.com>
	wrote:

	We are a small-ish, regional broadband ISP in the U.S. (inland Washington and Idaho) that has also rolled out an interconnected VoIP product over the past year.  I'm trying to wrestle through and understand what our responsibilities and obligations are with regards to CALEA compliance at both the legal and technical levels.

	Confession time: we did not purchase a commercial softswitch product.  We built our own solution on top of Asterisk.  (I can already hear the groans and feel the tangible disapproval.)  We went this route for cost reasons, yes, but more importantly we did it because with a custom-engineered solution, we were able to seamlessly integrate our new voice offering with our other existing products when it comes to both provisioning and billing, and this (I believe) leads to a better and more uniform experience for our customers.  For better or worse, we are an ISP first and foremost, and an ITSP second, and provisioning for the new product needed to conform to existing practices rather than be an island unto itself, as so many "turn-key" offerings are.

	But I recognize that going down this path has brought with it a distinct disadvantage when it comes to solving the CALEA complaince problem.  Notably, there are no known CALEA solutions for Asterisk of any stripe that I have been able to find, and any discussion about Asterisk and CALEA seems to have peaked around the time (2006-2007) that the feds announced VoIP providers were going to have to bring themselves into compliance, and then quickly faded after that.

	Sure, I could easily come up with something that would allow for live or recorded call interception and/or delivery of CDR/CPNI to law enforcement using existing tools already available to me.  What is unclear to me, though, is whether there is any particular format or delivery mechanism for this data that the law stipulates we follow.  I know that there is an ANSI standard, T1.678v2 (and the subsequent supplements), but of course I have no access to that (200+ page) document without paying the publisher hundreds of dollars for a copy.  And even if we got our hands on a copy, it sounds like it would be prohibitively difficult to implement by ourselves.

	Does the law actually stipulate that T1.678 be followed, and are you not in compliance with CALEA regulations unless you specifically use a solution that is T1.678-compatible?  Or is the T1.678 standard simply recommended and preferred by LEAs?  I have seen discussion threads where other people have talked about their "creative" solutions to CALEA compliance, which include things such as proxying the RTP stream and having a bank of E&M channels at the ready to mirror the audio to (http://fonality.com/trixbox/forums/trixbox-forums/open-discussion/what-i-need-start-ip-phone-service-provider-business).  Do these people actually know if their solution gets a passing grade, or are they taking a gamble?

	Thanks,

	-- 
	Nathan Anderson
	First Step Internet, LLC
	nathana at fsr.com
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