[VoiceOps] CALEA for the small fry operator

Fri Jan 18 18:54:10 EST 2013

I had thought of asking our CLEC partner who provides us with our DIDs about their CALEA readiness, but one of the complications we face is that we only use them for call origination.  They don't have a termination product, so we use someone else for that.  So the CLEC in question would only be able to tap inbound calls to the LEAs target, and not calls that the target makes him/herself.

I think this would necessitate our involvement at some level, rather than telling the agency in question to simply contact the CLEC and our termination provider separately.

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

-----Original Message-----
From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] On Behalf Of Ryan Delgrosso
Sent: Friday, January 18, 2013 3:44 PM
To: voiceops at voiceops.org
Subject: Re: [VoiceOps] CALEA for the small fry operator

I would respectfully disagree. We are most certainly not a CLEC, but we have received warrants for wire taps, and have complied. Fortunately we do use a commercial softswitch that can provide this.

Its a dangerous game, of not if but when they will come asking, and if you have a solution in place before that time comes, since the fines for non-compliance are extreme. 

Additionally, what you may do if you are using a reputable DID provider who is a CLEC (not a reseller) is inquire with them about them supporting CALEA, and see if they can fill this gap for you. I know in the past when speaking with certain large national providers on this topic (much may have changed since then) if they owned the DID AND I Could route all outbound calls for the subscriber with the warrant back to them, since they were the CLEC that the number was actually owned by, I could deflect the warrants to them. Might be worth looking into. 

On 01/18/2013 02:30 PM, Joshua Goldbard wrote:

	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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