[VoiceOps] CALEA for the small fry operator

[Nathan Anderson]

Carlos, thanks for doing that legwork.  A few questions come to mind:

1) What is the "one allowed data standard", and where did you find it referenced?

2) Is there any reference copy of the data standard publicly available?  Is it in fact the T1.678 that http://askcalea.fbi.gov/ mentions?

3) What signalling information do they require be recorded and/or streamed in real-time?

4) One might wonder if the concession made to operators not being required to completely redesign their networks was specifically made for those who had networks operating before CALEA compliance was made mandatory.  Is there any reason to believe that those of us who have started up networks in the last year or two, well after the CALEA requirements were put in place, cannot use this excuse?  It seems to me they could try to argue that we should have known at the outset that this would be required of us, and should have planned our network accordingly.

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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 Carlos Alvarez
Sent: Saturday, January 19, 2013 8:13 AM
To: voiceops at voiceops.org
Subject: Re: [VoiceOps] CALEA for the small fry operator

I'm trimming all previous replies because this isn't in reply to any one thing.  I spent several hours last night reading FCC docs, FBI stuff, and whatever I could find on this topic.  There are a few bullet points that stuck in my mind.  These are according to my interpretation, and while I've been reading FCC and other legal stuff for a very long time, I'm not a lawyer and my expertise isn't in law.

It seems that there is one allowed data standard, but repeatedly I saw that the FCC refused to limit delivery methods, particularly for packet-switched networks.  It seems to me that a meetme in Asterisk is almost compliant, though missing some of the signaling stuff.  There is in fact an option on the FCC compliance form for "proprietary/home-grown" solution.

On that topic however, I repeatedly saw "if reasonably available."  The FCC says that you must provide all the signaling requested "if reasonably available" at the network intercept point.  They specifically said they don't expect operators to completely redesign their networks.  This of course is rather unclear.  From our perspective, as a tiny company, it would be easy to argue that it's not reasonable for us to spend 50% of a year's profit changing our network.  I may be crazy and that may not work, I don't know.

You can charge any time you get a request for records or intercept.  Actually a lot.  As a comparative number, Comcast charges $1k to set up an intercept and provide a month of service, $750/mo thereafter.  They charge $200/mo for weekly call record delivery.

-- 

Carlos Alvarez
TelEvolve
602-889-3003