Subject: [Raven] To engage, or not to engage.....

From: Paul Ferguson <[email-masked]>
Date: Wed, 03 Nov 1999 09:09:10 -0500

Personally, I think the IETF should just steer clear of
"building tapability into existing & future protocols,"
and I have already said so on several occassions.

Case in point (and which has also been pointed out by
a few other folks), this is already being done elsewhere:

   "Revision of J-STD-025 for FCC Third Report and Order"
                   document (PN-4465)

          Telecommunications Industry Association
        TR45.2 Subcommittee: Intersystem Operations
     Ad Hoc on Lawfully Authorized Electronic Surveillance

The date on the latest revision in 15 November 1999.

[snip]

  "The specification of interface compatibility requirements
  between telecommunication service providers (TSPs) and law
  enforcement agencies (LEAs) was developed as a Joint Standards
  Project between ANSI accredited Telecommunications Industry
  Association Committee TR-45 and ANSI accredited Committee
  T1Telecommunications.

  "This Interim Standard defines the interfaces between a
  telecommunication service provider (TSP) and a Law Enforcement
  Agency (LEA) to assist the LEA in conducting lawfully authorized
  electronic surveillance. A TSP, manufacturer, or support service
  provider that is in compliance with this Interim Standard will
  have a "safe harbor" under Section 107 of the Communications
  Assistance for Law Enforcement Act (CALEA), Public Law 103-414:
  "a [TSP] shall be found to be in compliance with the assistance
  capability requirements under [CALEA] Section 103, and a
  manufacturer of telecommunication transmission or switching
  equipment or a provider of telecommunication support services
  shall be found in compliance with [CALEA] Section 106."

[snip]

Bear in mind, this is a "working document," so it is subject
to change.

Special consideration should be paid to Section 6, "Implementation
Perspective," specifically subsections dealing with Packet-Mode
Communications.

The gist of the paket-mode intercept is to pass all packets
originating from & destined for a "suspect" to the LEA. From what
I've read, it doesn't appear to be very workable, but that's just
my opinion.

Also, please do not e-mail me asking for a pointer to this document
(I am told that these sort of documents are kept in a "members only"
section of their document repository), or ask me to forward a copy
via e-mail.

Speaking only for myself,

- paul

ps. I'm looking forward to the open plenary next week.  :-)

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From: "Richard Payne" <[email-masked]>
Date: Wed, 3 Nov 1999 09:48:51 -0500

Paul Ferguson pointed out the existence of  J-STD-025.

Paul, do you know if this document defines "telecommunication service
provider" to mean the same thing as "telecommunications carrier" does in
CALEA (which would make sense, given the ostensible purpose of complying
with CALEA), or does it define it to mean something broader, capturing,
e.g., ISP's?

If it's the first, the packet-mode capture would seem to apply only to
telecommunications carriers' internal networks. If it's the second, it's
arguably stepping beyond the bounds of CALEA (which exempted information
services) and would seem to need, at the least, some narrowing.

Also, please forgive my ignorance, but do you know if ISP's are regulated by
the FCC in the U.S.? I would have guessed not...

Richard Payne

---

From: Paul Ferguson <[email-masked]>
Date: Wed, 03 Nov 1999 13:52:27 -0500

>with CALEA), or does it define it to mean something broader, capturing,

I think that's open to interpretation.

>the FCC in the U.S.? I would have guessed not...

I do not believe so, at least "vanilla" service providers which offer
only IP connectivity. However, I don't know for sure -- I'm not an
expert on FCC applicability, or any other legal issues, by any stretch
of the imagination.

- paul