[WISPA] CALEA Document
It's my understanding that one just needs to have documentation in place as to what they will do if presented with a CALEA request. Does this need to be extremely detailed, or can it be boilerplate? Does anyone have a CALEA document they wouldn't mind sharing? There's a couple beers in it for you at Wispapalooza. :) Thanks Sam ___ Wireless mailing list Wireless@wispa.org http://lists.wispa.org/mailman/listinfo/wireless
Re: [WISPA] Calea Compliance
Re: [WISPA] Calea ComplianceRight. There are documents that WISPA has created to help with this. http://www.wispa.org/?page_id=2022 We also have an implementation guide but the board has not determined how that's to be distributed. We can certainly get a copy to you if you are a member. Please note, that we're in the middle of a minor re-write that will focus on IPv6 issues and a couple of clarifications that needed work in the original version. marlon - Original Message - From: Jeff Broadwick - Lists To: ro...@g5i.net ; 'WISPA General List' Sent: Monday, March 07, 2011 5:59 AM Subject: Re: [WISPA] Calea Compliance You would be better off putting a passive tap inline and the router as a probe. If you do that, it will be completely invisible to the end customer. Regards, Jeff ImageStream Sales Manager 800-813-5123 x106 -- From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of Roger Howard Sent: Saturday, March 05, 2011 10:50 PM To: WISPA General List Subject: Re: [WISPA] Calea Compliance Ok, but the FBI wouldn't know I stuck the hardware there at the last minute. And the tower glitches off whenever I do a firmware upgrade anyway. The customer wouldn't know the difference. On Sat, Mar 5, 2011 at 9:45 PM, Josh Luthman j...@imaginenetworksllc.com wrote: Depends who you ask. Some might say the customer could notice a change in network and hence non compliant. On Mar 5, 2011 10:43 PM, Roger Howard g5inter...@gmail.com wrote: Would I cover myself for calea by having a mikrotik router on the shelf, set up as a bridge, with the calea module installed. Then if I get subpoenaed for a tap, I just run out to the appropriate tower and put it on the ethernet interface of whichever AP the subscriber is on? Thanks, Roger WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- No virus found in this message. Checked by AVG - www.avg.com Version: 10.0.1204 / Virus Database: 1435/3487 - Release Date: 03/07/11 -- WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Calea Compliance
You would be better off putting a passive tap inline and the router as a probe. If you do that, it will be completely invisible to the end customer. Regards, Jeff ImageStream Sales Manager 800-813-5123 x106 _ From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of Roger Howard Sent: Saturday, March 05, 2011 10:50 PM To: WISPA General List Subject: Re: [WISPA] Calea Compliance Ok, but the FBI wouldn't know I stuck the hardware there at the last minute. And the tower glitches off whenever I do a firmware upgrade anyway. The customer wouldn't know the difference. On Sat, Mar 5, 2011 at 9:45 PM, Josh Luthman j...@imaginenetworksllc.com wrote: Depends who you ask. Some might say the customer could notice a change in network and hence non compliant. On Mar 5, 2011 10:43 PM, Roger Howard g5inter...@gmail.com wrote: Would I cover myself for calea by having a mikrotik router on the shelf, set up as a bridge, with the calea module installed. Then if I get subpoenaed for a tap, I just run out to the appropriate tower and put it on the ethernet interface of whichever AP the subscriber is on? Thanks, Roger WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ _ No virus found in this message. Checked by AVG - www.avg.com Version: 10.0.1204 / Virus Database: 1435/3487 - Release Date: 03/07/11 WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Calea Compliance
The FBI told me (and I am paraphrasing) that if you work with them that they will work with you. Basically as long as you are not acting like you do not think they have a right to do the tap and are not being a pain in the behind then you will get all the support you need from them in a lawful intercept situation. I would say that having this box on the shelf shows your intentions of being compliant to the act. CALEA is all about 2 things. It is about making sure that tools exist to find and stop crime on the Internet and about making sure that we help be a check against government becoming too intrusive. CALEA has many regs which say when we are doing too much to help tap connections. The WISPA CALEA standard was created to act as a guideline for WISPs. It tells precisely what our obligations are in helping assure we can perform lawful intercepts in our network and in preventing overstepping the bounds of what is lawful. Scriv On Sat, Mar 5, 2011 at 9:49 PM, Roger Howard g5inter...@gmail.com wrote: Ok, but the FBI wouldn't know I stuck the hardware there at the last minute. And the tower glitches off whenever I do a firmware upgrade anyway. The customer wouldn't know the difference. On Sat, Mar 5, 2011 at 9:45 PM, Josh Luthman j...@imaginenetworksllc.com wrote: Depends who you ask. Some might say the customer could notice a change in network and hence non compliant. On Mar 5, 2011 10:43 PM, Roger Howard g5inter...@gmail.com wrote: Would I cover myself for calea by having a mikrotik router on the shelf, set up as a bridge, with the calea module installed. Then if I get subpoenaed for a tap, I just run out to the appropriate tower and put it on the ethernet interface of whichever AP the subscriber is on? Thanks, Roger WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Calea Compliance
On 03/06/2011 09:18 AM, John Scrivner wrote: The FBI told me (and I am paraphrasing) that if you work with them that they will work with you. Basically as long as you are not acting like you do not think they have a right to do the tap and are not being a pain in the behind then you will get all the support you need from them in a lawful intercept situation. I would say that having this box on the shelf shows your intentions of being compliant to the act. CALEA is all about 2 things. It is about making sure that tools exist to find and stop crime on the Internet and about making sure that we help be a check against government becoming too intrusive. Correct. Protect the rights of our customers, protect the rights of the service provider AND allow for what LEA needs to get a conviction for the guilty party. All of these are built into CALEA. CALEA has many regs which say when we are doing too much to help tap connections. The WISPA CALEA standard was created to act as a guideline for WISPs. It tells precisely what our obligations are in helping assure we can perform lawful intercepts in our network and in preventing overstepping the bounds of what is lawful. In addition, the WCS for IPNA provides technical requirements as well. It defines the technical standard that our software/hardware MUST meet. For the original poster: Be sure you are familiar enough with the way the MT handles the CALEA software so that you can properly capture this data for the LEA. Mikrotik's CALEA implementation is 2 parts. It requires a server AND a tap. One box CAN be both pieces. -- * Butch Evans * Professional Network Consultation* * http://www.butchevans.com/* Network Engineering * * http://store.wispgear.net/* Wired or Wireless Networks * * http://blog.butchevans.com/ * ImageStream, Mikrotik and MORE! * *NOTE THE NEW PHONE NUMBER: 702-537-0979 * WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Calea Compliance
The easy answer is if you get a warrant you should ask the agency for help before doing anything. They are more than willing to help in my experience. My advice is: 1.Get your attorney involved to the point they know what you are doing 2.Call the agency who the warrant is for and ask for technical assistance. They have done this many times and can make sure you don't mess things up. Justin -- Justin Wilson j...@mtin.net Aol Yahoo IM: j2sw http://www.mtin.net/blog xISP News http://www.twitter.com/j2sw Follow me on Twitter Wisp Consulting Tower Climbing Network Support On 3/6/11 11:02 AM, Butch Evans but...@butchevans.com wrote: On 03/06/2011 09:18 AM, John Scrivner wrote: The FBI told me (and I am paraphrasing) that if you work with them that they will work with you. Basically as long as you are not acting like you do not think they have a right to do the tap and are not being a pain in the behind then you will get all the support you need from them in a lawful intercept situation. I would say that having this box on the shelf shows your intentions of being compliant to the act. CALEA is all about 2 things. It is about making sure that tools exist to find and stop crime on the Internet and about making sure that we help be a check against government becoming too intrusive. Correct. Protect the rights of our customers, protect the rights of the service provider AND allow for what LEA needs to get a conviction for the guilty party. All of these are built into CALEA. CALEA has many regs which say when we are doing too much to help tap connections. The WISPA CALEA standard was created to act as a guideline for WISPs. It tells precisely what our obligations are in helping assure we can perform lawful intercepts in our network and in preventing overstepping the bounds of what is lawful. In addition, the WCS for IPNA provides technical requirements as well. It defines the technical standard that our software/hardware MUST meet. For the original poster: Be sure you are familiar enough with the way the MT handles the CALEA software so that you can properly capture this data for the LEA. Mikrotik's CALEA implementation is 2 parts. It requires a server AND a tap. One box CAN be both pieces. -- * Butch Evans * Professional Network Consultation* * http://www.butchevans.com/* Network Engineering * * http://store.wispgear.net/* Wired or Wireless Networks * * http://blog.butchevans.com/ * ImageStream, Mikrotik and MORE! * *NOTE THE NEW PHONE NUMBER: 702-537-0979 * -- -- WISPA Wants You! Join today! http://signup.wispa.org/ -- -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] Calea Compliance
Would I cover myself for calea by having a mikrotik router on the shelf, set up as a bridge, with the calea module installed. Then if I get subpoenaed for a tap, I just run out to the appropriate tower and put it on the ethernet interface of whichever AP the subscriber is on? Thanks, Roger WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Calea Compliance
Depends who you ask. Some might say the customer could notice a change in network and hence non compliant. On Mar 5, 2011 10:43 PM, Roger Howard g5inter...@gmail.com wrote: Would I cover myself for calea by having a mikrotik router on the shelf, set up as a bridge, with the calea module installed. Then if I get subpoenaed for a tap, I just run out to the appropriate tower and put it on the ethernet interface of whichever AP the subscriber is on? Thanks, Roger WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Calea Compliance
Ok, but the FBI wouldn't know I stuck the hardware there at the last minute. And the tower glitches off whenever I do a firmware upgrade anyway. The customer wouldn't know the difference. On Sat, Mar 5, 2011 at 9:45 PM, Josh Luthman j...@imaginenetworksllc.com wrote: Depends who you ask. Some might say the customer could notice a change in network and hence non compliant. On Mar 5, 2011 10:43 PM, Roger Howard g5inter...@gmail.com wrote: Would I cover myself for calea by having a mikrotik router on the shelf, set up as a bridge, with the calea module installed. Then if I get subpoenaed for a tap, I just run out to the appropriate tower and put it on the ethernet interface of whichever AP the subscriber is on? Thanks, Roger WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] Fw: [WISPA CALEA Questions] [CALEA] CALEA Question
signatureFor those asking about the recent FCC statement that broadband is now defined as 4/1 meg. and how that relates (if at all) to CALEA requirements. The answer to that question is below. In a nutshell, it doesn't change anything because the new definition only applies to reported deployment rates not the legal requirement for CALEA intercepts. For those that didn't make the breakfast board meeting at St. Louis, Larry Bruss is the one that gave the CALEA standards update on my behalf. Hope this helps! marlon - Original Message - From: To: ca...@wispa.org Cc: caleaquesti...@wispa.org Sent: Wednesday, July 28, 2010 2:56 PM Subject: Re: [WISPA CALEA Questions] [CALEA] CALEA Question Martha, Mike, Marlon, WISPA members, I have reviewed your EMail questions regarding the FCC's new definition of broadband and have discussed them with the DOJ's Office of General Counsel (OGC). OGC sent me the following response to your questions: The FCC has not changed its regulatory definition of broadband Internet access service provider. What changed most recently was that the FCC updated the standard it uses to determine whether households are served by broadband services. It uses this standard in its annual broadband deployment reports as mandated by section 706 of the Telecommunications Act of 1996 to determine whether advanced telecommunications capability (a term it uses interchangeably with broadband) is being deployed to all Americans in a reasonable and timely fashion. This standard is supposed to evolve over time in order to accurately reflect the minimum speed necessary to stream high-quality video while leaving sufficient bandwidth for basic web browsing and e-mail. The FCC's determination clearly applies only to that report: As a result, we find that the 200 kbps threshold is no longer the appropriate benchmark for measuring broadband deployment for the purpose of this broadband deployment report. See para. 4 of the Sixth Broadband Deployment Report, FCC 10-129 (July 20, 2010), available at http://www.fcc.gov/Daily_Releases/Daily_Business/2010/db0720/FCC-10-129A1.pdf (emphasis added). This is stated unambiguously in footnote 46: We emphasize that we are benchmarking broadband in this report solely for purposes of complying with our obligations under section 706. We specifically do not intend this speed threshold to have any other regulatory significance under the Commission's rules absent subsequent Commission action. For example, today's report has no impact on which entities are classified as interconnected VoIP providers or what facilities must be provided on an unbundled basis. . . . By contrast, the FCC in its 2005 First Report and Order declared that CALEA applies to all broadband Internet access service providers. There, it stated that broadband is defined as 200 kbps, but we also include as 'broadband' - for purposes of CALEA only - those services such as satellite-based Internet access services that provide similar functionalities but at speeds less than 200 kbps. FCC 05-153 para. 24 n.74. That ruling is completely undisturbed by what Julius Knapp was talking about in his keynote, which was referring only to the definition of broadband used in the broadband deployment report. The FCC did not state and did not intend that the definition of the service covered by CALEA would evolve to correspond with the definition used in those reports. CALEA remains applicable to WISPs and all other facilities-based Internet access service providers as defined in 2005. I hope this clarifies Mr. Knapp's remarks and the on-line article referenced in previous Emails regarding CALEA and the definition of Broadband. Regards, Larry Bruss Telecommunications Engineer Tridea Works, LLC 1 503 343 9010 1 703 985 6711 From: calea-boun...@wispa.org [mailto:calea-boun...@wispa.org] On Behalf Of Martha Huizenga Sent: Monday, July 26, 2010 5:17 AM To: ca...@wispa.org Cc: caleaquesti...@wispa.org; Michael Erskine Subject: Re: [CALEA] CALEA Question I can't believe that they are saying that even more Americans are not using broadband! I saw this article, completely ridiculous. Anyway I think we are still subject. I think it's anyone with a connection to the Internet. I bet they could come after people with dial-up. Maybe we should ask Larry though? Martha Huizenga DC Access, LLC 202-546-5898 Friendly, Local, Affordable, Internet! Connecting the Capitol Hill Community Join us on Facebook or follow us on Twitter On 7/25/2010 11:35 PM, Marlon K. Schafer wrote: Hi All, Anyone have a read on this? I didn't think CALEA was limited to broadband. If it is though.marlon - Original Message - From: Michael Erskine To: o...@odessaoffice.comSent: Thursday, July 22, 2010 11:29 AMSubject: CALEA Question Marlon; Since the FCC has redefined the term broadband again, I wonder whatimpact
[WISPA] Fw: [WISPA CALEA Questions] Trango and CALEA
fyi marlon - Original Message - From: J.C. Utter j...@imagestream.com To: CALEA Questions caleaquesti...@wispa.org Sent: Sunday, December 21, 2008 12:59 PM Subject: Re: [WISPA CALEA Questions] [WISPA] Trango and CALEA In an ideal world one would never even touch a packet that had nothing to do with the target of any legal requirement we might receive. The understanding that proceeds from the application of CALEA to packet switched networks from the circuit switched world is that the same privacy rights that exist in the circuit switched world exist in a packet switched world. In other words we are not allowed to let the probe touch any other circuit. When applying an intercept device, in an ideal world, it would isolate traffic by IP/MAC and completely ignore any other traffic. It would forward only the data packets which are associated with the target of the legal action that authorized the intercept. Sometimes that is possible, sometimes it is not. When it is not possible the physical TAP will likely forward all traffic to a storage system which will drop any packets that are not covered in the legal requirement establishing the intercept. Thanks for the background Mike. I think your analysis is generally spot-on, but I do have a technical issue to address in what you have said here. I would argue that the storage step in this process is the only step that is equivalent to what we are calling collection. For example, when a software tap in one of our routers is used to perform an intercept, we are already touching all of the packets in the sense that the router is looking at them and forwarding them. I don't think this is what you mean when you talk about touching a packet. I think when you talk about touching a packet you're talking about privacy. So, in an intercept like this, only the packets of interest are forwarded to the collector which is essentially the storage device. No extra touching of unauthorized traffic is required by our routers during an intercept, in the context of privacy, which I think is what you are talking about. Similarly, when you look at a passive hardware monitoring tap, which creates a second copy of the network traffic, the tap is nearly indistinguishable from a wire in terms of its intelligence and the device's actual ability (or inability in this cae) to collect network traffic. So in this scenario, installing a hardware tap on a ciruit to create a copy of the circuit's traffic is not really collecting anything, and in terms of privacy, it does not touch the traffic any more than the other wires that carry customer data to its appropriate destination. With a hardware tap, network traffic continues to be treated as private until the act of collection (or perhaps another act of viewing of the data) commences, where the output of the tap is actually stored or viewed by a person. This is why it is legal to install hardware taps throughout a network in advance of a court order, and then begin using the output of the tap to perform a lawful intercept once the court order is issued. In a lawful intercept, the output of the hardware tap is filtered before it is stored. In this scenario, if there is no storage of the data and no access to that data which is to remain private (i.e. not covered by the intercept order), then no one has effectively touched the data from a privacy perspective. In this context, it is also important to note that even though some traffic may be authorized for collection, it too must be kept private, and the carrier is not allowed to view the contents of an intercept. I know I'm being fairly nit-picky with terminology here, but we are interpreting the law, and the FBI can be quite nit-pickey when they want to. You comments made it sound like the act of installing a tap is somehow less private than not installing a tap, which is not the case. It is just as private as any other wire on the network that carries traffic and could be viewed or collected, but the traffic is not being collected or viewed. I hope this is helpful. I agree that CALEA codifies data privacy requirements under the law, and it is a big step in the right direction. I also believe that installing taps on a network is no more a threat to privacy than having other wires carrying private customer traffic that might be viewed and/or collected. It is really a matter of whether the carrier collects private traffic, and hardware taps do not collect traffic, even when an intercept is being performed with proper filtering. So, what I am saying is this. We must collect our packets as close to the target of the legal action as possible. We must filter those packets for any which are not pertinent and drop those at the earliest convenience. We must *never* record those packets which are not pertinent on any permanent medium unless that is the only possible way to satisfy the legal requirement. Yes
[WISPA] Fw: [WISPA CALEA Questions] Trango and CALEA
- Original Message - From: Michael Erskine mic...@kaballero.com To: CALEA Questions caleaquesti...@wispa.org Sent: Friday, December 19, 2008 11:01 AM Subject: Re: [WISPA CALEA Questions] [WISPA] Trango and CALEA CALEA prevents even the WISP from over collecting. We are no longer permitted to tap any communications in our own networks except for the purposes of satisfying a subpoena, a Title 3, or CALEA action or for maintainance purposes. We are now, because of CALEA, under exactly the same intercept constraints as the telcos. Your tap may run in permissive mode; however, if you interpret the statue strictly, you have to filter at the tap in the software. Hence my concern that the vendors get WCS-IPNA implemented post haste. Other solutions are too pricey for the little guys. We need OpenCALEA yesterday. just my two. -m- Jesse Norell wrote: On Fri, 2008-12-19 at 08:32 -0700, Jesse Norell wrote: So as long as you offer the data they ask regardless of what you actually collect that is acceptable? Correct, you can over collect data, then you filter out just what you need and only give them that. And if you're following a standard like WCS-IPNA, you would make/record the checksums on only the data you present the LEA. I guess I'll qualify that permissibility to overcollect with the requirements of the standard you're following. Eg. the CableLabs CBIS does not allow it (see 5.1.6 Isolation). But (from memory) the CALEA law does not prohibit that approach; it does require that you be capable of 103(a)(4) facilitating .. interceptinos .. in a manner that protects (A) the privacy and security of communications and call-identifying information not authorized to be intercepted, hence the WCS-IPNA standard (and all others) don't allow you to present that overcollected data to the LEA(*). Jesse (*) there is a controversial nat-in-the-ap exemption in wcs-ipna that will expire soon that violates this point ___ CALEAquestions mailing list caleaquesti...@wispa.org http://lists.wispa.org/mailman/listinfo/caleaquestions WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] Fw: [WISPA CALEA Questions] Trango and CALEA
fyi marlon - Original Message - From: Michael J. Erskine mic...@kaballero.com To: CALEA Questions caleaquesti...@wispa.org Sent: Friday, December 19, 2008 6:10 PM Subject: Re: [WISPA CALEA Questions] [WISPA] Trango and CALEA Good evening everyone! Happy Christmas to all of you. It has been a long and profitable day. I found a problem I have been working for four months. Yeah! I have time now to try to explain what I intended to say. CALEA complicates these issues because it is an application of circuit switching law to a packet switched environment. It was never suited, or intended, to apply to packet switched networks, but the FCC/FBI found it convenient in these times to force that foot into that glass slipper. :) No law longer than one sentence will ever be followed to the letter in every instance. That is impossible. Still, judges believe that the letter of the law is what matters. I guess that is because you can not infer spirit without also inferring opinion as well. Reasonable enough. The law of intercept has been hashed about between NSA, the FBI, and the State Department for about a hundred and fifty years at this point and the rights of the citizens are fairly well defined. We were intercepting telegraph during the Civil War, WWI, and all manner of communications by WWII. The various court cases which arose from those intercepts helped to exercise the Constitution and The Bill of Rights and to define the limits to which citizens and government may act in the invasion of another person's privacy. That battle will continue to be waged forever. Never the less, the FCC's application of CALEA to packet switched networks actually substantiates protections in a packet switched world which were not previously applied. For this reason, CALEA is actually a good thing. CALEA protects our customers from *anyone* who would collect information from their communications streams without proper court approval. CALEA applies the protections which the TELCOs must observe to *all* IP carriers, whether they are end nodes or transport nodes in the packet switched network. This is a good thing, but problematic when we are forced to discuss the letter (and not the intent) of the law. The pertinent principles defined in CALEA, are Authentication, Validation, Isolation, Proportionality, and Completeness. When reading the WISPA-CS-IPNA 2.0 we see that the committee derived from the statute that we must collect the minimum information that will satisfy any legal requirement. This was not done to relieve the ISP of work, rather it was done to ensure the privacy of the user is the *first* concern in any intercept action. In an ideal world one would never even touch a packet that had nothing to do with the target of any legal requirement we might receive. The understanding that proceeds from the application of CALEA to packet switched networks from the circuit switched world is that the same privacy rights that exist in the circuit switched world exist in a packet switched world. In other words we are not allowed to let the probe touch any other circuit. When applying an intercept device, in an ideal world, it would isolate traffic by IP/MAC and completely ignore any other traffic. It would forward only the data packets which are associated with the target of the legal action that authorized the intercept. Sometimes that is possible, sometimes it is not. When it is not possible the physical TAP will likely forward all traffic to a storage system which will drop any packets that are not covered in the legal requirement establishing the intercept. So, what I am saying is this. We must collect our packets as close to the target of the legal action as possible. We must filter those packets for any which are not pertinent and drop those at the earliest convenience. We must *never* record those packets which are not pertinent on any permanent medium unless that is the only possible way to satisfy the legal requirement. WISPA-CS-IPNA defines the relationship between the WISP/ISP and the LEA. It does not define the relationship between the WISP/ISP and the customer; however, the law, CALEA, is based upon the existence of a set of rights and responsibilities which were established in a circuit switched world. If, in the process of satisfying a legal action, we violate those established principles, we can find ourselves in a legal quagmire like the one that ATT so recently stepped into. Just my two. J.C. Utter wrote: Everyone gets confused easily in this conversation because participants use the word tap to mean different things. I use passive tap to refer to real taps that you install on the line for out-of-band collection. However, many people in the industry think of a tap as a software collector. I don't use the word tap in refernce to software, but I think Mike was not talking about the kind of device we
Re: [WISPA] [WISPA CALEA Questions] Trango and CALEA
That would be my suggestion. That's radio vendor neutral. Jeff -Original Message- From: caleaquestions-boun...@wispa.org [mailto:caleaquestions-boun...@wispa.org] On Behalf Of Marlon K. Schafer Sent: Friday, December 19, 2008 9:21 AM To: WISPA General List Cc: caleaquesti...@wispa.org Subject: Re: [WISPA CALEA Questions] [WISPA] Trango and CALEA You'll just have to drop a tap in right behind the AP. If you have client to client allowed I have no idea how to help you. Anyone else have any ideas for Josh? (remember to hit reply all) marlon - Original Message - From: Josh Luthman j...@imaginenetworksllc.com To: WISPA General List wireless@wispa.org Sent: Wednesday, December 17, 2008 8:50 AM Subject: [WISPA] Trango and CALEA Has anyone got any ideas on how to use Trango's p2mp equipment and support CALEA? Josh Luthman Office: 937-552-2340 Direct: 937-552-2343 1100 Wayne St Suite 1337 Troy, OH 45373 Those who don't understand UNIX are condemned to reinvent it, poorly. --- Henry Spencer WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ ___ CALEAquestions mailing list caleaquesti...@wispa.org http://lists.wispa.org/mailman/listinfo/caleaquestions WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] Fw: [WISPA CALEA Questions] Trango and CALEA
Jesse is one of the main writers of the WISPA CALEA standard. marlon - Original Message - From: Jesse Norell je...@kci.net To: Josh Luthman j...@imaginenetworksllc.com Cc: CALEA Questions caleaquesti...@wispa.org Sent: Friday, December 19, 2008 7:32 AM Subject: Re: [WISPA CALEA Questions] [WISPA] Trango and CALEA On Fri, 2008-12-19 at 09:57 -0500, Josh Luthman wrote: So as long as you offer the data they ask regardless of what you actually collect that is acceptable? Correct, you can over collect data, then you filter out just what you need and only give them that. And if you're following a standard like WCS-IPNA, you would make/record the checksums on only the data you present the LEA. Josh Luthman Office: 937-552-2340 Direct: 937-552-2343 1100 Wayne St Suite 1337 Troy, OH 45373 Those who don't understand UNIX are condemned to reinvent it, poorly. --- Henry Spencer On Fri, Dec 19, 2008 at 9:53 AM, Jeff Broadwick jeffl...@comcast.net wrote: Not if you have a collector behind the tap. You can still filter out the traffic that you don't need for the warrant. Jeff -Original Message- From: wireless-boun...@wispa.org [mailto:wireless-boun...@wispa.org] On Behalf Of Josh Luthman Sent: Friday, December 19, 2008 9:50 AM To: WISPA General List Subject: Re: [WISPA] Trango and CALEA That was my only idea, however that includes data from other CPE radios which voids the rules of engagement :/ On 12/19/08, Jeff Broadwick jeffl...@comcast.net wrote: That would be my suggestion. That's radio vendor neutral. Jeff -Original Message- From: caleaquestions-boun...@wispa.org [mailto:caleaquestions-boun...@wispa.org] On Behalf Of Marlon K. Schafer Sent: Friday, December 19, 2008 9:21 AM To: WISPA General List Cc: caleaquesti...@wispa.org Subject: Re: [WISPA CALEA Questions] [WISPA] Trango and CALEA You'll just have to drop a tap in right behind the AP. If you have client to client allowed I have no idea how to help you. Anyone else have any ideas for Josh? (remember to hit reply all) marlon - Original Message - From: Josh Luthman j...@imaginenetworksllc.com To: WISPA General List wireless@wispa.org Sent: Wednesday, December 17, 2008 8:50 AM Subject: [WISPA] Trango and CALEA Has anyone got any ideas on how to use Trango's p2mp equipment and support CALEA? Josh Luthman Office: 937-552-2340 Direct: 937-552-2343 1100 Wayne St Suite 1337 Troy, OH 45373 Those who don't understand UNIX are condemned to reinvent it, poorly. --- Henry Spencer -- -- WISPA Wants You! Join today! http://signup.wispa.org/ -- -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ ___ CALEAquestions mailing list caleaquesti...@wispa.org http://lists.wispa.org/mailman/listinfo/caleaquestions -- -- WISPA Wants You! Join today! http://signup.wispa.org/ -- -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- Josh Luthman Office: 937-552-2340 Direct: 937-552-2343 1100 Wayne St Suite 1337 Troy, OH 45373 Those who don't understand UNIX are condemned to reinvent it, poorly. --- Henry Spencer WISPA Wants You! Join today! http://signup.wispa.org
[WISPA] Calea compliance contractors
Hi all- I'm just curious if anyone has a contact for someone that is a CALEA compliance contractor. Essentially we are looking for a third party that can verify compliance. Hit me offlist, please. Regards, -chris WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] Calea compliance contractors
Hi Chris, Butch would be a good place to start. I've also cc'd the rest of the WISPA calea team. Maybe there are people on there that do things I don't know about. laters, Marlon (509) 982-2181 (408) 907-6910 (Vonage)Consulting services 42846865 (icq)WISP Operator since 1999! [EMAIL PROTECTED] www.odessaoffice.com/wireless www.odessaoffice.com/marlon/cam - Original Message - From: Christopher Orr [EMAIL PROTECTED] To: wireless@wispa.org Sent: Tuesday, November 25, 2008 9:42 AM Subject: [WISPA] Calea compliance contractors Hi all- I'm just curious if anyone has a contact for someone that is a CALEA compliance contractor. Essentially we are looking for a third party that can verify compliance. Hit me offlist, please. Regards, -chris WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA
The info in this post about being paid for this service is important to us smaller WISPs. This means that we CAN invest some small amount in equipment, just as we would deploy an AP to gain customers. Then, over time, we charge for the intercepts we receive and eventually can recover the expense. We can look at this as a marketable service to law enforcement. Thinking on the extreme hillarious side of it, we can even make our LEAs aware that we HAVE this capability. Message to all LEAs: We are here and ready, so think of using this method of law enforcement more often than not. Send us your subpoenas...we are not afraid...along with your billing address, of course. ;) PEOPLE THIS IS MEANT TO BE FUNNY, OK??? Mark Nash UnwiredOnline.Net 350 Holly Street Junction City, OR 97448 http://www.uwol.net 541-998- 541-998-5599 fax - Original Message - From: Butch Evans [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Friday, November 30, 2007 8:32 AM Subject: RE: [WISPA] CALEA On Fri, 30 Nov 2007, Jeff Broadwick wrote: 1. The ISP will know a actual intercept subpoena is coming before they receive it. Actually, in a couple of cases, this was true. In the others, the subpoena came without any notice. 3. The LEA would like the ISP to have all the CALEA I's dotted and T's crossed, but are willing to work with a cooperative provider. This is the main point of the post I made. They are willing to work with us, because we have something they need. Can you verify that they ISPs got their direct expenses back from the LEAs? That would be valuable information to have! I do know in one case, the ISP did get paid. He only billed the LEA for my fees, plus some other small expense, though I don't recall what it was for. If I recall correctly, the total bill was about $800. I was told by a law enforcement agent that Verizon charges something like $1250 + some amount per day for each tap. I don't recall the actual fees, but it was close to that amount. I DO believe that the LEAs will become more technically aware over time. I also believe that they will be less forgiving of providers who do not have a CALEA plan over time. This is still new to both law enforcement and WISPs. I agree that over time, those that are not capable of providing the information will begin to see themselves in trouble. -- Butch Evans Network Engineering and Security Consulting 573-276-2879 http://www.butchevans.com/ My calendar: http://tinyurl.com/y24ad6 Training Partners: http://tinyurl.com/smfkf Mikrotik Certified Consultant http://www.mikrotik.com/consultants.html -- -- WISPA Wants You! Join today! http://signup.wispa.org/ -- -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA
On Fri, 30 Nov 2007, Frank Muto wrote: I have a question though you may or may be able to answer it. In point 1, you said you gave the LEA information on how to word their subpoena? Was this knowledge based on an attorneys consult? I'll assume it may have been unless you are an attorney yourself. Perhaps I worded that incorrectly. What they asked for in the first subpoena was not technically possible to provide because they asked about a NAT address and they cannot allow us to provide them a list of 200 names. I simply explained to him how we could go about limiting the information and he got the appropriate subpoenas worded in a way that allowed us to gather the information he needed. From a procedural standpoint, it would have been much easier if he had let us help him understand that in the first place before he got the first subpoena, which was useless. Secondly, why would an attorney or anyone provide legal consult to the LEA? The DOJ has all the required information any LEA needs to obtain the information they need in an investigation. Most of it is basically fill in the blank and the forms have multiple QA to write up the subpoena. My consultation with them was not legal in natureit was technical. Either way, I specifically recommended that my customers seek legal council regarding the information they are providing the LEA. I don't know if they did that, but I did recommend that. Having gone through enough of this over the past couple years, I have doubts that helping an LEA is in your best interest. How do you warrant or have legal standing on telling an LEA that their subpoena does not have the correct information for the request? They asked for something that was not technically possible to provide. It is that simple. We could have given them the names of 200+ people, but that would not help them, and could have hurt their case. Whether it is CALEA or some other statute that the subpoena is based on, we, as citizens, have a duty to provide the information they are requesting under the law. I don't want to rehash this whole idea of whether it is in our best interest or not. The law is the law. It is up to the LEA to get the proper legal consult they need when writing up a subpoena and or warrant to present to the court. Not just legal consult, but technical. I don't mind if they get the technical part from me...it's what I do for a living. ;-) -- Butch Evans Network Engineering and Security Consulting 573-276-2879 http://www.butchevans.com/ My calendar: http://tinyurl.com/y24ad6 Training Partners: http://tinyurl.com/smfkf Mikrotik Certified Consultant http://www.mikrotik.com/consultants.html WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
RE: [WISPA] CALEA
On Fri, 30 Nov 2007, Jeff Broadwick wrote: 1. The ISP will know a actual intercept subpoena is coming before they receive it. Actually, in a couple of cases, this was true. In the others, the subpoena came without any notice. 3. The LEA would like the ISP to have all the CALEA I's dotted and T's crossed, but are willing to work with a cooperative provider. This is the main point of the post I made. They are willing to work with us, because we have something they need. Can you verify that they ISPs got their direct expenses back from the LEAs? That would be valuable information to have! I do know in one case, the ISP did get paid. He only billed the LEA for my fees, plus some other small expense, though I don't recall what it was for. If I recall correctly, the total bill was about $800. I was told by a law enforcement agent that Verizon charges something like $1250 + some amount per day for each tap. I don't recall the actual fees, but it was close to that amount. I DO believe that the LEAs will become more technically aware over time. I also believe that they will be less forgiving of providers who do not have a CALEA plan over time. This is still new to both law enforcement and WISPs. I agree that over time, those that are not capable of providing the information will begin to see themselves in trouble. -- Butch Evans Network Engineering and Security Consulting 573-276-2879 http://www.butchevans.com/ My calendar: http://tinyurl.com/y24ad6 Training Partners: http://tinyurl.com/smfkf Mikrotik Certified Consultant http://www.mikrotik.com/consultants.html WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
RE: [WISPA] CALEA
Comments Below... -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Frank Muto Sent: Friday, November 30, 2007 8:37 AM To: WISPA General List Subject: Re: [WISPA] CALEA I have a question though you may or may be able to answer it. In point 1, you said you gave the LEA information on how to word their subpoena? Was this knowledge based on an attorneys consult? I'll assume it may have been unless you are an attorney yourself. Secondly, why would an attorney or anyone provide legal consult to the LEA? The DOJ has all the required information any LEA needs to obtain the information they need in an investigation. Most of it is basically fill in the blank and the forms have multiple QA to write up the subpoena. Having gone through enough of this over the past couple years, I have doubts that helping an LEA is in your best interest. How do you warrant or have legal standing on telling an LEA that their subpoena does not have the correct information for the request? It is up to the LEA to get the proper legal consult they need when writing up a subpoena and or warrant to present to the court. - Comments -- If I am not mistaken, when you are being asked to provide information in a legal matter in which you are not a named-party in the legal action, you are being placed in the position of a witness. If a witness divulges information which proves to be harmful to one of the parties in the action AND if the information which is divulged is NOT protected as being required under subpoena, then the witness could potential open themselves up for a civil lawsuit with claims of libel, slander, defamation, wrongful interference, etc. So, it is NOT uncommon or unwise for a witness to seek legal counsel before disclosing information under a subpoena. I don't know if a witness' lawyer could coach the requesting party in the wording of the subpoena. On the other hand, I'm quite certain that IF a witness felt that the information that they held was pertinent and the witness wanted clarification on whether they could divulge the information under the subpoena, they could request a hearing before the judge in the pending matter. The judge could do an in-camera review to determine what stays and what goes. Then it's up to the judge to tell the requesting party if and to what extent their subpoena needs to be modified. Larry Yunker Network Consultant Law Student [EMAIL PROTECTED] Disclaimer: The information contained in this message is not to be considered legal advice. I am not a lawyer (yet) and therefore I am not in a position to provide legal advice. WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
RE: [WISPA] CALEA
On Fri, 30 Nov 2007, Larry Yunker wrote: If I am not mistaken, when you are being asked to provide information in a legal matter in which you are not a named-party in the legal action, you are being placed in the position of a witness. Exactly. This is where the duty that I mentioned in my response to Frank comes from. If we have information regarding illegal behaviour, we should provide that information to law enforcement. I'm gonna stop now with this line of thinking...it leads down a long dark road. :-) So, it is NOT uncommon or unwise for a witness to seek legal counsel before disclosing information under a subpoena. I don't know if a witness' lawyer As I said to Frank, my first recommendation to those WISPs who called for assistance was to talk to their attorney to let them handle the legal part of it. I am just being hired to handle the technical parts and am not qualified to provide legal advice. -- Butch Evans Network Engineering and Security Consulting 573-276-2879 http://www.butchevans.com/ My calendar: http://tinyurl.com/y24ad6 Training Partners: http://tinyurl.com/smfkf Mikrotik Certified Consultant http://www.mikrotik.com/consultants.html WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
RE: [WISPA] CALEA
According to the FBI, they have no interest in receiving real-time streamed data, despite the requirement in the standard. They want capture and send/retrieve. Our understanding is that the FBI will challenge that part of the standard once the WISPA Standard is ratified. That will give them the alternative they have been looking for. We are very close to sending the WISPA Standard to the FBI. They have been part of the process all along, so ratification should not be a major task. Jeff -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Jeromie Reeves Sent: Friday, November 30, 2007 8:33 AM To: WISPA General List Subject: Re: [WISPA] CALEA It looks like the FCC making us be CALEA compliant was a total waste of time effort (on both parties sides) and only made a atmosphere of fear. It also sounds like while they filed for information that has classically been available pre-calea, has anyone had to comply with the real time streaming section or the remote data logging and can share the experience? On 11/30/07, Butch Evans [EMAIL PROTECTED] wrote: I just wanted to make a brief post relating a few experiences relating to the CALEA scare that was recently the talk of the town (so to speak). I should preface this post with a bit of information that will give some insight into how common (or not) law enforcement will or will not use CALEA to get information from you/us. I have about 225 customers in my database. I work on a regular basis for about 15-20 of those each week. Since April, I have worked 4 cases with my customers (actually, it was 6, but 3 were related) that were filed as CALEA actions. Of these cases, 3 of my customers were using Mikrotik and 1 was using ImageStream. I can't reveal anything related to the cases, but I wanted to help people understand what kind of information we are being asked for under CALEA, and what that translates to in terms of capability requirements. 1. The first subpeona wanted to know who had a specific IP at a certain time and date. That was all that was requested. This particular WISP has about 450 customers, and about 225 of those are using private IPs that are natted at the border. It so happened that the IP we were requested information about was the NAT IP. I called the officer who had requested the data and explained the situation to him. After an hour or so, he understood that there is nothing we could do without more information. The case was an ongoing thing, and he was tracking contact to a specific website, so we were able to determine a specific customer who was using that website. We did not tell the officer who it was, but we DID explain how he needed to word his subpoena so that we COULD get him what he wanted. After he got the legal jargon to match the technical requirements of our capabilities, we were able to capture and provide him with the communications he was needing. 2. The next 3 were related to one another (sort of). In this case, the subpeona asked for customer billing records and login information for the past year for 3 IP addresses. We had part of this information (this WISP used public IP addresses for all his customers). Since the subpeona requested historical information, we were somewhat limited in what we could provide, but we did get the required information and LEA was happy. 3. The other 2 were not related but were similar. They asked for telephone information that the targets made between a couple of dates in the past. Since the WISPs in both cases were not the provider of the VoIP (they were just the transport) service, we explained to the LEA that the information they are seeking would not be available at the WISP, eventually they went elsewhere for their information (I guess), but the WISPs, in the end, did not provide ANY customer data to the LEA. The point I am making here is that all of the information requested in all 3 cases, was easily obtainable using equipment available within the WISP networks already. We used information that the Mikrotik and/or Imagestream enabled us to gather, log files and RADIUS logs to gather login information and capturing of data along with their business records to answer all 6 subpeonas (7 if you count the one that had to be re-done). In all cases, the law enforcement officer who was our first contact was not technically capable of understanding what they wanted/needed, but without fail, there WERE people at the agencies involved who were. Of these subpeonas, 3 were from the FBI, 2 were local LE and 1 was homeland security. Incidentally, none of these WISPs spent any extra money to be compliant (other than some legal work that had to be done). Billing for my time cost less than $350 (much less in some cases) to help gather necessary information. All of these (I think) ended up billing these costs
Re: [WISPA] CALEA
I have a question though you may or may be able to answer it. In point 1, you said you gave the LEA information on how to word their subpoena? Was this knowledge based on an attorneys consult? I'll assume it may have been unless you are an attorney yourself. Secondly, why would an attorney or anyone provide legal consult to the LEA? The DOJ has all the required information any LEA needs to obtain the information they need in an investigation. Most of it is basically fill in the blank and the forms have multiple QA to write up the subpoena. Having gone through enough of this over the past couple years, I have doubts that helping an LEA is in your best interest. How do you warrant or have legal standing on telling an LEA that their subpoena does not have the correct information for the request? It is up to the LEA to get the proper legal consult they need when writing up a subpoena and or warrant to present to the court. Frank Muto President FSM Marketing Group, Inc - Original Message - From: Butch Evans [EMAIL PROTECTED] To: Wispa List wireless@wispa.org Sent: Friday, November 30, 2007 3:57 AM Subject: [WISPA] CALEA I just wanted to make a brief post relating a few experiences relating to the CALEA scare that was recently the talk of the town (so to speak). I should preface this post with a bit of information that will give some insight into how common (or not) law enforcement will or will not use CALEA to get information from you/us. I have about 225 customers in my database. I work on a regular basis for about 15-20 of those each week. Since April, I have worked 4 cases with my customers (actually, it was 6, but 3 were related) that were filed as CALEA actions. Of these cases, 3 of my customers were using Mikrotik and 1 was using ImageStream. I can't reveal anything related to the cases, but I wanted to help people understand what kind of information we are being asked for under CALEA, and what that translates to in terms of capability requirements. 1. The first subpeona wanted to know who had a specific IP at a certain time and date. That was all that was requested. This particular WISP has about 450 customers, and about 225 of those are using private IPs that are natted at the border. It so happened that the IP we were requested information about was the NAT IP. I called the officer who had requested the data and explained the situation to him. After an hour or so, he understood that there is nothing we could do without more information. The case was an ongoing thing, and he was tracking contact to a specific website, so we were able to determine a specific customer who was using that website. We did not tell the officer who it was, but we DID explain how he needed to word his subpoena so that we COULD get him what he wanted. After he got the legal jargon to match the technical requirements of our capabilities, we were able to capture and provide him with the communications he was needing. 2. The next 3 were related to one another (sort of). In this case, the subpeona asked for customer billing records and login information for the past year for 3 IP addresses. We had part of this information (this WISP used public IP addresses for all his customers). Since the subpeona requested historical information, we were somewhat limited in what we could provide, but we did get the required information and LEA was happy. 3. The other 2 were not related but were similar. They asked for telephone information that the targets made between a couple of dates in the past. Since the WISPs in both cases were not the provider of the VoIP (they were just the transport) service, we explained to the LEA that the information they are seeking would not be available at the WISP, eventually they went elsewhere for their information (I guess), but the WISPs, in the end, did not provide ANY customer data to the LEA. The point I am making here is that all of the information requested in all 3 cases, was easily obtainable using equipment available within the WISP networks already. We used information that the Mikrotik and/or Imagestream enabled us to gather, log files and RADIUS logs to gather login information and capturing of data along with their business records to answer all 6 subpeonas (7 if you count the one that had to be re-done). In all cases, the law enforcement officer who was our first contact was not technically capable of understanding what they wanted/needed, but without fail, there WERE people at the agencies involved who were. Of these subpeonas, 3 were from the FBI, 2 were local LE and 1 was homeland security. Incidentally, none of these WISPs spent any extra money to be compliant (other than some legal work that had to be done). Billing for my time cost less than $350 (much less in some cases) to help gather necessary information. All of these (I think) ended up billing these costs to the LEA and as far as I know
RE: [WISPA] CALEA
Thanks for posting this Butch! It illustrates a number of things that I've believed from early on: 1. The ISP will know a actual intercept subpoena is coming before they receive it. 2. The LEA staff requesting the subpoena are generally less technically savvy than most service providers. 3. The LEA would like the ISP to have all the CALEA I's dotted and T's crossed, but are willing to work with a cooperative provider. Can you verify that they ISPs got their direct expenses back from the LEAs? That would be valuable information to have! I DO believe that the LEAs will become more technically aware over time. I also believe that they will be less forgiving of providers who do not have a CALEA plan over time. Regards, Jeff -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Butch Evans Sent: Friday, November 30, 2007 3:57 AM To: Wispa List Subject: [WISPA] CALEA I just wanted to make a brief post relating a few experiences relating to the CALEA scare that was recently the talk of the town (so to speak). I should preface this post with a bit of information that will give some insight into how common (or not) law enforcement will or will not use CALEA to get information from you/us. I have about 225 customers in my database. I work on a regular basis for about 15-20 of those each week. Since April, I have worked 4 cases with my customers (actually, it was 6, but 3 were related) that were filed as CALEA actions. Of these cases, 3 of my customers were using Mikrotik and 1 was using ImageStream. I can't reveal anything related to the cases, but I wanted to help people understand what kind of information we are being asked for under CALEA, and what that translates to in terms of capability requirements. 1. The first subpeona wanted to know who had a specific IP at a certain time and date. That was all that was requested. This particular WISP has about 450 customers, and about 225 of those are using private IPs that are natted at the border. It so happened that the IP we were requested information about was the NAT IP. I called the officer who had requested the data and explained the situation to him. After an hour or so, he understood that there is nothing we could do without more information. The case was an ongoing thing, and he was tracking contact to a specific website, so we were able to determine a specific customer who was using that website. We did not tell the officer who it was, but we DID explain how he needed to word his subpoena so that we COULD get him what he wanted. After he got the legal jargon to match the technical requirements of our capabilities, we were able to capture and provide him with the communications he was needing. 2. The next 3 were related to one another (sort of). In this case, the subpeona asked for customer billing records and login information for the past year for 3 IP addresses. We had part of this information (this WISP used public IP addresses for all his customers). Since the subpeona requested historical information, we were somewhat limited in what we could provide, but we did get the required information and LEA was happy. 3. The other 2 were not related but were similar. They asked for telephone information that the targets made between a couple of dates in the past. Since the WISPs in both cases were not the provider of the VoIP (they were just the transport) service, we explained to the LEA that the information they are seeking would not be available at the WISP, eventually they went elsewhere for their information (I guess), but the WISPs, in the end, did not provide ANY customer data to the LEA. The point I am making here is that all of the information requested in all 3 cases, was easily obtainable using equipment available within the WISP networks already. We used information that the Mikrotik and/or Imagestream enabled us to gather, log files and RADIUS logs to gather login information and capturing of data along with their business records to answer all 6 subpeonas (7 if you count the one that had to be re-done). In all cases, the law enforcement officer who was our first contact was not technically capable of understanding what they wanted/needed, but without fail, there WERE people at the agencies involved who were. Of these subpeonas, 3 were from the FBI, 2 were local LE and 1 was homeland security. Incidentally, none of these WISPs spent any extra money to be compliant (other than some legal work that had to be done). Billing for my time cost less than $350 (much less in some cases) to help gather necessary information. All of these (I think) ended up billing these costs to the LEA and as far as I know, they got their direct expenses back. I got another call today to assist with a subpoena and it got me thinking about the others. I just thought this information may be useful/educational to some on this list. -- Butch Evans Network Engineering and Security Consulting 573-276
[WISPA] CALEA
I just wanted to make a brief post relating a few experiences relating to the CALEA scare that was recently the talk of the town (so to speak). I should preface this post with a bit of information that will give some insight into how common (or not) law enforcement will or will not use CALEA to get information from you/us. I have about 225 customers in my database. I work on a regular basis for about 15-20 of those each week. Since April, I have worked 4 cases with my customers (actually, it was 6, but 3 were related) that were filed as CALEA actions. Of these cases, 3 of my customers were using Mikrotik and 1 was using ImageStream. I can't reveal anything related to the cases, but I wanted to help people understand what kind of information we are being asked for under CALEA, and what that translates to in terms of capability requirements. 1. The first subpeona wanted to know who had a specific IP at a certain time and date. That was all that was requested. This particular WISP has about 450 customers, and about 225 of those are using private IPs that are natted at the border. It so happened that the IP we were requested information about was the NAT IP. I called the officer who had requested the data and explained the situation to him. After an hour or so, he understood that there is nothing we could do without more information. The case was an ongoing thing, and he was tracking contact to a specific website, so we were able to determine a specific customer who was using that website. We did not tell the officer who it was, but we DID explain how he needed to word his subpoena so that we COULD get him what he wanted. After he got the legal jargon to match the technical requirements of our capabilities, we were able to capture and provide him with the communications he was needing. 2. The next 3 were related to one another (sort of). In this case, the subpeona asked for customer billing records and login information for the past year for 3 IP addresses. We had part of this information (this WISP used public IP addresses for all his customers). Since the subpeona requested historical information, we were somewhat limited in what we could provide, but we did get the required information and LEA was happy. 3. The other 2 were not related but were similar. They asked for telephone information that the targets made between a couple of dates in the past. Since the WISPs in both cases were not the provider of the VoIP (they were just the transport) service, we explained to the LEA that the information they are seeking would not be available at the WISP, eventually they went elsewhere for their information (I guess), but the WISPs, in the end, did not provide ANY customer data to the LEA. The point I am making here is that all of the information requested in all 3 cases, was easily obtainable using equipment available within the WISP networks already. We used information that the Mikrotik and/or Imagestream enabled us to gather, log files and RADIUS logs to gather login information and capturing of data along with their business records to answer all 6 subpeonas (7 if you count the one that had to be re-done). In all cases, the law enforcement officer who was our first contact was not technically capable of understanding what they wanted/needed, but without fail, there WERE people at the agencies involved who were. Of these subpeonas, 3 were from the FBI, 2 were local LE and 1 was homeland security. Incidentally, none of these WISPs spent any extra money to be compliant (other than some legal work that had to be done). Billing for my time cost less than $350 (much less in some cases) to help gather necessary information. All of these (I think) ended up billing these costs to the LEA and as far as I know, they got their direct expenses back. I got another call today to assist with a subpoena and it got me thinking about the others. I just thought this information may be useful/educational to some on this list. -- Butch Evans Network Engineering and Security Consulting 573-276-2879 http://www.butchevans.com/ My calendar: http://tinyurl.com/y24ad6 Training Partners: http://tinyurl.com/smfkf Mikrotik Certified Consultant http://www.mikrotik.com/consultants.html WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA
It looks like the FCC making us be CALEA compliant was a total waste of time effort (on both parties sides) and only made a atmosphere of fear. It also sounds like while they filed for information that has classically been available pre-calea, has anyone had to comply with the real time streaming section or the remote data logging and can share the experience? On 11/30/07, Butch Evans [EMAIL PROTECTED] wrote: I just wanted to make a brief post relating a few experiences relating to the CALEA scare that was recently the talk of the town (so to speak). I should preface this post with a bit of information that will give some insight into how common (or not) law enforcement will or will not use CALEA to get information from you/us. I have about 225 customers in my database. I work on a regular basis for about 15-20 of those each week. Since April, I have worked 4 cases with my customers (actually, it was 6, but 3 were related) that were filed as CALEA actions. Of these cases, 3 of my customers were using Mikrotik and 1 was using ImageStream. I can't reveal anything related to the cases, but I wanted to help people understand what kind of information we are being asked for under CALEA, and what that translates to in terms of capability requirements. 1. The first subpeona wanted to know who had a specific IP at a certain time and date. That was all that was requested. This particular WISP has about 450 customers, and about 225 of those are using private IPs that are natted at the border. It so happened that the IP we were requested information about was the NAT IP. I called the officer who had requested the data and explained the situation to him. After an hour or so, he understood that there is nothing we could do without more information. The case was an ongoing thing, and he was tracking contact to a specific website, so we were able to determine a specific customer who was using that website. We did not tell the officer who it was, but we DID explain how he needed to word his subpoena so that we COULD get him what he wanted. After he got the legal jargon to match the technical requirements of our capabilities, we were able to capture and provide him with the communications he was needing. 2. The next 3 were related to one another (sort of). In this case, the subpeona asked for customer billing records and login information for the past year for 3 IP addresses. We had part of this information (this WISP used public IP addresses for all his customers). Since the subpeona requested historical information, we were somewhat limited in what we could provide, but we did get the required information and LEA was happy. 3. The other 2 were not related but were similar. They asked for telephone information that the targets made between a couple of dates in the past. Since the WISPs in both cases were not the provider of the VoIP (they were just the transport) service, we explained to the LEA that the information they are seeking would not be available at the WISP, eventually they went elsewhere for their information (I guess), but the WISPs, in the end, did not provide ANY customer data to the LEA. The point I am making here is that all of the information requested in all 3 cases, was easily obtainable using equipment available within the WISP networks already. We used information that the Mikrotik and/or Imagestream enabled us to gather, log files and RADIUS logs to gather login information and capturing of data along with their business records to answer all 6 subpeonas (7 if you count the one that had to be re-done). In all cases, the law enforcement officer who was our first contact was not technically capable of understanding what they wanted/needed, but without fail, there WERE people at the agencies involved who were. Of these subpeonas, 3 were from the FBI, 2 were local LE and 1 was homeland security. Incidentally, none of these WISPs spent any extra money to be compliant (other than some legal work that had to be done). Billing for my time cost less than $350 (much less in some cases) to help gather necessary information. All of these (I think) ended up billing these costs to the LEA and as far as I know, they got their direct expenses back. I got another call today to assist with a subpoena and it got me thinking about the others. I just thought this information may be useful/educational to some on this list. -- Butch Evans Network Engineering and Security Consulting 573-276-2879 http://www.butchevans.com/ My calendar: http://tinyurl.com/y24ad6 Training Partners: http://tinyurl.com/smfkf Mikrotik Certified Consultant http://www.mikrotik.com/consultants.html WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List:
RE: [WISPA] CALEA (recovering costs) ???
In theory, you should be able to bill the government for your time/costs incurred for THE INTERCEPT, not any recurring or upfront charges. In theory... -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Dylan Bouterse Sent: Monday, October 29, 2007 1:33 PM To: WISPA General List Subject: [WISPA] CALEA (recovering costs) ??? I guess from the lack of response nobody is compensating for their CALEA costs?...or maybe my email didn't make it to the list? Dylan -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Dylan Bouterse Sent: Friday, October 26, 2007 5:25 PM To: WISPA General List Subject: [WISPA] CALEA (recovering costs) It was mentioned back during the CALEA hype that some had considered or did add a CALEA fee on their Internet Service bills. I'm curious if this was done and if it was successful (without upsetting customers or creating too many billing inquiries). Feel free to reply off list if you don't want to advertise your response to the general list. Dylan WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] CALEA (recovering costs) ???
I guess from the lack of response nobody is compensating for their CALEA costs?...or maybe my email didn't make it to the list? Dylan -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Dylan Bouterse Sent: Friday, October 26, 2007 5:25 PM To: WISPA General List Subject: [WISPA] CALEA (recovering costs) It was mentioned back during the CALEA hype that some had considered or did add a CALEA fee on their Internet Service bills. I'm curious if this was done and if it was successful (without upsetting customers or creating too many billing inquiries). Feel free to reply off list if you don't want to advertise your response to the general list. Dylan WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA (recovering costs) ???
Hi Dylan, I am not compensating for this. I am not sure that customers would be appreciative or understand. Also, the costs that you are referring to could possibly happen only when you are given a subpoenaed unless you are paying a monthly fee for a product you bought from a vendor. Martha Dylan Bouterse wrote: I guess from the lack of response nobody is compensating for their CALEA costs?...or maybe my email didn't make it to the list? Dylan -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Dylan Bouterse Sent: Friday, October 26, 2007 5:25 PM To: WISPA General List Subject: [WISPA] CALEA (recovering costs) It was mentioned back during the CALEA hype that some had considered or did add a CALEA fee on their Internet Service bills. I'm curious if this was done and if it was successful (without upsetting customers or creating too many billing inquiries). Feel free to reply off list if you don't want to advertise your response to the general list. Dylan WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA (recovering costs) ???
I understood from a vendor who was looking to sell me a calea solution that they would bill us for the cost of each intercept, etc, but not expect us to pay them until we get re-reimbursed by the government. Light bulb went off. Jeff Broadwick wrote: In theory, you should be able to bill the government for your time/costs incurred for THE INTERCEPT, not any recurring or upfront charges. In theory... -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Dylan Bouterse Sent: Monday, October 29, 2007 1:33 PM To: WISPA General List Subject: [WISPA] CALEA (recovering costs) ??? I guess from the lack of response nobody is compensating for their CALEA costs?...or maybe my email didn't make it to the list? Dylan -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Dylan Bouterse Sent: Friday, October 26, 2007 5:25 PM To: WISPA General List Subject: [WISPA] CALEA (recovering costs) It was mentioned back during the CALEA hype that some had considered or did add a CALEA fee on their Internet Service bills. I'm curious if this was done and if it was successful (without upsetting customers or creating too many billing inquiries). Feel free to reply off list if you don't want to advertise your response to the general list. Dylan WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- George Rogato Welcome to WISPA www.wispa.org http://signup.wispa.org/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
RE: [WISPA] CALEA (recovering costs) ???
One more question- I need 100Meg Ethernet (copper)as well- can you add a card for that or is there a combo that will do 10/100/1000 copper? MArfty -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Martha Huizenga Sent: Monday, October 29, 2007 1:32 PM To: WISPA General List Subject: Re: [WISPA] CALEA (recovering costs) ??? Hi Dylan, I am not compensating for this. I am not sure that customers would be appreciative or understand. Also, the costs that you are referring to could possibly happen only when you are given a subpoenaed unless you are paying a monthly fee for a product you bought from a vendor. Martha Dylan Bouterse wrote: I guess from the lack of response nobody is compensating for their CALEA costs?...or maybe my email didn't make it to the list? Dylan -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of Dylan Bouterse Sent: Friday, October 26, 2007 5:25 PM To: WISPA General List Subject: [WISPA] CALEA (recovering costs) It was mentioned back during the CALEA hype that some had considered or did add a CALEA fee on their Internet Service bills. I'm curious if this was done and if it was successful (without upsetting customers or creating too many billing inquiries). Feel free to reply off list if you don't want to advertise your response to the general list. Dylan -- -- WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] CALEA (recovering costs)
It was mentioned back during the CALEA hype that some had considered or did add a CALEA fee on their Internet Service bills. I'm curious if this was done and if it was successful (without upsetting customers or creating too many billing inquiries). Feel free to reply off list if you don't want to advertise your response to the general list. Dylan ** Join us at the WISPA Reception at 6:30 PM on October the 16th 2007 at ISPCON ** ** ISPCON Fall 2007 - October 16-18 - San Jose, CA www.ispcon.com ** ** THE INTERNET INDUSTRY EVENT ** ** FREE Exhibits and Events Pass available until August 31 ** ** Use Customer Code WSEMF7 when you register online at http://www.ispcon.com/register.php ** WISPA Wants You! Join today! http://signup.wispa.org/ WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] CALEA FCC Comments
PLEADING CYCLE EXTENDED IN THE MATTER OF PETITION FOR EXPEDITED RULEMAKING TO ESTABLISH TECHNICAL REQUIREMENTS AND STANDARDS PURSUANT TO SECTION 107(b) OF THE COMMUNICATIONS ASSISTANCE FOR LAW ENFORCEMENT ACT (CALEA) RM-11376 http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-07-2522A1.pdf Comments Due: July 25, 2007 Reply Comments Due: September 25, 2007 On May 15, 2007, the United States Department of Justice, the Federal Bureau of Investigation, and the Drug Enforcement Administration (“Petitioners”) filed a “Petition for Expedited Rulemaking” requesting the Commission to initiate a proceeding to find that the J-STD-025-B standard published jointly by the Telecommunication Industry Association and the Alliance for Telecommunications, is deficient pursuant to Section 107(b) of the Communications Assistance for Law Enforcement Act (“CALEA”), 47 U.S.C. 1006(b).1 Petitioners specifically contend that four additional or modified intercept capabilities must be included in the J-STD-025-B with respect to CDMA2000 packet data wireless services, pursuant to the requirements of CALEA Section 103(a), 47 U.S.C. § 1002(a). These capabilities are: packet activity reporting; provision of more granular mobile handset location information at the beginning and end of a communication; service quality, including security, performance and reliability requirements; and timing information (time stamping). Petitioners ask the Commission to mandate these capabilities, adopt appropriate rules, and order telecommunications carriers to provide the capabilities within twelve months after the effective date of a final Commission order. Petitioner’s CALEA Section 107(b) filing requires the Commission to undertake a detailed analysis of complex technical and legal issues associated with each of the four intercept capabilities identified in the petition. Although the Commission appreciates the need to move quickly to address the petition, it is essential that commenters have the opportunity to develop a full and detailed record for the Commission’s consideration. Accordingly, on its own motion and pursuant to delegated authority, the Public Safety and Homeland Security Bureau hereby extends the comment and reply comment filing dates in the above-referenced matter as follows: interested parties may file comments on or before July 25, 2007 and reply comments on or before September 25, 2007. See 47 U.S.C. § 154(i); 47 C.F.R. §§ 0.191, and 0.392. The Commission expects that all parties will fully utilize this opportunity to carefully and completely address in their filed comments all relevant issues. The Commission reiterates, however, its desire to expeditiously address Petitioners’ request. No additional extensions of comment and reply comment dates should be expected.2 All comment and reply comment filings should refer to RM-11376. -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] CALEA solutions.
Hi All, The CALEA committee is currently working on a number of possible CALEA solutions for you guys. These won't be a WISPA standard but should do the trick for you if you do get called upon before we can get a standard written. As I get these from the folks we're working with (all solutions will be either from or looked over by the CALEA committee members, no endorsements etc. blah blah blah though) on the committee I'll get them added to the WISPA CALEA page so you can easily find them again. Here's the first one I've gotten back from a committee member. Yeah, I know this only talks about one companies solution, I'll add more as I get them. Also, in light of the recent self promotion thread please direct all issues to me directly. It's MY decision to publicize the solutions that our committee members prefer. ImageStream recently released new software for its routers that can be used to perform CALEA intercepts with or without a TTP. The current ImageStream Linux distribution supports direct LEA delivery with fan-out to multiple collectors using the ATIS LAES intercept delivery protocol, which provides a safe harbor for intercept compliance. This solution also includes a collector module, which can be run on a standard Linux server to support local capture-to-disk. In the coming weeks, ImageStream plans to release a new product called Intercept Manager, which will provision intercepts remotely to comply with the CALEA confidentiality requirements that affect most midsize and large carriers. Intercept Manager will also be available with a hard drive to support capture-to-disk for those who prefer not build their own Linux systems. ImageStream routers support WAN and LAN interfaces from T1 through OC12, and ethernet over copper and fiber. Prices for the entry-level Envoy router start at $499. WISPs who already use ImageStream routers can simply upgrade to the latest ImageStream Linux distribution, which includes the tools required to perform CALEA intercepts. As an alternative to buying new production routers, WISPs may use ImageStream taps to passively tap LAN or WAN links for CALEA intercepts with legacy equipment. An ImageStream router is connected to the tap and acts as an out-of-band probe for intercept filtering and delivery. A tap and probe solution like this for a single 10/100 ethernet segment lists for under $1,300 including a year of technical support and warranty. ImageStream is also offering an intensive 1-day training seminar on its CALEA solutions, to be held concurrently with ICNA certification in Orlando, Florida on June 18th, 2007. If you have any questions about CALEA compliance solutions, please contact ImageStream at (800) 813-5123 x106 or e-mail [EMAIL PROTECTED] Jeff Broadwick Sales Manager, ImageStream 800-813-5123 x106 (US/Can) +1 574-935-8484 x106 (Int'l) +1 574-935-8488 (Fax) Hope this helps some folks out. Marlon (509) 982-2181 (408) 907-6910 (Vonage)Consulting services 42846865 (icq)WISP Operator since 1999! [EMAIL PROTECTED] www.odessaoffice.com/wireless www.odessaoffice.com/marlon/cam -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] What is WISPA? (CALEA timeline)
Sam Tetherow wrote: I don't want to drag this topic up again, BUT ;) Two years ago, did this apply to ISPs or just VOIP providers? I don't remember anyone on the lists talking about CALEA being for anything other than VOICE in various forms, but maybe my memory is selective, wouldn't be the first and probably won't be the last time. On March 10, 2004, DOJ filed a petition asking the Commission to declare that broadband Internet access services and VoIP services are covered by CALEA. It was a part of the original order: Adopted: August 5, 2005 Released: September 23, 2005 In May 2006, the second order was released answering specific questions. - Peter -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] CALEA FAQ Questions
Marlon, I have been reading the WISPA CALEA FAQ and was a little concerned about question #10. If the LEA does not know who the suspect is using an open access point does this mean that everyone that has used that access point will have their data handed over to the LEA? It would seem that if the LEA is only allowed to receive the data requested in the subpoena this would be a violation. As far as I can tell question #15 does not get answered in the paragraph following the question. It talks more about acceptable billing and the fact that WISPA might have a solution in the future. One of the questions in section 23 asks Does the FBI speak for other LEA's?. Unless I am mistaken this question does not get answered. Also the document says over and over again that the LEA's will work with WISP's, which sounds like there is no easy way this can always be done transparently with the current broadband equipment deployed by WISP's. So the workaround is the WISP should give them the all the data from the device in question and the LEA's will sort it out and separate it. If I am out of line please let me know but if I have questions about the FAQ then I am guessing there are others that do too. Regards, Dawn DiPietro -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA FAQ Questions
On Thu, 2007-05-10 at 09:37 -0400, Dawn DiPietro wrote: Marlon, I have been reading the WISPA CALEA FAQ and was a little concerned about question #10. If the LEA does not know who the suspect is using an open access point does this mean that everyone that has used that access point will have their data handed over to the LEA? It would seem that if the LEA is only allowed to receive the data requested in the subpoena this would be a violation. I asked a similar question in the Bear Hill webinar. I had asked about private IPs and how the request would be made to us, would it be an IP or name, unfortunately it can be either one. We would most likely need to provide the data from that IP if that is how the request was made. Now with a tap of a external IP of a private IP range, you would have to provide the data from the inside of the network, so that they could analyze it and determine what internal IP is the suspect. I have only been working in this industry for a little under a year and I have been amazed at the use of private IPs for customers. We have them setup here, in my opinion it cause more trouble than its worth I hope to move away from private IPs over the next year. They will still exist in our network for networking devices, but ideally no more customers would get them. As far as I can tell question #15 does not get answered in the paragraph following the question. It talks more about acceptable billing and the fact that WISPA might have a solution in the future. One of the questions in section 23 asks Does the FBI speak for other LEA's?. Unless I am mistaken this question does not get answered. Also the document says over and over again that the LEA's will work with WISP's, which sounds like there is no easy way this can always be done transparently with the current broadband equipment deployed by WISP's. So the workaround is the WISP should give them the all the data from the device in question and the LEA's will sort it out and separate it. If I am out of line please let me know but if I have questions about the FAQ then I am guessing there are others that do too. Regards, Dawn DiPietro -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA FAQ Questions
I have been reading the WISPA CALEA FAQ and was a little concerned about question #10. If the LEA does not know who the suspect is using an open access point does this mean that everyone that has used that access point will have their data handed over to the LEA? It would seem that if the LEA is only allowed to receive the data requested in the subpoena this would be a violation. In the past WISP's have asked if there was anyway to keep users from NATing and connecting more then 1 PC. There is no way to block this and no easy way to prevent or detect it. From the ISP perspective there is no way isolate single hotspot user since they all come in on the same IP. If the ISP has control and management of the hotspot they may be able to isolate the traffic of a given mac but this would not be reliable if they connect with a different laptop the next day. Of course it depends what kind of hotspot and how its setup. I would say your going to have to give the LEA all the traffic for the hotspot and let them filter/figure out what they need. Moral of the story: open non-encrypted wireless routers are NOT secure to use. Unless your a bad guy and just drive around tell you find one then do your ill deeds there. Just my opinion. Matt -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA FAQ Questions
This is not the sense that I get from the meeting we had with the FBI. They will know who the target is and be issuing an order for that person. However, if they happen to live with several people all on one wireless network, then the traffic is going to be mixed most likely. The best you can do is give them the traffic at that IP. According to the FBI, it's just like when they tap phones. The are to listen to only the target conversations and not the other people in the home. Lonnie Nunweiler wrote: Do they issue search warrants for a whole apartment building because they suspect someone living there is doing something bad? It was my understanding that a bit more info is required and it has to actually have a person or persons in mind. Why would data taps be treated any differently? Lonnie On 5/10/07, Matt [EMAIL PROTECTED] wrote: I have been reading the WISPA CALEA FAQ and was a little concerned about question #10. If the LEA does not know who the suspect is using an open access point does this mean that everyone that has used that access point will have their data handed over to the LEA? It would seem that if the LEA is only allowed to receive the data requested in the subpoena this would be a violation. In the past WISP's have asked if there was anyway to keep users from NATing and connecting more then 1 PC. There is no way to block this and no easy way to prevent or detect it. From the ISP perspective there is no way isolate single hotspot user since they all come in on the same IP. If the ISP has control and management of the hotspot they may be able to isolate the traffic of a given mac but this would not be reliable if they connect with a different laptop the next day. Of course it depends what kind of hotspot and how its setup. I would say your going to have to give the LEA all the traffic for the hotspot and let them filter/figure out what they need. Moral of the story: open non-encrypted wireless routers are NOT secure to use. Unless your a bad guy and just drive around tell you find one then do your ill deeds there. Just my opinion. Matt -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA FAQ Questions
Hi Dawn, Please let me preface this by saying that there are not always easy answers. And we can't always come up with a pre-made solution for every situation that may arise. We've talked with the FBI about all of these issues. We all know what the law says, and we all know what's actually possible. They aren't always lined up in nice little rows with all of the i's dotted and t's crossed. More below. Marlon (509) 982-2181 (408) 907-6910 (Vonage)Consulting services 42846865 (icq)WISP Operator since 1999! [EMAIL PROTECTED] www.odessaoffice.com/wireless www.odessaoffice.com/marlon/cam - Original Message - From: Dawn DiPietro [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, May 10, 2007 6:37 AM Subject: [WISPA] CALEA FAQ Questions Marlon, I have been reading the WISPA CALEA FAQ and was a little concerned about question #10. If the LEA does not know who the suspect is using an open access point does this mean that everyone that has used that access point will have their data handed over to the LEA? It would seem that if the LEA is only allowed to receive the data requested in the subpoena this would be a violation. We've talked about this a lot. *I've* personally talked with the head of the FBI CALEA division about this issue both via email and phone. It's one of the very first issues we talked about and why the WISPA standards effort is so important. If we can clear it, things like this will fall under the safe harbor. They (the FBI) know that some things just won't be possible/practical. Lets use my office as an example (I've done this with them so don't go hollering from the mountains about how I'm being a fool, too late). I have a FREE OPEN Linksys wireless router set up as a hotspot. Anyone that comes to town can sit in my office, in their car out front, or soon on a picinic table that I'll provide, and get all the free internet that they need while they are in the area. No charge. No tracking, heck, I won't even know it's happened. What happens when that IP addy shows up on a wire tap order? I can't change the ap so that we can insert an MT unit or some other box that would allow an individual's tap. Doing so would tip off the suspect. There are only two ways to get the data. One, tap the wireless transmissions and sort it all out on that side. Not something I have the ability, expertise, tools etc. to do. OR, we can just grab all of the data going to/from that device on the ethernet side. The LEA will have to sort out the data streams on their own. WE can't do it because we're not going to know exactly what data they are looking for. It's not a perfect solution but it's all there is. They'll have to do the same thing if the local Starbucks has a user that shows up somewhere. As far as I can tell question #15 does not get answered in the paragraph following the question. It talks more about acceptable billing and the fact that WISPA might have a solution in the future. The FAQ is only a starting point. We took the major questions people had, condenced them and got the best answers we could. We're also hanstrung a little bit because there are some things that we're not allowed to tell publicly. Much more of that coming. Might as well get ready to be even more frustrated by those of us on the committee telling you things that you can't verify other ways and we won't be able to tell you exactly what we're basing our statements on due to NDA's signed with the FBI. One of the questions in section 23 asks Does the FBI speak for other LEA's?. Unless I am mistaken this question does not get answered. They do and they don't. They are the ones to approve a standard. If they clear it, all other LEAs are bound by it. But there may be things we are asked to do etc. that are not up to the FBI. Also the document says over and over again that the LEA's will work with WISP's, which sounds like there is no easy way this can always be done transparently with the current broadband equipment deployed by WISP's. So the workaround is the WISP should give them the all the data from the device in question and the LEA's will sort it out and separate it. There are likely going to be times when this is true. The reason for CALEA is to make sure that the LEA can't get to things that they've not been specifically cleared to get. I believe that sometimes they get things that they weren't looking for in physical searches too. If they raid a house looking for stolen property and run into a meth lab, that doesn't mean that they shouldn't have gone into the house in the first place. OR, if on their way to a bust they see a stolen car in your driveway, they just happened to be in the right place at the right time. As I said before, we can all come up with more situations that don't fit the law than the law can possibly deal
Re: [WISPA] CALEA FAQ Questions
This is one of the things that has always bothered me when it comes to wire tapping a data connection. On a phone call it can be pretty easy to tell if your suspect is involved in the conversation, assuming they have not used a voice modulator. But when it comes to a data connection, how do you know? Sam Tetherow Sandhills Wireless Martha Huizenga wrote: This is not the sense that I get from the meeting we had with the FBI. They will know who the target is and be issuing an order for that person. However, if they happen to live with several people all on one wireless network, then the traffic is going to be mixed most likely. The best you can do is give them the traffic at that IP. According to the FBI, it's just like when they tap phones. The are to listen to only the target conversations and not the other people in the home. Lonnie Nunweiler wrote: Do they issue search warrants for a whole apartment building because they suspect someone living there is doing something bad? It was my understanding that a bit more info is required and it has to actually have a person or persons in mind. Why would data taps be treated any differently? Lonnie On 5/10/07, Matt [EMAIL PROTECTED] wrote: I have been reading the WISPA CALEA FAQ and was a little concerned about question #10. If the LEA does not know who the suspect is using an open access point does this mean that everyone that has used that access point will have their data handed over to the LEA? It would seem that if the LEA is only allowed to receive the data requested in the subpoena this would be a violation. In the past WISP's have asked if there was anyway to keep users from NATing and connecting more then 1 PC. There is no way to block this and no easy way to prevent or detect it. From the ISP perspective there is no way isolate single hotspot user since they all come in on the same IP. If the ISP has control and management of the hotspot they may be able to isolate the traffic of a given mac but this would not be reliable if they connect with a different laptop the next day. Of course it depends what kind of hotspot and how its setup. I would say your going to have to give the LEA all the traffic for the hotspot and let them filter/figure out what they need. Moral of the story: open non-encrypted wireless routers are NOT secure to use. Unless your a bad guy and just drive around tell you find one then do your ill deeds there. Just my opinion. Matt -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA FAQ Questions
Sam, The evidence that LEAs collect is just part of a case. If a suspect is doing bad things then data will be collected. Next steps would usually involve a warrant to get the computer and have it looked over. I have seen other tools used by LEAs to gather evidence. I am guessing that data-taps will rarely be the basis for an entire case. If it is then defense attorneys better call on us because I can tell them how easy it is to make data traffic appear to come from one person or another without the person's knowledge. That is Hacker 101 type stuff. People sneaking access on open APs is obviously going to lead to some false data tap information in many cases. Maybe people will start locking down their home APs after that happens a few times. Scriv Sam Tetherow wrote: This is one of the things that has always bothered me when it comes to wire tapping a data connection. On a phone call it can be pretty easy to tell if your suspect is involved in the conversation, assuming they have not used a voice modulator. But when it comes to a data connection, how do you know? Sam Tetherow Sandhills Wireless Martha Huizenga wrote: This is not the sense that I get from the meeting we had with the FBI. They will know who the target is and be issuing an order for that person. However, if they happen to live with several people all on one wireless network, then the traffic is going to be mixed most likely. The best you can do is give them the traffic at that IP. According to the FBI, it's just like when they tap phones. The are to listen to only the target conversations and not the other people in the home. Lonnie Nunweiler wrote: Do they issue search warrants for a whole apartment building because they suspect someone living there is doing something bad? It was my understanding that a bit more info is required and it has to actually have a person or persons in mind. Why would data taps be treated any differently? Lonnie On 5/10/07, Matt [EMAIL PROTECTED] wrote: I have been reading the WISPA CALEA FAQ and was a little concerned about question #10. If the LEA does not know who the suspect is using an open access point does this mean that everyone that has used that access point will have their data handed over to the LEA? It would seem that if the LEA is only allowed to receive the data requested in the subpoena this would be a violation. In the past WISP's have asked if there was anyway to keep users from NATing and connecting more then 1 PC. There is no way to block this and no easy way to prevent or detect it. From the ISP perspective there is no way isolate single hotspot user since they all come in on the same IP. If the ISP has control and management of the hotspot they may be able to isolate the traffic of a given mac but this would not be reliable if they connect with a different laptop the next day. Of course it depends what kind of hotspot and how its setup. I would say your going to have to give the LEA all the traffic for the hotspot and let them filter/figure out what they need. Moral of the story: open non-encrypted wireless routers are NOT secure to use. Unless your a bad guy and just drive around tell you find one then do your ill deeds there. Just my opinion. Matt -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] calea notes
Is there a standard for the captured data and do you have to use it to be CALEA compliant? Individual carriers are free to choose any technical solution that meets the assistance capability requirements of CALEA, whether based on an industry standard or not. Carriers, therefore, have some degree of flexibility in deciding how they will comply with the section 103 requirements.20 Subsection 107(a)(2) of CALEA contains a safe harbor provision, stating that [a] telecommunications carrier shall be found to be in compliance with the assistance capability requirements under section 103, and a manufacturer of telecommunications transmission or switching equipment or a provider of telecommunications support services shall be found to be in compliance with section 106, if the carrier, manufacturer, or support service provider is in compliance with publicly available technical requirements or standards adopted by an industry association or standard-setting organization, or by the Commission under subsection (b), to meet the requirements of section 103. The above demonstrates that no standard is required. However, if you want safe harbor then you really need to use a standard. To date, only ATIS's standard has been approved for safe harbor. Any additional standards need to be submitted for review and approval. My understanding is the DoJ is the agency that must ultimately sign off as the FBI's sign off does not get you all the way. Is WISPA going to have an approved standard that provides safe harbor in time for Monday? If you aren't waiting on WISPA, ask your CALEA vendor is they are using the ATIS standard. If not, find out if they will provide a written statement regarding safe harbor. If you can't get safe harbor through using a CALEA vendor then why not just take your chances with PCAP? Ask your attorney. I spoke with a number of CALEA vendors today and most seem willing to admit that you can't achieve safe harbor with their equipment. Watch out for limited liability clauses like the following: SOLERA NETWORKS, INC. IS NOT RESPONSIBLE FOR YOUR ORGANIZATION'S COMPLIANCE WITH CALEA. SOLERA NETWORKS, INC. WILL NOT PAY ANY FEES, FINES, OR OTHER COSTS ASSOCIATED WITH YOUR COMPLIANCE EFFORTS Here are some interesting stats from 2004 regarding intercepts. One can only assume the numbers will increase dramatically after May 14th. Authorized intercept orders: 1,710 Federal: 730 State: 980 Average duration: 43 days Longest duration: 390 days Average cost: $63,011 -Matt -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Question
We use a DLINK hotspot router that emails me every connect and disconnect from our hotels. The FBI could take that log and compare it to room number and date of stay and they can find their man that way... FYI - Original Message - From: Marlon K. Schafer (509) 982-2181 [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Friday, May 04, 2007 12:57 PM Subject: Re: [WISPA] CALEA Question There will likely be cases where that's impossible. Lets say that I have a customer that's a hotel. They, at first, only know the ip addy or mac addy. A subpoena comes to me looking for info on the user in question. There's no way to use the hotel's Linksys hardware to do the tap to find the specific think that LEA is looking for. Can't change the network because any action on our side tips off the suspect. In some cases it won't be possible to filter out all info. Especially if we don't know what we're looking for (which we won't and shouldn't) as far as specific data goes. I talked to the head of the FBI's CALEA group for about an hour again yesterday. They know full well that there are just some things that can't be done. At the end of the day, the just need our help when and where we can give it to them. There are far too many possibilities to deal with every single possible situation, we know that, they know that. As long as we make a real effort to help I don't think we have to worry about getting in trouble. It's those that thumb their noses that will run enforcement risks. I was told that there has NEVER been an enforcement issue occur. laters, Marlon (509) 982-2181 (408) 907-6910 (Vonage)Consulting services 42846865 (icq)WISP Operator since 1999! [EMAIL PROTECTED] www.odessaoffice.com/wireless www.odessaoffice.com/marlon/cam - Original Message - From: Dawn DiPietro [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Friday, May 04, 2007 3:48 AM Subject: Re: [WISPA] CALEA Question Marlon, I was under the impression the providers are only supposed to send the LEA the data covered in the subpoena and no more. Regards, Dawn DiPietro Marlon K. Schafer wrote: Read the FAQ. In some cases they may have to sort through ALL data to get at what they want. marlon - Original Message - From: Tom DeReggi [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, May 03, 2007 9:12 AM Subject: Re: [WISPA] CALEA Question In my opinion, I don;t think it will fly because of NAT. The law inforcement agrency needs to be able to differenciate what customer traffic is comming from, and if you use NAT for any of your customers, the facilities based upstream provider would have no way to identify the end user, and the WISP would become the customer and be liable. To many degrees of seperation at the upstream for the captured data to be meaningful. Tom DeReggi RapidDSL Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message - From: David E. Smith [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, May 02, 2007 11:27 PM Subject: Re: [WISPA] CALEA Question The FCC wrote: we conclude that establishments that acquire broadband Internet access service from a facilities-based provider to enable their patrons or customers to access the Internet from their respective establishments are not considered facilities-based broadband Internet access service providers Hm. It'd be one heckuva stretch, but by reading the letter (as opposed to the spirit) of that paragraph, many smaller WISPs would automatically be exempt. I know my office has acquired broadband Internet access service from a facilities-based provider (our upstream ISP) and we're enabling our customers to access the Internet from their respective establishments (i.e. our customers pay for Internet at their homes or offices). By the letter of that paragraph (and, to be fair, I haven't read all the context surrounding it) most any single-homed WISP would be exempt, as they could just say go talk to our upstream. (I doubt it'd work for multi-homed ISPs, as that would require multiple upstreams to be tapped and somehow synchronized, which is probably technically annoying.) David Smith MVN.net -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http
Re: [WISPA] CALEA Question
I don't think this is covered anyway, unless the guy is a permanent resident at the hotel. The subpoena will cover the suspect and any known IP or MAC info and I believe would cover a particular physical location. I was told that a subpoena cannot simply say anything, anywhere. It has to get fairly specific, and traffic from a Motel is not very specific. Lonnie On 5/4/07, Marlon K. Schafer (509) 982-2181 [EMAIL PROTECTED] wrote: There will likely be cases where that's impossible. Lets say that I have a customer that's a hotel. They, at first, only know the ip addy or mac addy. A subpoena comes to me looking for info on the user in question. There's no way to use the hotel's Linksys hardware to do the tap to find the specific think that LEA is looking for. Can't change the network because any action on our side tips off the suspect. In some cases it won't be possible to filter out all info. Especially if we don't know what we're looking for (which we won't and shouldn't) as far as specific data goes. I talked to the head of the FBI's CALEA group for about an hour again yesterday. They know full well that there are just some things that can't be done. At the end of the day, the just need our help when and where we can give it to them. There are far too many possibilities to deal with every single possible situation, we know that, they know that. As long as we make a real effort to help I don't think we have to worry about getting in trouble. It's those that thumb their noses that will run enforcement risks. I was told that there has NEVER been an enforcement issue occur. laters, Marlon (509) 982-2181 (408) 907-6910 (Vonage)Consulting services 42846865 (icq)WISP Operator since 1999! [EMAIL PROTECTED] www.odessaoffice.com/wireless www.odessaoffice.com/marlon/cam - Original Message - From: Dawn DiPietro [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Friday, May 04, 2007 3:48 AM Subject: Re: [WISPA] CALEA Question Marlon, I was under the impression the providers are only supposed to send the LEA the data covered in the subpoena and no more. Regards, Dawn DiPietro Marlon K. Schafer wrote: Read the FAQ. In some cases they may have to sort through ALL data to get at what they want. marlon - Original Message - From: Tom DeReggi [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, May 03, 2007 9:12 AM Subject: Re: [WISPA] CALEA Question In my opinion, I don;t think it will fly because of NAT. The law inforcement agrency needs to be able to differenciate what customer traffic is comming from, and if you use NAT for any of your customers, the facilities based upstream provider would have no way to identify the end user, and the WISP would become the customer and be liable. To many degrees of seperation at the upstream for the captured data to be meaningful. Tom DeReggi RapidDSL Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message - From: David E. Smith [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, May 02, 2007 11:27 PM Subject: Re: [WISPA] CALEA Question The FCC wrote: we conclude that establishments that acquire broadband Internet access service from a facilities-based provider to enable their patrons or customers to access the Internet from their respective establishments are not considered facilities-based broadband Internet access service providers Hm. It'd be one heckuva stretch, but by reading the letter (as opposed to the spirit) of that paragraph, many smaller WISPs would automatically be exempt. I know my office has acquired broadband Internet access service from a facilities-based provider (our upstream ISP) and we're enabling our customers to access the Internet from their respective establishments (i.e. our customers pay for Internet at their homes or offices). By the letter of that paragraph (and, to be fair, I haven't read all the context surrounding it) most any single-homed WISP would be exempt, as they could just say go talk to our upstream. (I doubt it'd work for multi-homed ISPs, as that would require multiple upstreams to be tapped and somehow synchronized, which is probably technically annoying.) David Smith MVN.net -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman
Re: [WISPA] CALEA Question
Marlon, I was under the impression the providers are only supposed to send the LEA the data covered in the subpoena and no more. Regards, Dawn DiPietro Marlon K. Schafer wrote: Read the FAQ. In some cases they may have to sort through ALL data to get at what they want. marlon - Original Message - From: Tom DeReggi [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, May 03, 2007 9:12 AM Subject: Re: [WISPA] CALEA Question In my opinion, I don;t think it will fly because of NAT. The law inforcement agrency needs to be able to differenciate what customer traffic is comming from, and if you use NAT for any of your customers, the facilities based upstream provider would have no way to identify the end user, and the WISP would become the customer and be liable. To many degrees of seperation at the upstream for the captured data to be meaningful. Tom DeReggi RapidDSL Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message - From: David E. Smith [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, May 02, 2007 11:27 PM Subject: Re: [WISPA] CALEA Question The FCC wrote: we conclude that establishments that acquire broadband Internet access service from a facilities-based provider to enable their patrons or customers to access the Internet from their respective establishments are not considered facilities-based broadband Internet access service providers Hm. It'd be one heckuva stretch, but by reading the letter (as opposed to the spirit) of that paragraph, many smaller WISPs would automatically be exempt. I know my office has acquired broadband Internet access service from a facilities-based provider (our upstream ISP) and we're enabling our customers to access the Internet from their respective establishments (i.e. our customers pay for Internet at their homes or offices). By the letter of that paragraph (and, to be fair, I haven't read all the context surrounding it) most any single-homed WISP would be exempt, as they could just say go talk to our upstream. (I doubt it'd work for multi-homed ISPs, as that would require multiple upstreams to be tapped and somehow synchronized, which is probably technically annoying.) David Smith MVN.net -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Question
There will likely be cases where that's impossible. Lets say that I have a customer that's a hotel. They, at first, only know the ip addy or mac addy. A subpoena comes to me looking for info on the user in question. There's no way to use the hotel's Linksys hardware to do the tap to find the specific think that LEA is looking for. Can't change the network because any action on our side tips off the suspect. In some cases it won't be possible to filter out all info. Especially if we don't know what we're looking for (which we won't and shouldn't) as far as specific data goes. I talked to the head of the FBI's CALEA group for about an hour again yesterday. They know full well that there are just some things that can't be done. At the end of the day, the just need our help when and where we can give it to them. There are far too many possibilities to deal with every single possible situation, we know that, they know that. As long as we make a real effort to help I don't think we have to worry about getting in trouble. It's those that thumb their noses that will run enforcement risks. I was told that there has NEVER been an enforcement issue occur. laters, Marlon (509) 982-2181 (408) 907-6910 (Vonage)Consulting services 42846865 (icq)WISP Operator since 1999! [EMAIL PROTECTED] www.odessaoffice.com/wireless www.odessaoffice.com/marlon/cam - Original Message - From: Dawn DiPietro [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Friday, May 04, 2007 3:48 AM Subject: Re: [WISPA] CALEA Question Marlon, I was under the impression the providers are only supposed to send the LEA the data covered in the subpoena and no more. Regards, Dawn DiPietro Marlon K. Schafer wrote: Read the FAQ. In some cases they may have to sort through ALL data to get at what they want. marlon - Original Message - From: Tom DeReggi [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, May 03, 2007 9:12 AM Subject: Re: [WISPA] CALEA Question In my opinion, I don;t think it will fly because of NAT. The law inforcement agrency needs to be able to differenciate what customer traffic is comming from, and if you use NAT for any of your customers, the facilities based upstream provider would have no way to identify the end user, and the WISP would become the customer and be liable. To many degrees of seperation at the upstream for the captured data to be meaningful. Tom DeReggi RapidDSL Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message - From: David E. Smith [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, May 02, 2007 11:27 PM Subject: Re: [WISPA] CALEA Question The FCC wrote: we conclude that establishments that acquire broadband Internet access service from a facilities-based provider to enable their patrons or customers to access the Internet from their respective establishments are not considered facilities-based broadband Internet access service providers Hm. It'd be one heckuva stretch, but by reading the letter (as opposed to the spirit) of that paragraph, many smaller WISPs would automatically be exempt. I know my office has acquired broadband Internet access service from a facilities-based provider (our upstream ISP) and we're enabling our customers to access the Internet from their respective establishments (i.e. our customers pay for Internet at their homes or offices). By the letter of that paragraph (and, to be fair, I haven't read all the context surrounding it) most any single-homed WISP would be exempt, as they could just say go talk to our upstream. (I doubt it'd work for multi-homed ISPs, as that would require multiple upstreams to be tapped and somehow synchronized, which is probably technically annoying.) David Smith MVN.net -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Question
Tim Kery wrote: Examples of these types of establishments may include some hotels, coffee shops, schools, libraries, or book stores. DOJ has stated that it has no desire to require such retail establishments to implement CALEA solutions, DOJ Comments at 36, and we conclude that the public interest at this time does not weigh in favor of subjecting such establishments to CALEA. So, Starbucks doesn't need to comply with CALEA but the service provider that provides bandwidth to Starbucks does. Hope this helps. Tim Kery BearHill Security, Inc. [EMAIL PROTECTED] Starbucks doesn't, but T-Mobile, the actual ISP does. Joe's Cup-a-Joe does have to , but the ISP providing the service does. SOME schools don't have to be because it is defined as a private network (see the ACE PDF on exemptions here: www.rad-info.net/fcc/ACE_CALEA_sum.pdf) Commercial offering of Internet access means you need to be compliant. -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Question
David E. Smith wrote: The FCC wrote: we conclude that establishments that acquire broadband Internet access service from a facilities-based provider to enable their patrons or customers to access the Internet from their respective establishments are not considered facilities-based broadband Internet access service providers Hm. It'd be one heckuva stretch, but by reading the letter (as opposed to the spirit) of that paragraph, many smaller WISPs would automatically be exempt. I know my office has acquired broadband Internet access service from a facilities-based provider (our upstream ISP) and we're enabling our customers to access the Internet from their respective establishments (i.e. our customers pay for Internet at their homes or offices). By the letter of that paragraph (and, to be fair, I haven't read all the context surrounding it) most any single-homed WISP would be exempt, as they could just say go talk to our upstream. (I doubt it'd work for multi-homed ISPs, as that would require multiple upstreams to be tapped and somehow synchronized, which is probably technically annoying.) David Smith MVN.net Why not check with a knowledgeable legal professional instead of guessing? Susan Crawford, Kris Twomey, Chris Savage, Jim Baller, and the offices of Cole, Raywid Braverman have written opinions that if you operate a router or switch and commercially sell internet, you must be CALEA compliant. Now you can choose to ignore it, and say a prayer daily that Barney Fife or any other LEA officer does not knock on your door, but the ISP's who will see the most warrants are Residential ISP's. (Not much child porn or terrorrism happening at the work place). So, roll the dice. Call an attorney for advice Or get on the call with Chris Savage of DWT on May 9. -- Regards, Peter Radizeski RAD-INFO, Inc. - NSP Strategist We Help ISPs Connect Communicate 813.963.5884 http://www.marketingIDEAguy.com -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Question
Peter R. wrote: Why not check with a knowledgeable legal professional instead of guessing? That'd be my boss's department. :D I'm just a pundit - full of opinions and hot air. Now you can choose to ignore it, and say a prayer daily that Barney Fife or any other LEA officer does not knock on your door I'd encourage Barney Fife to knock on my door, I wouldn't mind having his autograph. Remember him from Three's Company? Edit: Apparently Don Knotts died last year. Now I'm sad. :( David Smith MVN.net -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Question
I give up I just signed a contract to ensure my protection under CALEA. My hope is tht those that become compliant do not get underminded by those that have hidden in the bushes and took the risk upon themselves by not becoming compliant. It appears that it is time to start charging a homeland security fee. Since we cannot authorize taxes, we can charge fees that will allow us to mange these cost. By my figures, I will have to charge at least $1.53 per month per customer. Since this doens't include dialup customers, my broadband customers will have to incurr this burden alone. What are you thougths on this. - Original Message - From: David E. Smith [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, May 03, 2007 10:42 AM Subject: Re: [WISPA] CALEA Question Peter R. wrote: Why not check with a knowledgeable legal professional instead of guessing? That'd be my boss's department. :D I'm just a pundit - full of opinions and hot air. Now you can choose to ignore it, and say a prayer daily that Barney Fife or any other LEA officer does not knock on your door I'd encourage Barney Fife to knock on my door, I wouldn't mind having his autograph. Remember him from Three's Company? Edit: Apparently Don Knotts died last year. Now I'm sad. :( David Smith MVN.net -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Question
In my opinion, I don;t think it will fly because of NAT. The law inforcement agrency needs to be able to differenciate what customer traffic is comming from, and if you use NAT for any of your customers, the facilities based upstream provider would have no way to identify the end user, and the WISP would become the customer and be liable. To many degrees of seperation at the upstream for the captured data to be meaningful. Tom DeReggi RapidDSL Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message - From: David E. Smith [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, May 02, 2007 11:27 PM Subject: Re: [WISPA] CALEA Question The FCC wrote: we conclude that establishments that acquire broadband Internet access service from a facilities-based provider to enable their patrons or customers to access the Internet from their respective establishments are not considered facilities-based broadband Internet access service providers Hm. It'd be one heckuva stretch, but by reading the letter (as opposed to the spirit) of that paragraph, many smaller WISPs would automatically be exempt. I know my office has acquired broadband Internet access service from a facilities-based provider (our upstream ISP) and we're enabling our customers to access the Internet from their respective establishments (i.e. our customers pay for Internet at their homes or offices). By the letter of that paragraph (and, to be fair, I haven't read all the context surrounding it) most any single-homed WISP would be exempt, as they could just say go talk to our upstream. (I doubt it'd work for multi-homed ISPs, as that would require multiple upstreams to be tapped and somehow synchronized, which is probably technically annoying.) David Smith MVN.net -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Question ... fees
Ross Cornett wrote: I give up I just signed a contract to ensure my protection under CALEA. My hope is tht those that become compliant do not get underminded by those that have hidden in the bushes and took the risk upon themselves by not becoming compliant. It appears that it is time to start charging a homeland security fee. Since we cannot authorize taxes, we can charge fees that will allow us to mange these cost. By my figures, I will have to charge at least $1.53 per month per customer. Since this doens't include dialup customers, my broadband customers will have to incurr this burden alone. What are you thougths on this. Design a web page to explain the fee clearly and concisely. Point all questions about CALEA to the FCC or FBI. Emphasize it is a law; it is for homeland security; it is about child porn and terrorism - and it is to protect you. All providers must follow these rules. - Peter -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Question
I think you better just take a rate increase and chalk it up to increased expenses all the way around as opposed to creating a CALEA charge line item. Adding a fee as a line item could get you in trouble with the FTC if not approved as a legitimate added government fee (just my opinion, nothing to base this on other than my gut). Your fuel and electricity have jumped considerably I am sure. I am considering a rate increase over these added costs also. I see no way around it. I have never raised my rates in 10 years. Times are changing I am afraid. Scriv Ross Cornett wrote: I give up I just signed a contract to ensure my protection under CALEA. My hope is tht those that become compliant do not get underminded by those that have hidden in the bushes and took the risk upon themselves by not becoming compliant. It appears that it is time to start charging a homeland security fee. Since we cannot authorize taxes, we can charge fees that will allow us to mange these cost. By my figures, I will have to charge at least $1.53 per month per customer. Since this doens't include dialup customers, my broadband customers will have to incurr this burden alone. What are you thougths on this. - Original Message - From: David E. Smith [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, May 03, 2007 10:42 AM Subject: Re: [WISPA] CALEA Question Peter R. wrote: Why not check with a knowledgeable legal professional instead of guessing? That'd be my boss's department. :D I'm just a pundit - full of opinions and hot air. Now you can choose to ignore it, and say a prayer daily that Barney Fife or any other LEA officer does not knock on your door I'd encourage Barney Fife to knock on my door, I wouldn't mind having his autograph. Remember him from Three's Company? Edit: Apparently Don Knotts died last year. Now I'm sad. :( David Smith MVN.net -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
RE: [WISPA] CALEA Question
A few years ago, I added a line item to my invoices as follows... Surcharge for Bellsouth, FCC and other regulatory compliance fees and costs. This added fee is based on what I think it cost me to comply with reporting to the FCC, licensed links, and 'hidden' fees that the phone company itemizes inexcess of the actual circuit costs. This is no different than airlines and trucking companies adding 'fuel surcharges' and the quick lube business charging me an 'environmental disposal fee' when I have my oil changed. I added $2.97 per month, at the time it was the same that Bellsouth was charging for the USF on their 'itemized invoices.' I didn't loose one customer, but did have to explain the reason to two and they completely understood. That additional $3 for each DSL and wireless user was worth those two explinations. I don't charge the fee for hosting or dialup plans. There is nothing wrong raising your prices to be competitive with the 'big boys!' :) Cliff -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of John Scrivner Sent: Thursday, May 03, 2007 2:46 PM To: WISPA General List Subject: Re: [WISPA] CALEA Question I think you better just take a rate increase and chalk it up to increased expenses all the way around as opposed to creating a CALEA charge line item. Adding a fee as a line item could get you in trouble with the FTC if not approved as a legitimate added government fee (just my opinion, nothing to base this on other than my gut). Your fuel and electricity have jumped considerably I am sure. I am considering a rate increase over these added costs also. I see no way around it. I have never raised my rates in 10 years. Times are changing I am afraid. Scriv Ross Cornett wrote: I give up I just signed a contract to ensure my protection under CALEA. My hope is tht those that become compliant do not get underminded by those that have hidden in the bushes and took the risk upon themselves by not becoming compliant. It appears that it is time to start charging a homeland security fee. Since we cannot authorize taxes, we can charge fees that will allow us to mange these cost. By my figures, I will have to charge at least $1.53 per month per customer. Since this doens't include dialup customers, my broadband customers will have to incurr this burden alone. What are you thougths on this. - Original Message - From: David E. Smith [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, May 03, 2007 10:42 AM Subject: Re: [WISPA] CALEA Question Peter R. wrote: Why not check with a knowledgeable legal professional instead of guessing? That'd be my boss's department. :D I'm just a pundit - full of opinions and hot air. Now you can choose to ignore it, and say a prayer daily that Barney Fife or any other LEA officer does not knock on your door I'd encourage Barney Fife to knock on my door, I wouldn't mind having his autograph. Remember him from Three's Company? Edit: Apparently Don Knotts died last year. Now I'm sad. :( David Smith MVN.net -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ BEGIN:VCARD VERSION:2.1 X-MS-SIGNATURE:YES N;LANGUAGE=en-us:LeBoeuf;Cliff FN:Cliff LeBoeuf ORG:Computer Sales Services, Inc. TEL;WORK;VOICE:(985) 879-3219 ADR;WORK;PREF:;;1162 Barrow Street;Houma;LA;70360;United States of America LABEL;WORK;PREF;ENCODING=QUOTED-PRINTABLE:1162 Barrow Street=0D=0A= Houma, LA 70360 X-MS-OL-DEFAULT-POSTAL-ADDRESS:2 URL;WORK:www.cssla.com www.triparish.net EMAIL;PREF;INTERNET:[EMAIL PROTECTED] X-MS-TEXT;CUSTOM1:Computers - Copiers - Internet PHOTO;TYPE=JPEG;ENCODING=BASE64: /9j/4AAQSkZJRgABAQEAeAB4AAD/2wBDAAYEBQYFBAYGBQYHBwYIChAKCgkJChQODwwQFxQY GBcUFhYaHSUfGhsjHBYWICwgIyYnKSopGR8tMC0oMCUoKSj/2wBDAQcHBwoIChMKChMoGhYa KCgoKCgoKCgoKCgoKCgoKCgoKCgoKCgoKCgoKCgoKCgoKCgoKCgoKCgoKCgoKCgoKCj/wAAR CABQAEsDASIAAhEBAxEB/8QAHwAAAQUBAQEBAQEAAAECAwQFBgcICQoL/8QAtRAA AgEDAwIEAwUFBAQAAAF9AQIDAAQRBRIhMUEGE1FhByJxFDKBkaEII0KxwRVS0fAkM2JyggkK FhcYGRolJicoKSo0NTY3ODk6Q0RFRkdISUpTVFVWV1hZWmNkZWZnaGlqc3R1dnd4eXqDhIWG h4iJipKTlJWWl5iZmqKjpKWmp6ipqrKztLW2t7i5usLDxMXGx8jJytLT1NXW19jZ2uHi4+Tl 5ufo6erx8vP09fb3+Pn6/8QAHwEAAwEBAQEBAQEBAQECAwQFBgcICQoL/8QAtREA AgECBAQDBAcFBAQAAQJ3AAECAxEEBSExBhJBUQdhcRMiMoEIFEKRobHBCSMzUvAVYnLRChYk NOEl8RcYGRomJygpKjU2Nzg5OkNERUZHSElKU1RVVldYWVpjZGVmZ2hpanN0dXZ3eHl6goOE hYaHiImKkpOUlZaXmJmaoqOkpaanqKmqsrO0tba3uLm6wsPExcbHyMnK0tPU1dbX2Nna4uPk 5ebn6Onq8vP09fb3+Pn6/9oADAMBAAIRAxEAPwD0/U7ybXRqGt6xqFzZ6HaSy29vbW07RLME J+Z8dWOG74xjivKNS+JfhW0vJIU811U9ftRqT4x3MsHwd0xYm2iS8ugw9eDXzb4X0G/8Ta5b aVpMXm3U5wATgKByST2AFU207I56dOM4KUlds97u
Re: [WISPA] CALEA Question
Sounds good thanks Sriv. - Original Message - From: John Scrivner [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, May 03, 2007 2:46 PM Subject: Re: [WISPA] CALEA Question I think you better just take a rate increase and chalk it up to increased expenses all the way around as opposed to creating a CALEA charge line item. Adding a fee as a line item could get you in trouble with the FTC if not approved as a legitimate added government fee (just my opinion, nothing to base this on other than my gut). Your fuel and electricity have jumped considerably I am sure. I am considering a rate increase over these added costs also. I see no way around it. I have never raised my rates in 10 years. Times are changing I am afraid. Scriv Ross Cornett wrote: I give up I just signed a contract to ensure my protection under CALEA. My hope is tht those that become compliant do not get underminded by those that have hidden in the bushes and took the risk upon themselves by not becoming compliant. It appears that it is time to start charging a homeland security fee. Since we cannot authorize taxes, we can charge fees that will allow us to mange these cost. By my figures, I will have to charge at least $1.53 per month per customer. Since this doens't include dialup customers, my broadband customers will have to incurr this burden alone. What are you thougths on this. - Original Message - From: David E. Smith [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, May 03, 2007 10:42 AM Subject: Re: [WISPA] CALEA Question Peter R. wrote: Why not check with a knowledgeable legal professional instead of guessing? That'd be my boss's department. :D I'm just a pundit - full of opinions and hot air. Now you can choose to ignore it, and say a prayer daily that Barney Fife or any other LEA officer does not knock on your door I'd encourage Barney Fife to knock on my door, I wouldn't mind having his autograph. Remember him from Three's Company? Edit: Apparently Don Knotts died last year. Now I'm sad. :( David Smith MVN.net -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Question
If you decide to take advantage of companies that have solutions in place, you'll have to do what you have to do. Know, however, that you do NOT have to follow anyone's standard! You just have to be able to give the LEA the data they MAY ask for. I've rounded up folks that know how to get the stream off of my routers and folks that know how to program the server to store the data till LEA can download it. I have to pick up a managed switch or two but other than that, I'll cross my fingers and hope that I don't have to spend money complying till the WISPA effort is approved. marlon - Original Message - From: Ross Cornett [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, May 03, 2007 8:52 AM Subject: Re: [WISPA] CALEA Question I give up I just signed a contract to ensure my protection under CALEA. My hope is tht those that become compliant do not get underminded by those that have hidden in the bushes and took the risk upon themselves by not becoming compliant. It appears that it is time to start charging a homeland security fee. Since we cannot authorize taxes, we can charge fees that will allow us to mange these cost. By my figures, I will have to charge at least $1.53 per month per customer. Since this doens't include dialup customers, my broadband customers will have to incurr this burden alone. What are you thougths on this. - Original Message - From: David E. Smith [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, May 03, 2007 10:42 AM Subject: Re: [WISPA] CALEA Question Peter R. wrote: Why not check with a knowledgeable legal professional instead of guessing? That'd be my boss's department. :D I'm just a pundit - full of opinions and hot air. Now you can choose to ignore it, and say a prayer daily that Barney Fife or any other LEA officer does not knock on your door I'd encourage Barney Fife to knock on my door, I wouldn't mind having his autograph. Remember him from Three's Company? Edit: Apparently Don Knotts died last year. Now I'm sad. :( David Smith MVN.net -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Question
Read the FAQ. In some cases they may have to sort through ALL data to get at what they want. marlon - Original Message - From: Tom DeReggi [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, May 03, 2007 9:12 AM Subject: Re: [WISPA] CALEA Question In my opinion, I don;t think it will fly because of NAT. The law inforcement agrency needs to be able to differenciate what customer traffic is comming from, and if you use NAT for any of your customers, the facilities based upstream provider would have no way to identify the end user, and the WISP would become the customer and be liable. To many degrees of seperation at the upstream for the captured data to be meaningful. Tom DeReggi RapidDSL Wireless, Inc IntAirNet- Fixed Wireless Broadband - Original Message - From: David E. Smith [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, May 02, 2007 11:27 PM Subject: Re: [WISPA] CALEA Question The FCC wrote: we conclude that establishments that acquire broadband Internet access service from a facilities-based provider to enable their patrons or customers to access the Internet from their respective establishments are not considered facilities-based broadband Internet access service providers Hm. It'd be one heckuva stretch, but by reading the letter (as opposed to the spirit) of that paragraph, many smaller WISPs would automatically be exempt. I know my office has acquired broadband Internet access service from a facilities-based provider (our upstream ISP) and we're enabling our customers to access the Internet from their respective establishments (i.e. our customers pay for Internet at their homes or offices). By the letter of that paragraph (and, to be fair, I haven't read all the context surrounding it) most any single-homed WISP would be exempt, as they could just say go talk to our upstream. (I doubt it'd work for multi-homed ISPs, as that would require multiple upstreams to be tapped and somehow synchronized, which is probably technically annoying.) David Smith MVN.net -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Question
We have a line item of: Surcharge to cover the cost of a sales tax being charged against our fiber connection. Or words to that effect. We don't call it a tax, we specifically call it a surcharge. I think that several out here do something similar. We also charge a $10 trip charge anytime gas is over $2.50 per gallon in this area. If it hits anywhere close to $4 I'll likely raise that to $15. People don't like it but they do understand. Especially when nearly everyone else out here has also put on fuel charges. The only good thing about current gas prices is that crop prices are also way up. I'll take $3 fuel with $6 wheat any day :-) marlon - Original Message - From: John Scrivner [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, May 03, 2007 12:46 PM Subject: Re: [WISPA] CALEA Question I think you better just take a rate increase and chalk it up to increased expenses all the way around as opposed to creating a CALEA charge line item. Adding a fee as a line item could get you in trouble with the FTC if not approved as a legitimate added government fee (just my opinion, nothing to base this on other than my gut). Your fuel and electricity have jumped considerably I am sure. I am considering a rate increase over these added costs also. I see no way around it. I have never raised my rates in 10 years. Times are changing I am afraid. Scriv Ross Cornett wrote: I give up I just signed a contract to ensure my protection under CALEA. My hope is tht those that become compliant do not get underminded by those that have hidden in the bushes and took the risk upon themselves by not becoming compliant. It appears that it is time to start charging a homeland security fee. Since we cannot authorize taxes, we can charge fees that will allow us to mange these cost. By my figures, I will have to charge at least $1.53 per month per customer. Since this doens't include dialup customers, my broadband customers will have to incurr this burden alone. What are you thougths on this. - Original Message - From: David E. Smith [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, May 03, 2007 10:42 AM Subject: Re: [WISPA] CALEA Question Peter R. wrote: Why not check with a knowledgeable legal professional instead of guessing? That'd be my boss's department. :D I'm just a pundit - full of opinions and hot air. Now you can choose to ignore it, and say a prayer daily that Barney Fife or any other LEA officer does not knock on your door I'd encourage Barney Fife to knock on my door, I wouldn't mind having his autograph. Remember him from Three's Company? Edit: Apparently Don Knotts died last year. Now I'm sad. :( David Smith MVN.net -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Question
gas 3.20 per gallon here. $95.00 to fill my truck yesterday. Sheesh Marlon K. Schafer wrote: We have a line item of: Surcharge to cover the cost of a sales tax being charged against our fiber connection. Or words to that effect. We don't call it a tax, we specifically call it a surcharge. I think that several out here do something similar. We also charge a $10 trip charge anytime gas is over $2.50 per gallon in this area. If it hits anywhere close to $4 I'll likely raise that to $15. People don't like it but they do understand. Especially when nearly everyone else out here has also put on fuel charges. The only good thing about current gas prices is that crop prices are also way up. I'll take $3 fuel with $6 wheat any day :-) marlon - Original Message - From: John Scrivner [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, May 03, 2007 12:46 PM Subject: Re: [WISPA] CALEA Question I think you better just take a rate increase and chalk it up to increased expenses all the way around as opposed to creating a CALEA charge line item. Adding a fee as a line item could get you in trouble with the FTC if not approved as a legitimate added government fee (just my opinion, nothing to base this on other than my gut). Your fuel and electricity have jumped considerably I am sure. I am considering a rate increase over these added costs also. I see no way around it. I have never raised my rates in 10 years. Times are changing I am afraid. Scriv Ross Cornett wrote: I give up I just signed a contract to ensure my protection under CALEA. My hope is tht those that become compliant do not get underminded by those that have hidden in the bushes and took the risk upon themselves by not becoming compliant. It appears that it is time to start charging a homeland security fee. Since we cannot authorize taxes, we can charge fees that will allow us to mange these cost. By my figures, I will have to charge at least $1.53 per month per customer. Since this doens't include dialup customers, my broadband customers will have to incurr this burden alone. What are you thougths on this. - Original Message - From: David E. Smith [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, May 03, 2007 10:42 AM Subject: Re: [WISPA] CALEA Question Peter R. wrote: Why not check with a knowledgeable legal professional instead of guessing? That'd be my boss's department. :D I'm just a pundit - full of opinions and hot air. Now you can choose to ignore it, and say a prayer daily that Barney Fife or any other LEA officer does not knock on your door I'd encourage Barney Fife to knock on my door, I wouldn't mind having his autograph. Remember him from Three's Company? Edit: Apparently Don Knotts died last year. Now I'm sad. :( David Smith MVN.net -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- George Rogato Welcome to WISPA www.wispa.org http://signup.wispa.org/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Question
Yes and up here is $350.00 oer month for a 1MB Business connect. Alaska Wireless Systems 1(907)240-2183 Cell 1(907)349-2226 Fax 1(907)349-4308 Office www.akwireless.net - Original Message - From: George Rogato [mailto:[EMAIL PROTECTED] To: WISPA General List [mailto:[EMAIL PROTECTED] Sent: Thu, 03 May 2007 20:00:17 -0800 Subject: Re: [WISPA] CALEA Question gas 3.20 per gallon here. $95.00 to fill my truck yesterday. Sheesh Marlon K. Schafer wrote: We have a line item of: Surcharge to cover the cost of a sales tax being charged against our fiber connection. Or words to that effect. We don't call it a tax, we specifically call it a surcharge. I think that several out here do something similar. We also charge a $10 trip charge anytime gas is over $2.50 per gallon in this area. If it hits anywhere close to $4 I'll likely raise that to $15. People don't like it but they do understand. Especially when nearly everyone else out here has also put on fuel charges. The only good thing about current gas prices is that crop prices are also way up. I'll take $3 fuel with $6 wheat any day :-) marlon - Original Message - From: John Scrivner [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, May 03, 2007 12:46 PM Subject: Re: [WISPA] CALEA Question I think you better just take a rate increase and chalk it up to increased expenses all the way around as opposed to creating a CALEA charge line item. Adding a fee as a line item could get you in trouble with the FTC if not approved as a legitimate added government fee (just my opinion, nothing to base this on other than my gut). Your fuel and electricity have jumped considerably I am sure. I am considering a rate increase over these added costs also. I see no way around it. I have never raised my rates in 10 years. Times are changing I am afraid. Scriv Ross Cornett wrote: I give up I just signed a contract to ensure my protection under CALEA. My hope is tht those that become compliant do not get underminded by those that have hidden in the bushes and took the risk upon themselves by not becoming compliant. It appears that it is time to start charging a homeland security fee. Since we cannot authorize taxes, we can charge fees that will allow us to mange these cost. By my figures, I will have to charge at least $1.53 per month per customer. Since this doens't include dialup customers, my broadband customers will have to incurr this burden alone. What are you thougths on this. - Original Message - From: David E. Smith [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, May 03, 2007 10:42 AM Subject: Re: [WISPA] CALEA Question Peter R. wrote: Why not check with a knowledgeable legal professional instead of guessing? That'd be my boss's department. :D I'm just a pundit - full of opinions and hot air. Now you can choose to ignore it, and say a prayer daily that Barney Fife or any other LEA officer does not knock on your door I'd encourage Barney Fife to knock on my door, I wouldn't mind having his autograph. Remember him from Three's Company? Edit: Apparently Don Knotts died last year. Now I'm sad. :( -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] CALEA Question
As I am finding myself back into sales, I have a question concerning CALEA. I just read this blurb: The “facilities-based” terminology was meant to include providers offering connectivity infrastructure between end users and the Internet. However, establishments that acquire broadband Internet access service from a facilities-based provider to enable their customers to access the Internet from their respective establishments are excluded. The FCC explicitly exempted retail providers such as those offering hot spot WiFi (News - Alert) service where the actual Internet connectivity is obtained from another provider From this site: http://www.rad-info.net/fcc/calea1.htm This would indicate to me that if you are a retail provider, i.e. you buy your broadband from someone else and resell it to your customers, that you are exempt. This would suggest that the onus is on your provider to monitor your T-1 or other connection to them in the event of a need for a tap. Any clarity on this would be great. WirelessGuys David Peterson Senior Wireless Engineer [EMAIL PROTECTED] 207 W. Los Angeles Avenue, Suite 300 Moorpark, CA 93021-1862 tel: 800-945-3294 mobile: 979.224.4192 AIM: ultramesh inc Skype ID:nexuswirelessusa No virus found in this outgoing message. Checked by AVG Free Edition. Version: 7.5.467 / Virus Database: 269.6.2/784 - Release Date: 5/1/2007 2:57 PM CONFIDENTIALITY NOTICE: This e-mail communication and any attachments may contain confidential and privileged information for the use of the designated recipients. If you are not the intended recipient, (or authorized to receive for the recipient) you are hereby notified that you have received this communication in error and that any review, disclosure, dissemination, distribution or copying of it or its contents is prohibited. If you have received this communication in error, please destroy all copies of this communication and any attachments and contact the sender by reply email or telephone (800) 945-3294. -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Compliance
I appreciated Tim's remarks, but this sounded very much like a response from someone that is getting fed by the process of CALEA. If I am wrong I duly appologize. if I am correct then I have said enough. I agree with you Sam. It boils down to Uncle Sam is pushing an INTERNET SECURITY TAX on the everyone in the industry and only funding the TELCO's Side of it and we have no say so in the matter. They have plenty of resources and just determined that we can take it or shut down. This too is another way that the multi funded telcos will continue to be fed by the feds and we will have to pickup the scraps that the telco's don't have time or the interest to reach. Now doing that will just be a tougher battle. It must be nice getting a subcity... only a telcos know how to spell that the rest of us have never had money give to us we have to earn it. lol Ross - Original Message - From: Sam Tetherow [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, May 02, 2007 4:20 PM Subject: Re: [WISPA] CALEA Compliance Tim Kery wrote: Hi Ross, SNIP You also have to remember that Law Enforcement's primary focus is Law Enforcement and not developing technology. The FBI/DEA/DOJ said as much when in 2004 they petitioned the FCC to expand CALEA to broadband and VoIP. Essentially, they argued that it isn't possible for them to keep up with the pace of technology. (By the way, this isn't an ability issue, the FBI and Secret Service, ect. have exceptionally talented teams. Instead it really is a resource issue; the number of staff they have to cover these issues can't cover the scale of the problem.) So I, as a small provider, am suppose to have more and better resources than the federal government and their various agencies? Sam Tetherow Sandhills Wireless -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Question
As I understand it anyone who runs a router has to be CALEA compliant. Call the FCC ... these guys will answer your question and call you back: www.fcc.gov/calea Or ask a Legal Professional like Kris Twomey. Chris Savage or KC Halm from Davis Wright Tremaine LLP will take your questions about CALEA on May 9th (http://radinfo.blogspot.com/2007/05/attorney-call-for-calea.html) - Peter David Peterson wrote: As I am finding myself back into sales, I have a question concerning CALEA. I just read this blurb: The “facilities-based” terminology was meant to include providers offering connectivity infrastructure between end users and the Internet. However, establishments that acquire broadband Internet access service from a facilities-based provider to enable their customers to access the Internet from their respective establishments are excluded. The FCC explicitly exempted retail providers such as those offering hot spot WiFi (News - Alert) service where the actual Internet connectivity is obtained from another provider From this site: http://www.rad-info.net/fcc/calea1.htm This would indicate to me that if you are a retail provider, i.e. you buy your broadband from someone else and resell it to your customers, that you are exempt. This would suggest that the onus is on your provider to monitor your T-1 or other connection to them in the event of a need for a tap. Any clarity on this would be great. WirelessGuys David Peterson Senior Wireless Engineer -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Question
Well, everybody gets their Internet from someone else. - Mike Hammett Intelligent Computing Solutions http://www.ics-il.com - Original Message - From: David Peterson [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, May 02, 2007 1:57 PM Subject: [WISPA] CALEA Question As I am finding myself back into sales, I have a question concerning CALEA. I just read this blurb: The “facilities-based” terminology was meant to include providers offering connectivity infrastructure between end users and the Internet. However, establishments that acquire broadband Internet access service from a facilities-based provider to enable their customers to access the Internet from their respective establishments are excluded. The FCC explicitly exempted retail providers such as those offering hot spot WiFi (News - Alert) service where the actual Internet connectivity is obtained from another provider From this site: http://www.rad-info.net/fcc/calea1.htm This would indicate to me that if you are a retail provider, i.e. you buy your broadband from someone else and resell it to your customers, that you are exempt. This would suggest that the onus is on your provider to monitor your T-1 or other connection to them in the event of a need for a tap. Any clarity on this would be great. WirelessGuys David Peterson Senior Wireless Engineer [EMAIL PROTECTED] 207 W. Los Angeles Avenue, Suite 300 Moorpark, CA 93021-1862 tel: 800-945-3294 mobile: 979.224.4192 AIM: ultramesh inc Skype ID:nexuswirelessusa No virus found in this outgoing message. Checked by AVG Free Edition. Version: 7.5.467 / Virus Database: 269.6.2/784 - Release Date: 5/1/2007 2:57 PM CONFIDENTIALITY NOTICE: This e-mail communication and any attachments may contain confidential and privileged information for the use of the designated recipients. If you are not the intended recipient, (or authorized to receive for the recipient) you are hereby notified that you have received this communication in error and that any review, disclosure, dissemination, distribution or copying of it or its contents is prohibited. If you have received this communication in error, please destroy all copies of this communication and any attachments and contact the sender by reply email or telephone (800) 945-3294. -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Question
Hmmm, Well during the dial up days, Jokingly, I was thinking about starting a new internet business. Internet on a disk! . Each week we send you a new disk. We start you off with disk labeled, beginning internet a-ab, next week it will be ac-ad. This way the sites will be fast loading and won't tie up your telephone lines, nor will you have to buy a fancy high speed internet line. No more connection issues. Well I did ell a couple of my subs this, and they wanted to know what would be cheaper grin Mike Hammett wrote: Well, everybody gets their Internet from someone else. - Mike Hammett Intelligent Computing Solutions http://www.ics-il.com - Original Message - From: David Peterson [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, May 02, 2007 1:57 PM Subject: [WISPA] CALEA Question As I am finding myself back into sales, I have a question concerning CALEA. I just read this blurb: The “facilities-based” terminology was meant to include providers offering connectivity infrastructure between end users and the Internet. However, establishments that acquire broadband Internet access service from a facilities-based provider to enable their customers to access the Internet from their respective establishments are excluded. The FCC explicitly exempted retail providers such as those offering hot spot WiFi (News - Alert) service where the actual Internet connectivity is obtained from another provider From this site: http://www.rad-info.net/fcc/calea1.htm This would indicate to me that if you are a retail provider, i.e. you buy your broadband from someone else and resell it to your customers, that you are exempt. This would suggest that the onus is on your provider to monitor your T-1 or other connection to them in the event of a need for a tap. Any clarity on this would be great. WirelessGuys David Peterson Senior Wireless Engineer [EMAIL PROTECTED] 207 W. Los Angeles Avenue, Suite 300 Moorpark, CA 93021-1862 tel: 800-945-3294 mobile: 979.224.4192 AIM: ultramesh inc Skype ID:nexuswirelessusa No virus found in this outgoing message. Checked by AVG Free Edition. Version: 7.5.467 / Virus Database: 269.6.2/784 - Release Date: 5/1/2007 2:57 PM CONFIDENTIALITY NOTICE: This e-mail communication and any attachments may contain confidential and privileged information for the use of the designated recipients. If you are not the intended recipient, (or authorized to receive for the recipient) you are hereby notified that you have received this communication in error and that any review, disclosure, dissemination, distribution or copying of it or its contents is prohibited. If you have received this communication in error, please destroy all copies of this communication and any attachments and contact the sender by reply email or telephone (800) 945-3294. -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Exemption for Small Wireless ISPs
My opinion is that you're not helping the big picture by saying compliance is more than you can handle. The FCC is not going to go out of their way to hand out more spectrum to providers that can't perform basic requirements. Just like they're not going to help providers that refuse to file 475 forms. You can build a unix box for five hundred dollars that will do the job for you. Or you can buy a turnkey box with support for seven thousand. I've seen it suggested people pool their funds and share a $7000 turnkey box. If you can't do any of these things, then you can't provide required services. I don't like or trust government but I don't think they're out of line requiring providers be CALEA compliant. This one ain't special interests motivated. - cw Jack Unger wrote: Dear Representative Stupak, I'm writing to support your request on March 14, 2007 asking that the FCC Commissioners consider a waiver from CALEA regulations for small broadband providers. In a nutshell, the costs of complying with the CALEA provisions are far in excess of what small broadband providers can afford to pay. It is poor government policy to allow the costs of CALEA compliance to literally put small broadband providers out of business thereby denying broadband Internet access to many rural Americans. Do you plan to introduce legislation that directs the FCC to reconsider their regulations and to consider the compliance costs when regulating small Internet access providers? Please advise me how I can further support your effort to retain broadband Internet access service for rural Americans. Thank you for your time, interest, and efforts. Sincerely, Jack Unger P.S. - I am copying this email to the general email list maintained by the Wireless Internet Service Providers Association (WISPA.org) to help as many small ISPs as possible learn about and support your efforts in their behalf. I will forward your response to this list. -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Exemption for Small Wireless ISPs
Dear cw, Thank you for your opinion. I respectfully disagree. There's nothing wrong with admitting that small local providers can't afford to comply with the same requirements that big carriers like ATT can comply with. That's the problem here; small local businesses are being asked to shell out more money than they can afford just so the FBI/DOJ/ATF/CIA/NSA/DHS can quickly and conveniently wiretap. As to whether the big carriers have provided input to the FCC (FBI/DOJ/ATF/CIA/NSA/DHS) on this issue; the jury is out on that question for the moment. jack P.S. - The issue of obtaining more spectrum from the FCC will be moot once the ranks of the small, local license-free spectrum users are thinned much further. In short, no one will be around to need any more spectrum. cw wrote: My opinion is that you're not helping the big picture by saying compliance is more than you can handle. The FCC is not going to go out of their way to hand out more spectrum to providers that can't perform basic requirements. Just like they're not going to help providers that refuse to file 475 forms. You can build a unix box for five hundred dollars that will do the job for you. Or you can buy a turnkey box with support for seven thousand. I've seen it suggested people pool their funds and share a $7000 turnkey box. If you can't do any of these things, then you can't provide required services. I don't like or trust government but I don't think they're out of line requiring providers be CALEA compliant. This one ain't special interests motivated. - cw Jack Unger wrote: Dear Representative Stupak, I'm writing to support your request on March 14, 2007 asking that the FCC Commissioners consider a waiver from CALEA regulations for small broadband providers. In a nutshell, the costs of complying with the CALEA provisions are far in excess of what small broadband providers can afford to pay. It is poor government policy to allow the costs of CALEA compliance to literally put small broadband providers out of business thereby denying broadband Internet access to many rural Americans. Do you plan to introduce legislation that directs the FCC to reconsider their regulations and to consider the compliance costs when regulating small Internet access providers? Please advise me how I can further support your effort to retain broadband Internet access service for rural Americans. Thank you for your time, interest, and efforts. Sincerely, Jack Unger P.S. - I am copying this email to the general email list maintained by the Wireless Internet Service Providers Association (WISPA.org) to help as many small ISPs as possible learn about and support your efforts in their behalf. I will forward your response to this list. -- Jack Unger ([EMAIL PROTECTED]) - President, Ask-Wi.Com, Inc. FCC License # PG-12-25133 Serving the Broadband Wireless Industry Since 1993 Author of the WISP Handbook - Deploying License-Free Wireless WANs True Vendor-Neutral Wireless Consulting-Training-Troubleshooting FCC Part 15 Certification Assistance for Wireless Service Providers Phone (VoIP Over Broadband Wireless) 818-227-4220 www.ask-wi.com -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Exemption for Small Wireless ISPs
I believe the feds have secret deals with the telcos so they can do what ever they want besides calea. Just like I pointed out that fiber att wiretapping deal in the very first days of wispa calea discussion. This is where I see the imbalance, The little guys carry the weight and the big guys get gravy secret contracts that help shoulder the burden. I will still do what I have to do to be compliant. But there is a reality to the even handedness of this. George Jack Unger wrote: Dear cw, Thank you for your opinion. I respectfully disagree. There's nothing wrong with admitting that small local providers can't afford to comply with the same requirements that big carriers like ATT can comply with. That's the problem here; small local businesses are being asked to shell out more money than they can afford just so the FBI/DOJ/ATF/CIA/NSA/DHS can quickly and conveniently wiretap. As to whether the big carriers have provided input to the FCC (FBI/DOJ/ATF/CIA/NSA/DHS) on this issue; the jury is out on that question for the moment. jack P.S. - The issue of obtaining more spectrum from the FCC will be moot once the ranks of the small, local license-free spectrum users are thinned much further. In short, no one will be around to need any more spectrum. cw wrote: My opinion is that you're not helping the big picture by saying compliance is more than you can handle. The FCC is not going to go out of their way to hand out more spectrum to providers that can't perform basic requirements. Just like they're not going to help providers that refuse to file 475 forms. You can build a unix box for five hundred dollars that will do the job for you. Or you can buy a turnkey box with support for seven thousand. I've seen it suggested people pool their funds and share a $7000 turnkey box. If you can't do any of these things, then you can't provide required services. I don't like or trust government but I don't think they're out of line requiring providers be CALEA compliant. This one ain't special interests motivated. - cw Jack Unger wrote: Dear Representative Stupak, I'm writing to support your request on March 14, 2007 asking that the FCC Commissioners consider a waiver from CALEA regulations for small broadband providers. In a nutshell, the costs of complying with the CALEA provisions are far in excess of what small broadband providers can afford to pay. It is poor government policy to allow the costs of CALEA compliance to literally put small broadband providers out of business thereby denying broadband Internet access to many rural Americans. Do you plan to introduce legislation that directs the FCC to reconsider their regulations and to consider the compliance costs when regulating small Internet access providers? Please advise me how I can further support your effort to retain broadband Internet access service for rural Americans. Thank you for your time, interest, and efforts. Sincerely, Jack Unger P.S. - I am copying this email to the general email list maintained by the Wireless Internet Service Providers Association (WISPA.org) to help as many small ISPs as possible learn about and support your efforts in their behalf. I will forward your response to this list. -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Exemption for Small Wireless ISPs
My opinion then, is that the FCC can get off their duffs and provide internet to the hinterlands themselves. There is more to CALEA than having a $500 unix box, and sharing a $7000 turnkey box is not an option unless you are sharing it within a tight geographical area since response times on execution of certain parts of CALEA is shorter than an overnight shipment. As for getting more spectrum, quite honestly I will believe it when I see it. The FCC is far more interested in the cash that spectrum sales bring in than it is interested in providing the best use of the spectrum for the American public. Sam Tetherow Sandhills Wireless cw wrote: My opinion is that you're not helping the big picture by saying compliance is more than you can handle. The FCC is not going to go out of their way to hand out more spectrum to providers that can't perform basic requirements. Just like they're not going to help providers that refuse to file 475 forms. You can build a unix box for five hundred dollars that will do the job for you. Or you can buy a turnkey box with support for seven thousand. I've seen it suggested people pool their funds and share a $7000 turnkey box. If you can't do any of these things, then you can't provide required services. I don't like or trust government but I don't think they're out of line requiring providers be CALEA compliant. This one ain't special interests motivated. - cw Jack Unger wrote: Dear Representative Stupak, I'm writing to support your request on March 14, 2007 asking that the FCC Commissioners consider a waiver from CALEA regulations for small broadband providers. In a nutshell, the costs of complying with the CALEA provisions are far in excess of what small broadband providers can afford to pay. It is poor government policy to allow the costs of CALEA compliance to literally put small broadband providers out of business thereby denying broadband Internet access to many rural Americans. Do you plan to introduce legislation that directs the FCC to reconsider their regulations and to consider the compliance costs when regulating small Internet access providers? Please advise me how I can further support your effort to retain broadband Internet access service for rural Americans. Thank you for your time, interest, and efforts. Sincerely, Jack Unger P.S. - I am copying this email to the general email list maintained by the Wireless Internet Service Providers Association (WISPA.org) to help as many small ISPs as possible learn about and support your efforts in their behalf. I will forward your response to this list. -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Compliance (Netequalizer)
For people that run Netequalizers, they are helping you comply As promised, NetEqualizer is now offering the utilities necessary to meet requirements set forth this month by CALEA, or the Communications Assistance for Law Enforcement Act. This law oversees telecommunication security and has now been expanded to Internet security. There are some fairly harsh federal penalties for noncompliance that became effective May 1. John Marlon K. Schafer wrote: There won't be a WISPA standard done in time. We're still waiting on some documentation from the FBI and we need to get some internal documentation together as well. But you don't have to be compliant with ANY standard to be CALEA compliant! You just have to understand what you have to do if they ask and have mechanisms in place to do it. The basic parts you'll need are: Linux based router or tap capabilities on the on you have. OR a managed switch that will allow you to mirror a port. Linux server with OpenCALEA and an FTP program on it. Knowledge of how to make it record and distribute the needed data for LEA. You don't HAVE to use a TTP. You don't HAVE to follow a standard. You don't HAVE to panic just yet. *I've* talked to the folks at the FBI. They are NOT interested in running anyone out of business. They just want to catch bad guys and they *may* need our help to do it. Everything past that point is FUD. Why have a standard at all then? Because if you don't follow a standard you have to TRY to do anything that LEA asks of you. If you are standards compliant you only have to do what the standard says you have to do. Believe it or not, guys like Tim at Bearhill are working WITH WISPA in our efforts to develop a low cost/no cost solution to CALEA. We all know that many in this industry are still trying to figure out how to pay the bill on that latest order for 3 cpe units. I was sometimes 60 days behind with EC. I always paid but rarely on time. Sucked for me and for them. Fortunately, they hung with me and today we're as likely to be prepaid as we are to owe them. It's a nice change of pace. We also order radios in bulk, every couple to few weeks, rather than 1 or 2 at a time. Wondering how to make payroll, or buy diapers sucks. Most of us have been there. We got through those times partly because others reached a hand down and helped us where they could. We worked hard, honestly and consistently. I suggest that those of you in panic mode over CALEA go to www.askcalea.net and read up on it. Contact the FCC and the FBI yourselves if you don't believe those of us that are doing this work. So far I've found that folks are more than happy to answer my direct questions. At LEAST contact those that WISPA sent to the FBI! They know a lot of answers and they have a direct line to the FBI if they don't know the answer. Yeah, CALEA is a big deal. Yeah it's complicated. Yeah, it'll suck to have to perform. Yeah, you have to do it anyway :-). Might as well stop whining and start figuring out what all of those ttp's have already gotten figured out. Someone's gonna make money off of those out there that can't/won't figure it out for themselves. Might as well be you! marlon - Original Message - From: Todd Barber [EMAIL PROTECTED] To: 'WISPA General List' wireless@wispa.org Sent: Monday, April 30, 2007 8:19 PM Subject: RE: [WISPA] CALEA Compliance John, The part that is causing disbelief for me is the deadline is only days away and I haven't seen this solution or the costing for the solution. Todd Barber Skylink Broadband Internet [EMAIL PROTECTED] 970-454-9499 -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of John Scrivner Sent: Monday, April 30, 2007 9:14 PM To: WISPA General List Subject: Re: [WISPA] CALEA Compliance I personally do not believe that any CALEA can be cost effective. Quite simply, solving CALEA requires spending money without earning any additional revenue. The only way to justify the CALEA expense is to accept it as a cost of doing business. This means simply that your market opportunity is lost if you aren't CALEA compliant. I firmly believe every service provider should have plans for being CALEA compliant or have plans for exiting the business. This one is different than E911; the liability will be staggering. -Matt Matt, We look forward to proving that this thinking is wrong. What part of CALEA compliance is it that makes you think we cannot develop a low cost and reasonable solution which will not break the bank? Scriv -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- No virus found in this incoming message. Checked by AVG Free Edition. Version: 7.5.467 / Virus Database: 269.6.2/781 - Release Date: 4/30/2007 9:14 AM -- WISPA Wireless List: wireless
Re: [WISPA] CALEA Exemption for Small Wireless ISPs
Uh Sam, you do remember the 5.4 gig band right? 255 mhz of NEW spectrum, made available last year. There's also 24ghz and 60ghz available. We just need people building the new toys at price points that will work for us. Know what I want? A 15 or 20 meg $1500 to $2000 60 gig solution good for a mile or two. marlon - Original Message - From: Sam Tetherow [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, May 02, 2007 6:52 PM Subject: Re: [WISPA] CALEA Exemption for Small Wireless ISPs My opinion then, is that the FCC can get off their duffs and provide internet to the hinterlands themselves. There is more to CALEA than having a $500 unix box, and sharing a $7000 turnkey box is not an option unless you are sharing it within a tight geographical area since response times on execution of certain parts of CALEA is shorter than an overnight shipment. As for getting more spectrum, quite honestly I will believe it when I see it. The FCC is far more interested in the cash that spectrum sales bring in than it is interested in providing the best use of the spectrum for the American public. Sam Tetherow Sandhills Wireless cw wrote: My opinion is that you're not helping the big picture by saying compliance is more than you can handle. The FCC is not going to go out of their way to hand out more spectrum to providers that can't perform basic requirements. Just like they're not going to help providers that refuse to file 475 forms. You can build a unix box for five hundred dollars that will do the job for you. Or you can buy a turnkey box with support for seven thousand. I've seen it suggested people pool their funds and share a $7000 turnkey box. If you can't do any of these things, then you can't provide required services. I don't like or trust government but I don't think they're out of line requiring providers be CALEA compliant. This one ain't special interests motivated. - cw Jack Unger wrote: Dear Representative Stupak, I'm writing to support your request on March 14, 2007 asking that the FCC Commissioners consider a waiver from CALEA regulations for small broadband providers. In a nutshell, the costs of complying with the CALEA provisions are far in excess of what small broadband providers can afford to pay. It is poor government policy to allow the costs of CALEA compliance to literally put small broadband providers out of business thereby denying broadband Internet access to many rural Americans. Do you plan to introduce legislation that directs the FCC to reconsider their regulations and to consider the compliance costs when regulating small Internet access providers? Please advise me how I can further support your effort to retain broadband Internet access service for rural Americans. Thank you for your time, interest, and efforts. Sincerely, Jack Unger P.S. - I am copying this email to the general email list maintained by the Wireless Internet Service Providers Association (WISPA.org) to help as many small ISPs as possible learn about and support your efforts in their behalf. I will forward your response to this list. -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] CALEA Question
David, Regarding your question, the FCC was referring to Retail Establishments and not Retail Providers. The FCC defines facilities based as follows: facilities-based meant entities that provide transmission or switching over their own facilities between the end user and the Internet Service Provider (ISP) So if your customer traffic traverses over a router, switch or bridge that you own, and your offering exceeds 200Kbps in either direction in the last mile, then you meet the commissions definition of a facilities-based broadband service provider. The FCC did exclude some retail establishments from the CALEA requirement. Specifically, in the FCC's First Report and Order and NPRM (05-153), pg 19. paragraph 36 states: Finally, in finding CALEA's SRP to cover facilities-based providers of broadband Internet access service, we conclude that establishments that acquire broadband Internet access service from a facilities-based provider to enable their patrons or customers to access the Internet from their respective establishments are not considered facilities-based broadband Internet access service providers subject to CALEA under the SRP.99 We note, however, that the provider of underlying facilities to such an establishment would be subject to CALEA, as discussed above. Footnote #99 on the same page further clarifies: Examples of these types of establishments may include some hotels, coffee shops, schools, libraries, or book stores. DOJ has stated that it has no desire to require such retail establishments to implement CALEA solutions, DOJ Comments at 36, and we conclude that the public interest at this time does not weigh in favor of subjecting such establishments to CALEA. So, Starbucks doesn't need to comply with CALEA but the service provider that provides bandwidth to Starbucks does. Hope this helps. Tim Kery BearHill Security, Inc. [EMAIL PROTECTED] [WISPA] CALEA Question David Peterson DPeterson at Wirelessguys.com mailto:wireless%40wispa.org?Subject=%5BWISPA%5D%20CALEA%20QuestionIn-R eply-To=e702557f0705021144t38638587y585f4544732c9b6d%40mail.gmail.com Wed May 2 13:57:48 CDT 2007 * Previous message: NOW: CALEA Waiver Request WAS: [WISPA] Ok, here's my CALEA statement, and farewell. http://lists.wispa.org/pipermail/wireless/2007-May/035125.html * Next message: [WISPA] CALEA Question http://lists.wispa.org/pipermail/wireless/2007-May/035173.html * Messages sorted by: [ date ] http://lists.wispa.org/pipermail/wireless/2007-May/date.html [ thread ] http://lists.wispa.org/pipermail/wireless/2007-May/thread.html [ subject ] http://lists.wispa.org/pipermail/wireless/2007-May/subject.html [ author ] http://lists.wispa.org/pipermail/wireless/2007-May/author.html As I am finding myself back into sales, I have a question concerning CALEA. I just read this blurb: The facilities-based terminology was meant to include providers offering connectivity infrastructure between end users and the Internet. However, establishments that acquire broadband Internet access service from a facilities-based provider to enable their customers to access the Internet from their respective establishments are excluded. The FCC explicitly exempted retail providers such as those offering hot spot WiFi (News - Alert) service where the actual Internet connectivity is obtained from another provider From this site: http://www.rad-info.net/fcc/calea1.htm This would indicate to me that if you are a retail provider, i.e. you buy your broadband from someone else and resell it to your customers, that you are exempt. This would suggest that the onus is on your provider to monitor your T-1 or other connection to them in the event of a need for a tap. Any clarity on this would be great. WirelessGuys David Peterson Senior Wireless Engineer DPeterson at WirelessGuys.com http://lists.wispa.org/mailman/listinfo/wireless 207 W. Los Angeles Avenue, Suite 300 Moorpark, CA 93021-1862 tel: 800-945-3294 mobile: 979.224.4192 AIM: ultramesh inc Skype ID:nexuswirelessusa http://www.bearhill.com/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Exemption for Small Wireless ISPs
You do have a point on the 5.4 Marlon, although it was otherwise unsellable spectrum. The power restrictions along with DFS requirements limited it to something I doubt many would be willing to pay for. Not saying we can't use it though. I'm eagerly awaiting affordable gear since it fits my model quite well. Most of my customers are within 3 miles of my towers. Sam Tetherow Sandhills Wireless Marlon K. Schafer wrote: Uh Sam, you do remember the 5.4 gig band right? 255 mhz of NEW spectrum, made available last year. There's also 24ghz and 60ghz available. We just need people building the new toys at price points that will work for us. Know what I want? A 15 or 20 meg $1500 to $2000 60 gig solution good for a mile or two. marlon - Original Message - From: Sam Tetherow [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Wednesday, May 02, 2007 6:52 PM Subject: Re: [WISPA] CALEA Exemption for Small Wireless ISPs My opinion then, is that the FCC can get off their duffs and provide internet to the hinterlands themselves. There is more to CALEA than having a $500 unix box, and sharing a $7000 turnkey box is not an option unless you are sharing it within a tight geographical area since response times on execution of certain parts of CALEA is shorter than an overnight shipment. As for getting more spectrum, quite honestly I will believe it when I see it. The FCC is far more interested in the cash that spectrum sales bring in than it is interested in providing the best use of the spectrum for the American public. Sam Tetherow Sandhills Wireless cw wrote: My opinion is that you're not helping the big picture by saying compliance is more than you can handle. The FCC is not going to go out of their way to hand out more spectrum to providers that can't perform basic requirements. Just like they're not going to help providers that refuse to file 475 forms. You can build a unix box for five hundred dollars that will do the job for you. Or you can buy a turnkey box with support for seven thousand. I've seen it suggested people pool their funds and share a $7000 turnkey box. If you can't do any of these things, then you can't provide required services. I don't like or trust government but I don't think they're out of line requiring providers be CALEA compliant. This one ain't special interests motivated. - cw Jack Unger wrote: Dear Representative Stupak, I'm writing to support your request on March 14, 2007 asking that the FCC Commissioners consider a waiver from CALEA regulations for small broadband providers. In a nutshell, the costs of complying with the CALEA provisions are far in excess of what small broadband providers can afford to pay. It is poor government policy to allow the costs of CALEA compliance to literally put small broadband providers out of business thereby denying broadband Internet access to many rural Americans. Do you plan to introduce legislation that directs the FCC to reconsider their regulations and to consider the compliance costs when regulating small Internet access providers? Please advise me how I can further support your effort to retain broadband Internet access service for rural Americans. Thank you for your time, interest, and efforts. Sincerely, Jack Unger P.S. - I am copying this email to the general email list maintained by the Wireless Internet Service Providers Association (WISPA.org) to help as many small ISPs as possible learn about and support your efforts in their behalf. I will forward your response to this list. -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Question
The FCC wrote: we conclude that establishments that acquire broadband Internet access service from a facilities-based provider to enable their patrons or customers to access the Internet from their respective establishments are not considered facilities-based broadband Internet access service providers Hm. It'd be one heckuva stretch, but by reading the letter (as opposed to the spirit) of that paragraph, many smaller WISPs would automatically be exempt. I know my office has acquired broadband Internet access service from a facilities-based provider (our upstream ISP) and we're enabling our customers to access the Internet from their respective establishments (i.e. our customers pay for Internet at their homes or offices). By the letter of that paragraph (and, to be fair, I haven't read all the context surrounding it) most any single-homed WISP would be exempt, as they could just say go talk to our upstream. (I doubt it'd work for multi-homed ISPs, as that would require multiple upstreams to be tapped and somehow synchronized, which is probably technically annoying.) David Smith MVN.net -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Exemption for Small Wireless ISPs
Thank you Jack. I am glad to see someone doing something for their beliefs instead of kicking WISPA in the chins for not doing it for them. WISPA is here for all of you to interact and decide what and how you want to represent yourselves and your industry. Jack knows that means he can do something and is doing something. Way to go Jack. It is usually only 4 or 5 of us within WISPA who actually do something to light a fire under people's butts. I am glad to see you take the step this time. That's called leadership people. Jack showed you how its done folks. If you want change then make it happen. This was less work than complaining about the problem and is infinitely more productive toward getting something done about the issues that many have been talking about here with regard to fears of inability to meet the demands of CALEA. Scriv Jack Unger wrote: Dear Representative Stupak, I'm writing to support your request on March 14, 2007 asking that the FCC Commissioners consider a waiver from CALEA regulations for small broadband providers. In a nutshell, the costs of complying with the CALEA provisions are far in excess of what small broadband providers can afford to pay. It is poor government policy to allow the costs of CALEA compliance to literally put small broadband providers out of business thereby denying broadband Internet access to many rural Americans. Do you plan to introduce legislation that directs the FCC to reconsider their regulations and to consider the compliance costs when regulating small Internet access providers? Please advise me how I can further support your effort to retain broadband Internet access service for rural Americans. Thank you for your time, interest, and efforts. Sincerely, Jack Unger P.S. - I am copying this email to the general email list maintained by the Wireless Internet Service Providers Association (WISPA.org) to help as many small ISPs as possible learn about and support your efforts in their behalf. I will forward your response to this list. -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Compliance
- Original Message - From: Jack Unger [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Monday, April 30, 2007 7:56 PM Subject: Re: [WISPA] CALEA Compliance I went to email him, but his website says he will not respond to emails from outside his district. his website has no mention of his letter to the FCC. Is there anyone in his district on-list who can email or call him? People from outside his district are obviously going to be far back on the list of things to take time to deal with. I won't call unless there's nobody in his district. I did a lot of searching for additional information about his request, but I found nothing. I did find he has a lot of interest in internet / telecommunications, though I see he and I are on the opposite sides of a lot of things. His district is the upper peninsula of Michigan. Anyone? I'd like to hear the FCC response to Rep. Bart Stupak's request to waive the CALEA regulations for small broadband providers, as described in the following link. http://www.wispa.org/?p=21 -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Compliance
On Mon, 30 Apr 2007, Todd Barber wrote: I have seen numerous posts on the WISPA list indicating that a cost effective and compliant solution for this issue was being worked on and would become available in the near future. All I can say is please be patient. An answer to your question is coming. We (the wispa calea committee) are working on building the standard now. I have seen numerous posts indicating that small providers should not be concerned and that attaining CALEA compliance would not put them out of business. Those posts would be correct. I contacted them today. If this is the cost effective solution that is available, it isnt cost effective enough for our operation. The monthly is ¼ of our current bandwidth costs and the upfront is twice the cost of our head-end router that is servicing all of our customers. Bearhill (or any other TTP) is a good solution if you want someone else to assist in managing your CALEA compliance. A TTP is NOT a requirement, however. If someone has better information on how a small ISP can become CALEA compliant in a cost effective manner, please contact me as I am all ears. If there is better information or a defined solution being presented on the WISPA member list, I am more than willing to pay membership dues to access it. If there isnt a better solution being discussed there, I would just as well save the due money as it will probably not be long before we are out of business or sell to a larger competitor and the membership will be useless. All I can say is (again), be patient. This information is coming. BTW, becoming a WISPA member is a good idea anyway. CALEA will not be the downfall of anyone (except those that refuse to obey the law). -- Butch Evans Network Engineering and Security Consulting 573-276-2879 http://www.butchevans.com/ My calendar: http://tinyurl.com/y24ad6 Training Partners: http://tinyurl.com/smfkf Mikrotik Certified Consultant http://www.mikrotik.com/consultants.html-- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Compliance
John Scrivner wrote: We look forward to proving that this thinking is wrong. What part of CALEA compliance is it that makes you think we cannot develop a low cost and reasonable solution which will not break the bank? Even if you do come up with a way to handle LI in time for the deadline that is only going to solve one part of CALEA. We checked with Cisco in the beginning regarding CALEA. We were assured they were working on it and would have a solution in time (much the same way WISPA has). We now have Cisco's solution and understand it does exactly what they say it would do; namely LI. Unfortunately, LI isn't enough as I have outlined in other posts. We have had to develop the rest of the solution on our own. Reread my post on the practical requirements of dealing with ELSUR and check with your attorneys. I think you'll find no technical solution to those requirements. -Matt -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Compliance
I still would like to know the amount of incident that this CALEA will cause for all of its costs to our industry. Did anyone ask the FBI, why they cannot have several machines and deliver them as needed pre-configured then we can install them when they are needed. It is highly unreasonable for the FBI to ask everyone to have a utility and manage this utility when it will never be used by a very large portion of our industry. It is far cheaper for the government to sameday ship their device to us anywhere in the nation then it is to have everyone else trying to scramble to satisfy a need that will largely be an expensive dust collector in most businesses. Anyone know if this has been posed to the FBI. - Original Message - From: Matt Liotta [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Tuesday, May 01, 2007 7:54 AM Subject: Re: [WISPA] CALEA Compliance John Scrivner wrote: We look forward to proving that this thinking is wrong. What part of CALEA compliance is it that makes you think we cannot develop a low cost and reasonable solution which will not break the bank? Even if you do come up with a way to handle LI in time for the deadline that is only going to solve one part of CALEA. We checked with Cisco in the beginning regarding CALEA. We were assured they were working on it and would have a solution in time (much the same way WISPA has). We now have Cisco's solution and understand it does exactly what they say it would do; namely LI. Unfortunately, LI isn't enough as I have outlined in other posts. We have had to develop the rest of the solution on our own. Reread my post on the practical requirements of dealing with ELSUR and check with your attorneys. I think you'll find no technical solution to those requirements. -Matt -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Compliance
If we can come up with a device to capture and send to an FTP server and allow for VPN connectivity then why can the most powerful law agency in the world not do the same. This way they controll it all. We just provide the pipe to get the data back to their preferred location. I do not know much about CALEA. I am still reading more and more, but if they are asking us to do something, then they had better already know how to do it. ross - Original Message - From: Matt Liotta [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Tuesday, May 01, 2007 9:54 AM Subject: Re: [WISPA] CALEA Compliance Ross Cornett wrote: I still would like to know the amount of incident that this CALEA will cause for all of its costs to our industry. Did anyone ask the FBI, why they cannot have several machines and deliver them as needed pre-configured then we can install them when they are needed. It is highly unreasonable for the FBI to ask everyone to have a utility and manage this utility when it will never be used by a very large portion of our industry. It is far cheaper for the government to sameday ship their device to us anywhere in the nation then it is to have everyone else trying to scramble to satisfy a need that will largely be an expensive dust collector in most businesses. Let's assume that the FBI would send you a box for LI. What about the remaining requirements for CALEA? -Matt -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Compliance
You'd come across a lot of privacy issues giving the FBI that sort of access. - Mike Hammett Intelligent Computing Solutions http://www.ics-il.com - Original Message - From: Ross Cornett [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Tuesday, May 01, 2007 9:59 AM Subject: Re: [WISPA] CALEA Compliance If we can come up with a device to capture and send to an FTP server and allow for VPN connectivity then why can the most powerful law agency in the world not do the same. This way they controll it all. We just provide the pipe to get the data back to their preferred location. I do not know much about CALEA. I am still reading more and more, but if they are asking us to do something, then they had better already know how to do it. ross - Original Message - From: Matt Liotta [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Tuesday, May 01, 2007 9:54 AM Subject: Re: [WISPA] CALEA Compliance Ross Cornett wrote: I still would like to know the amount of incident that this CALEA will cause for all of its costs to our industry. Did anyone ask the FBI, why they cannot have several machines and deliver them as needed pre-configured then we can install them when they are needed. It is highly unreasonable for the FBI to ask everyone to have a utility and manage this utility when it will never be used by a very large portion of our industry. It is far cheaper for the government to sameday ship their device to us anywhere in the nation then it is to have everyone else trying to scramble to satisfy a need that will largely be an expensive dust collector in most businesses. Let's assume that the FBI would send you a box for LI. What about the remaining requirements for CALEA? -Matt -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Compliance
Ross Cornett wrote: I still would like to know the amount of incident that this CALEA will cause for all of its costs to our industry. Did anyone ask the FBI, why they cannot have several machines and deliver them as needed pre-configured then we can install them when they are needed. It is highly unreasonable for the FBI to ask everyone to have a utility and manage this utility when it will never be used by a very large portion of our industry. It is far cheaper for the government to sameday ship their device to us anywhere in the nation then it is to have everyone else trying to scramble to satisfy a need that will largely be an expensive dust collector in most businesses. Let's assume that the FBI would send you a box for LI. What about the remaining requirements for CALEA? -Matt -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Compliance
You need to filter out data that is not under the subpoena. And (as I understand it) the LEA should work with you to get the data. Ross Cornett wrote: If we can come up with a device to capture and send to an FTP server and allow for VPN connectivity then why can the most powerful law agency in the world not do the same. This way they controll it all. We just provide the pipe to get the data back to their preferred location. I do not know much about CALEA. I am still reading more and more, but if they are asking us to do something, then they had better already know how to do it. ross -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Compliance
Prior to CALEA, my plan for helping law enforcement consisted of the following... Introducing them to my upstream (they'd already know them anyway, because my netblocks belong to them) and having them use my provider's nice, secure NOC for tapping into my upstream traffic via a managed switch and mirroring. I have no place to put a mediation box, no place to put any kind of physical tap. I have no physical point this can be done, WITHIN THE BOUNDARIES OF MY NETWORK. Physically, it has to be located at someone else's facility. This is not compliant. And one says why are you stressing? Ok, how many of you have dealt with the IRS? How about electrical codes? Building codes? OSHA? Saying that the feds just want the data is just like saying the IRS just wants some money. Wrong. They want absolute compliance, to the letter. When we had to dispose of solvents and cleaners, we went many rounds with the DEQ for Oregon. There was no accomplish this goal, it was obey the letter, period. Great solutions were not allowed, because they didn't fit the absolute letter. Welcome to the world of regulatory hell. Conversations with people in DC are one thing. They will present as a nice of face as possible to disarm you. The IRS people are pleasant... at first.. too.So was the DEQ. Oh, we don't want to fine you, just get you into compliance, but the moment we talked to them, we had to immediately do what they demanded, or face fines. For instance, we had to clean some parts in something like carb cleaner. It is washed off with high pressure hot water. That means that it, and the water you wash it off with... is hazardous waste. So, limits on the disposal of hazardous waste? Well, we had a gallon limit. So, we said, we buy 20 gallons a year, does this mean we generate 20 gallons of waste? The answer was no. Every gallon of water used to rinse it off became another measured gallon. They told us that the preferred method of disposal was to evaporate the carb cleaner. So, we said great... we'll just rinse it off with water and evaporate the water and cleaner. Nope. if we rinse it with water, then that water counts toward hazardous waste gallons. Stupid, eh? No matter how much water we used, we were still evaporating 20 gallons of this solvent. But the evaporated water was 'hazardous waste and if we mixed too much water in this, we went over the gallon limit. Read the document... They will read your filings, and then they will start on a process of bringing you into compliance. Tapping at your gateway? That's fine. That's good faith to start. Then you will have to demonstrate contined progress toward compliance. Dont' have 24 hour response? That's fine. You will only need to say WHEN you'll have it. You WILL eventually have to capture it at the client end, or at the AP if you're wireless. You WILL provide a date when this will happen. I hate to say it, but it sounds like some very gullible people talked to the feds. They're not the ones who will be reading the forms and assessing fines. They are there to put a nice face on things. But compliance, to the letter? That's what the name of the game is. Always will be. Always has been. What has to be gotten across, is that some technologies do not work this way. They will have to make a definitive statement ( the calea faq is woefully out of date - www.askcalea.net , with contradictory information published later) . I quote: The primary goal of the Order is to ensure that Law Enforcement Agencies have all of the resources that CALEA authorizes with regard to facilities-based broadband Internet access providers (ISP) and interconnected voice over Internet protocol (VOIP) providers. Not to do what you can but to get EVERYTHING they they are authorized to get. That's my opinion of how the future is going to play out, unless something changes between now and then. They make the statement that we don't intend to alter the way networks work. But when you read the way enforcement works.. You will. Just witness how many people are talking about fundamentally altering network operations to be compliant now. But more importantly... from this day forward, you will not be able to start, or deploy a wireless or any other kind of internet providing network that doesn't have ALL aspects of CALEA compatibility built in. That pretty much rules out the vast majority of present equipment and methods of deployment. - Original Message - From: Ross Cornett [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Tuesday, May 01, 2007 7:40 AM Subject: Re: [WISPA] CALEA Compliance I still would like to know the amount of incident that this CALEA will cause for all of its costs to our industry. Did anyone ask the FBI, why they cannot have several machines and deliver them as needed pre-configured then we can install them when they are needed. It is highly unreasonable for the FBI to ask
Re: [WISPA] CALEA Compliance
Hi Ross, To your point below, it was actually the FBI's (and other law enforcement agencies(LEAs)) inability to do just what you describe that precipitated expanding CALEA to facilitates based broadband and interconnected VOIP providers. To date, every time law enforcement has shown up at one of our clients' doors, the intercept had to be handled on an individual case basis (ICB). Now if you think about the variety of broadband offerings (DSL, Cable, Fiber, Wireless, Satellite, Broadband over Power Lines, etc), the endless possible backbone configurations and vendor equipment choices, and then factor in the complexity and mobility of VOIP offerings from Skype to Vonnage, ect, you end-up with a situation where no one LEA can have a 'magic box' that they can drop into every environment that: 1.)collects evidence in a legally admissible manner 2.)protects the privacy of users that aren't targeted Because of this it isn't possible for the LEA to quickly get a intercept up and running in many environments and in time sensitive situations such as an Amber Alert or public safety emergency (i.e. - terrorism), this can be a serious impediment. You also have to remember that Law Enforcement's primary focus is Law Enforcement and not developing technology. The FBI/DEA/DOJ said as much when in 2004 they petitioned the FCC to expand CALEA to broadband and VoIP. Essentially, they argued that it isn't possible for them to keep up with the pace of technology. (By the way, this isn't an ability issue, the FBI and Secret Service, ect. have exceptionally talented teams. Instead it really is a resource issue; the number of staff they have to cover these issues can't cover the scale of the problem.) As a result of the FBI/DEA/DOJ request, the FCC posted a Notice of Proposed Rulemaking (NPRM) in August of 2004 seeking comment from all effected parties (industry, consumers, and law enforcement). In August of 2005 the FCC Released the First Report and Order and Further NPRM that outlined some of the FCC's ruling sought further comment on certain aspects the ruling. In May of 2006 the FCC's Second Order and Report on this issue finalized the expansion of CALEA to facilities based broadband providers and interconnected VoIP providers. Shortly thereafter in June 2006, the DC circuit court of appeals upheld FCC's CALEA Broadband Order in American Council on Education vs. FCC. Hope this helps. Tim Kery BearHill Security, Inc. [EMAIL PROTECTED] Date: Tue, 1 May 2007 09:40:06 -0500 From: Ross Cornett [EMAIL PROTECTED] Subject: Re: [WISPA] CALEA Compliance To: WISPA General List wireless@wispa.org Message-ID: [EMAIL PROTECTED] Content-Type: text/plain; format=flowed; charset=iso-8859-1; reply-type=response I still would like to know the amount of incident that this CALEA will cause for all of its costs to our industry. Did anyone ask the FBI, why they cannot have several machines and deliver them as needed pre-configured then we can install them when they are needed. It is highly unreasonable for the FBI to ask everyone to have a utility and manage this utility when it will never be used by a very large portion of our industry. It is far cheaper for the government to sameday ship their device to us anywhere in the nation then it is to have everyone else trying to scramble to satisfy a need that will largely be an expensive dust collector in most businesses. Anyone know if this has been posed to the FBI. http://www.bearhill.com/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Compliance
I have seen numerous posts on the WISPA list indicating that a cost effective and compliant solution for this issue was being worked on and would become available in the near future. I think that is wishful thinking on some people's part. When you see companies like Cisco struggle to provide a minimum of support on a small subset of their products you can begin to imagine the scope of the problem. Every post I have seen where people have suggest a solution, the suggestion only solved one specific part of CALEA. Solving part of the problem is not enough. I have seen numerous posts indicating that small providers should not be concerned and that attaining CALEA compliance would not put them out of business. I would argue that small providers should be very concerned. Not just about CALEA, but a concerted effort on the part of large telcos to ruin competition through seemingly legimate public safety issues. The facts remain that our business model currently is profitable and we are providing a valuable service in a rural area. The added costs of CALEA compliance jeopardize our ability to continue providing service. Who needs to explain to the hundreds of happy customers I currently service in a rural community that they no longer have high speed internet and dont have an alternative broadband solution? Unfortunately, many consumers will lose as small companies go under. This won't be the first policy that is designed for the good of the many as opposed to the few. It isn't fair, but it is done. If someone has better information on how a small ISP can become CALEA compliant in a cost effective manner, please contact me as I am all ears. If there is better information or a defined solution being presented on the WISPA member list, I am more than willing to pay membership dues to access it. If there isnt a better solution being discussed there, I would just as well save the due money as it will probably not be long before we are out of business or sell to a larger competitor and the membership will be useless. I personally do not believe that any CALEA can be cost effective. Quite simply, solving CALEA requires spending money without earning any additional revenue. The only way to justify the CALEA expense is to accept it as a cost of doing business. This means simply that your market opportunity is lost if you aren't CALEA compliant. I firmly believe every service provider should have plans for being CALEA compliant or have plans for exiting the business. This one is different than E911; the liability will be staggering. -Matt -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Compliance
I'd like to add my own brief CALEA comments and concerns. Out of respect for the maximum of 5 posts per day proposal, I'll keep it short. I'm thinking that extending CALEA to small WISPs without compensating them for their costs has more to do with the big fish eating the little fish than it has to do with national security or fighting crime. It also has a lot to do with Big Brother's quest for efficient control of the citizenry. It's much easier for government overseers to deal with a few big businesses than it is for them to deal with thousands of small businesses. I also can't help but wonder who owns the TTPs. Heck, if some of those are government front companies or owned by friends of people already installed in the Justice Department or the CIA, wouldn't that make illegal information gathering (for business or political purposes) even easier? But that's only my 2 cents worth... and I could be wrong. I'd like to hear the FCC response to Rep. Bart Stupak's request to waive the CALEA regulations for small broadband providers, as described in the following link. http://www.wispa.org/?p=21 In addition, this next link provides an interesting summary of what CALEA means to small ISPs and WISPs. http://www.freerepublic.com/focus/f-chat/1825361/posts jack [EMAIL PROTECTED] wrote: I have seen numerous posts on the WISPA list indicating that a cost effective and compliant solution for this issue was being worked on and would become available in the near future. I think that is wishful thinking on some people's part. When you see companies like Cisco struggle to provide a minimum of support on a small subset of their products you can begin to imagine the scope of the problem. Every post I have seen where people have suggest a solution, the suggestion only solved one specific part of CALEA. Solving part of the problem is not enough. I have seen numerous posts indicating that small providers should not be concerned and that attaining CALEA compliance would not put them out of business. I would argue that small providers should be very concerned. Not just about CALEA, but a concerted effort on the part of large telcos to ruin competition through seemingly legimate public safety issues. The facts remain that our business model currently is profitable and we are providing a valuable service in a rural area. The added costs of CALEA compliance jeopardize our ability to continue providing service. Who needs to explain to the hundreds of happy customers I currently service in a rural community that they no longer have high speed internet and don’t have an alternative broadband solution? Unfortunately, many consumers will lose as small companies go under. This won't be the first policy that is designed for the good of the many as opposed to the few. It isn't fair, but it is done. If someone has better information on how a small ISP can become CALEA compliant in a cost effective manner, please contact me as I am all ears. If there is better information or a defined solution being presented on the WISPA member list, I am more than willing to pay membership dues to access it. If there isn’t a better solution being discussed there, I would just as well save the due money as it will probably not be long before we are out of business or sell to a larger competitor and the membership will be useless. I personally do not believe that any CALEA can be cost effective. Quite simply, solving CALEA requires spending money without earning any additional revenue. The only way to justify the CALEA expense is to accept it as a cost of doing business. This means simply that your market opportunity is lost if you aren't CALEA compliant. I firmly believe every service provider should have plans for being CALEA compliant or have plans for exiting the business. This one is different than E911; the liability will be staggering. -Matt -- Jack Unger ([EMAIL PROTECTED]) - President, Ask-Wi.Com, Inc. FCC License # PG-12-25133 Serving the Broadband Wireless Industry Since 1993 Author of the WISP Handbook - Deploying License-Free Wireless WANs True Vendor-Neutral Wireless Consulting-Training-Troubleshooting FCC Part 15 Certification Assistance for Wireless Service Providers Phone (VoIP Over Broadband Wireless) 818-227-4220 www.ask-wi.com -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Compliance
I personally do not believe that any CALEA can be cost effective. Quite simply, solving CALEA requires spending money without earning any additional revenue. The only way to justify the CALEA expense is to accept it as a cost of doing business. This means simply that your market opportunity is lost if you aren't CALEA compliant. I firmly believe every service provider should have plans for being CALEA compliant or have plans for exiting the business. This one is different than E911; the liability will be staggering. -Matt Matt, We look forward to proving that this thinking is wrong. What part of CALEA compliance is it that makes you think we cannot develop a low cost and reasonable solution which will not break the bank? Scriv -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
RE: [WISPA] CALEA Compliance
John, The part that is causing disbelief for me is the deadline is only days away and I haven't seen this solution or the costing for the solution. Todd Barber Skylink Broadband Internet [EMAIL PROTECTED] 970-454-9499 -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of John Scrivner Sent: Monday, April 30, 2007 9:14 PM To: WISPA General List Subject: Re: [WISPA] CALEA Compliance I personally do not believe that any CALEA can be cost effective. Quite simply, solving CALEA requires spending money without earning any additional revenue. The only way to justify the CALEA expense is to accept it as a cost of doing business. This means simply that your market opportunity is lost if you aren't CALEA compliant. I firmly believe every service provider should have plans for being CALEA compliant or have plans for exiting the business. This one is different than E911; the liability will be staggering. -Matt Matt, We look forward to proving that this thinking is wrong. What part of CALEA compliance is it that makes you think we cannot develop a low cost and reasonable solution which will not break the bank? Scriv -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- No virus found in this incoming message. Checked by AVG Free Edition. Version: 7.5.467 / Virus Database: 269.6.2/781 - Release Date: 4/30/2007 9:14 AM -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Compliance
There won't be a WISPA standard done in time. We're still waiting on some documentation from the FBI and we need to get some internal documentation together as well. But you don't have to be compliant with ANY standard to be CALEA compliant! You just have to understand what you have to do if they ask and have mechanisms in place to do it. The basic parts you'll need are: Linux based router or tap capabilities on the on you have. OR a managed switch that will allow you to mirror a port. Linux server with OpenCALEA and an FTP program on it. Knowledge of how to make it record and distribute the needed data for LEA. You don't HAVE to use a TTP. You don't HAVE to follow a standard. You don't HAVE to panic just yet. *I've* talked to the folks at the FBI. They are NOT interested in running anyone out of business. They just want to catch bad guys and they *may* need our help to do it. Everything past that point is FUD. Why have a standard at all then? Because if you don't follow a standard you have to TRY to do anything that LEA asks of you. If you are standards compliant you only have to do what the standard says you have to do. Believe it or not, guys like Tim at Bearhill are working WITH WISPA in our efforts to develop a low cost/no cost solution to CALEA. We all know that many in this industry are still trying to figure out how to pay the bill on that latest order for 3 cpe units. I was sometimes 60 days behind with EC. I always paid but rarely on time. Sucked for me and for them. Fortunately, they hung with me and today we're as likely to be prepaid as we are to owe them. It's a nice change of pace. We also order radios in bulk, every couple to few weeks, rather than 1 or 2 at a time. Wondering how to make payroll, or buy diapers sucks. Most of us have been there. We got through those times partly because others reached a hand down and helped us where they could. We worked hard, honestly and consistently. I suggest that those of you in panic mode over CALEA go to www.askcalea.net and read up on it. Contact the FCC and the FBI yourselves if you don't believe those of us that are doing this work. So far I've found that folks are more than happy to answer my direct questions. At LEAST contact those that WISPA sent to the FBI! They know a lot of answers and they have a direct line to the FBI if they don't know the answer. Yeah, CALEA is a big deal. Yeah it's complicated. Yeah, it'll suck to have to perform. Yeah, you have to do it anyway :-). Might as well stop whining and start figuring out what all of those ttp's have already gotten figured out. Someone's gonna make money off of those out there that can't/won't figure it out for themselves. Might as well be you! marlon - Original Message - From: Todd Barber [EMAIL PROTECTED] To: 'WISPA General List' wireless@wispa.org Sent: Monday, April 30, 2007 8:19 PM Subject: RE: [WISPA] CALEA Compliance John, The part that is causing disbelief for me is the deadline is only days away and I haven't seen this solution or the costing for the solution. Todd Barber Skylink Broadband Internet [EMAIL PROTECTED] 970-454-9499 -Original Message- From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED] On Behalf Of John Scrivner Sent: Monday, April 30, 2007 9:14 PM To: WISPA General List Subject: Re: [WISPA] CALEA Compliance I personally do not believe that any CALEA can be cost effective. Quite simply, solving CALEA requires spending money without earning any additional revenue. The only way to justify the CALEA expense is to accept it as a cost of doing business. This means simply that your market opportunity is lost if you aren't CALEA compliant. I firmly believe every service provider should have plans for being CALEA compliant or have plans for exiting the business. This one is different than E911; the liability will be staggering. -Matt Matt, We look forward to proving that this thinking is wrong. What part of CALEA compliance is it that makes you think we cannot develop a low cost and reasonable solution which will not break the bank? Scriv -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- No virus found in this incoming message. Checked by AVG Free Edition. Version: 7.5.467 / Virus Database: 269.6.2/781 - Release Date: 4/30/2007 9:14 AM -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Compliance
John, the reason I don't buy it, is as has been said...we're days from the deadline, and we have nothing. And, further, we don't know what's being worked on. There's a whole LOT of issues. There's extraction. There's picking out what's required. There's storage, there's VPN to the LEA, the list just goes on and on and on. Nobody can build a single device or program that can be applied to even the majority of networks. Not even a single point passthrough device that caches everyting (think solera) is going to work, if we have mutliple gateways in physically diverse locations.No solution is going to be universal. We all have such diverse ways of doing things that I'd say that any single solution won't even apply to the majority. There's the data format requirement, and the list goes on and on. What particular aspect is being worked on? The part that converts data to what they want? What about the tools to get the right information? What about a handbook that explains what data is required by the babble that shows up as acronyms or legalese?What about LEA's VPN's? What standard do they follow? Once you start down the road analyzing what you have to do after looking at the requirements, the 'assurances' here, at least, leave more questions than before. Without knowing what WISPA's doing, or anyone else is doing, we don't even know what parts won't work for us and we need to try to synthesize in two weeks. I have many hours of reading everything I can find, starting with the rules published by the FCC. Much of what is being said on this list by WISPA CALEA project people appears to conflict with what I read from the FCC itself.Once you start through the process they outline, you will FULLY comply, or you will exit the business, and that FULLY comply requires a lot of things that have been pooh-pooh'ed publicly here. Now, not to pick a fight, which I don't want to do. Nor to argue the merits of ANY of this, I consider myself reasonably bright and at least somewhat capable of running a WISP... And yet I cannot, seriusly, cannot figure out what I really have to do and not do. Much of what's being discussed here and elsewhere is VERY confusing.For instance, I keep reading that if you follow the industry standard, then you only have to do what's in the standard. But if you don't, then you have to do everything they ask. How the heck can the standard be acceptable if it doesn't do everything they want?If we must capture all the traffic, then it must be done at the client end. If we can't, then we really ARE NOT compliant. What's the point in working on something that's obviously deficient in the first place? Mostly, a lot of us just understand in our guts, that they have all the power, and absolutely NO hesitation in destroying us individually. Washington DC DOES NOT CARE ABOUT INDIVIDUAL PROVIDERS. Learn this, accept it, it is the definitive truth.Reassurances that they're not out to get us is nothing more than the attitude of a few political types in DC that have talked to WISPA people. We won't be dealing with them. Their assurances are... worth less than the ink required to print them out. The only hesitation they have, is if they get painted badly in the evening news.And we'll never make the news. The fact is, the people enforcing the rules are going to go by the letter. The absolute letter, bent as far as possible in the direction they want it bent. And that won't be our favor.Enforcement won't be impressed by but I was assured you won't put me out of business.We're just a number and name, and not even a face. They'll do what government does... hand out fines as agressively as they can justify. And since none of us can individually mount a defense of any kind, we ARE gone and dead. Why WISPA did not say in first response This CANNOT BE DONE, I have no idea. But you spoke for us and said you thought it ws a good idea. You killed us without any more consideration, apparently, than DC has for us. I say this to the people who communicated / filed / responded to the FCC and FBI. Frankly, I suggest we collectively hire some legal counsel to find some way of just stepping around it or a solid strategy for dealing with the fallout. Some real legal eagle shark type stuff. I suspect whether we do our utmost or ignore it, we're mostly going to end up in the same shoes. - Original Message - From: John Scrivner [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Monday, April 30, 2007 8:13 PM Subject: Re: [WISPA] CALEA Compliance I personally do not believe that any CALEA can be cost effective. Quite simply, solving CALEA requires spending money without earning any additional revenue. The only way to justify the CALEA expense is to accept it as a cost of doing business. This means simply that your market opportunity is lost if you aren't CALEA compliant. I firmly believe every
Re: [WISPA] CALEA Costs-Shifting Relief
I'm a bit confused, because I thougth the FCC specifically stated that there is no longer any funds, nor are any applications under those sections accepted anymore. http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-56A1.pdf Relevant paragraph: 2. More generally, we herein specify mechanisms to ensure that telecommunications carriers comply with CALEA. Specifically, under the express terms of the statute, all carriers subject to CALEA are obliged to become CALEA-compliant. We find that sections 107(c) and 109(b) of CALEA provide only limited and temporary relief from compliance requirements, and that they are complementary provisions that serve different purposes, which are, respectively: (1) extension of the CALEA section 103 compliance deadline for equipment, facility, or service deployed before October 25, 1998; and (2) recovery of CALEA-imposed costs. - Original Message - From: Dawn DiPietro [EMAIL PROTECTED] To: [EMAIL PROTECTED]; WISPA General List wireless@wispa.org Sent: Thursday, April 26, 2007 9:38 AM Subject: Re: [WISPA] CALEA Costs-Shifting Relief Peter, Thank you for posting this information. Since there is a $5000 application fee and that the provider has to prove that they have tried to comply I doubt the providers that scream the loudest will even take this information seriously and discount it like everything else we have heard about recently. I have heard on other lists that it is very difficult to get anything to come of this but as you know the misinformation flies rampantly these days. :-) Regards, Dawn DiPietro Peter R. wrote: *Section 109(b)(1) Petitions for Cost-Shifting Relief* CALEA section 109(b) permits a “telecommunications carrier,” as that term is defined by CALEA, to file a petition with the FCC and an application with the Department of Justice (DOJ) to request that DOJ pay the costs of the carrier’s CALEA compliance (cost-shifting relief) with respect to any equipment, facility or service installed or deployed after January 1, 1995. First, the carrier must file a section 109(b)(1) petition with the FCC and prove that, based on one or more of the criteria set forth in section 109(b)(1)(A)-(K), implementation of at least one particular solution that would comply with a particular CALEA section 103 capability requirement is not “reasonably achievable.” Second, if the Commission grants a section 109(b)(1) petition, the carrier must then apply to DOJ, pursuant to section 109(b)(2), to pay the reasonable costs of compliance for one of the solutions proposed in the section 109(b)(1) petition. DOJ may then either pay the reasonable costs of compliance or deny the application. If DOJ denies the section 109(b)(2) application, then the carrier is deemed to be CALEA compliant for the facilities, networks, and services (facilities) described in the section 109(b)(1) petition until those facilities are replaced, significantly upgraded or otherwise undergo a major modification. When those facilities are replaced, significantly upgraded or otherwise undergo a major modification, the carrier is obligated under the law to become CALEA compliant. The FCC may also specify in its CALEA section 109(b)(1) order granting a carrier’s petition the specific date when the replacement, upgrade or modification will occur and when CALEA compliance is required. Thus, a carrier’s obligation to comply with all CALEA requirements is only deferred when (1) the FCC grants a section 109(b)(1) petition, and (2) DOJ declines to pay the additional reasonable costs to comply with one or more of the CALEA requirements. No qualifying carrier is exempt from CALEA. Section 109(b)(1) petitions must be adequately supported, and the FCC decides whether to grant the petition strictly in reference to criteria set out in section 109(b)(1). Accordingly, carriers are encouraged to consult with competent legal and technical counsel before filing such a petition. Please note that a filing fee of $5,000.00 is required to accompany all CALEA section 109(b)(1) petitions filed with the FCC. See Appendix E entitled “Section 109(b)(1) Petitions for Cost-Shifting Relief: Filing Instructions,” and paragraphs 38-57 of the CALEA Second Report and Order http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-56A1.pdf for detailed filing instructions and further explanation of the scope of relief, and its limitations, available under section 109(b). More at the bottom of this page: http://www.fcc.gov/calea/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Costs-Shifting Relief
On one of the documents that I've rad that maybe is not that public, they have taken into consideration that some isp's can not afford to impliment calea and they have a solution for that. Dawn DiPietro wrote: Peter, Thank you for posting this information. Since there is a $5000 application fee and that the provider has to prove that they have tried to comply I doubt the providers that scream the loudest will even take this information seriously and discount it like everything else we have heard about recently. I have heard on other lists that it is very difficult to get anything to come of this but as you know the misinformation flies rampantly these days. :-) Regards, Dawn DiPietro Peter R. wrote: *Section 109(b)(1) Petitions for Cost-Shifting Relief* CALEA section 109(b) permits a “telecommunications carrier,” as that term is defined by CALEA, to file a petition with the FCC and an application with the Department of Justice (DOJ) to request that DOJ pay the costs of the carrier’s CALEA compliance (cost-shifting relief) with respect to any equipment, facility or service installed or deployed after January 1, 1995. First, the carrier must file a section 109(b)(1) petition with the FCC and prove that, based on one or more of the criteria set forth in section 109(b)(1)(A)-(K), implementation of at least one particular solution that would comply with a particular CALEA section 103 capability requirement is not “reasonably achievable.” Second, if the Commission grants a section 109(b)(1) petition, the carrier must then apply to DOJ, pursuant to section 109(b)(2), to pay the reasonable costs of compliance for one of the solutions proposed in the section 109(b)(1) petition. DOJ may then either pay the reasonable costs of compliance or deny the application. If DOJ denies the section 109(b)(2) application, then the carrier is deemed to be CALEA compliant for the facilities, networks, and services (facilities) described in the section 109(b)(1) petition until those facilities are replaced, significantly upgraded or otherwise undergo a major modification. When those facilities are replaced, significantly upgraded or otherwise undergo a major modification, the carrier is obligated under the law to become CALEA compliant. The FCC may also specify in its CALEA section 109(b)(1) order granting a carrier’s petition the specific date when the replacement, upgrade or modification will occur and when CALEA compliance is required. Thus, a carrier’s obligation to comply with all CALEA requirements is only deferred when (1) the FCC grants a section 109(b)(1) petition, and (2) DOJ declines to pay the additional reasonable costs to comply with one or more of the CALEA requirements. No qualifying carrier is exempt from CALEA. Section 109(b)(1) petitions must be adequately supported, and the FCC decides whether to grant the petition strictly in reference to criteria set out in section 109(b)(1). Accordingly, carriers are encouraged to consult with competent legal and technical counsel before filing such a petition. Please note that a filing fee of $5,000.00 is required to accompany all CALEA section 109(b)(1) petitions filed with the FCC. See Appendix E entitled “Section 109(b)(1) Petitions for Cost-Shifting Relief: Filing Instructions,” and paragraphs 38-57 of the CALEA Second Report and Order http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-56A1.pdf for detailed filing instructions and further explanation of the scope of relief, and its limitations, available under section 109(b). More at the bottom of this page: http://www.fcc.gov/calea/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA Costs-Shifting Relief
- Original Message - From: George Rogato [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Thursday, April 26, 2007 11:43 AM Subject: Re: [WISPA] CALEA Costs-Shifting Relief On one of the documents that I've rad that maybe is not that public, they have taken into consideration that some isp's can not afford to impliment calea and they have a solution for that. Yes, you get to submit to them ALL of your financial data, including your ability to borrow, and all state and federal money avaialble... Ohhh...and the fee for filing that you can't afford to comply is $5200, and they'll decide whether or not you can afford it... but you still pay the fee either way. Dawn DiPietro wrote: Peter, Thank you for posting this information. Since there is a $5000 application fee and that the provider has to prove that they have tried to comply I doubt the providers that scream the loudest will even take this information seriously and discount it like everything else we have heard about recently. I have heard on other lists that it is very difficult to get anything to come of this but as you know the misinformation flies rampantly these days. :-) Regards, Dawn DiPietro Peter R. wrote: *Section 109(b)(1) Petitions for Cost-Shifting Relief* CALEA section 109(b) permits a “telecommunications carrier,” as that term is defined by CALEA, to file a petition with the FCC and an application with the Department of Justice (DOJ) to request that DOJ pay the costs of the carrier’s CALEA compliance (cost-shifting relief) with respect to any equipment, facility or service installed or deployed after January 1, 1995. First, the carrier must file a section 109(b)(1) petition with the FCC and prove that, based on one or more of the criteria set forth in section 109(b)(1)(A)-(K), implementation of at least one particular solution that would comply with a particular CALEA section 103 capability requirement is not “reasonably achievable.” Second, if the Commission grants a section 109(b)(1) petition, the carrier must then apply to DOJ, pursuant to section 109(b)(2), to pay the reasonable costs of compliance for one of the solutions proposed in the section 109(b)(1) petition. DOJ may then either pay the reasonable costs of compliance or deny the application. If DOJ denies the section 109(b)(2) application, then the carrier is deemed to be CALEA compliant for the facilities, networks, and services (facilities) described in the section 109(b)(1) petition until those facilities are replaced, significantly upgraded or otherwise undergo a major modification. When those facilities are replaced, significantly upgraded or otherwise undergo a major modification, the carrier is obligated under the law to become CALEA compliant. The FCC may also specify in its CALEA section 109(b)(1) order granting a carrier’s petition the specific date when the replacement, upgrade or modification will occur and when CALEA compliance is required. Thus, a carrier’s obligation to comply with all CALEA requirements is only deferred when (1) the FCC grants a section 109(b)(1) petition, and (2) DOJ declines to pay the additional reasonable costs to comply with one or more of the CALEA requirements. No qualifying carrier is exempt from CALEA. Section 109(b)(1) petitions must be adequately supported, and the FCC decides whether to grant the petition strictly in reference to criteria set out in section 109(b)(1). Accordingly, carriers are encouraged to consult with competent legal and technical counsel before filing such a petition. Please note that a filing fee of $5,000.00 is required to accompany all CALEA section 109(b)(1) petitions filed with the FCC. See Appendix E entitled “Section 109(b)(1) Petitions for Cost-Shifting Relief: Filing Instructions,” and paragraphs 38-57 of the CALEA Second Report and Order http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-06-56A1.pdf for detailed filing instructions and further explanation of the scope of relief, and its limitations, available under section 109(b). More at the bottom of this page: http://www.fcc.gov/calea/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] CALEA articles
A collection of CALEA info: http://www.rad-info.net/fcc/calea4.htm BTW, I even included some links to stuff that Mark would like. Regards, Peter Radizeski RAD-INFO, Inc. - NSP Strategist We Help ISPs Connect Communicate 813.963.5884 http://www.marketingIDEAguy.com -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA articles
Peter, Thank you very much for taking the time to prepare this very informative CALEA page and especially for the following link: http://www.eff.org/Privacy/Surveillance/CALEA/?f=faq.html jack Peter R. wrote: A collection of CALEA info: http://www.rad-info.net/fcc/calea4.htm BTW, I even included some links to stuff that Mark would like. Regards, Peter Radizeski RAD-INFO, Inc. - NSP Strategist We Help ISPs Connect Communicate 813.963.5884 http://www.marketingIDEAguy.com -- Jack Unger ([EMAIL PROTECTED]) - President, Ask-Wi.Com, Inc. FCC License # PG-12-25133 Serving the Broadband Wireless Industry Since 1993 Author of the WISP Handbook - Deploying License-Free Wireless WANs True Vendor-Neutral Wireless Consulting-Training-Troubleshooting FCC Part 15 Certification Assistance for Wireless Service Providers Phone (VoIP Over Broadband Wireless) 818-227-4220 www.ask-wi.com -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
Re: [WISPA] CALEA
We're waiting on the FBI to check a sample data intercept we've sent to them. Image Stream is very close to a fairly inexpensive box that can be used in a pinch. I'll let Jeff B. get into any needed details. We (wispa) are still working on this issue. We're in a holding pattern for the FCC though. Here is a VERY important point that has to be hammered home. You don't HAVE to follow anyone's standard to be compliant. You just have to be able to give the LEA the data. Having a standard limits the things that the LEA can ask you to do. It also give you more specific steps to follow etc. The CALEA team can verify or refute this. I believe it was decided that an MT router could deliver the needed data in the approved format. Mike? marlon - Original Message - From: Matt [EMAIL PROTECTED] To: WISPA General List wireless@wispa.org Sent: Monday, April 16, 2007 1:08 PM Subject: [WISPA] CALEA Where are things at? We paid Kris $100 to file SSI Plan but I am sure another deadline is coming soon. Hopefully a Mikrotik router will suffice. What is next? We are members of WISPA and Part-15. Matt -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/ -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
[WISPA] CALEA FAQ-rant
To All, Thanks to all that participated. I know you worked hard and used valuable time which could have been spent on your business. However, Am I the only person in WISPA who disapproves of this 'STUFF'. This is the way Saudi Arabia is run, and that's a total police state. I know, I spent three years there. Are we just supposed to just swallow whatever the Bureaucrats 'shovel' our way? Man, this scares the bejesus out of me. ARGGG! Ron Wallace Hahnron, Inc. 220 S. Jackson Dt. Addison, MI 49220 Phone: (517)547-8410 Mobile: (517)605-4542 e-mail: [EMAIL PROTECTED] [EMAIL PROTECTED] -- WISPA Wireless List: wireless@wispa.org Subscribe/Unsubscribe: http://lists.wispa.org/mailman/listinfo/wireless Archives: http://lists.wispa.org/pipermail/wireless/
