Mark,
You say there are others that share your view.
Did any of you comment to the FCC about CALEA?
Or do you guys just do that on listservs?
Here's the FCC team:
*Public Safety & Homeland Security Bureau (PSHSB) CALEA Team*:
David Ward, /Senior Attorney/, PSHSB Policy Division (202.418.2336)
Darryl Cooper, /Senior Attorney/, PSHSB Policy Division (202.418.7131)
Eric Ehrenreich, /Attorney Advisor/, PSHSB Policy Division (202.418.1726)
Thomas J. Beers, /Deputy Division Chief/, PSHSB Policy Division
(202.418.0952)
Call them. Tell them your stand on CALEA.
About form 477: It is written into TA96. There was no exceptions in that
section. (It didn't read: any small guys do not have to file). The SBA
Office of Advocacy is the one who usually fights for the over-regulation
of the small business. Unfortunately, the SBA has taken some hits under
the current Administration. But I would suggest writing to that office
about the burden form 477 and CALEA will have on you.
I'm beginning to get the feeling that you want the FCC to cut you a
check for being compliant.
Yes, the original act had monies in it for compliance, but that was
years ago and the cash is gone.
because this silly nonsense that applies to TELCOS doesn't apply to IP
networks.
Instead, we should be telling them that due to diversity and innovation,
it's absolutely impossible to not stifle the way we do things and
conform to
obscure and frankly... SILLY demands.
IF it were me, my comments would be, we as an industry stand ready and
willing to assist law enforcement and homeland security any way we
can, but
it is NOT our obligation to morph our networks into the federal mold
at our
expense. Rather, it is imperative that the FBI, DOJ, and local law
enforcement develop reasonable abilities to deal with IP networks, and
that
we can work with agencies that have reasonable ability to understand and
work with cutting edge technologies, rather than trying to restrain an
entire industry for their convenience.
It is nicely worded. But the two guys at the DOJ know that it is not
rocket science to tap IP streams.
I would add that if you were vigilant, you would have been shouting
about CALEA when ACE and the EFF were fighting it in Federal Court.
I agree that you should have your say to the Feds. Everyone that feels
the same way should indeed write to the DOJ and their Congress Critter
that CALEA is expensive and difficult to apply. My stance is that it is
easier to piss in the wind here and on similar listservs, but to
actually get a petition or letter writing campaign going would be a far
better use of your time, unless you realize that few if any will
actually follow.
No one thinks they can win in DC because no one ever has won in DC.
CLECs spent millions with hundreds of lawyers and were regulated almost
to extinction. Many legal experts predicted that ISP's would win
Brand-X, and yet we lost - badly. So if someone has a plan on how to go
to DC and persuade the powers that be... stand up and be voted President.
And if you think that telco rules do not apply to IP, I think that your
vigilance needs work, because VOIP is IP and there are many, many rules
in place for that.. E-911 is very difficult and costs Vonage millions to
implement and maintain. CALEA on VOIP makes tapping your network look
like grade school stuff. And there is case after case fighting this -
all lost in federal court.
One final point, in today's infrastructure, IP is a replacement
communication system - indeed that is what it is marketed as. Also, in
today's political environment to say that you don't want to be compliant
with CALEA is not PC. You don't want to help catch child porn? Terrorists?
Mark, you make valid points. So take the lead. Draft a message to the
DOJ, the FCC, and Congress. Distribute them. Start getting them faxed
in. You need 7 to go to each person. (7 different ones).
Regards,
Peter @ RAD-INFO, Inc.
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