Everyone involved in CALEA and Lawful Intercept should be well aware of the May 14 CALEA compliance deadline for "facilities-based broadband" and "inter-connected VoIP" providers. But one of the other intermediary dates is fast approaching (only 11 days to go). February 12th is the deadline for the filing of Monitoring reports. And as such I thought a quick refresher and review of this form and its' purpose might be useful.
Back on December 12th the OMB (in compliance with the Reduction in Paperwork Act) authorized the FCC to move forward with requiring service providers to file Monitoring reports. The FCC's declaration of the approved dates and the forms themselves can be found at the link below.
http://www.fcc.gov/Daily_Releases/Daily_Digest/2006/dd061214.html
and look for:
Released: 12/14/2006. OMB APPROVES CALEA COMPLIANCE MONITORING REPORT FOR PROVIDERS OF FACILITIES-BASED BROADBAND INTERNET ACCESS AND INTERCONNECTED VOIP SERVICE; REPORTS ARE DUE FEBRUARY 12, 2007. (DA No. 06-2513). (Dkt No 04-295). PSHSB. Contact: Thomas J. Beers at (202) 418-0952 DA-06-2513A1.doc DA-06-2513A2.doc DA-06-2513A3.doc DA-06-2513A1.pdf DA-06-2513A2.pdf DA-06-2513A3.pdf DA-06-2513A1.txt DA-06-2513A2.txt DA-06-2513A3.txt
The reason for the Monitoring Report (445 form) filing is so that law enforcement understands the progress being made by carriers to reach compliance. In the late 90's when carriers were working to reach compliance for the first CALEA deadline(s), law enforcement had no idea where everyone stood until the deadline was reached. This time they are requiring "progress" reports to give them a better idea of where things stand.
For a 445 filing, there are 3 relevant documents:
DA-06-2513A1 - this describes the ruling and the fact that the Office of Management and Budget has now fulfilled the requirements of the Reduction in Paperwork Act (the item that held the dates up to begin with) and the reports can now be filed
DA-06-2513A2 - This is the instructions document. This describes each of the lines in the actual 455 form, what should be filled in, where copies are to be sent and by when.
DA-06-2513A3 - This is the 445 Form itself. This is a brief 4 page document with 12 line items (the first 7 really don't count) to fill in and a small glossary. No essay questions, no multiple choice, no true/false, just simple questions as described below.
Form 445 Questions:
1 -7 Contact information: Name, State, FCC #, 499 Id, affiliate names, parent company, address
8. Will your networks be compliant by May 14?
Type of facilities
9. Which networks will not be compliant?
Type of facilities
Expected date to reach compliance
Reasons for delay
10. Compliance Method(s) being used
Industry standard
Proprietary/custom
Consultation with DOJ
TTP If so which one?
11. What items are causing delays?
Type of Equipment
Installation
Manufacturer
Other
Mediation Actions being taken to resolve the delays
12. Signature of company officer
So all in all pretty simple. Take a look and feel free to comment. Till next time ...
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1 comment:
Good words.
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