Hi David, >Attachements not allowed to a text newsgroup. Please provide a URL.
http://gullfoss2.fcc.gov/prod/ecfs/comsrch_v2.cgi enter "RM-11376" in box 1 and click on search. You will get the three documents in the docket. The public notice is 2 pages and describes the comment process created. The 74 page PET RM describes the proposed requirements. The relevant NTP related section is provided below. The explicit NPT references occur near the end of the section >Please be aware that the rest of the world no longer follows the US. Were >an international body involved, others might be more likely to listen. Almost every country has a similar requirement. The standards followed globally are those of ETSI and have a required accuracy of one second, but with a recently changed precision expression option to one millisecond. The 200 millisecond requirement and reference to NTP will likely proceed in ETSI. Hope this helps. --tony Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 PETITION FOR EXPEDITED RULEMAKING Filed May 15 2007 United States Department of Justice ..... [At Page 19] B. Timing Information (Time Stamping) 1. Timing Information Is a Required CII Capability Timing information is information that distinguishes and properly associates CII with the content of several communications that occur at approximately the same time. A timing information capability would require a carrier to time stamp each CII message within a specific amount of time from when the event triggering the message occurred, and send the CII message to law enforcement within a defined amount of time after the triggering event. Together, this allows law enforcement to associate the CII message with the communication content information (i.e., the communication) and associate the party contacted by the subject with the communication. The Commission already has held in the Third R&O that a timing information requirement is a CII capability required by CALEA Sections 102(2) and 103(a)(2).46 Specifically, the Commission stated: We will adopt a timing information requirement as an assistance capability requirement of section 103 of CALEA. First, we find that time stamping is call-identifying information as defined in section 102(2) of CALEA. This information is needed to distinguish and properly associate the call identifying information with the content of several calls occurring at approximately the same time. In other words, time stamp information is needed to identify "the origin, direction, destination, or termination" of any given call and, thus, fits within the statutory definition of section 102(2). Second, we find that delivery of call identifying information, including time stamp information, to the [law enforcement agency] must, pursuant to section 103(a)(2), be provided in such a timely manner to allow that information "to be associated with the communication to which it pertains."47 In adopting a timing information requirement, the Commission also adopted specific parameters for delivery of the required timing information. Specifically, a CII message must be transmitted to the law enforcement agency's Collection Function within eight seconds of its receipt by the intercept access point ("IAF") 95% of the time, and with an accuracy within 200 milliseconds.48 The timing information requirement - including the specific parameters for delivery of the required timing information - was codified in the Commission's rules49 and remains in force today. As a result of the Commission's conclusions in the Third R&O and the adoption of a rule requiring a timing information capability, the timing information (time stamping) capability was added by industry to J-STD-025-A.j0 As more fully discussed below, there is no reason why this capability should not have been included in J-STD-025-B. 2. The Commission Should Reaffirm That Timing Information (Time Stamping) Is a Required Capability Despite the requirements of CALEA Section 103(a)(2) and the Commission's directive in the Third R&V, J-STD-025-B does not contain language that establishes specific parameters for delivery of the required timing information (time stamping). As a result, unlike its predecessor J-STD-025-A, J-STD-025-B is ambiguous as to whether the Commission's timing requirements for accuracy and delivery of CII apply to packet data services. J-STD-025-Bs ambiguity over the timing information (time stamping) capability arises from a footnote added to a June 2004 version of J-STD-025-B at the request of an industry representative. The footnote stated that the Third R&O's timing "requirement is established by the [Commission] for circuit-mode only."51 Notwithstanding that the Commission's Third R&O clearly addressed both circuit-mode and packet-mode communications,52 certain TIA members took the position - based on the addition of the footnote - that the Commission's time stamping requirement does not apply to any packet data services. Although the footnote subsequently was removed from J-STD- 025-B, that standard is silent as to whether timing information (time stamping) must be provided, and several TIA members continue to this day to dispute whether the timing requirements set forth in the Third R&O apply to packet data services. The Commission held in the Third R&O that circuit- and packet-mode communications services are each subject to CALEA, and adopted capabilities in the Third R&O that apply to both circuit- and packet-mode services.53 Given the Commission's holding, it is entirely unclear why certain TIA members continue to maintain that the time stamping requirement does not apply to packet data services. The Commission should make clear that, irrespective of what the standard states, carriers nonetheless must comply with the letter and spirit of the Commission's timing information capability rule. Although the Commission concluded in the Third R&O that J-STD-025 (later J- STD-025-A) was not a sufficient CALEA solution for packet-mode services,54 the Commission set a September 2001 deadline for packet-mode compliance,55 and specifically requested that TIA "study CALEA solutions for packet-mode technology and report to the Commission [by September 20001 on steps that can be taken, including particular amendments to J-STD-025."56 It is clear from the Commission's statements that such packet-mode compliance would include providing the capabilities adopted in the Third RDO via amendments to J-STD-025 - i.e., in J-STD-025-B. Therefore, there is nothing in the Third RbO that suggests that the capabilities adopted therein - including the timing information (time stamping) requirement - do not apply to packet-mode (data) services.57 Nor is there anything in the Third RbO that would preclude the application of the timing information requirements specified therein to packet-mode (data) services. In fact, the Commission's rules contain no distinction about the type of communications ( i e , circuit-mode vs. packet-mode) to which the timing capability applies; the rules state only that "wireline, cellular, and PCS telecommunications carriers shall provide to a [law enforcement agency] [a timing information capability]."58 Highly accurate timing information is critical for a number of important reasons. First, as the Commission recognized, time stamping is critical to proper correlation of the CII events to the associated intercepted communications content stream. 59 The less accurate the time stamp, the greater the possibility that multiple events occurring in the same time frame will lead to a misinterpretation of the sequence of CII events. Second, unlike traditional circuit-switched networks, electronic intercepts in packet data sessions may occur at multiple points (nodes) within a carrier's network. In fact, because of the diffuse nature of packet-based technologies (i.e., that packet data sessions can occur at multiple nodes in a carrier's network and involve multiple IAPs), time stamping is even more critical in the packet-mode communications context than the circuit-mode context. Thus, it is critically important that time stamping occur so that the CII events between these multiple network nodes can be properly correlated with the communications content. Third, multiple simultaneous packet data sessions can be established by a user of packet-mode services. A time stamp capability is needed to correlate the CII events and communications content on a timeline for each session, and to permit law enforcement to distinguish between CII events for each different session. Moreover, to the extent that two communications sessions may be related, this level of accuracy will allow law enforcement to correlate, where necessary, the two sessions. Finally, accurate time stamping for packet data intercepts - regardless of the format used to deliver the intercepted communications to law enforcement - is crucial to law enforcement's reconstruction of the sequence of events contained in the interception. The lack of accurate timing information (time stamping) requirements frustrates CALEA's purpose because it impedes law enforcement's ability accurately to associate CII with communications content. Indeed, as a practical matter, without accurate time stamping, law enforcement may not be able to correctly determine when the CII events occurred or correlate them with the communications content. As a result, a court order can be frustrated as much as if the information were not delivered to law enforcement at all. Given that packet mode communications are subject to CALEA,60 and in light of the Commission's conclusion in the Third R&0 that timing information is CII under Section 102(2), 61 there is no rational basis for omitting a timing information (time stamping) assistance capability from a packet mode standard such as J-STD-025-B. Indeed, the fact that a time stamping capability is more significant with respect to packet-mode communications should compel its inclusion in such standards. Therefore, in order to resolve any ambiguity, DOJ requests that the Commission reaffirm that a timing information (time stamping) requirement is applicable to packet data services, regardless of the technology used by the carrier to provide the service. In addition, DOJ asks the Commission to require that carriers provide, at a minimum, a timing information (time stamping) capability that meets the requirements prescribed in the Third R&O and codified in the Commission's rules - including the specific parameters for delivery of the required timing information. 62, 63 FOOTNOTES 46 Third R&O at 16835 para. 95. 47 Id. 48 Id. at 16835 para. 96. 49 47 C.F.R. Secs. 64.2202, 64.2203(c) (now contained in 47 C.F.R. secs. 1.20007(a)(14), (b)(5)). 50 See ANSI/J-STD-025-A-2003, sec. 4.7. 51 Ballot Version of ANSI J-STD-025-B, secs. 3, 4.7 n.2 (June 2004) (emphasis added). 52 Third R&O at 16795 para. 1. 53 Id. 54 Third R&O at 19819 para. 55. The Commission's conclusion was rooted in its concerns about the technical mechanisms for providing the required capabilities to law enforcement, rather than the required capabilities themselves. See id. at 16795 para. 1, 16819-20 paras. 55-56. 55 Id. at 16819 para 55. 56 Id. (emphasis added); see also id. at 16820 para. 56. TIA commenced work on the J-STD- 025-B packet data standard in direct response to the Commission's directive in the Third R&O. 57 Third R&0 at 16795 para. 1,16819-20 paras. 55-56. 58 47 C.F.R. sec. 1.20007(b)(5). 59 Third R&O at 16835 para. 95. 60 Id. at 16795 para 1. 61 Id. at 16835 para 95. 62 The 200 millisecond time stamp requirement prescribed in the Third R&O (see Third R&O at 16835-36 paras. 95-96) is reasonable for industry with respect to packet-mode services because it already is included in various CALEA packet data standards (e.g., ANSI standard T1.678; ANSI standard T1.724; TIA Trial Use Version of J-STD-025-B) and has been deployed by vendors and carriers. Moreover, several equipment manufacturers have stated publicly that the 200 millisecond time stamp requirement is feasible and provided by their equipment. There are also a number of protocols that support time synchronization of up to one (1) millisecond, including the Network Time Protocol (see IETF RFC 1305), Simple Network Time Protocol (see IETF RFC 2030), and the Precise Time Protocol (PTP) (see IEEE 1588). 63 Since a time stamp indicates the date and time that an event is detected in the network, the time stamp also should include the time zone offset from universal coordinated time (UTC). A number of vendors already provide this feature as part of the time stamp capability. _______________________________________________ questions mailing list [email protected] https://lists.ntp.isc.org/mailman/listinfo/questions
