TR45 LAES/2004.08.11.08 R1 1 2 3 4 Telecommunications Industry Association TR-45.2 Intersystem Operations 5 6 7 8 Montreal, Quebec, CANADA August 11, 2004 9 10 11 12 13 TITLE: Proposed Re-organization of TR45 LAES Work Product DATE: August 11, 2004 14 15 16 17 18 19 20 21 SOURCE: Ben Levitan 22 23 Work: Mobile: E-Mail 24 25 26 703-856-3222 703-856-3222 Ben.Levitan@nextel.com 27 28 29 30 31 ABSTRACT: This contribution proposes re-organization of the J-STD-025 work and related Lawfully Authorized Electronic Surveillance work for efficiency. 32 33 34 RECOMMENDATION: 35 36 Review, discuss and approve recommended proposal. 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 Notice 54 The contributor grants a free, irrevocable license to the Telecommunications Industry Association (TIA) to incorporate text or other copyrightable material contained in this contribution and any modifications thereof in the creation of a TIA Publication; to copyright and sell in TIA's name any TIA Publication even though it may include all or portions of this contribution; and at TIA's sole discretion to permit others to reproduce in whole or in part such contribution or the resulting TIA Publication. This contributor will also be willing to grant licenses under such copyrights to third parties on reasonable, non-discriminatory terms and conditions for purpose of practicing a TIA Publication which incorporates this contribution. This document has been prepared by NEXTEL Communications to assist the TIA Engineering Committee. It is proposed to the Committee as a basis for discussion and is not to be construed as a binding proposal on NEXTEL Communications. NEXTEL Communications specifically reserves the right to amend or modify the material contained herein and nothing herein shall be construed as conferring or offering licenses or rights with respect to any intellectual property of NEXTEL Communications other than provided in the copyright statement above. The company represented by this individual may have patents or published pending patent applications, the use of which may be essential to the practice of all or part of this contribution incorporated in a TIA Publication and the company represented by this individual is willing to grant a license to applicants for such intellectual property contained in this contribution in a manner consistent with 2a) or 2b) of Annex H of the TIA Engineering Manual. A license under any Essential Patent(s) or published pending patent application(s) held by the undersigned company will be made available under reasonable terms and conditions that are demonstrably free of any unfair discrimination to applicants only and to the extent necessary for the practice of the TIA Publication. 55 56 57 58 59 60 61 62 63 64 65 66 67 68 TR45 LAES/2004.08.11.08 R1 1 2 3 4 5 6 7 8 9 10 Executive Summary This contribution proposes a reorganization of the Lawfully Authorized Electronic Surveillance work. The original work was intended for circuit switched systems and was appropriately developed as a joint effort between the wireless and wireline community. 11 12 13 14 Today, a wide variety of networks, systems and technologies have evolved that are under the mandate to support law enforcement. Attempts to add all the new technologies to J-STD-025, (a circuit switched solution) have been ineffective and confusing. 15 16 17 18 19 20 Further, since many vendors required to support CALEA compliance build stand-alone platforms for the specific technologies, the approach of using “one standard” is inefficient. The current working arrangement does not lend itself to have the true experts of these technologies involved in the development of the standard. 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 This contribution suggests that: 1) J-STD-025, the current standards document should service two functions. a. The document becomes the index of to all CALEA solutions, pointing to existing or developing CALEA standards that are technology or service specific and are developed by the experts in that technology. b. The current J-STD-025 standard will becomes a requirements document repository for CALEA compliance c. The current J-STD-025 document will break off the section that contains the solution for circuit switched CALEA compliance as a separate document, which will serve as the circuit switched telephony solution. 2) TR45 LAES (the ad hoc standards group of TR45) should become a focus group of the TR45 committee and meet as a part of that meeting. The LAES focus group will be the “CALEA compliance advisory team for the TR45 assuring that any new projects developed have built CALEA capability into their systems if judged necessary by law enforcement and the FCC (just as TR45 AHAG takes the role of security review of all new projects.) Further, they can act as advisors to developers of CALEA solutions rather than attempt to bring the technology experts to the LAES meetings, which has not been largely successful. 3) There are a number of existing CALEA solutions for various technologies which don’t need to be reinvented and placed in J-STD-025. These only have to be pointed to in J-STD-025 re-organized document. To have a document included in the J-STD-025 “Index” the technical committee must have their document approved through their own standards development process and approved by the CIS. 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 Introduction Lawfully Authorized Electronic Surveillance (J-STD-025) was originally developed in 1997 in response to the 103rd Congress of the United States new Public Law 103-414 requiring telecommunications carriers to provide cooperation with law enforcement in the interception of communications. In the ten years since the inception of the law, telecommunication capabilities have increased dramatically and the variety of access types have increased significantly. Further, the network has increasingly become “unbundled” (meaning that carriers don’t have to buy turnkey networks from a single vendor. Due to standards which define the network as a series of functional entities, a carrier has the option of building their network using equipment that is connected together in a compatible manner that comes from multiple vendors.). Further, carriers can now combine multiple technologies in a network allowing a migration from 2G networks to 3G networks in an evolutionary manner. J-STD-025 was an appropriate tool for telecommunication providers and law enforcement in 1994 however in 2004, it has become clear that a single document is unwieldy and is actually inappropriate as a guide to CALEA compliance. 64 65 66 67 68 02/17/2016 2 of 6 Nextel Communications TR45 LAES/2004.08.11.08 R1 1 2 J-STD-025 was appropriate for circuit switched switch-centric systems. With the advent of IP networks, IMS, broadband networks for voice communications and the large number of service specific platforms such as Multimedia Media Messaging Service (MMS) servers, Push-to-Talk over Cellular (PoC) servers and fraud systems, a single Surveillance document is no longer appropriate nor is it serving industry’s needs. Additionally, it is not possible for the TR45 LAES Ad Hoc to gather all the necessary experts needed to produce technically accurate recommendations for each of the new platforms and technology networks in service today. 3 4 5 6 7 8 9 10 11 This contribution proposes a reorganizing of the CALEA documentation to be more useful for service providers, manufacturers, third-party service providers and law enforcement. TR45 LAES Ad Hoc would then be responsible for the “Table of Contents” of the plethora of wiretap standards and for the identification of CALEA mandated capabilities. The technology experts in each specific area will produce the recommendations with assistance and liaison with TR45 LAES Ad Hoc. 12 13 14 15 16 17 18 19 Scope of LAES 20 21 TR-45 LAES Ad Hoc’s technical areas of responsibility is the development of standards, recommendations and technical reports to support Law Enforcement’s need in the United States for surveillance of a subscribers communication use and activity (“wiretap”) when lawfully authorized by an appropriate court order. 22 23 24 25 26 TR-45 LAES Ad Hoc produces surveillance capabilities for all subscriber useable features, standards and networks developed by any TIA committee, including circuit switched and packetized network architectures. 27 28 29 30 31 The original solution for LAES published in 1997 was predominately a solution for the circuit switched public network and the circuit switched mobile telephony network. As such, a joint recommendation was appropriate. 32 33 34 35 Court challenges, industry negotiations and actual implementations revealed a number of challenges in the document, which lead to additions, changes and several upgrades. 36 37 38 39 40 Proposal 41 42 This contribution proposes the restructuring of the J-STD-025 series recommendation in order to make it easier for service providers, manufacturers, third party providers and law enforcement themselves to develop standards. Further, this new structure enables equipment vendors to more easily build CALEA compliant systems and allows law enforcement to more easily declare “compliance”. 43 44 45 46 47 This contribution proposes the “unbundling” of J-STD-025 into more manageable pieces that will allow all parties to more easily use the standards, and easily find the sections of the standard that are appropriate to their equipment or service. 48 49 50 51 52 For example, companies that provide data only services have no need to understand or implement the voice capabilities of J-STD-025 however, without implementing the full J-STD-025 they can be considered “non-compliant”. Further, if that company provides services as a “third party provider” to a network, it is unclear who is responsible for the CALEA compliance of the equipment. Ultimately, the Operator is responsible, however, often with third-party solutions, the Operator does not have access to the data used by the third party thus often point to that equipment as the “network provider”. Unbundling will solve these problems. 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 02/17/2016 3 of 6 Nextel Communications 68 TR45 LAES/2004.08.11.08 R1 1 2 3 4 5 6 7 Justification of Unbundling/Reorganizing a. Third Party Scenarios – During the implementation of J-STD-025 in 1999, several operators were using a third party fraud solution. The solution intercepted ANSI-41 Registration Messages from visiting systems and performed validation on behalf of the carrier. Under CALEA, the third parties equipment was part of the carrier’s network; however, since the network only received a small number of the registration messages they could not report “Serving System” changes to Law Enforcement. The Operator pointed to the third party as the “network” responsible for providing this information. The third party, since it only saw IS-41 registration messages and no voice services, could not become fully CALEA compliant without a negotiated agreement with Law Enforcement. These negotiations were extensive and never full resolved. Providing a “recommendation” for the fraud systems would have solved the problems of both the Operator and the Third Party. This is also the case for “Messaging Systems” such as stand alone SMS systems, stand alone MMS servers and in the future PoC services and systems. b. Inappropriate Parallels – Much discussion has taken place lately on how to fit Voice over Packet Networks into J-STD-025. Each section of J-STD-025 has been reviewed and the discussion has centered on what changes have to be made to support VoP. For example, the circuit switched section of J-STD-025 requires that after cut through, any dialed digits (DTMF tone) entered by a subject need to be reported. This was originally intended to determine what numbers are being dialed by a subject who is using an 800-number calling card to place multiple calls during a single “call session”. There is not really an appropriate parallel in VoP. Attempting to fit the round pegs of VoP into the square holes provided by J-STD-025 is simply not appropriate. A separate recommendation on VoP would be more appropriate, and serve industry and law enforcement more effectively. Similarly, in other cases of this technology and other new technologies, some requirements do not "translate" directly from one technology to another, requiring a revision of the requirement. In other instances, the solutions to provide similar information may be completely different. There may not be identical parallels of all circuit switched concepts in all technologies. c. Future Services Evaluated – The FBI filed with the FCC to review interception requirements for Broadband, PoC, and other services. These services may provide end-to-end voice communications without the involvement of a circuit switch public network at all. As such providing these networks with J-STD-025 as their source for CALEA compliance information would only be confusing and ineffective. d. Separate needs for separate networks – J-STD designation shows that the recommendation is a joint effort. In this case the work started as a joint effort of TIA and Committee T1. Today the two groups work in parallel and there is little “joint” work at this point. e. Simplify voting and balloting – Tremendous confusion has ensued due to the Joint Balloting process that has been used for LAES. From the first ballot where, TIA approved the ballot and T1 rejected it, there have been difficulties in maintaining a consistent set of documents. Unbundling of the recommendation will allow the most technically aware parties to vote on the separate recommendation as appropriate. For example, in the case of Packet Cable standards, the Packet Cable Association, with it’s own experts, can develop and approve a recommendation related to its own technology. TR45 LAES Ad Hoc can update their “index” to allow parties interested in locating Packet Cable CALEA specifications to easily locate them. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 Proposed Re-organization of J-STD-025 62 63 64 65 66 The CALEA law Public Law 103-414 has four basic requirements: 1) Expeditiously intercept call content 2) Expeditiously intercept call identifying information 67 68 02/17/2016 4 of 6 Nextel Communications TR45 LAES/2004.08.11.08 R1 1 2 3) Deliver the information to Law Enforcement at a location away from the carriers premise 4) Make the system unobtrusive and minimize interference. Protect all identities. This is the basis of the CALEA recommendation. As such it is proposed that the following reorganization take place. The actual final “names” of the recommendations is not considered here nor is it pertinent to the discussion at this point. If it is desired, J-STD-025 can be superceded, revised, or renumbered. A new recommendation could supercede J-STD-025 and newly numbered recommendations can be issued based on a new project number. 3 4 5 6 7 8 9 10 11 12 The current J-STD-025 work should be RESTRUCTURED into several volumes and modified as such: 13 14 a) b) c) d) e) f) g) h) Volume 1: Introduction to CALEA – Includes the purpose and legal mandate for CALEA. Much of the existing discussions already in J-STD-025 series can be kept in this section. Volume II: Description of CALEA – Includes the Stage 0 description of LAES. Much of this is already well discussed in J-STD-025 and can be reused in this section. Also the Stage 1 descriptions of CALEA in J-STD-025 are appropriate. Volume III: Encoding for LAES – This section discusses the LAESP developed for communications to the LEA equipment. Much of the text already in the protocol section of JSTD-025 is still valid. Volumes IV: NEW SECTION – Development of LAES recommendations for communications technologies. This section will describe a standardized approach for developing a recommendation for any new technology. It will provide a checklist for technology owners to develop a “safe harbor” recommendation. For example, in the case of third party fraud system provider described on page 4a above, the approach would lead the developers to the conclusion that they did need to provide CALEA compliance for all call identifying information they have readily available but not for any of the voice capabilities required by CALEA. Further, the final recommendation that they would produce would be in “technology language appropriate terms” rather than the forced terms used in J-STD-025 and make it easier for the developers to build CALEA into their equipment yet easily meet the four goals intended by Congress in Public Law 103-414. Volume V: Definitions and Acronyms for LAES – This section can be pulled right from the existing LAES J-STD-025 documentation Part VI: NEW SECTION – Index to LAES recommendations for communications technologies. This section is simply a living list of recommendations that support CALEA compliance. It may contain a short description of each technology. An example of the section is shown: a. Public Switched Telephone Networks – J-STD-025-A published by TIA. Provides safe harbor for telecommunication networks that provide circuit switched telephony services. b. Multi-media Messaging Service Platforms - Recommendation XXX published by YYY. Provides safe harbor for telecommunication platforms that support Multimedia Messaging. c. Broadband Networks – Recommendation AAA published by BBB. Provides safe harbor for stand-alone broadband networks. d. PoC – Recommendation CCC published by DDD. Provides safe harbor for Push-toTalk over Cellular Networks. Volume VII: Public Switched Telephone Networks – This section can be pulled right from the existing LAES J-STD-025-A documentation. This provides the safe harbor for telecommunication networks that provide circuit switched telephony services. Volumes VIII – TBD: Individual Volumes developed by TIA Committees for different technologies/services (as appropriate). 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 02/17/2016 5 of 6 Nextel Communications 68 TR45 LAES/2004.08.11.08 R1 1 2 3 4 5 6 Proposed Re-alignment of TR45 LAES Ad Hoc Mission and Scope or disbanding of the Ad Hoc 7 8 9 10 11 12 13 14 15 16 17 After these changes are implemented and the Lawfully Authorized Surveillance documents across the industry are indexed, there may no longer be a need to have an Ad Hoc for LAES. Updates and maintenance for the documents can occur under the TR45 committee per standard document maintenance rules. If it is determined that the group needs to continue, the group does not need to meet separately from TR45. Since the attendance to the stand-alone meetings has been minimal in the past two years, it would benefit the topic to meet as part of TR45 as a whole during the quarterly meeting. The group could simply be reduced to the status of a focus group. 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Should the group remain as an ad hoc, the mission and scope of TR45 LAES Ad Hoc would need to be aligned with this re-organization of the J-STD-025 work. The group should be a focal point of information to TIA/TR-45 members on CALEA work TR45 LAES Ad Hoc would fold back into TR45 as a focus group and perform: 1) Management and tracking of the TIA/TR-45 CALEA projects. They will provide a central place for law enforcement and carriers to determine what documents are needed to provide safe harbor. Also advise other TIA/TR-45 committees and possibly external organizations of the need to develop CALEA standards for their network equipment or systems. 2) Management of Part I to VI of the reorganized J-STD-025. This includes: a. Adding new requirements for CALEA as determined by court decisions or FCC action for those technologies within the scope of TIA/TR45 LAES. b. Updating of the Part VI, the index of recommendation. c. Voting on the changes to Parts I to VI per TIA procedures. 35 36 37 Reinstatement of the Goal 38 39 40 41 42 In the end, the goal of this contribution is to assure that the very important law enforcement work move forward in an efficient manner that satisfies Carriers, Vendors, Users, Law Enforcement and the Public Interest and further that the maximum participation in the decisions that need to be made for this deliverable be achieved. 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 02/17/2016 6 of 6 Nextel Communications