Re: POLICY ALERT: College and University CALEA Exemption Rests on Private Network Status

[Alan Amesbury <amesbury () OITSEC UMN EDU>]

Rodney Petersen wrote:

> Please excuse any cross-posting of this information.  However, I thought
> that many of you might be interested in the announcement below that
> includes an interpretation of the application of CALEA to institutions
> of higher education after the ruling of the D.C. Court of Appeals.  The
> key document introduced below is available at
> http://www.educause.edu/ir/library/pdf/EPO0654.pdf
[snip]
> From: educause [mailto:educause () EDUCAUSE EDU]
> Sent: Thursday, July 13, 2006 4:55 PM
> To: EMARKETING () LISTSERV EDUCAUSE EDU
> Subject: [EDUCAUSECOPY] POLICY ALERT: College and University CALEA
> Exemption Rests on Private Network Status
[snip]
> "An institution should be exempt where it restricts the use of its
>
> network to particular classes of users (e.g., students, faculty, and
>
> administrators), and where the institution relies on a third party
>
> (such as a commercial ISP or a regional network) to provide the
>
> transmission and switching facilities used to route traffic to the
>
> Internet, rather than self-supplying such facilities," the analysis
>
> concludes.

I have to wonder how "transmission and switching facilities" are
defined, at least in the context of this document.  If an .EDU has a fat
pipe and a /16 provided by friendly.local.isp, then splits its /16 up
using its own switching and routing gear, does it now have to provide
all the intercept capabilities defined in CALEA?  What if it's an .EDU
who's got a narrower pipe with a /24 and uses some cheap managed
switches to segment traffic?  Both are arguably "transmission
facilities" and there's definitely some sort of switching going on.
Note that it doesn't touch on the myriad odd, remote installations that
I'm sure many/most of us have to service.  (Yes, I'll say it:  What of
NAT?  Does each Linksys WRT54G now need CALEA hooks?)


--
Alan Amesbury
(not speaking for the) University of Minnesota