[ntp:questions] Petition to FCC for accurate timestamps and NTP

mills at udel.edu mills at udel.edu
Wed Jun 6 18:09:53 UTC 2007


Tony,

You got me going. So far as I see, the timestamping issue is centered 
only on wiretap (CALEA) issues. I scanned CFR Title 47 at the FCC 
looking for Part 102 et seq, as revealed on the CALEA page, but the list 
ends at Part 101. I learned from other searches that some Parts are way 
out of date.

To comply with CALEA, all a VoIP operator would need to do is send an 
NTP packet to time.nist.gove and attach the transmit timestamp in the 
reply to the intercept report. For just about any provider, that should 
be good enough.

Dave

Tony Rutkowski wrote:

> Hi Dave,
> 
> 
>>The DoJ and FBI strategy apparently is to request the FCC to promote the
>>DoJ position as a rulemaking issue. That is an interesting strategy, as
>>formerly the carriers operated with a voluntary industry standard. The
>>Feds didn't get what they wanted in the industry standard, so  now they
>>want the FCC to be the hammer.
> 
> 
> That's a good summary, although it's worth noting that some of the
> history - namely that the carrier industry refused a 100 millisecond
> timestamp requirement back in 1999, and it went to the FCC then
> and they imposed 200 milliseconds as a compromise and placed the
> requirement in the Code of Federal Regulations directly.  They also
> last year reapplied the same requirements in the CFR to IP services,
> so it is possible the FCC may simply say this - it's 200 ms, it's in the
> CFR, providers must comply irrespective of what's in or not in any
> industry standard.
> 
> Most other countries have similar requirements, only the work is
> done through ETSI standards and the national authority imposes
> the standards.  Those standards are now 1 second, but different
> countries impose more tight specifications.
> 
> 
>>The issue on timestamping says nothing about NTP, just the accuarcy
>>requirement of 200 ms and delivery of the intercept within 8 s. It says
>>nothing about UTC or NIST/USNO traceability.
> 
> 
> You've put your finger on the key omission.  The FCC requirement
> implies traceability - just as they do for frequency standards
> requirements - but doesn't explicitly state it.  Some of the U.S.
> standards groups have taken that "hole," and actually recast the
> implied traceability requirement to be a local network clock with
> no stated accuracy or traceability.  Thus the timestamp becomes
> essentially worthless as the local clock could be reset to 1970
> and still meet the standard.
> 
> There is a need for counsel by folks who know something about
> time specifications.  Whatever one's views about the context of
> the requirement, getting the right specifications articulated and
> good NTP based time practices driven into the infrastructure seems
> like a "good thing."
> 
> --tony
> 
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