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CALEA Broadband Coverage Order (2005)

The order that brought broadband and VoIP inside CALEA. It answered the question every IP provider had been asking since 1994 — does this apply to us? — and left a few it never came back to.

What it is

CALEA and Broadband Access and Services — First Report and Order and Further Notice of Proposed Rulemaking

The CALEA Broadband Coverage Order is a ruling of the Federal Communications Commission establishing that the CALEA statute governs not only traditional telecommunications carriers but facilities-based broadband Internet access providers and two-way interconnected VoIP providers. Facilities-based broadband Internet access is defined to cover all broadband platforms, including cable modem, wireline (DSL), wireless and satellite. Two-way interconnected VoIP is a VoIP service capable of transporting calls both to and from the public switched telephone network.

The FCC reached that result through CALEA's unique definition of "telecommunications carrier." For most FCC purposes the term is defined by the Communications Act of 1934. CALEA sets out its own definition, which contains a "substantial replacement provision": if the FCC finds that a service is a replacement for a substantial portion of the local exchange service, it may deem the provider subject to CALEA. The FCC ruled that both facilities-based broadband Internet access and two-way interconnected VoIP provide such a replacement.

The order also opened a Further Notice of Proposed Rulemaking asking, among other things, whether CALEA should extend to one-way interconnected VoIP and whether a streamlined set of requirements should exist for small or rural providers. The FCC never followed the Further Notice with a report and order deciding those questions, so they remain unresolved. The D.C. Circuit upheld the order in American Council on Education v. FCC (2006).

What it says

The parts that matter to a provider.

Facilities-based broadband is covered

Providers of transmission or switching over their own facilities between the end user and the Internet — cable, DSL, fiber, wireless, satellite — provide a replacement for a substantial portion of local exchange service and are telecommunications carriers for CALEA purposes.

Interconnected VoIP is covered

A VoIP service that permits users to receive calls from and terminate calls to the PSTN. The information-services exclusion does not apply to it; the FCC noted that call-management and call-setup information available to a VoIP provider is unlikely to be available to a broadband provider.

The substantial-replacement provision

The legal hinge of the order. CALEA's carrier definition reaches beyond the Communications Act's, and the FCC used it to bring IP services inside the statute without reclassifying them as telecommunications services for any other purpose.

What it did not decide

One-way interconnected VoIP and streamlined obligations for small providers were put out for comment and never resolved. Establishments that merely provide Internet access to patrons — hotels, coffee shops, libraries — are not covered; the underlying provider is.

Who it reaches

Does this apply to you?

Every facilities-based broadband Internet access provider and every interconnected VoIP provider in the United States, from national networks to the smallest ISP or hosted-voice provider whose service reaches the PSTN both ways.

The document

First Report and Order, FCC 05-153

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