Minutes of the 2013-06-03 IAB Teleconference (Tech Chat)
- Bernard Aboba
- Jari Arkko (IETF Chair)
- Marc Blanchet
- Ross Callon
- Alissa Cooper
- Joel Halpern
- Russ Housley (IAB Chair)
- Xing Li
- Cindy Morgan (IAB Executive Assistant)
- Andrew Sullivan
- Dave Thaler
- Hannes Tschofenig
- Mary Barnes (IAB Executive Director)
- Lars Eggert (IRTF Chair)
- Heather Flanagan (RFC Editor Liaison)
- Mat Ford (ISOC Liaison)
- Eliot Lear
- Barry Leiba (IESG Liaison)
- Trey Forgety (NENA)
- Tony O’Brien (EENA)
2. Tech Chat: Interaction with Regulators
Hannes Tschofenig introduced Tony O’Brien, Deputy Executive Director at European Emergency Number Association (EENA) and Trey Forgety, Director of Government Affairs at National Emergency Number Association (NENA). Hannes asked Tony and Trey to provide the IAB with advice about how to interact with regulators.
Tony O’Brien provided a brief overview of EENA, which was set up in 1999 to promote high-quality emergency services reached by the number 112 throughout the European Union. The actors in the regulatory horizon that EENA interacts with include:
- European Commission (EC): drafts legislation, publishes directives/recommendations
- European Parliament (EP): influences legislation, brings amendments
- Body of European Regulators (BEREC): has key influencing powers, acts as consensus-driven, collective organization
- National Regulatory Authorities (NRAs): individual regulators that implement EC directives in line with the national legislation
- Standards Developing Organizations (SDOs): e.g. ETSI; the EC requests SDOs set standards where legislation is unhelpful.
Tony O’Brien noted that regulators often have a narrow scope for things like 112 because they do not understand all of the technical issues, and they are obligated to ensure that the decisions they make are proportional and will not cause downstream market effects.
EENA works to fill in the knowledge gaps by educating key policy makers and influencers. Tony O’Brien noted that while the EC and policy makers deserve key attention, other influencers should not be overlooked. EENA has had some success in using the EP to lobby to the EC, and it is important to build those relationships.
Trey Forgety provided a brief overview of NENA, which was formed to promote a universal emergency telephone number (911) in the United States. Trey noted that the regulatory structure in the United States is different from that in Europe, being deeply federated. In the US, the Federal Communications Commission (FCC) regulates inter-state communications. NENA is also federated, as a national organization with chapters that operate at state levels. Nearly every state has their own individual statues that govern their emergency services.
In the FCC, there are three different kinds of rule-making: 1) Adjudication, 2) Formal rule-making, and 3) Informal rule-making. Informal rule-making is the most common form of rule-making, and works by having the FCC put out questions for which they would like to receive answers from a cross-section of those that will be impacted by the potential rule. Anyone can respond to the questions. NENA files around 300 pages of comments in response to these inquiries per year.
Trey Fogerty noted that interacting effectively with regulatory bodies requires an understanding of the internal processes of the agencies involved. Regulators generally do not want to engage in heavy-handed tactics, and they have to balance commercial and public safety concerns. Trey advised that when dealing with regulators, one must have a clear view, but not lose sight of the fact that there are other views as well.
The board thanked Tony O’Brien and Trey Forgety for their presentations and discussed ways to apply their lessons to the IETF. Trey noted that it was easier when there is professional staff to interact with the regulatory bodies, which the IETF does not have; ISOC generally files comments on behalf of the IETF.
Ross Callon noted that the number of people on the IAB is relatively small, and that the number of governments and regulatory bodies is relatively large. Alissa Cooper suggested that for things like emergency services, there is expertise within the IETF, and that the IAB should think about how to funnel that expertise to ISOC. Trey Forgety suggested that one approach would be for the IAB to create a set of universal technical principles believed to be important from a policy perspective, and give that to ISOC.
Alissa Cooper noted that she does not think that the IAB will be able to have a general approach for dealing with regulators, and that issues will need to be handled on a case-specific basis.
Tony O’Brien suggested that the IAB might want to look for other organizations with similar interests and positions that have had success in lobbying regulators in the past, and work with them to combine efforts. He noted that EENA has used that strategy in the past, and that EENA would welcome technical expertise from the IETF. Trey Forgety agreed that NENA would be interested in that as well, noting that one possibility would be IAB membership in their government affairs committee. Hannes Tschofenig said that they would explore that option further in the IAB Emergency Services Program.
Both Tony O’Brien and Trey Forgety agreed that the IAB could make the slides they presented available to the public.
- Tony O’Brien: http://iab.org/wp-content/IAB-uploads/2013/06/eena.pdf
- Trey Forgety: http://iab.org/wp-content/IAB-uploads/2013/06/nena.pdf
3. Other Business
There was no other business and the meeting was adjourned.