Concur with Señor Nathan here actually, the TICSA has not been much of a handbrake to our operations to date, despite the gnashing of teeth from some quarters before its introduction. Callum On Wed, Oct 21, 2015 at 3:54 PM, Nathan Ward wrote:

Hi,

What an odd post. I have a question about the one piece of (sort-of) operational content in this post.

information provided to me by a network operator about how the TICSA notification scheme was sometimes the cause of outages in consumer internet use, as it hindered the ability of NetOps to make quick decisions for basic things such as replacing larger routers that would serve a city like Dunedin.

Can you provide (off-list is OK, to avoid further non-operational discussion or if it is private) information about this? This seems trumped up, as TICSA guidance from NCSC permits emergency equipment replacements etc. See this document for information, page 14:

http://www.ncsc.govt.nz/assets/TICSA/NCSC-Guidance-for-Network-Operators.pdf

I have never heard of the TICSA process causing outages, and would be very surprised to hear if that was actually the case.

As a group of engineers we need evidence, rather than conjecture.

-- Nathan Ward

On 21/10/2015, at 13:23, B. Morgan Murrah wrote:

Hello NZNOG,

With respect to the soliciting PhD Candidate below, thought Id seek a confirmation of my understanding there is a long-held resistance to formalising peering relationships in legal fterms? Its a phenomenon I have am open mind to understanding, particularly with recent forms of not so desirable regulation...

As an aside, I am emigrating from NZ in December which has been very distracting but I am putting work on a very late submission to Kiwicon for some kind of workshop or talk. For now I have labelled it “State of TICSA: no country for NetOps”. Thought I am not a NetOp but have been researching and talking too people about this issue at a sustained if uneven pace since the Bill was introduced.

I feel I have had some success in broadening out TICSA for a wider audience understanding about various points. For example, I spoke at a Dunedin Free University event about information provided to me by a network operator about how the TICSA notification scheme was sometimes the cause of outages in consumer internet use, as it hindered the ability of NetOps to make quick decisions for basic things such as replacing larger routers that would serve a city like Dunedin. Whereas just one outage may have been necessary, two outages could occur as interim measures had to be taken while aspects of TICSA approval took place for such an example. Ultimately, disruptions to netflix streaming need to become understood as synonymous with TICSA kinds of intrusiveness by regular subscribers.

For my possibly final solicitation to this group:

1. You can view… well almost all about me at https://www.airbridge.ac.nz/about including options for communication to make a more informed judgement about me. 2. I solicit you to communicate to me any lawfully shareable information, hypothetical future concerns with TICSA or critical thoughts to me as soon as practicable for the opportunity to have them incorporate them in whatever I potentially present at Kiwicon under whatever conditions you specify. 3. New Zealand is small place and professionalism would pressure against netops from publicly voicing these concerns themselves. This has been evident from my communications with a few NetOps I have talked to and under TICSA this could be considered evidence bad faith under the legislation and invite extra scrutiny from the NCSC. Keeping the mouth shut would likely be my advice to any NetOp if I was currently practicing and able to give legal advice and likewise I might also have these professional concerns. This is regrettable but the reality. 4. However, I am an American New Zealander who is hard case about this topic and New Zealands independent foreign policy including networking with few or no qualms as I am not currently practicing and soon emigrating. I am confident in my ability to present things appropriately and engage with an audience from previous public speaking experiences.

With that I hope you give it some thought. If everything works out Ill be presenting something at Kiwicon and possibly voicing concerns on your behalf that deserve to be pooled togethor for full force.

Kind Regards,

___________ Beau Morgan Murrah - www.airbridge.ac.nz Enrolled Barrister and Solicitor of the High Court of New Zealand (NB: not a lawyer https://www.lawsociety.org.nz/for-lawyers/joining-the-legal-profession/admit... )

On 20/10/2015, at 11:01 pm, Uta Meier-Hahn wrote:

Dear networkers from around the world,

Internet interconnection is largely unregulated. However, in some countries, public regulation has emerged – be it through transparency rules, mandatory peering or licensing terms.

Currently, we lack an overview about where regulation exists and we know little about how it affects internet connectivity on a global scale.

To start filling this information gap, I have set up a short survey for network engineers, peering coordinators and network-savvy legal staffers. The goal is to crowdsource an initial overview about formal regulation of internet interconnection around the world.

Please participate! It takes no more than 10 minutes and will serve the community: http://limesurvey.hiig.de/index.php/675663?lang=en I will publish the results under a Creative Commons license.

Also, please consider helping by forwarding the link to fellow interconnection professionals - think of your Facebook, VKontakte or LinkedIn groups, of chat channels and mailing lists. The more regional diversity, the better. Thank you!

Thank you!

Kind regards,

Uta Meier-Hahn PhD Candidate Alexander von Humboldt Institute for Internet and Society Oberwallstr. 9 | 10117 Berlin meier-hahn(a)hiig.de | T +49 30 200 760-82 | www.hiig.de/en _______________________________________________ NZNOG mailing list NZNOG(a)list.waikato.ac.nz http://list.waikato.ac.nz/mailman/listinfo/nznog

_______________________________________________ NZNOG mailing list NZNOG(a)list.waikato.ac.nz http://list.waikato.ac.nz/mailman/listinfo/nznog

_______________________________________________ NZNOG mailing list NZNOG(a)list.waikato.ac.nz http://list.waikato.ac.nz/mailman/listinfo/nznog

-- Callum Barr me(a)callumb.com

When TICSA was being rolled out there were roadshows held in the main centres, where GCSB folks were at great pains to point out that they were keen to work with the telcos and ISP's affected by the law. They were very clear that there would be no need to delay outage remediation or require service interruption of any sort in order to comply with TICSA reporting requirements. (though retrospective notification would be required if the change didn't fall into an exception case). There was plenty of open and honest communication, including at the last two NZNOG conferences. With much credit to both Police and NCSC, they've been quite accessible and relatively easy to engage, and the whole thing has been pretty drama-free (at least in my experience). Time will tell, of course. Mark. On 21/10/2015 5:19 p.m., B. Morgan Murrah wrote:

Hello-

I appreciate this immediate feedback and reality check- Ive had this in the back of the mind for a while and kind of just put it out there… and very much running the risk of conjecture. People are also welcomed to contact me along these lines to tell me this to put me in place/reality check.

To clarify example of the router- to take some risk and speak purely from my interpretation from notes several months old and I will seek clarification/confirmation- was that the burden of the approval scheme faced the result in two outages having to be scheduled rather one as the operator(s) did not have sufficient clarity about the approval of the desired end replacement but were required to make quick decisions facing other decisions. This burden stemmed from the operators resources and ability to plan changes on the timeframe that fitted their other obligations- there is potential this just reflected the lack of attention applied by the operators to the scheme. While the guidance allows for emergency replacement there was still a burden in terms of the “needing permission to innovate” that intruded on their ability to operate.

This is one example that is perhaps no longer is liable to occur as people have adjusted to the system. It possibly did not actually in fact happen but was merely a perceived risk at the time, or a second hand account I received- I put some disclaimers on it in my talk in Dunedin. I do note some operators and organisations more than others may be able to absorb these real or perceived issue and there are a variety of experiences.

I still think is important for these things to be considered more publicly and Id like to see some of them in some kind of talk or workshop discission. The result could possibly be just to disprove or put people like me in place.

Regards

...

On 21/10/2015, at 4:12 pm, Callum Barr mailto:me(a)callum.net.nz> wrote:

Concur with Señor Nathan here actually, the TICSA has not been much of a handbrake to our operations to date, despite the gnashing of teeth from some quarters before its introduction.

Callum

On Wed, Oct 21, 2015 at 3:54 PM, Nathan Ward mailto:nznog(a)daork.net> wrote:

Hi,

What an odd post. I have a question about the one piece of (sort-of) operational content in this post.

...

information provided to me by a network operator about how the TICSA notification scheme was sometimes the cause of outages in consumer internet use, as it hindered the ability of NetOps to make quick decisions for basic things such as replacing larger routers that would serve a city like Dunedin.

Can you provide (off-list is OK, to avoid further non-operational discussion or if it is private) information about this? This seems trumped up, as TICSA guidance from NCSC permits emergency equipment replacements etc. See this document for information, page 14: http://www.ncsc.govt.nz/assets/TICSA/NCSC-Guidance-for-Network-Operators.pdf

I have never heard of the TICSA process causing outages, and would be very surprised to hear if that was actually the case.

As a group of engineers we need evidence, rather than conjecture.

-- Nathan Ward

...

On 21/10/2015, at 13:23, B. Morgan Murrah mailto:bmmurrah(a)gmail.com> wrote:

Hello NZNOG,

With respect to the soliciting PhD Candidate below, thought Id seek a confirmation of my understanding there is a long-held resistance to formalising peering relationships in legal fterms? Its a phenomenon I have am open mind to understanding, particularly with recent forms of not so desirable regulation...

As an aside, I am emigrating from NZ in December which has been very distracting but I am putting work on a very late submission to Kiwicon for some kind of workshop or talk. For now I have labelled it “State of TICSA: no country for NetOps”. Thought I am not a NetOp but have been researching and talking too people about this issue at a sustained if uneven pace since the Bill was introduced.

I feel I have had some success in broadening out TICSA for a wider audience understanding about various points. For example, I spoke at a Dunedin Free University event about information provided to me by a network operator about how the TICSA notification scheme was sometimes the cause of outages in consumer internet use, as it hindered the ability of NetOps to make quick decisions for basic things such as replacing larger routers that would serve a city like Dunedin. Whereas just one outage may have been necessary, two outages could occur as interim measures had to be taken while aspects of TICSA approval took place for such an example. Ultimately, disruptions to netflix streaming need to become understood as synonymous with TICSA kinds of intrusiveness by regular subscribers.

For my possibly final solicitation to this group:

1. You can view… well almost all about me at https://www.airbridge.ac.nz/about including options for communication to make a more informed judgement about me. 2. I solicit you to communicate to me any lawfully shareable information, hypothetical future concerns with TICSA or critical thoughts to me as soon as practicable for the opportunity to have them incorporate them in whatever I potentially present at Kiwicon under whatever conditions you specify. 3. New Zealand is small place and professionalism would pressure against netops from publicly voicing these concerns themselves. This has been evident from my communications with a few NetOps I have talked to and under TICSA this could be considered evidence bad faith under the legislation and invite extra scrutiny from the NCSC. Keeping the mouth shut would likely be my advice to any NetOp if I was currently practicing and able to give legal advice and likewise I might also have these professional concerns. This is regrettable but the reality. 4. However, I am an American New Zealander who is hard case about this topic and New Zealands independent foreign policy including networking with few or no qualms as I am not currently practicing and soon emigrating. I am confident in my ability to present things appropriately and engage with an audience from previous public speaking experiences.

With that I hope you give it some thought. If everything works out Ill be presenting something at Kiwicon and possibly voicing concerns on your behalf that deserve to be pooled togethor for full force.

Kind Regards,

___________ Beau Morgan Murrah -www.airbridge.ac.nz http://www.airbridge.ac.nz/ Enrolled Barrister and Solicitor of the High Court of New Zealand (NB: not a lawyer https://www.lawsociety.org.nz/for-lawyers/joining-the-legal-profession/admit...)

...

On 20/10/2015, at 11:01 pm, Uta Meier-Hahn mailto:meier-hahn(a)hiig.de> wrote:

Dear networkers from around the world,

Internet interconnection is largely unregulated. However, in some countries, public regulation has emerged – be it through transparency rules, mandatory peering or licensing terms.

Currently, we lack an overview about where regulation exists and we know little about how it affects internet connectivity on a global scale.

To start filling this information gap, I have set up a short survey for network engineers, peering coordinators and network-savvy legal staffers. The goal is to crowdsource an initial overview about formal regulation of internet interconnection around the world.

Please participate! It takes no more than 10 minutes and will serve the community: http://limesurvey.hiig.de/index.php/675663?lang=en I will publish the results under a Creative Commons license.

Also, please consider helping by forwarding the link to fellow interconnection professionals - think of your Facebook, VKontakte or LinkedIn groups, of chat channels and mailing lists. The more regional diversity, the better. Thank you!

Thank you!

Kind regards,

Uta Meier-Hahn PhD Candidate Alexander von Humboldt Institute for Internet and Society Oberwallstr. 9 | 10117 Berlin meier-hahn(a)hiig.de mailto:meier-hahn(a)hiig.de | T +49 30 200 760-82 tel:%2B49%2030%20200%20760-82 | www.hiig.de/en http://www.hiig.de/en _______________________________________________ NZNOG mailing list NZNOG(a)list.waikato.ac.nz mailto:NZNOG(a)list.waikato.ac.nz http://list.waikato.ac.nz/mailman/listinfo/nznog

_______________________________________________ NZNOG mailing list NZNOG(a)list.waikato.ac.nz mailto:NZNOG(a)list.waikato.ac.nz http://list.waikato.ac.nz/mailman/listinfo/nznog

_______________________________________________ NZNOG mailing list NZNOG(a)list.waikato.ac.nz mailto:NZNOG(a)list.waikato.ac.nz http://list.waikato.ac.nz/mailman/listinfo/nznog

-- Callum Barr me(a)callumb.com mailto:me(a)callumb.com

_______________________________________________ NZNOG mailing list NZNOG(a)list.waikato.ac.nz http://list.waikato.ac.nz/mailman/listinfo/nznog

Hey everyone thank you- appreciate this. After sleeping on it, I realised I have been just approaching this the wrong way from the start for sometime. I have been trying to put myself in a netops shoes and indeed becoming conjectural, ranty, political. Trying to grok what operating under it is like is just more likely to fail and just be irritating for people who are just carrying on with it. I am genuinely happy to hear that implementation hasn’t been as awful as I had come to view it. I still think its a terrible law for wider reasons, evidence about how these types of laws change professions or innovation over time, but if I have anything of value add to a conversation or criticism it should come just from my own experience/background and how it might play out before or in Court if it ever did (or why it will never). This is something Ill take back to my blog at airbridge.ac.nz http://airbridge.ac.nz//TICSA Ill retract and say I no longer actively solicit any information from NetOps about their experiences with compliance but appreciate any further engagement above link. Kind regards

On 22/10/2015, at 8:41 am, Dave Mill wrote:

On Wed, Oct 21, 2015 at 5:30 PM, Mark Foster mailto:blakjak(a)blakjak.net> wrote: When TICSA was being rolled out there were roadshows held in the main centres, where GCSB folks were at great pains to point out that they were keen to work with the telcos and ISP's affected by the law. They were very clear that there would be no need to delay outage remediation or require service interruption of any sort in order to comply with TICSA reporting requirements. (though retrospective notification would be required if the change didn't fall into an exception case).

There was plenty of open and honest communication, including at the last two NZNOG conferences. With much credit to both Police and NCSC, they've been quite accessible and relatively easy to engage, and the whole thing has been pretty drama-free (at least in my experience). Time will tell, of course.

And just a +1 to this in general. The law might suck, but the implementation by the GCSB has been good.

To re-iterate previous points there is no reason for a provider to be held back by the TICSA at all with an emergency outage. Fix the issue however you can and then deal with the TICSA afterwards.

Dave _______________________________________________ NZNOG mailing list NZNOG(a)list.waikato.ac.nz http://list.waikato.ac.nz/mailman/listinfo/nznog