Dear Susan, The draft bill is not astounding. With only one exception (POPs), it provides nothing more than is generally required in almost every other venue worldwide, and demonstrates its value many times a day in criminal and terrorist investigatory incidents. To answer specific points: 1. All publicly provided services have long been covered worldwide and there is no effect on innovation. The equipment (actually generally the software) has been designed to support these capabilities. Where is has not, a simple passive probe can be readily employed. The rest of the world has now moved on to retained data requirements. 2. The point of presence requirement is a matter of some concern, but can be easily effected if virtual point of presence capabilities are used. 3. Call Identifying Information - also knon as IRI internationally or real time traffic data in the Cybercrime Convention - poses no special problem. It's long been required in almost every country, and new Direct Signal Reporting techniques make it a "no brainer." 4. There is no apparent adverse effect on performance, and indeed, many of the requirements already are being provided on a far greater scale to enable operators to effectively manage their networks. Privacy concerns are actually enhanced under CALEA because it mandates a set of process and authentication requirements that must be filed with the FCC. 5. The compliance costs are trivial - an estimated one cent per subscriber per month when outsourced to a service bureau. The triviality is underscored by comparing these costs to other public infrastructure mandates such as USF, 911, priority access, etc, etc. Tony Rutkowski, Distinguished Senior Research Fellow Center for International Strategy, Technology and Policy Sam Nunn School Georgia Institute of Technology