From: Sean Donelan <SEAN@SDG.DRA.COM>
To: NTIA.NTIAHQ(infrastructure)
Date: Wednesday, August 12, 1998 2:14 PM
Subject: Docket No. 980716177-8177-01

Re: Docket No. 980716177-8177-01
Presidential Decision Directive 63 on Critical Infrastructure Protection: Sector Coordinators

I am writing to inform you about efforts to improve communications between Internet service providers during a widespread communications outage. I am requesting your suggestions and support to encourage Internet service providers to improve their coordination and backup communications capabilities.

NOCwire is an industry consortium to coordinate backup communication between Network Operation Centers (NOCs) of Internet service providers and related infrastructure providers. This is required to prevent a "deadlock" where Internet service providers need information from the telephone network operators to recover, and the telephone network operators require information from Internet operators to recover. As the Galaxy IV satellite showed when it disrupted pager service across the country, many infrastructure have critical dependencies on other infrastructure since several NOC's depended on pager service to contact people at other NOC's. And current backup communication networks do not currently connect the people and sites with Internet expertise.

The NOCwire would be a dedicated communications network separate from the public Internet and switched telephone system. All NOCwire members would have links from their own Network Operation Centers to the NOCwire network. In addition, NOCwire would be open to participation by infrastructure providers such as equipment manufacturers, root name servers and Internet Domain Name System database operators, and multi-vendor parts depots such as Federal Express in Memphis. Each of these participants have have expertise, information or materials which may be needed to resolve the outage.

NOCwire could also act as a liaison between ISPs and virtual network providers and existing industry or government communication networks such as the Alerting and Coordination Network (ACN) operated by the regional Bell Operating Companies. The NOCwire is not intended to directly focus on any single type of outage causing event, for example Year 2000, human error, natural or malicious events. Rather it is intended to maintain a minimum level of communication between the people with expertise so they can coordinate their efforts to restore the network. It is also intended to alert network operators about unusual events, so they can track seemingly unconnected events which result from a common root cause.

NOCwire is intended as an industry driven organization, although it also recognizes the government is both an ISP customer and a cooperative operator of some agency Internet networks such as ESnet and NASA Science Internet. This effort is already under way, independent of U.S. Government direction, and a number of large, medium and small Internet Service Providers have already indicated their support.

Since this project was initiated and already under way prior to the publication of the NTIA Notice and request for expressions of interest for Sector Coordinators, NOCwire does not directly address the criteria listed. The primary purpose of the NOCwire project is to improve the communication and coordination capabilities between network operators, not necessarily the U.S. Government. However, I believe the two efforts are compatible.

For further information about NOCwire please contact:

Sean Donelan
Data Research Associates, Inc.
1276 N Warson Road
Saint Louis, MO 63132
314-432-1100
sean@dra.com