◆ SpookStack

proprietary network information (“CPNI’) without sacrificing lawful access to important information that helps solve crimes, prevent terrorist attacks, and safeguard our national security. This proceeding was initiated primarily in response to a Petition for Rulemaking filed by the Electronic Privacy Information Center (“EPIC”) that raised concerns about the sufficiency of carrier practices related to CPNI.’ Among other things, EPIC recommended that the Commission adopt rules requiring that cai! detail records be destroyed when they are no longer needed for billing or dispute purposes or, in the alternative, requiring carriers to “de-identify” identification data from the transactional records. Inthe Notice, the Commission requested conmment on “whether CPNI records should eventually be deleted, and if so, for how long such records should be kept.”* In exploring the potential negative consequences of a record destruction mandate, the Commission has asked whether “deleting CPNI or removing personal identification conflict with other priorities, such as... law enforcement.” The answer to the above question is an unequivocal “yes,” and we urge the Commission to explore ways to resolve the issues EPIC has raised in ways that preserve lawful access to comniunications records and other CPNI. For law enforcement, such CPNI is an invaluable investigative resource, the mandatory destruction of which would severely impact the Departments’ ability to protect national security and public safety. 4 Petition of the Electronic Privacy Information Center for Rulemaking to Enhance the Security and Authentication Standards for Access to Customer Proprietary Network Information, CC Docket No. 96-115 (filed Aug. 30, 2005) (“EPIC Petition’). ‘ See EPIC Petition at 11-12. Notice J 20. ; id. 6