no. SAPI only exists in E1 based A-bis.
Pfff, I was going crazy...
A-bis over E1 is what the BS-11 uses. ip.access has their own proprietary protocol stacking and A-bis dialect. There is no public documentation about it, apart from what we deducted from protocol traces and implemented in OpenBSC / wireshark and put into the OpenBSC wiki.
Damn, did you had a lot of cola and chips? :p
In any case, the Layer 2 (Q.921 on E1, with TEI and SAPI) is completely uninteresting. All you should care about is layer 3 (12.21 OML and 08.58 RSL).
Yeah, I kind of figured that out now.