What Does it Mean to Be a “Peer?”

Posted by: Bob Quinn on December 10, 2010 at 2:09 pm

The blogosphere continues to churn over the Comcast-Level 3 kerfuffle.  Level 3 even saw fit to respond to this humble blogger in a press release (a comment on a blog, a response blog or even a to-the-point tart tweet I get, but a press release?).

According to Level 3, I “missed the point completely,” in suggesting that there may be some inconsistencies between what Level 3 is saying now about Comcast and what it said five years ago about Cogent.  Level 3 insists that this dispute, unlike its dispute with Cogent, is not “just a peering dispute.”  Now look, I’m a Cubs fan so obviously I miss on a lot of things, but on this…let’s take a closer look.

The way I understand what happened here was that Level 3 went to Comcast and asked Comcast to provision capacity to meet Level 3’s expected (doubled) traffic volume.  Comcast offered to provide some capacity but said that, if Level 3 needed more, it would have to pay for it.  Level 3 believes that Comcast should simply provision the capacity to exchange traffic with Level 3 at no charge.  Sounds an awful lot like a peering dispute to me.  And, it sounds a lot like the press release rationale Level 3 used in its dispute with Cogent five years ago.  And while Level 3 says now (and then to be fair) that traffic balance was one factor in a peering relationship, it was the ONLY factor they deemed fit to discuss in that release back in 2005. 

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AT&T on Upton’s Appointment
To Chair Commerce Committee

Posted by: AT&T Blog Team on December 8, 2010 at 3:06 pm

The House Republican Conference today approved the appointment of Congressman Fred Upton as Chairman of the House Committee on Energy and Commerce.  The following statement may be attributed to Tim McKone, AT&T Executive Vice President of Federal Relations:

“AT&T congratulates Congressman Upton on his appointment as Chairman of the House Energy and Commerce Committee. With his extensive knowledge of telecommunications and his unwavering support for policies that foster investment and job growth, Congressman Upton’s leadership will be invaluable in shaping our country’s broadband future.  We look forward to working with him as well as the other members of the Committee.”

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NewsFlash: It’s Not Really Louder
Just Because it Goes to Eleven

Posted by: Bob Quinn on December 2, 2010 at 11:40 am

When I read earlier this week that Level 3 was trying to elevate its peering dispute with Comcast into some kind of a major net neutrality gaffe, I immediately typed into my search engine the names Cogent Communications and Level 3 to see if I hadn’t somehow slipped into an alternative universe over the long Thanksgiving weekend.  I was relieved to learn that I was merely back in Washington, D.C. where spin is both King and Queen.  Here is what I found:

Level 3’s Shifting Positions on Peering -

As a Backbone Provider in 2005, Level 3 Said:

There are a number of factors that determine whether a peering relationship is mutually beneficial. For example, Cogent was sending far more traffic to the Level 3 network than Level 3 was sending to Cogent’s network. It is important to keep in mind that traffic received by Level 3 in a peering relationship must be moved across Level 3′s network at considerable expense. Simply put, this means that, without paying, Cogent was using far more of Level 3′s network, far more of the time, than the reverse. Following our review, we decided that it was unfair for us to be subsidizing Cogent’s business.” Level 3 Press Release, Oct. 7, 2005

As a Content Delivery Network Operator in 2010, Level 3 Said:

“It is regrettable that Comcast has sought to portray this simply as a commercial disagreement or a peering dispute. They miss the point and are attempting to distract from the fundamental issue….The fundamental issue is not whether Comcast sends more traffic to Level 3 or whether Level 3 sends more traffic to Comcast. Both Level 3 and Comcast are responding to the requests of Comcast’s subscribers, who want to be free to see and use the full suite of content and applications that are available on the Internet today and in the future. Level 3 wants to assure that freedom is preserved.” Level 3 Press Release, November 29, 2010

Despite all the spin from Level 3 and political organizations like “Free Press,” and at the risk of contradicting one of my old Spinal Tap heroes Nigel Tufnel, I have to conclude that it’s not, in fact, louder just because it “goes to eleven”…this is just a peering dispute no matter how loudly Level 3 and Free Press shout “net neutrality violation.”

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AT&T Statement on Proposed FCC Rules to Preserve an Open Internet

Posted by: AT&T Blog Team on December 1, 2010 at 11:18 am

Background – The FCC has announced that it will address proposed rules to preserve the open Internet at its December 21st Open Meeting. The following statement may be attributed to Jim Cicconi, AT&T Senior Executive Vice President of External & Legislative Affairs:

“The prospect of net neutrality regulation has lingered as a very real threat to industry investment and jobs for several years.  Obviously, AT&T’s strong preference would be for the FCC to refrain from any regulation in the Internet space.   We feel the industry’s track record, the utter absence of any specific ongoing problem, and the state of the economy all argue for regulatory restraint.  We also believe, based on jurisdictional concerns, that the issue should rightly be deferred to the Congress, a view also expressed by a bipartisan majority of that body.  Nonetheless, we recognize that the FCC has decided to move ahead.

“We understand that the FCC Chairman has prepared a compromise proposal aimed at bridging the differences that have long polarized this debate.  Based on our understandings, this measure would avoid onerous Title II regulation; would be narrowly drawn along the lines of a compromise we have endorsed previously; would reject limits on our ability to properly manage our network and efficiently utilize our wireless spectrum; would recognize the capabilities and limitations of different broadband technologies; would ensure specialized services are protected against intrusive regulation; and would provide for a case-by-case resolution of complaints that also encourages non-governmental dispute settlement.

“While any final statement of position by AT&T must await a careful reading of the actual order and rules when issued, we are pleased that the FCC appears to be embracing a compromise solution that is sensitive to the dynamics of investment in a difficult economy and appears to avoid over-regulation.  We are also mindful of, and grateful for, the impact Congressional views have had in this process.  Such an approach would reduce regulatory uncertainty, and should encourage investment and innovation in next generation broadband services and technologies.  In that regard, we remain committed to working with the FCC to bring the benefits of broadband to all Americans.”

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Unsafe at Any Rate

Posted by: Hank Hultquist on November 24, 2010 at 12:54 pm

In recent blogs I have explored: (a) the FCC’s absurd practice of regulating the structure of long distance pricing even as long distance is rapidly vanishing as a distinct consumer service; and (b) the foolishness of extending obsolete interconnection rules to IP networks.

Today, I will try to tie these seemingly distinct modes of transportation together and, in so doing, explain how the FCC can finally put this industry on the road to rationality.

It is axiomatic that interconnection on the telephone network (a.k.a., the PSTN) has become an upside-down world of inefficiencies and arbitrage. This entire system is built on a series of arbitrary rules and assumptions that have long been overtaken by reality.

We have a system that entitles service providers to file tariffs pursuant to which they can unilaterally extract payments from other service providers for “terminating” calls from those other service providers’ customers. To make matters worse, and despite the fact that the functions performed in “terminating” all calls are identical, the applicable rates can vary greatly depending on whether a call is “local,” “intrastate long distance,” or “interstate long distance,” or dialed from a mobile smartphone, skyped from a laptop or placed from the dusty home “landline.”   

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