Definition of ISP vs Transit provider
The FCC is about to reclassify "Broadband Internet Access Service" as an information service instead of Telecommunications Service. This prombpted the following question which isn't about the FCC action per say. This is about how does one define Transit provider vs ISP ? Cogent for instance acts as a transit provider to other networks but also sells connectivity to companies. Peer1 in Canada used to sell "transit" to a then small emerging ISP, but as its sole transit provider, provided the BGP management as well as peering at Torix. Is the service to the ISP still called "transit" ? Or would ISP be defined as the organsation which assigns IPs to end users via PPPoE of DHCP ? One could argue that a network which assigns 4 or less IPs per customer would be an ISP. But what about IPv6 where the ISP could give each end user a /64 ? Just curious to see if there are agreed upon definitions from the network operators's point of view. I note that large companies tend to do everything from transit, to residential ISP, business ISP, libraries, airports etc. For Bell Canada, it is almost all under AS577. So separating what is telecom and what is information becomes more "interesting". As a point of reference this is what I *think* the FCC defines as an ISP: ## 23. Broadband Internet access service also does not include virtual private network (VPN) services, content delivery networks (CDNs), hosting or data storage services, or Internet backbone services (if those services are separate from broadband Internet access service), consistent with past Commission precedent.69 The Commission has historically distinguished these services from “mass market” services, as they do not provide the capability to transmit data to and receive data from all or substantially all Internet endpoints.70 We do not disturb that finding here. 24. Finally, we observe that to the extent that coffee shops, bookstores, airlines, private end- user networks such as libraries and universities, and other businesses acquire broadband Internet access service from a broadband provider to enable patrons to access the Internet from their respective establishments, provision of such service by the premise operator would not itself be considered a broadband Internet access service unless it was offered to patrons as a retail mass market service, as we define it here.71 Likewise, when a user employs, for example, a wireless router or a Wi-Fi hotspot to create a personal Wi-Fi network that is not intentionally offered for the benefit of others, he or she is not offering a broadband Internet access service, under our definition, because the user is not marketing and selling such service to residential customers, small business, and other end-user customers such as schools and libraries. ## The full 210 proposed FCC decision is at: https://apps.fcc.gov/edocs_public/attachmatch/DOC-347927A1.pdf
I can't seem to find the answer for this. But I'm curious as to what exactly is proposed. On Wed, Nov 22, 2017 at 3:35 PM, Jean-Francois Mezei < jfmezei_nanog@vaxination.ca> wrote:
The FCC is about to reclassify "Broadband Internet Access Service" as an information service instead of Telecommunications Service. This prombpted the following question which isn't about the FCC action per say.
This is about how does one define Transit provider vs ISP ?
Cogent for instance acts as a transit provider to other networks but also sells connectivity to companies.
Peer1 in Canada used to sell "transit" to a then small emerging ISP, but as its sole transit provider, provided the BGP management as well as peering at Torix. Is the service to the ISP still called "transit" ?
Or would ISP be defined as the organsation which assigns IPs to end users via PPPoE of DHCP ?
One could argue that a network which assigns 4 or less IPs per customer would be an ISP. But what about IPv6 where the ISP could give each end user a /64 ?
Just curious to see if there are agreed upon definitions from the network operators's point of view.
I note that large companies tend to do everything from transit, to residential ISP, business ISP, libraries, airports etc. For Bell Canada, it is almost all under AS577. So separating what is telecom and what is information becomes more "interesting".
As a point of reference this is what I *think* the FCC defines as an ISP:
## 23. Broadband Internet access service also does not include virtual private network (VPN) services, content delivery networks (CDNs), hosting or data storage services, or Internet backbone services (if those services are separate from broadband Internet access service), consistent with past Commission precedent.69 The Commission has historically distinguished these services from “mass market” services, as they do not provide the capability to transmit data to and receive data from all or substantially all Internet endpoints.70 We do not disturb that finding here.
24. Finally, we observe that to the extent that coffee shops, bookstores, airlines, private end- user networks such as libraries and universities, and other businesses acquire broadband Internet access service from a broadband provider to enable patrons to access the Internet from their respective establishments, provision of such service by the premise operator would not itself be considered a broadband Internet access service unless it was offered to patrons as a retail mass market service, as we define it here.71 Likewise, when a user employs, for example, a wireless router or a Wi-Fi hotspot to create a personal Wi-Fi network that is not intentionally offered for the benefit of others, he or she is not offering a broadband Internet access service, under our definition, because the user is not marketing and selling such service to residential customers, small business, and other end-user customers such as schools and libraries. ##
The full 210 proposed FCC decision is at: https://apps.fcc.gov/edocs_public/attachmatch/DOC-347927A1.pdf
On Wed, Nov 22, 2017 at 3:35 PM, Jean-Francois Mezei < jfmezei_nanog@vaxination.ca> wrote:
The FCC is about to reclassify "Broadband Internet Access Service" as an information service instead of Telecommunications Service. This prombpted the following question which isn't about the FCC action per say.
This is about how does one define Transit provider vs ISP ?
Corn on the cob vs. corn in a can.
Just curious to see if there are agreed upon definitions from the network operators's point of view.
No. Regards, Bill Herrin -- William Herrin ................ herrin@dirtside.com bill@herrin.us Dirtside Systems ......... Web: <http://www.dirtside.com/>
On Wed, Nov 22, 2017 at 3:35 PM, Jean-Francois Mezei < jfmezei_nanog@vaxination.ca> wrote:
The FCC is about to reclassify "Broadband Internet Access Service" as an information service instead of Telecommunications Service. This prombpted the following question which isn't about the FCC action per say.
This is about how does one define Transit provider vs ISP ? For that matter, how does one distinguish between someone delivering IP
On 11/22/17 2:50 PM, William Herrin wrote: packets, vs. someone offering frame relay, or ATM - which are clearly telecom services? Miles Fidelman -- In theory, there is no difference between theory and practice. In practice, there is. .... Yogi Berra
Those normally come with ASRs and a tariff from the regulated side of things. At least from my experience anyway. Sent from my iPad On Nov 22, 2017, at 10:08 PM, Miles Fidelman <mfidelman@meetinghouse.net<mailto:mfidelman@meetinghouse.net>> wrote: On 11/22/17 2:50 PM, William Herrin wrote: On Wed, Nov 22, 2017 at 3:35 PM, Jean-Francois Mezei < jfmezei_nanog@vaxination.ca<mailto:jfmezei_nanog@vaxination.ca>> wrote: The FCC is about to reclassify "Broadband Internet Access Service" as an information service instead of Telecommunications Service. This prombpted the following question which isn't about the FCC action per say. This is about how does one define Transit provider vs ISP ? For that matter, how does one distinguish between someone delivering IP packets, vs. someone offering frame relay, or ATM - which are clearly telecom services? Miles Fidelman -- In theory, there is no difference between theory and practice. In practice, there is. .... Yogi Berra Luke Guillory Vice President – Technology and Innovation [cid:imagea31855.JPG@9f5ca8aa.498ff694] <http://www.rtconline.com> Tel: 985.536.1212 Fax: 985.536.0300 Email: lguillory@reservetele.com Web: www.rtconline.com Reserve Telecommunications 100 RTC Dr Reserve, LA 70084 Disclaimer: The information transmitted, including attachments, is intended only for the person(s) or entity to which it is addressed and may contain confidential and/or privileged material which should not disseminate, distribute or be copied. Please notify Luke Guillory immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. Luke Guillory therefore does not accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission.
Well yes, but functionally, how is IP transport sufficiently different to make it an "information service" rather than a "telecommunications service?" At least that's the argument I'd make against reclassifying access services. Miles On 11/22/17 9:24 PM, Luke Guillory wrote:
Those normally come with ASRs and a tariff from the regulated side of things. At least from my experience anyway.
Sent from my iPad
On Nov 22, 2017, at 10:08 PM, Miles Fidelman <mfidelman@meetinghouse.net <mailto:mfidelman@meetinghouse.net>> wrote:
On 11/22/17 2:50 PM, William Herrin wrote:
On Wed, Nov 22, 2017 at 3:35 PM, Jean-Francois Mezei < jfmezei_nanog@vaxination.ca <mailto:jfmezei_nanog@vaxination.ca>> wrote:
The FCC is about to reclassify "Broadband Internet Access Service" as an information service instead of Telecommunications Service. This prombpted the following question which isn't about the FCC action per say.
This is about how does one define Transit provider vs ISP ? For that matter, how does one distinguish between someone delivering IP packets, vs. someone offering frame relay, or ATM - which are clearly telecom services?
Miles Fidelman
-- In theory, there is no difference between theory and practice. In practice, there is. .... Yogi Berra
Luke Guillory Vice President – Technology and Innovation
<http://www.rtconline.com> Tel: 985.536.1212 Fax: 985.536.0300 Email: lguillory@reservetele.com Web: www.rtconline.com
Reserve Telecommunications 100 RTC Dr Reserve, LA 70084
*Disclaimer:* The information transmitted, including attachments, is intended only for the person(s) or entity to which it is addressed and may contain confidential and/or privileged material which should not disseminate, distribute or be copied. Please notify Luke Guilloryimmediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. Luke Guillorytherefore does not accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission.
-- In theory, there is no difference between theory and practice. In practice, there is. .... Yogi Berra
ISP: Anybody offering services over the internet, including Transit Providers. Transit Provider: An internet service "transit" where the whole Internet can reach your advertised network addresses. :-) Jack -----Original Message----- From: NANOG [mailto:nanog-bounces@nanog.org] On Behalf Of Miles Fidelman Sent: November 22, 2017 11:29 PM To: Luke Guillory <lguillory@reservetele.com> Cc: nanog@nanog.org Subject: Re: Definition of ISP vs Transit provider Well yes, but functionally, how is IP transport sufficiently different to make it an "information service" rather than a "telecommunications service?" At least that's the argument I'd make against reclassifying access services. Miles On 11/22/17 9:24 PM, Luke Guillory wrote:
Those normally come with ASRs and a tariff from the regulated side of things. At least from my experience anyway.
Sent from my iPad
On Nov 22, 2017, at 10:08 PM, Miles Fidelman <mfidelman@meetinghouse.net <mailto:mfidelman@meetinghouse.net>> wrote:
On 11/22/17 2:50 PM, William Herrin wrote:
On Wed, Nov 22, 2017 at 3:35 PM, Jean-Francois Mezei < jfmezei_nanog@vaxination.ca <mailto:jfmezei_nanog@vaxination.ca>> wrote:
The FCC is about to reclassify "Broadband Internet Access Service" as an information service instead of Telecommunications Service. This prombpted the following question which isn't about the FCC action per say.
This is about how does one define Transit provider vs ISP ? For that matter, how does one distinguish between someone delivering IP packets, vs. someone offering frame relay, or ATM - which are clearly telecom services?
Miles Fidelman
-- In theory, there is no difference between theory and practice. In practice, there is. .... Yogi Berra
Luke Guillory Vice President – Technology and Innovation
<http://www.rtconline.com> Tel: 985.536.1212 Fax: 985.536.0300 Email: lguillory@reservetele.com Web: www.rtconline.com
Reserve Telecommunications 100 RTC Dr Reserve, LA 70084
*Disclaimer:* The information transmitted, including attachments, is intended only for the person(s) or entity to which it is addressed and may contain confidential and/or privileged material which should not disseminate, distribute or be copied. Please notify Luke Guilloryimmediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete, or contain viruses. Luke Guillorytherefore does not accept liability for any errors or omissions in the contents of this message, which arise as a result of e-mail transmission.
-- In theory, there is no difference between theory and practice. In practice, there is. .... Yogi Berra
Regarding transit and traffic exchange, in today’s FCC Declaratory Ruling: 166. Deregulating Internet Traffic Exchange. Today, we return to the pre-Title II Order status quo by classifying broadband Internet access service as an information service, and in doing so, reverse the extension of Title II authority to Internet traffic exchange arrangements.603 There is no dispute that ISPs, backbone transit providers, and large edge providers are sophisticated, well-capitalized businesses.604 Indeed, the Title II Order acknowledged as much,605 and refused to impose “prescriptive rules” or even “draw policy conclusions concerning new paid Internet traffic arrangements.”606 Notwithstanding, the Title II Order cast a shadow on new arrangements in this sector by applying a range of common carrier requirements to Internet traffic exchange. 167. We believe that applying Title II to Internet traffic exchange arrangements was unnecessary and is likely to inhibit competition and innovation. We find that freeing Internet traffic exchange arrangements from burdensome government regulation, and allowing market forces to discipline this emerging market is the better course.607 Indeed, the cost of Internet transit fell over 99 percent on a cost-per-megabit basis from 2005 to 2015.608 168. We welcome the growth of alternative Internet traffic exchange arrangements, including direct interconnection, CDNs, and other innovative efforts. All parties appear to agree that direct interconnection has benefited consumers by reducing congestion, increasing speeds, and housing content closer to consumers, and allowed ISPs to better manage their networks.609 CDNs play a similar role.610 We believe that market dynamics, not Title II regulation, allowed these diverse arrangements to thrive.611 Our decision to reclassify broadband Internet access service as an information service, and to remove Title II utility-style regulation from Internet traffic exchange, will spur further innovation in this market.612 Returning to the pre-Title II Order light-touch framework will also eliminate the asymmetrical regulatory treatment of parties to Internet traffic exchange arrangements.613 As NTCA explains, the Title II Order imposed a one-sided interconnection duty upon last-mile ISPs—even though, especially in rural areas, “many ISPs are a tiny fraction of the size of upstream middle mile and transit networks or content and edge providers.”614 The record reflects that the asymmetric regulation reduced incentives to share costs, and we anticipate that eliminating one-sided regulation of Internet traffic exchange and restoring regulatory parity among sophisticated commercial entities will allow the parties to more efficiently allocate the costs arising from increased demands on the network.615 -Thomas -- Thomas Edwards FOX Networks Engineering & Operations VP Engineering & Development thomas.edwards@fox.com 10201 W Pico Blvd Los Angeles, CA 90035 On 11/22/17, 12:36 PM, "NANOG on behalf of Jean-Francois Mezei" <nanog-bounces@nanog.org on behalf of jfmezei_nanog@vaxination.ca> wrote: The FCC is about to reclassify "Broadband Internet Access Service" as an information service instead of Telecommunications Service. This prombpted the following question which isn't about the FCC action per say. This is about how does one define Transit provider vs ISP ? Cogent for instance acts as a transit provider to other networks but also sells connectivity to companies. Peer1 in Canada used to sell "transit" to a then small emerging ISP, but as its sole transit provider, provided the BGP management as well as peering at Torix. Is the service to the ISP still called "transit" ? Or would ISP be defined as the organsation which assigns IPs to end users via PPPoE of DHCP ? One could argue that a network which assigns 4 or less IPs per customer would be an ISP. But what about IPv6 where the ISP could give each end user a /64 ? Just curious to see if there are agreed upon definitions from the network operators's point of view. I note that large companies tend to do everything from transit, to residential ISP, business ISP, libraries, airports etc. For Bell Canada, it is almost all under AS577. So separating what is telecom and what is information becomes more "interesting". As a point of reference this is what I *think* the FCC defines as an ISP: ## 23. Broadband Internet access service also does not include virtual private network (VPN) services, content delivery networks (CDNs), hosting or data storage services, or Internet backbone services (if those services are separate from broadband Internet access service), consistent with past Commission precedent.69 The Commission has historically distinguished these services from “mass market” services, as they do not provide the capability to transmit data to and receive data from all or substantially all Internet endpoints.70 We do not disturb that finding here. 24. Finally, we observe that to the extent that coffee shops, bookstores, airlines, private end- user networks such as libraries and universities, and other businesses acquire broadband Internet access service from a broadband provider to enable patrons to access the Internet from their respective establishments, provision of such service by the premise operator would not itself be considered a broadband Internet access service unless it was offered to patrons as a retail mass market service, as we define it here.71 Likewise, when a user employs, for example, a wireless router or a Wi-Fi hotspot to create a personal Wi-Fi network that is not intentionally offered for the benefit of others, he or she is not offering a broadband Internet access service, under our definition, because the user is not marketing and selling such service to residential customers, small business, and other end-user customers such as schools and libraries. ## The full 210 proposed FCC decision is at: https://urldefense.proofpoint.com/v2/url?u=https-3A__apps.fcc.gov_edocs-5Fpublic_attachmatch_DOC-2D347927A1.pdf&d=DwIDaQ&c=uw6TLu4hwhHdiGJOgwcWD4AjKQx6zvFcGEsbfiY9-EI&r=lekNOOM5noV61zrPH3rwPyhtNnLLWoLEHgd0quQxly8&m=GHmzQ0km_bzDFxKtOEAcIzvU7zev3i1P1jY7qFGLy4k&s=4FtLgoZ1nfkDyBnfDz0h5PejWPDIromH__9WAl7s2hY&e=
Though not an industry standard definition, we've defined them at a product level where I work. These have changed somewhat over the years, but pretty much fall along the following lines. IP Transit: A wholesale product that does not include IP Addresses, email address, DNS, or any other "value-added" services. When customer has filed a 499-a, collection of USF surcharges is waived. Availability is typically limited to a sub-set of the total POP footprint and generally does not include access backhaul on our network. Dedicated Internet Access: A product generally sold to businesses that includes IP addresses, recursive DNS, and 5 domain names. Available across the whole of the footprint and pricing includes backhaul on our network, but not off-net (3rd party) backhaul. USF is always assessed. (email and usenet services are defunct with our service, but I'm sure many still offer email). I can see the second product definition for DIA being a pretty good match for your ISP definition, be that consumer broadband or what have you, with minor modifications. FWIW, hope that's helpful. Dave Dave Siegel Vice President Product Management CenturyLink 1025 Eldorado Blvd Broomfield, CO 80021 p: 720.888.0953 m: 520.229.7627 e: dave.siegel@centurylink.com -----Original Message----- From: NANOG [mailto:nanog-bounces@nanog.org] On Behalf Of Jean-Francois Mezei Sent: Wednesday, November 22, 2017 1:35 PM To: Nanog@nanog.org Subject: Definition of ISP vs Transit provider The FCC is about to reclassify "Broadband Internet Access Service" as an information service instead of Telecommunications Service. This prombpted the following question which isn't about the FCC action per say. This is about how does one define Transit provider vs ISP ? Cogent for instance acts as a transit provider to other networks but also sells connectivity to companies. Peer1 in Canada used to sell "transit" to a then small emerging ISP, but as its sole transit provider, provided the BGP management as well as peering at Torix. Is the service to the ISP still called "transit" ? Or would ISP be defined as the organsation which assigns IPs to end users via PPPoE of DHCP ? One could argue that a network which assigns 4 or less IPs per customer would be an ISP. But what about IPv6 where the ISP could give each end user a /64 ? Just curious to see if there are agreed upon definitions from the network operators's point of view. I note that large companies tend to do everything from transit, to residential ISP, business ISP, libraries, airports etc. For Bell Canada, it is almost all under AS577. So separating what is telecom and what is information becomes more "interesting". As a point of reference this is what I *think* the FCC defines as an ISP: ## 23. Broadband Internet access service also does not include virtual private network (VPN) services, content delivery networks (CDNs), hosting or data storage services, or Internet backbone services (if those services are separate from broadband Internet access service), consistent with past Commission precedent.69 The Commission has historically distinguished these services from “mass market” services, as they do not provide the capability to transmit data to and receive data from all or substantially all Internet endpoints.70 We do not disturb that finding here. 24. Finally, we observe that to the extent that coffee shops, bookstores, airlines, private end- user networks such as libraries and universities, and other businesses acquire broadband Internet access service from a broadband provider to enable patrons to access the Internet from their respective establishments, provision of such service by the premise operator would not itself be considered a broadband Internet access service unless it was offered to patrons as a retail mass market service, as we define it here.71 Likewise, when a user employs, for example, a wireless router or a Wi-Fi hotspot to create a personal Wi-Fi network that is not intentionally offered for the benefit of others, he or she is not offering a broadband Internet access service, under our definition, because the user is not marketing and selling such service to residential customers, small business, and other end-user customers such as schools and libraries. ## The full 210 proposed FCC decision is at: https://apps.fcc.gov/edocs_public/attachmatch/DOC-347927A1.pdf This communication is the property of CenturyLink and may contain confidential or privileged information. Unauthorized use of this communication is strictly prohibited and may be unlawful. If you have received this communication in error, please immediately notify the sender by reply e-mail and destroy all copies of the communication and any attachments.
participants (8)
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Jacques Latour
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Javier J
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Jean-Francois Mezei
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Luke Guillory
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Miles Fidelman
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Siegel, David
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Thomas Edwards
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William Herrin