Internet partitioning event regulations (was: RE: Sending vs requesting. Was: Re: Sprint / Cogent)
Charles Wyble charles@thewybles.com wrote:
Lamar Owen wrote:
There are three ways that I know of (feel free to add to this list) to limit the events: 1.) As you mentioned, regulation (or a government run and regulated backbone);
Right. But what do we want this to look like?
Well, since I've already stepped out on a limb, here goes my try at a rough outline of what such a regulation might look like (with the caveat that this is likely too simple to actually make it as a regulation): 1.) Define the regulation's scope, that it is, who is being regulated and why. In this case, I would say 'transit-free Internet carriers' are the who, and to maintain a 'complete Internet' is the why. 2.) Allocate regulatory responsibility and enforcement authority to an entity. I would suggest the FCC would be appropriate. (This outline might then be the start of a 47 CFR 221 or similar). 3.) Define 'transit-free Internet carrier.' This has been done already by Patrick Gilmore and others, and done quite well. 4.) Define 'complete Internet.' I'm staying away from that one. ;-) 5.) Define 'peering arrangement.' This has also been done quite well by others, so I'll not repeat that here. 6.) Mandate that all transit-free Internet carriers shall maintain peering arrangements with all other transit-free Internet carriers to maintain a complete Internet (citing some law that makes a 'complete Internet' a national security matter, or somesuch, and belongs in 47 CFR 221 as a result). 7.) Mandate that only carriers who voluntarily accept this regulation may use the term 'Tier 1 Internet Provider' and provide penalties for Internet providers who wish to 'opt-out' of the regulation but who do not obtain transit from another provider. IOW, become a Tier 2, no need for regulation. 8.) Authorize the issuance of a 'Tier 1 Internet Provider' license (that must be renewed periodically, with documentation supporting the Tier 1 status) to participating transit-free Internet carriers (for a fee to cover the opex). 9.) Authorize the FCC's Enforcement Bureau to enforce. This is, IMHO, the best case regulatory scenario. But I reserve the right to be wrong. Not that it is a desired scenario, but as far as regulation goes I think it would be the scenario that does the least harm.
Hmmmm. I need to read that over. Thank you for the reference.
You're very welcome. My previous career was as a broadcast chief operator. Knowing 47 CFR Parts 1, 2, 73, 74, and 101 was part of that job (and a part I do not miss). Radio (both amateur and professional) used to be, prior to the late 1920's, an unregulated free-for-all similar to the current state of the Internet; but that proved to be unworkable, eventually producing the Communications Act of 1934, which established the Federal Communications Commission with real authority to regulate radio. If you want to see just how technically ridiculous such regulation can get, research the term 'CONELRAD' for a horrifying example. Now, on the flipside, current providers who also happen to be LEC's covered by 47 CFR 51 might actually not mind the addition of IP carriage to Part 51's scope. Makes everything consistent for them and their legal departments. But Part 51 is quite a bit more cumbersome than the simple 'Regulate the Tier 1's only' outline above, and carriers who are not already covered by Part 51 would likely raise a holy tantrum about it. But I'm sure there are loopholes in my rough outline above; it's too simple to be real regulation. :-)
Lamar Owen wrote:
Charles Wyble charles@thewybles.com wrote:
Lamar Owen wrote:
There are three ways that I know of (feel free to add to this list) to limit the events: 1.) As you mentioned, regulation (or a government run and regulated backbone);
Which government?
Right. But what do we want this to look like?
Well, since I've already stepped out on a limb, here goes my try at a rough outline of what such a regulation might look like (with the caveat that this is likely too simple to actually make it as a regulation):
Which government?
1.) Define the regulation's scope, that it is, who is being regulated and why. In this case, I would say 'transit-free Internet carriers' are the who, and to maintain a 'complete Internet' is the why.
In which country?
2.) Allocate regulatory responsibility and enforcement authority to an entity. I would suggest the FCC would be appropriate. (This outline might then be the start of a 47 CFR 221 or similar).
Is every part of "the Internet" going to recognize the sovereignty of the United States Federal Communications Commission (assuming they staff up to be able to administer this and the Fairness Doctrine)?
3.) Define 'transit-free Internet carrier.' This has been done already by Patrick Gilmore and others, and done quite well.
4.) Define 'complete Internet.' I'm staying away from that one. ;-)
5.) Define 'peering arrangement.' This has also been done quite well by others, so I'll not repeat that here.
6.) Mandate that all transit-free Internet carriers shall maintain peering arrangements with all other transit-free Internet carriers to maintain a complete Internet (citing some law that makes a 'complete Internet' a national security matter, or somesuch, and belongs in 47 CFR 221 as a result).
How will that work in, say, China? Or Iran
7.) Mandate that only carriers who voluntarily accept this regulation may use the term 'Tier 1 Internet Provider' and provide penalties for Internet providers who wish to 'opt-out' of the regulation but who do not obtain transit from another provider. IOW, become a Tier 2, no need for regulation.
8.) Authorize the issuance of a 'Tier 1 Internet Provider' license (that must be renewed periodically, with documentation supporting the Tier 1 status) to participating transit-free Internet carriers (for a fee to cover the opex).
9.) Authorize the FCC's Enforcement Bureau to enforce.
This is, IMHO, the best case regulatory scenario. But I reserve the right to be wrong. Not that it is a desired scenario, but as far as regulation goes I think it would be the scenario that does the least harm.
Hmmmm. I need to read that over. Thank you for the reference.
You're very welcome. My previous career was as a broadcast chief operator. Knowing 47 CFR Parts 1, 2, 73, 74, and 101 was part of that job (and a part I do not miss). Radio (both amateur and professional) used to be, prior to the late 1920's, an unregulated free-for-all similar to the current state of the Internet; but that proved to be unworkable, eventually producing the Communications Act of 1934, which established the Federal Communications Commission with real authority to regulate radio.
If you want to see just how technically ridiculous such regulation can get, research the term 'CONELRAD' for a horrifying example.
Now, on the flipside, current providers who also happen to be LEC's covered by 47 CFR 51 might actually not mind the addition of IP carriage to Part 51's scope. Makes everything consistent for them and their legal departments. But Part 51 is quite a bit more cumbersome than the simple 'Regulate the Tier 1's only' outline above, and carriers who are not already covered by Part 51 would likely raise a holy tantrum about it.
But I'm sure there are loopholes in my rough outline above; it's too simple to be real regulation. :-)
One World Government at last! -- Requiescas in pace o email Two identifying characteristics of System Administrators: Ex turpi causa non oritur actio Infallibility, and the ability to learn from their mistakes. Eppure si rinfresca ICBM Targeting Information: http://tinyurl.com/4sqczs
On Wed, Nov 5, 2008 at 12:12 PM, Larry Sheldon <LarrySheldon@cox.net> wrote:
Lamar Owen wrote:
There are three ways that I know of (feel free to add to this list) to limit the events: 1.) As you mentioned, regulation (or a government run and regulated backbone);
Which government?
First, let me say that I think peering regulation is a terrible idea. No matter how cleverly you plan it, the result will be that fewer small companies can participate. That's the character of regulation: compliance creates more barriers to entry than it removes. That having been said, jurisdiction is a red herring. Every transit-free provider does at least some of its business in the United States. Economic reality compels them to continue to do so for the foreseeable future. That's all the hook the Feds need. Regards, Bill Herrin -- William D. Herrin ................ herrin@dirtside.com bill@herrin.us 3005 Crane Dr. ...................... Web: <http://bill.herrin.us/> Falls Church, VA 22042-3004
William Herrin wrote:
On Wed, Nov 5, 2008 at 12:12 PM, Larry Sheldon <LarrySheldon@cox.net> wrote:
Lamar Owen wrote:
There are three ways that I know of (feel free to add to this list) to limit the events: 1.) As you mentioned, regulation (or a government run and regulated backbone); Which government?
First, let me say that I think peering regulation is a terrible idea. No matter how cleverly you plan it, the result will be that fewer small companies can participate. That's the character of regulation: compliance creates more barriers to entry than it removes.
The problem isn't that which networks don't peer with each other it is that some networks don't buy transit from anyone. That is what causes partition related outages and distortions in peering policies. If regulation could be part of the 'solution' then that would be the place to start. But despite the flaws with the current environment it really isn't that bad and any regulation would likely be a disaster for the industry. - Kevin
First, let me say that I think peering regulation is a terrible idea. No matter how cleverly you plan it, the result will be that fewer small companies can participate. That's the character of regulation: compliance creates more barriers to entry than it removes.
That having been said, jurisdiction is a red herring. Every transit-free provider does at least some of its business in the United States. Economic reality compels them to continue to do so for the foreseeable future. That's all the hook the Feds need.
Have you kept in your mind that this may be changed in future? I know, we are talking in NANOG, but ... Some regions works on Internet development a bit faster than US and in future, this regulation may motivate some overseas players to stop peering in US. For example LINX and AMS-IX are good place to get peering in EU. Regards MK
On Wed, Nov 05, 2008 at 11:59:09AM -0500, Lamar Owen wrote:
You're very welcome. My previous career was as a broadcast chief operator. Knowing 47 CFR Parts 1, 2, 73, 74, and 101 was part of that job (and a part I do not miss). Radio (both amateur and professional) used to be, prior to the late 1920's, an unregulated free-for-all similar to the current state of the Internet; but that proved to be unworkable, eventually producing the Communications Act of 1934, which established the Federal Communications Commission with real authority to regulate radio.
Yeah, and we're all just thrilled at how the FCC has conducted itself over the past 20 years, aren't we? (Speaking as one who grew around the technical side of broadcasting.) :-/ I'm undecided wether such regulation is a good thing or not. I agree that the current state of affairs is ultimately unworkable but government's role is to provide necessary restraints to protect the ability of new competitors to enter into the market place and to enable fair competition, not to regulate for the sake of regulating. With yesterday's results, I do not believe this is quite the right time to be persuing such actions since there is now a worrisome imbalance in the system. See, thing is, if "tier 1" becomes regulated, "tier 2" will almost certainly follow. Probably much more open, but regulation will still follow. (Open doors are hard to close.) When you get right down to it, this discussion really sounds like a request for something along the lines of Telecom '96. Not sure I like that thought or not. I'm still undecided as to wether that was a good or a bad thing but leaning towards good. -Wayne --- Wayne Bouchard web@typo.org Network Dude http://www.typo.org/~web/
:-> "Lamar" == Lamar Owen <lowen@pari.edu> writes: > Charles Wyble charles@thewybles.com wrote: >> Lamar Owen wrote: >> > There are three ways that I know of (feel free to add to this list) to limit the events: >> > 1.) As you mentioned, regulation (or a government run and regulated backbone); >> Right. But what do we want this to look like? > Well, since I've already stepped out on a limb, here goes my try > at a rough outline of what such a regulation might look like > (with the caveat that this is likely too simple to actually make > it as a regulation): [...] > 2.) Allocate regulatory responsibility and enforcement authority > to an entity. I would suggest the FCC would be appropriate. > (This outline might then be the start of a 47 CFR 221 or > similar). [...] > 6.) Mandate that all transit-free Internet carriers shall > maintain peering arrangements with all other transit-free > Internet carriers to maintain a complete Internet (citing some > law that makes a 'complete Internet' a national security matter, > or somesuch, and belongs in 47 CFR 221 as a result). [...] > 8.) Authorize the issuance of a 'Tier 1 Internet Provider' > license (that must be renewed periodically, with documentation > supporting the Tier 1 status) to participating transit-free > Internet carriers (for a fee to cover the opex). > 9.) Authorize the FCC's Enforcement Bureau to enforce. err... do you realize there's about 6.4 * 10^9 other people outside of the USA, don't you? -- ------------------------------------------------------------------------------- Pierfrancesco Caci | Network & System Administrator - INOC-DBA: 6762*PFC p.caci@seabone.net | Telecom Italia Sparkle - http://etabeta.noc.seabone.net/ Linux clarabella 2.6.15-29-server #1 SMP Mon Sep 24 17:37:57 UTC 2007 i686 GNU/Linux
participants (7)
-
Kevin Loch -
Lamar Owen -
Larry Sheldon -
Michal Krsek -
Pierfrancesco Caci -
Wayne E. Bouchard -
William Herrin