French Regulator to ask all your information about your Peering
Hello All, This is now the end. The French regulator ( Arcep ) is now asking all the people with an ASN in France ( with a L33 license ) to get all their information on their peering. The Arcep claim it's for the "net neutrality" and still don't understand it works because it's self regulated. So, some of US network with a L33 License will also have to respond ( obligation because you have the L33-1) The documents can be downloaded here http://www.arcep.fr/index.php?id=8571&L=&tx_gsactualite_pi1[uid]=1508&tx_gs actualite_pi1[backID]=1&cHash=ed82d44a55 : ( french for now, english courtesy version will come soon ) The document is asking for informations like : BW, Prices, contract or not, level of use, date of the contract S You have to give them information twice a year We ( @Neo Telecoms ) and other folks in France will probably setup something with other carriers ( I already had some discussion with some of you ) to talk to them on a single voice. -- Raphaël Maunier NEO TELECOMS CTO / Directeur Ingénierie AS8218
-----BEGIN PGP SIGNED MESSAGE----- Hash: SHA256 On Mar 30, 2012, at 11:21 AM, Raphael MAUNIER wrote:
Hello All,
This is now the end. The French regulator ( Arcep ) is now asking all the people with an ASN in France ( with a L33 license ) to get all their information on their peering.
The Arcep claim it's for the "net neutrality" and still don't understand it works because it's self regulated.
So, some of US network with a L33 License will also have to respond ( obligation because you have the L33-1)
The documents can be downloaded here http://www.arcep.fr/index.php?id=8571&L=&tx_gsactualite_pi1[uid]=1508&tx_gs actualite_pi1[backID]=1&cHash=ed82d44a55 : ( french for now, english courtesy version will come soon )
The document is asking for informations like : BW, Prices, contract or not, level of use, date of the contract S
You have to give them information twice a year
For those anglophones following this from afar, Malcolm Hutty's excellent submission is relevant to your interests: https://publicaffairs.linx.net/news/wp-content/uploads/2012/02/ARCEP-2012-02... -Bill -----BEGIN PGP SIGNATURE----- Version: GnuPG/MacGPG2 v2.0.17 (Darwin) Comment: GPGTools - http://gpgtools.org iQIcBAEBCAAGBQJPdfr7AAoJEG+kcEsoi3+HpAEQALR2kyVDVqiVWnGVps3UUcRZ +BxdiGEmcmmI+ZvDopR1vz00hzcojp3C+7tKQ7oCnabVKISgsN4egF9WTR03Xahp TNSQqgDRf7mph2RGba5S/DAt1QEHfdSwRGVv+egjtJE7en7k2E90MU1q3rkT2y9P gKRNusd4m4I0rIRFm4G6WVMy2O6VmWqtgQcUyHzj6yocl84jf+yO2KfyxsLwz5PM Sln3oE7wKsFqtwf8uTxrEdslVTcbzCQ5ZgkNVdVXO/KiMbXe37IHjDZIZ4v1bUtq NcqznnVSlKoMUgGFOJ1dRocWOw4JcgxD+U3xTHx3xRyx3ggwnG0gjpp38198wFVw 1B5pIJ+I7UIOM4lDtSV5gJYlxA1YKYXHcktyqyAVtCh+4oPWiHKhFtpsFv77lrhl NOGy5NC66YN+u8Bpmo7l+2Z1yLqJmasLsmRazOm81V6wMzwiCF9ZEJsbU+ULz7Rc ObzvpqD585ObkCUVJYmjk1IptxJJOMBhX6qbBnlf2UlU2BhY/+r/EGu10EB8XNMw U8QW0CNIUucgVNHdLWoIdIakij7wuSlJEGoNiK6BVTi6TqJe5eZRXH5OSGYx4QrE BQ0iG7nTf7LFUo+W07G5hscfvCUZSBV/iL6O69T3zcmc3jqG544iIjcnASTeol8R 5rBSLVqixj5fwP4ephyb =dNaW -----END PGP SIGNATURE-----
interesting discussion of jurisdiction.
In the present instance, we regard ARCEP’s proposed reporting requirement as constituting an extra- territorial obligation that ought not to be applied to operators who are neither established in France nor directly providing services within France, merely by virtue of their interconnecting with a network that does operate in France.
Similar considerations apply, mutatis mutandis, to the application of a reporting requirement to the providers of content services established and operating outside France. We do not consider the provision of content in the French language to be sufficient, by itself, to place the content provider within ARCEP’s jurisdiction.
We consider this lack of jurisdiction to be sufficient reason for ARCEP to withdraw categories (b) and (d) from the scope of persons enumerated in Article 1 of the Draft Decision.
-e
On 30 March 2012 19:27, Bill Woodcock <woody@pch.net> wrote:
For those anglophones following this from afar, Malcolm Hutty's excellent submission is relevant to your interests:
https://publicaffairs.linx.net/news/wp-content/uploads/2012/02/ARCEP-2012-02...
And here is who is caught: http://www.arcep.fr/index.php?id=9320 That's quite a big list. :-( (assuming I understand that list to be everyone licenced under L33-1) Mike -- Mike Blanche / mblanche@google.com / +44 7917 635 931 Google Peering & Content Distribution - Europe, Middle East and Africa
In a message written on Fri, Mar 30, 2012 at 07:50:43PM +0100, Mike Blanche wrote:
http://www.arcep.fr/index.php?id=9320
That's quite a big list. :-( (assuming I understand that list to be everyone licenced under L33-1)
Can someone with more local knowledge explain a "L33" license? Looking at the names and some quick googling make me think this is like a CLEC license in the US. If so, aren't they missing a fair number of the folks who might be present at an exchange but not have such a license? I'm almost afraid to ask, since they will likely want to license such folks... *sigh* -- Leo Bicknell - bicknell@ufp.org - CCIE 3440 PGP keys at http://www.ufp.org/~bicknell/
On Fri, Mar 30, 2012 at 9:06 PM, Leo Bicknell <bicknell@ufp.org> wrote:
In a message written on Fri, Mar 30, 2012 at 07:50:43PM +0100, Mike Blanche wrote:
http://www.arcep.fr/index.php?id=9320
That's quite a big list. :-( (assuming I understand that list to be everyone licenced under L33-1)
Can someone with more local knowledge explain a "L33" license?
In France, L33 is the license for companies that operate public networks and provide public electronic communications services, here is a translation (if you dare) : http://translate.googleusercontent.com/translate_c?act=url&hl=fr&ie=UTF8&prev=_t&rurl=translate.google.fr&sl=fr&tl=en&twu=1&u=http://www.legifrance.gouv.fr/affichCodeArticle.do%3FidArticle%3DLEGIARTI000024506015%26cidTexte%3DLEGITEXT000006070987%26categorieLien%3Did%26dateTexte%3D20120330&usg=ALkJrhj-oUuDkvh8f068LcNFYXc0ceE-RQ Looking at the names and some quick googling make me think this is
like a CLEC license in the US. If so, aren't they missing a fair number of the folks who might be present at an exchange but not have such a license?
all companies that operate their network for their own use, but ARCEP will know most of the major peering relationships. Let's hope it will help peering.... :/
On 03/30/2012 08:21 PM, Raphael MAUNIER wrote:
This is now the end. The French regulator ( Arcep ) is now asking all the people with an ASN in France ( with a L33 license ) to get all their information on their peering.
[...]
You have to give them information twice a year
Well, then for a few hundered peerings send them one letter each and wait for a reaction :-) Cheers, Stefan
-----BEGIN PGP SIGNED MESSAGE----- Hash: SHA256 On Mar 30, 2012, at 11:29 AM, Stefan Neufeind wrote:
You have to give them information twice a year
Well, then for a few hundered peerings send them one letter each and wait for a reaction :-)
Remember, these are bureaucrats… Their reaction would be to fine you for not submitting each letter in triplicate, and then charge you interest on the fines. :-) -Bill -----BEGIN PGP SIGNATURE----- Version: GnuPG/MacGPG2 v2.0.17 (Darwin) Comment: GPGTools - http://gpgtools.org iQIcBAEBCAAGBQJPdgP/AAoJEG+kcEsoi3+H/sYP/2PY0yeJh6KMmP0yQIYfE7+C XSH43rsKpMoP8vMs8OPuA4MNcVYXRbXly1XGhtrVR2dnc2EXpRb/bcpRrHdYbdwg wD36EFPlrdv42mtw1e9lMUitod91xuIlYhqvJ+h5qMBfDjtcHVMRp4CAGcNzlRa4 +Tfc6mAKOeKl84DiL1UDl7QSxcIBBsS3pM/Y1kKcxtR5hP8BhPY3WIFGSEslMa1R TC3sxfS/aux626JNtAdOyqjPF3NACkX4TwdKpfCGJusG1H7LkCj1lTqfpLT++yQP suSnJsrmJmGPlu83Bm/yuRFMQ8RiyEYNcfWOUMkjnWlCIaVmbBC/5q9DWd9h457B 3reZdCx540s1Of7bz6l5z4wPUx233BnPZ+jbrp5VMgTAJ3Qr+EbPCisA6YZVk1/D W1LcRvE0NOIqbTlBwG04qbbJCCmqljVcC9a3lYra1ULP4UEcLj64k41VEtN8iNZj PnAePhib4fBR0ZGT1qd1mrfSTB5oRN5FA5hcqRYXtdIKNafakhBUbUAlXZrdQrcX lHhyNzgkhtCClzqq7tR0e0chjpFKwh2Lo5nWVNExareWGnx1lGGypkz9Qj4UFENs w3S8InqOaHnyjyXvzm1DVh/VjIpjEVNT71V/YcqheymmG2CDC+rArl6vAfxWTkH+ DayMftFMf8u0UZ6/j+qB =1jgK -----END PGP SIGNATURE-----
On Fri, Mar 30, 2012 at 12:05:35PM -0700, Bill Woodcock wrote:
On Mar 30, 2012, at 11:29 AM, Stefan Neufeind wrote:
You have to give them information twice a year
Well, then for a few hundered peerings send them one letter each and wait for a reaction :-)
Remember, these are bureaucrats??? Their reaction would be to fine you for not submitting each letter in triplicate, and then charge you interest on the fines. :-)
"The official state religion of France is Bureaucracy. They've replaced the Trinity with the Triplicate." (David Richerby) Besides which, you'd be boosting the economy! They'd have to hire people, and cash flow would increase. How can they *not* do it? -- Mike Andrews, W5EGO mikea@mikea.ath.cx Tired old sysadmin
From nanog-bounces+bonomi=mail.r-bonomi.com@nanog.org Fri Mar 30 13:30:19 2012 Date: Fri, 30 Mar 2012 20:29:03 +0200 From: Stefan Neufeind <nanog@stefan-neufeind.de> To: "'NANOG list'" <nanog@nanog.org> Subject: Re: French Regulator to ask all your information about your Peering
On 03/30/2012 08:21 PM, Raphael MAUNIER wrote:
This is now the end. The French regulator ( Arcep ) is now asking all the people with an ASN in France ( with a L33 license ) to get all their information on their peering.
[...]
You have to give them information twice a year
Well, then for a few hundered peerings send them one letter each and wait for a reaction :-)
If I were in an *evil* frame of mind, I'd do something like a color pdf with white lettering on a white backgound. Or maybe just do everything in a 0.01 point high font.
Am 30.03.2012 20:21, schrieb Raphael MAUNIER:
This is now the end. The French regulator ( Arcep ) is now asking all the people with an ASN in France ( with a L33 license ) to get all their information on their peering.
The Arcep claim it's for the "net neutrality" and still don't understand it works because it's self regulated.
I suggest to stop whining. Why do we see regulators stepping in? Simply because some networks (mainly, but not only incumbents) abused their market power. It doesn't surprise me that it starts in France, as it's a common knowledge that the French incumbent has only one default answer, which is 'no'.
[...]
You have to give them information twice a year
We ( @Neo Telecoms ) and other folks in France will probably setup something with other carriers ( I already had some discussion with some of you ) to talk to them on a single voice.
Much appreciated. They certainly will come to some automated solution where they can generate reports on BGP feeds we send to their route collector. Everyone with proper route tagging should be ok and live happily. If, after all, the French incumbent has trouble to find an appropriate explanation for the regulator to justify their policy, so be it...
Sorry Fredy, but you are living in a care bear world ? Do you think some people build an intense national backbone You were @GPF last week, when Martin asked : Who want this to be regulated ? And Who want to have his peering controled ? why you didn't raise your hand ? In my memory, no one did. I didn't get my peering with France Telecom, so I get in touch with them and I have a fair contrat and I have a good backbone quality. In my market, I need for now direct access to them, and that's life. My business is not made on the "wishes" to have free peering with my incumbent. -- Raphaël Maunier NEO TELECOMS CTO / Directeur Ingénierie AS8218 -----Original Message----- From: Fredy Kuenzler <kuenzler@init7.net> Organization: Init Seven AG - http://www.init7.net/ Date: Fri, 30 Mar 2012 23:06:39 +0200 To: 'NANOG list' <nanog@nanog.org> Subject: Re: French Regulator to ask all your information about your Peering
Am 30.03.2012 20:21, schrieb Raphael MAUNIER:
This is now the end. The French regulator ( Arcep ) is now asking all the people with an ASN in France ( with a L33 license ) to get all their information on their peering.
The Arcep claim it's for the "net neutrality" and still don't understand it works because it's self regulated.
I suggest to stop whining. Why do we see regulators stepping in? Simply because some networks (mainly, but not only incumbents) abused their market power. It doesn't surprise me that it starts in France, as it's a common knowledge that the French incumbent has only one default answer, which is 'no'.
[...]
You have to give them information twice a year
We ( @Neo Telecoms ) and other folks in France will probably setup something with other carriers ( I already had some discussion with some of you ) to talk to them on a single voice.
Much appreciated. They certainly will come to some automated solution where they can generate reports on BGP feeds we send to their route collector. Everyone with proper route tagging should be ok and live happily.
If, after all, the French incumbent has trouble to find an appropriate explanation for the regulator to justify their policy, so be it...
In a message written on Fri, Mar 30, 2012 at 09:20:10PM +0000, Raphael MAUNIER wrote:
You were @GPF last week, when Martin asked : Who want this to be regulated ? And Who want to have his peering controled ? why you didn't raise your hand ?
In my memory, no one did.
It's also fearmongering. I am not in favor of the type of regulation that Martin alluded to in his question. However, I also do not think all regulation is bad. As long as the industry's attitude is to avoid the regulator at all costs the regulator will make decisions without information and consultation, and those decisions will be bad. "Regulation" could be as benign as "Anyone who peers in France must publically post their peering policy" to something as sinister as "the regulator will dictate all peering arrangements to all parties". Everyone on this list should be working _with_ the regulators wherever possible to educate them, and help shape regulations to meet your business needs. Other industries have done this for years. Lobbiests get paid millions of dollars to shape government regulations in favor of their employer; peering and more importantly regulation of the Internet is no different. -- Leo Bicknell - bicknell@ufp.org - CCIE 3440 PGP keys at http://www.ufp.org/~bicknell/
-----Original Message----- From: Leo Bicknell <bicknell@ufp.org> Organization: United Federation of Planets Date: Fri, 30 Mar 2012 14:37:51 -0700 To: 'NANOG list' <nanog@nanog.org> Subject: Re: French Regulator to ask all your information about your Peering
In a message written on Fri, Mar 30, 2012 at 09:20:10PM +0000, Raphael MAUNIER wrote:
You were @GPF last week, when Martin asked : Who want this to be regulated ? And Who want to have his peering controled ? why you didn't raise your hand ?
In my memory, no one did.
It's also fearmongering.
You may be right.
I am not in favor of the type of regulation that Martin alluded to in his question. However, I also do not think all regulation is bad. As long as the industry's attitude is to avoid the regulator at all costs the regulator will make decisions without information and consultation, and those decisions will be bad.
I spent time to talk to them ( hours honestly ) trying to explain what is really the peering. I don't get the point to ask for a "consultation" and less than the month after, oblige people to do it ?
"Regulation" could be as benign as "Anyone who peers in France must publically post their peering policy" to something as sinister as "the regulator will dictate all peering arrangements to all parties".
This is my problem. In a near future, this will be the case. My guess is : how to get some vat on top of this. Today there is no prices, so no vat, we need to get some.
Everyone on this list should be working _with_ the regulators wherever possible to educate them, and help shape regulations to meet your business needs.
Toons of hours for this ? Really ? Ok, I don't speak english very well, it seems that it's the same for french.
Other industries have done this for years. Lobbiests get paid millions of dollars to shape government regulations in favor of their employer; peering and more importantly regulation of the Internet is no different. +1
-- Leo Bicknell - bicknell@ufp.org - CCIE 3440 PGP keys at http://www.ufp.org/~bicknell/
Am 30.03.2012 23:20, schrieb Raphael MAUNIER:
Sorry Fredy, but you are living in a care bear world ?
Do you think some people build an intense national backbone
You were @GPF last week, when Martin asked : Who want this to be regulated ? And Who want to have his peering controled ? why you didn't raise your hand ?
In my memory, no one did.
I didn't get my peering with France Telecom, so I get in touch with them and I have a fair contrat and I have a good backbone quality. In my market, I need for now direct access to them, and that's life.
My business is not made on the "wishes" to have free peering with my incumbent.
I'm not saying I want this regulated, in fact I prefer to have it as it is and keep authorities out of the game. That's why I didn't raise my hand. But: Fact is that competition commissions and regulators are investigating against incumbents and such. They could have avoided this easily if they would have been more cooperative and keep their policy less restrictive. I don't blame anyone who is filing against someone who is abusing market power. Now, obviously, the French regulator sees the trouble and trys to understand and 'regulate' it the way they do it usually. From our perspective certainly not a good way, but why blaming the regulator? Blame those which made it all happen! Read: the restrictive incumbents which put obstacles in the way of everyone else. You've choosen to pay to get obstacles away. Others prefer to call the court. And probably the majority suffers in silence, especially the countless broadband users which actually pay our salaries and make our industry happening. Regulators should primarily care about those, and therefore it's good that the French regulator actually made a move, however arguably in the wrong direction. F.
On Mar 30, 2012, at 23:46, "Fredy Kuenzler" <kuenzler@init7.net> wrote:
Am 30.03.2012 23:20, schrieb Raphael MAUNIER:
Sorry Fredy, but you are living in a care bear world ?
Do you think some people build an intense national backbone
You were @GPF last week, when Martin asked : Who want this to be regulated ? And Who want to have his peering controled ? why you didn't raise your hand ?
In my memory, no one did.
I didn't get my peering with France Telecom, so I get in touch with them and I have a fair contrat and I have a good backbone quality. In my market, I need for now direct access to them, and that's life.
My business is not made on the "wishes" to have free peering with my incumbent.
I'm not saying I want this regulated, in fact I prefer to have it as it is and keep authorities out of the game. That's why I didn't raise my hand.
But: Fact is that competition commissions and regulators are investigating against incumbents and such. They could have avoided this easily if they would have been more cooperative and keep their policy less restrictive. I don't blame anyone who is filing against someone who is abusing market power.
Now, obviously, the French regulator sees the trouble and trys to understand and 'regulate' it the way they do it usually. From our perspective certainly not a good way, but why blaming the regulator? Blame those which made it all happen! Read: the restrictive incumbents which put obstacles in the way of everyone else.
I respect your position, but I'm not buying it. Those issue are the result of cheap transit provider trying to abuse their peers by selling a cheap ip transit and force the incumbent to upgrade. That's exactly the start of all of this.
You've choosen to pay to get obstacles away. Others prefer to call the court. And probably the majority suffers in silence, especially the countless broadband users which actually pay our salaries and make our industry happening.
I came to see my incumbent to talk to them and really explain what I'm doing, I spent time to explain and get their points and I had some very good discussion about backbone and cost for a big eyeball ... They told me : no one came to us to really understand what are really the "global cost" even the French regulator ! So I still don't buy it !
Regulators should primarily care about those, and therefore it's good that the French regulator actually made a move, however arguably in the wrong direction.
That's my point here. We are on the same line.
F.
Hi Fredy, On 30 Mar 2012, at 22:48, Fredy Kuenzler wrote:
Now, obviously, the French regulator sees the trouble and trys to understand and 'regulate' it the way they do it usually. From our perspective certainly not a good way, but why blaming the regulator? Blame those which made it all happen! Read: the restrictive incumbents which put obstacles in the way of everyone else.
I wish the world was so simple .. There is reasons why incumbents do not peer. Each time I had the time to seat with one of their peering coordinator, I always got a good reason to why they did what they did. I do not always agree with all of them but most of the time I could not fail their logic. I am quite exasperated by the number of networks who believe they have a god given right to free peering (and this goes from small content with no backbone cost but lots of traffic to network which are seen as T1), perhaps Peering sould be called it "limited cross-transit contract with equal billing on each side " (ie: it is not free the invoice just contra themselves), even if it is a mouthful, it may better explain why it is not a right. And I agree with Raphael that once the asset are listed, it is sooo tempting to TAX the very profitable Internet industry. I am already hearing the **AA asking for an income per Mb of transfer to compensate for the piracy the ISP are sooo clearly accomplice of ( Time to add bandwidth to the list on http://en.wikipedia.org/wiki/Private_copying_levy ). Peering is an "abnormality" which regulators will have much need of help to understand and not destroy. As the thread names him, time to employ so more lobbyist to help Malcolm making sure they are kept at bay. Thomas
Personally, I don't see this as a bad thing. Open disclosure of peering relationships strikes me as a "sunlight is the best disinfectant" kind of situation. Will they be making this information public or accepting it under seal? If they're making it public, then, I think overall it's a good thing. If not, then it's just another burdensome regulation without much public good. Owen On Mar 30, 2012, at 11:21 AM, Raphael MAUNIER wrote:
Hello All,
This is now the end. The French regulator ( Arcep ) is now asking all the people with an ASN in France ( with a L33 license ) to get all their information on their peering.
The Arcep claim it's for the "net neutrality" and still don't understand it works because it's self regulated.
So, some of US network with a L33 License will also have to respond ( obligation because you have the L33-1)
The documents can be downloaded here http://www.arcep.fr/index.php?id=8571&L=&tx_gsactualite_pi1[uid]=1508&tx_gs actualite_pi1[backID]=1&cHash=ed82d44a55 : ( french for now, english courtesy version will come soon )
The document is asking for informations like : BW, Prices, contract or not, level of use, date of the contract S
You have to give them information twice a year
We ( @Neo Telecoms ) and other folks in France will probably setup something with other carriers ( I already had some discussion with some of you ) to talk to them on a single voice.
-- Raphaël Maunier NEO TELECOMS CTO / Directeur Ingénierie AS8218
participants (12)
-
Arnaud Fenioux -
Bill Woodcock -
Eric Brunner-Williams -
Fredy Kuenzler -
Leo Bicknell -
Mike Andrews -
Mike Blanche -
Owen DeLong -
Raphael MAUNIER -
Robert Bonomi -
Stefan Neufeind -
Thomas Mangin