North American Network Operators Group

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Re: Unsubstantiated Rumor - this is not simply about RBOC ISP Tariff

  • From: David Holub
  • Date: Tue Feb 18 00:18:30 1997

Perhaps this is not contributing significantly to the S/N ratio on the
operational mailing list and not without a potential to interrupt the non
progress that some are making in their mission to establish interplanetary
name services - read on.

I'd like to thank Hong and Simona for pointing out the deadline for comments
to the FCC and take a moment of your time to plead to the technically minded
for a serious contribution to how the regulatory laws regarding
interconnection between our networks are about to be written.

A few data points rather than a policy diatribe:

a) The "free peering" relationship is directly analogous to a "bill & 
keep" interconnection relationship between traditional telephone companies.

b) Under the Communications Act of 1934 As amended by the Telecommunications
Act of 1996 ("Act"), "telecommunications carriers" are under obligation to
interconnect "with the facilities and equipment of other telecommunications
carriers..." (Act, Sec. 251 (a) (1)

c) The term "telecommunications", as used in the Act means "the transmission,
between or among points specified by the user, of information of the user's
choosing, without change in the form or content of the information as sent
and received" Act, Section 3 (43)

Like it or not, the FCC is now obligated to translate this into regulations
that will surely be litigated and enforced. It's just my guess but more than
a few of us have an interest in the outcome of the first round of regulations
in this area. We have just a few weeks to file something meaningful. To be
sure, those with interests that may not exactly coincide with your own will
file comments. 

Whole Earth Networks will be filling formal comments utilizing specialized
legal counsel. I'd encourage others to do so. It is true that numbers count
when regulatory bodies get around to doing their knitting. To date, we ISP's
in haven't paid much attention to this telco regulatory stuff and it could
cost us real big if we don't take a serious interest in what these folks are
about to draft. 


David S. Holub
President CTO
Whole Earth Networks
(Hooked and The WELL)

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