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Re: Level 3 Peering Guidelines
From: "Patrick W. Gilmore" <patrick () ianai net>
Date: Sun, 28 Aug 2011 18:25:41 -0400

On Aug 28, 2011, at 3:51 PM, Leo Bicknell wrote:
In a message written on Fri, Aug 26, 2011 at 09:32:00PM -0400, Patrick W. Gilmore wrote:
Why is that any different than forcing businesses to explain which links are paid?  Or any other internal data?  
Private businesses are private.  Their relationships with other private businesses are private.  Saying some data 
should be public while others are not is arbitrary.

It is, but it's also in the effort of allowing consumers to be
informed.  Why do we require food items to list the ingredients?
Why do public companies have to disclose particular events to the
SEC?  Why do car companies have to list the MPG on their cars?

While I see some similarities, I do believe there are differences between food ingredients & financial disclosures and 
peering ports.  I guess one could argue MPG is a comparable metric, but it's not really a useful number.  (Perhaps why 
it is comparable? :)

The FCC is very interested right now in finding out if when ISP X
says "your service is 16M down" you can get 16M.  Peering has an
impact on that.  If I have a 16M service, and every single pering
link they have is flatlined 10 hours a day I won't be able to get
16M down for those 10 hours.

Without disagreeing with your last point, we all know it will not be that simple.  Suppose I have 100 peering partners 
and 3 are congested.  Further assume those 3 are the three smallest peers I have, and refuse to upgrade because they do 
not have the cash (or whatever)?  How many customers are going to be mad at me, even though it likely has zero effect 
on them?  And what should I do about it?  (If your answer is "explain to them why this is not a problem", then I submit 
you have never spoken to a pissed-off, irrational customer.)

Some more questions:
Are you going to limit this to just networks that sell consumer access?
What will you do if the peering links are outside the US?
Will some countries become havens for peering (like Lichtenstein is for banking)?
How many links do you think will be dropped if this rule is put into place?
Are transit ports required to be shown?

Etc., etc.

That said, I'm not going to Washington to lobby against it if this law is written.


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