level3Level3 Communications wants the FCC to impose interconnection requirements on Internet service providers – a move the company said is necessary to “fully protect the free and open Internet.”

The company recommends three specific ISP interconnection requirements, which were outlined in a blog post written by the company’s general counsel for regulatory policy Michael Mooney yesterday. Mooney said Level3 already has similar arrangements with several ISPs and “the solution is good for everyone.”

Proposed ISP Interconnection Requirements
Level3’s proposed ISP interconnection requirements include:

  1. If a content provider or a network operator providing connectivity for the content provider delivers content into the ISP’s local market closest to the location of the ISP’s customer requesting the content, the ISP should be required to deliver the traffic to its customer without charging an interconnection fee – provided that the content provider delivers a certain amount of traffic in the aggregate to the ISP.
  2. The ISP would be able to select the interconnection location but selections would have to be “reasonable.” For example, each location would have to serve a minimum number of the ISP’s customers and the location would have to be served by several different metro transport service providers to ensure that the ISP has competitive choices.
  3. If interconnection capacity becomes congested at any interconnection location, it would have to be promptly augmented.

An Ongoing Assault
Level3’s recommendations are the latest salvo in ongoing assault that the company — along with Netflix and some other parties —  has been making on the traditional interconnection practices of large residential broadband ISPs such as Comcast and Verizon.

The ISPs say they receive more traffic from  content providers like Netflix and from companies like Level3 that offer connectivity for content providers – a service often referred to as content delivery, and which typically involves interconnecting with ISPs at multiple points in the network in order to minimize the distance content has to travel to reach end users. When a traffic imbalance exists, some of the ISPs require content providers and content delivery providers to pay interconnection fees – fees that the content and content delivery providers say they shouldn’t have to pay.

To support their position, content and content delivery providers have made a point of tying the issue in with the ongoing debate about the Open Internet, also known as Net Neutrality – although ISP traffic interconnection has not been part of previous Net Neutrality actions. Neither the rules originally imposed by the FCC and subsequently struck down by an appeals court nor the new Net Neutrality rules under consideration address ISP interconnection, instead focusing on preventing ISPs from charging extra to prioritize certain content delivered over the final link into the customer location.

Mooney challenged this state of affairs in his blog post, arguing that “even if fast lanes are not allowed in the last mile of the Internet, if they are allowed where the Internet connects into these same last mile networks, then the ISPs can continue to anti-competitively interfere with Internet content delivery.”

What’s Next?
Earlier this year Netflix begrudgingly reached agreements with Comcast and Verizon requiring the content provider to pay interconnection fees to the ISPs. But the matter did not end with that. More recently Netflix said its connections with Verizon remain congested, while Verizon hinted that Netflix was not delivering content as detailed in the agreement.

In response the FCC has asked various parties to provide copies of interconnection agreements with the goal of resolving the matter.

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