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.
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-2012-02-09-FINAL.pdf
-Bill
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
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
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
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
In a message written on Fri, Mar 30, 2012 at 07:50:43PM +0100, Mike Blanche wrote:
Les titres de la presse du lundi 19 juin 2023 | Arcep
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*
"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?
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
>
> 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.
In a message written on Fri, Mar 30, 2012 at 07:50:43PM +0100, Mike
Blanche wrote:
> Les titres de la presse du lundi 19 juin 2023 | Arcep
>
> 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.... 
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.
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.
Organization: United Federation of Planets
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.
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.
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