NANOG:
Our owner has hired a consultant who insists that we should have an ISP
license to operate in the United States. (Like they have in other countries
like Germany and in Africa where he has extensive personal experience.)
I am asking him to tell me which license we should have because I don't know
of a license that we are required to have to route IP traffic to end
customers.
I am familiar with CLEC status filed with our state. But it is not a
requirement to pass traffic.
He is suggesting COALS with which I am completely unfamiliar.
Can anyone tell me if there is a Texas state and/or USA Federal license for
a small operator to pass IP traffic from the internet to end users
(commercial and/or residential).
I am aware that there are some CALEA requirements of ISPs that seem to kick
in once a CALEA request is made, but is that different from a license.
Thanks,
Lorell Hathcock
Not familiar with the process, but look at E-rate if you want to provide
service to schools, libraries and health providers.
Just to clarify. You don't need a SPIN (e-rate Service Provider
Identification Number) to provide service to those entities. You only need a
SPIN to qualify for USF/USAC funding for those entities. If they want to pay
full price (which some do) you don't need the SPIN. Applying for a SPIN is
extremely easy. Applying for e-rate funding, on the other hand, is usually
best done via a consultant. Thankfully that's the customer's problem, not
yours.
Regards,
Ray Orsini – CEO
Orsini IT, LLC – Technology Consultants
VOICE DATA BANDWIDTH SECURITY SUPPORT
P: 305.967.6756 x1009 E: ray@orsiniit.com TF: 844.OIT.VOIP
7900 NW 155th Street, Suite 103, Miami Lakes, FL 33016
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Your Tickets
E-Rate is more of a "discounted" rate process than a license.
I work for a mid-sized school district and apply for and are granted E-Rate funding every year.
So from the end user stand point not as a transit ISP, E-Rate would not apply.
Curtis Starnes
Senior Network Administrator
Granbury ISD
600 W. Bridge St. Ste. 40
Granbury, Texas 76048
(817) 408-4104
(817) 408-4126 Fax
curtis.starnes@granburyisd.org
www.granburyisd.org
OPEN RECORDS NOTICE: This email and responses may be subject to Texas Open Records laws and may be disclosed to the public upon request.
+1 on the SPIN, when we file our e-Rate form 470 and form 471's each year with USAC, we have to provide our carrier's SPIN on these forms.
Curtis Starnes
Senior Network Administrator
Granbury ISD
600 W. Bridge St. Ste. 40
Granbury, Texas 76048
(817) 408-4104
(817) 408-4126 Fax
curtis.starnes@granburyisd.org
www.granburyisd.org
OPEN RECORDS NOTICE: This email and responses may be subject to Texas Open Records laws and may be disclosed to the public upon request.
> He is suggesting COALS .........
as in lumps of coals, is what you are going to get on christmas from him, if he does not get this gig !
Faisal Imtiaz
Snappy Internet & Telecom
I would suggest getting a new consultant .. 
Possible Acronyms
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Chance of a Lifetime (raffle)
Lol got me! There is nothing that I know of that you have to "license" to become a ISP in the US of A. . You do have to fill out Form 477 twice a year.
www.linktechs.net - 314-735-0270 x103 - dmburgess@linktechs.net
As always, you should consult with your company's attorney or legal advisor.
ISP's do not have a seperate license in the USA (besides normal business and tax licenses).
COALS refers to cable operators and multichannel video programming distributors.
CLEC refers to competitive local exchange carriers (i.e. telephone and
private line circuits).
Wireless ISPs may need a FCC radio frequency license for high power or exclusive use of radio frequencies. Low-powered Wi-Fi doesn't need a
license.
Generally you need some kind of permission or license to install facilities in a public right of way or exclusive use of public airwaves.
ISPs can lease those facilities from licensed operators, and don't need a license themselves. In practice, most cable operators and telephone companies are also "self-provisioned" ISPs. They have "license" from a state and/or FCC; but that's because they are cable or telephone companies installing telecommunication facilities in public rights of way, not because they are ISPs.
There is no such thing as an 'ISP license' in the US. I have a hard time
imagining Texas of all places would have such a requirement.
Depending on what exactly you are doing, there are various and highly
varied requirements, such as acquiring a SPIN number for E-Rate, filing FCC
477 if you do broadband, FCC 499 if you do VoIP (CLEC and ETC also apply
there), a FRN if you do pretty much anything FCC-related, various sorts of
licenses for most radio/microwave systems (excepting part 15 stuff), CALEA,
open internet, etc...
COALS _could_ apply _if_ you are running a cable TV system that also
delivers data services, but it isn't an 'ISP thing'.
More to the point...
I wouldn't take US legal advice from any consultant not familiar with US
law, or really any non-lawyer consultant at all. I wouldn't take it from
NANOG either; while it's a tremendous technical resource, it is not your
attorney.
There are a number of telecommunications focused law firms out there, with
knowledgeable lawyers. It would be a good idea to establish a relationship
with one, if you intend to enter the increasingly complex legal minefield
of being an ISP.
--Eric
I would suggest getting a new consultant ..
What Dennis said.
Lol got me! There is nothing that I know of that you have to "license" to become a ISP in the US of A. . You do have to fill out Form 477 twice a year.
But only if you provide:
- facilities-based broadband services, and/or,
- provide wired or fixed wireless local exchange telephone service
- provide interconnected VoIP service
- provide facilities based wireless telephony
(see https://transition.fcc.gov/form477/WhoMustFileForm477.pdf)
If you provide basic dial-up services, or wireless Internet over unlicensed channels - there's no licensing requirement whatever.
As Dennis said - first get a new consultant. Look for one who can work through your service model - what you're going to be selling, to whom, using what technology(ies) - and work from there to whatever licenses (if any) that you require.
Miles Fidelman
+1
Do not confuse a desire from some party you wish to do business
saying, "Our own consultants have said that we shouldn't do business
with anyone not compliant with these standards," as a requirement for
licensure. Bureaucrats simply like certificates and that's all this
really boils down to, a way for consultants and/or politicians to
meddle in both ends of what has previously been a pretty open process,
creating a solution in search of a problem and adding complexity where
it's generally not needed.
In fine, the only thing you need in the US to be an ISP is a network.
The rest is mostly all about trying to get customers from one section
or another of business or of the general public.
-Wayne
Maybe the consultant is confusing "licensing" with IP address allocations from ARIN.
Curtis Starnes
Senior Network Administrator
Granbury ISD
600 W. Bridge St. Ste. 40
Granbury, Texas 76048
(817) 408-4104
(817) 408-4126 Fax
curtis.starnes@granburyisd.org
www.granburyisd.org
OPEN RECORDS NOTICE: This email and responses may be subject to Texas Open Records laws and may be disclosed to the public upon request.
Well, now you're talking tax ID or, rather, a general license to
operate a commercial enterprise, not a specific license related to
ISPs.
I've got it! Send $25,000 and I will print you a shiny new license to hang on the wall!
Curtis Starnes
Senior Network Administrator
Granbury ISD
600 W. Bridge St. Ste. 40
Granbury, Texas 76048
(817) 408-4104
(817) 408-4126 Fax
curtis.starnes@granburyisd.org
www.granburyisd.org
OPEN RECORDS NOTICE: This email and responses may be subject to Texas Open Records laws and may be disclosed to the public upon request.
What you have been hearing so far is correct. You do not need a license to be an ISP other than normal business licenses in your municipality/state. The only thing I can think of would be if you were a voice carrier or wanted to become a CLEC which would give you better/cheaper access to local infrastructure via interconnection agreements (like local loops for DSL and duct/conduit access for building out your own fiber network). I can tell you that the CLEC route is pretty expensive and has quite extensive regulatory hurdles at both the state and federal level. If you are a pure data ISP (i.e. not originating voice services) running on leased access circuits there is not much more you should need to do. Of course, you could and should ask this same question of your state's communications commission if you need a legally sound opinion on this.
Steven Naslund
Chicago IL
Our owner has hired a consultant who insists that we should have an ISP
license to operate in the United States. (Like they have in other countries
like Germany and in Africa where he has extensive personal experience.)
Howdy,
There is generally no license required to be an ISP.
If you wish to own physical infrastructure located in the public right
of ways or use licensed radio frequencies, there are various licensing
and regulatory requirements.
We call those "cable companies," "telcos," "LECs," or "CLECs" even if
they also provide ISP service.
If you lease your long-haul cabling infrastructure (from folks who are
licensed) or implement physical infrastructure only on property you
own or lease, you need not address licensing yourself.
He is suggesting COALS with which I am completely unfamiliar.
https://apps.fcc.gov/coals/
That's if you want to be a cable TV operator (plus Internet). Unless
you're planning to run your own coax on the telephone poles, you don't
need that.
Regards,
Bill Herrin
In some cases it’s very simple to do something, in Michigan (for example) you
can run fiber and place items in the right of way by meeting the standards of
a Metro Permit, eg:
http://www.michigan.gov/lcsa/0,5798,7-333-23730-221070--,00.html
For most places, you just need to pay the state or local licensing
fees. You can generally do this for low cost, setting up a new C-corp
or LLC is $50 to file in my area. Well worth it if you just want to
establish yourself as a legal entity. Then you can do business with
that and usual minimal paperwork. You can pay hundreds to nearly
infinite money to establish your structure(s).
You do need to have some sort of TIN or EIN. This gets complex and
imposes requirements, consult an accountant, CPA or lawyer as well
in this area. It shouldn’t be more than $1k to establish the legal entity
unless there are very complex situations involved.
https://www.irs.gov/businesses/small-businesses-self-employed/apply-for-an-employer-identification-number-ein-online
Unless you are offering certain regulated services, the bar is quite
low to establish a company and maintain yourself. I’d say when possible
avoid complex programs, they tend to come with high reporting and auditing
costs.
- Jared
Not necessarily…
If you aren’t a facilities-based carrier:
https://transition.fcc.gov/form477/WhoMustFileForm477.pdf
You don’t need to.
Owen
This also applies if you are applying over unbundled elements or other leased facilities AIUI.
Owen