Unsubstantiated Rumor - this is not simply about RBOC ISP Tariff

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

I suspect that "directly analogous" is neither a legal nor a regulatory
term.

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)

It may be worth your while to learn what a "telecommunications carrier"
is. (I rather doubt that you are one. I also rather doubt that the
people you want to peer with are either.)

The telecomreg mail list might be a useful place for you to explore this topic.

-tjs

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

I suspect that "directly analogous" is neither a legal nor a regulatory
term.

Tim this is new legal ground. That is my whole point.

> 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)

It may be worth your while to learn what a "telecommunications carrier"
is. (I rather doubt that you are one. I also rather doubt that the
people you want to peer with are either.)

I'm very aware of what a "telecommunications carrier" is and without boring
you with the details I'm also very secure in Whole Earth Networks ability to
fall under that definition. The question as to whether we peer with other
"telecommunications carriers" is what should be of interest to the
operational community.

I'm going to take this off of this list but all I'm trying to get across if I
can't be more subtle about it is:

A broad FCC interpretation of the 'Act' with regard to regulations concerning
what 'Interconnection' is among 'Carriers' could be of operational benefit to
many on this list and we need to make that clear to our future regulators.

--david

You really should go to http://www.fcc.gov and read some of Reed Hundt's
speeches concerning the Internet. You are headed 180 degrees opposite
of where the FCC is currently headed. And this discussion really does
belong on com-priv@lists.psi.com where FCC issues are regularly discussed.

Michael Dillon - Internet & ISP Consulting
Memra Software Inc. - Fax: +1-250-546-3049
http://www.memra.com - E-mail: michael@memra.com

You really should go to http://www.fcc.gov and read some of Reed Hundt's
speeches concerning the Internet. You are headed 180 degrees opposite
of where the FCC is currently headed. And this discussion really does
belong on com-priv@lists.psi.com where FCC issues are regularly discussed.

Thank you again for the pointer, very useful.

I'm trying to pay more attention to the rulings and the dates than the
speeches.

--david

ISSUE/BUREAUS STATUTORY FCC PROCEEDINGS TIMETABLE STATUS
                 REQUIREMENTS
                 DEADLINES
                 
Interconnection Intelligent Network CC Docket 91-346 Q1 1997 OPEN