Net Neutrality is really something that has me worried.  I know there have to 
be some ground rules, but I believe that government regulation of internet 
interconnection and peering is a sure way to stagnate things.  I have been in 
the business a long time and remember how peering kind of evolved based on 
mutual benefit or some concept of "doing the right thing".  For example, at 
InterAccess Chicago, our peer policy in the late 90s was pretty much the 
following.

1.  Non-profits or educational institutions could private peer with us as long 
as they bore the cost of the circuit.  (this kind of connection was more 
beneficial to them than us).
2.  Comparable sized carriers got to peer with us, with each of us picking up 
our portions of equipment and circuit cost since it was mutually beneficial.
3.  We would peer with anyone at any NAP we had a mutual appearance in.
4.  Larger network usual would not peer with smaller networks without some sort 
of compensation.

Seemed to work pretty fair at the time and we managed the backbone by watching 
customer traffic.  If things got congested, you paid for or peered with whoever 
you needed to in order to get acceptable performance for our customers.  The 
big guys did get to call the shots and made you pay but then again they 
provided the largest fastest connections so I guess it was fair enough.  It may 
have been the wild west in some ways but at that time everyone needed to get 
along because if your peering policies were unfair you would get universally 
shunned and then you would have real problems.  I hate that the network 
operators now feel the need to ask the government to step in.  When you ask for 
that don't be surprised that the government creates a cumbersome mess and 
disadvantages you in another way.  The problem is that the gov does not react 
at internet speed.

I remember the first unbundling agreements and trust me when I say that 
ourselves and the ILEC both found the gov't rules to be nearly unworkable.  We 
eventually started with the telecom act framework that forced them to the table 
where they finally sat down with us and said "Ok, Ok, what do you really need 
here" and we banged out a pretty good interconnection agreement that was 
workable for both of us.  Well, about as workable as it gets with an ILEC.

I think what will really drive everything is the market forces.  You either 
provide what your end user wants or you go out of business.  The customer could 
care less who pays for what pieces or what is fair because in the end, their 
service provider is the only one they will punish.  If Netflix becomes 
universally hard to connect to, then they will lose the customers.  The 
customer does not really care why your connectivity sucks, they just know that 
it does and that if someone better comes along, they are gone.

Maybe something better would be some sort of industry group that you could 
become a member of and that group could resolve peering disputes through some 
kind of arbitration process.   The benefit of being a member could be something 
like the opportunity to peer with any other member on demand with some sort of 
cost splitting arrangement.  They would need something like a group wide 
interconnection agreement.  The responsibility would then be the industry and 
not some appointed FCC working group that spends all of their time writing 
convoluted gibberish.  If the group was big enough and powerful enough, the 
incentive to get on board would be huge.

Steven Naslund
Chicago IL



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