Level3 Wants FCC to Impose ISP Interconnection Requirements

Level3 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.
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