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Will FCC Act On Level3 Comcast Dispute?
Level3 Tells Us They Still Hope So, But Signs Point To No
by Karl Bode Friday 18-Feb-2011 tags: legal · business · bandwidth · net-neutrality · Comcast · Comcast
The other day FCC boss Julius Genachowski insisted that peering disputes wouldn't be covered by the agency's new neutrality rules, joining a long list of uncovered items like wireless networks or discriminatory application-based pricing. Genachowski was responding to a request by the cable industry and AT&T that the FCC clarify their position on Comcast's financial dispute with Level3 -- which Level3 insists involves Comcast using their size to impose a new toll on Netflix traffic, but Comcast insists is just a run of the mill peering dispute. The truth is probably somewhere in the middle, but it's hard to for anyone to be certain given the agreement between Comcast and Level3 is confidential.

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While many (us included) interpreted Genachowski's comments to mean he saw things Comcast's way and would side with last mile ISPs, not everybody agrees. Harold Feld, primary lawyer for consumer advocacy firm Public Knowledge, pointed out on Twitter yesterday that Genachowski wasn't actually definitive in any way. Level3 spokesperson Monica Martinez tells Broadband Reports they also believe Genachowski's comments before Congress were just ambiguous enough not to preclude future action on the Comcast dispute:

Representative Blackburn: Okay, let’s talk about peering and interconnectivity. We know that these arrangements have never been regulated, and the FCC’s net neutrality order says that the rules do not cover peering. So, Mr Chairman, do you believe the Commission’s new net neutrality order and its underlying rules govern the Level 3/Comcast dispute?

Chairman Genachowski: Well, as you said, the order says that it doesn’t change anything with respect to existing peering arrangements. It applies to Internet access service provided to consumers and small businesses. You're referring to a dispute that's occurring outside the Commission, a commercial dispute. I hope those parties settle it and resolve it, but it’s not something that we have facts and data on. I do think the order speaks for itself in the way that you suggest.

"We've seen some coverage that makes the leap that the Chairman specifically indicated that the Level 3/Comcast dispute was a peering dispute, but...he never actually said that the Level 3/Comcast issue was a peering dispute nor did he say it would be outside the rules," says Martinez. She notes that no formal complaint has been filed and the rules aren't even "live" yet -- which could be why Genachowski hasn't taken a position. "We also believe that the Chairman carefully limited his agreement to the notion that peering would not be covered by the Open Internet Order – with which we also agree, (since) our dispute with Comcast is not a peering dispute."

Level3 Senior VP Robert Yates agrees. "Chairman Genachowski took great pains to avoid such an implication, correctly stating that the Comcast/Level 3 dispute is not yet before the FCC and that the FCC has gathered no facts about it," said Yates. "To the contrary, Level 3 was encouraged by Chairman Genachowski’s observation that the Open Internet Order applies to Internet service to consumers and small businesses, the very service that Comcast is using to extract a fee from content owners and their carriers as a condition to delivering the content that Comcast’s subscribers request."

So will Genachowski hear tier1 ISPs complaints and act? Genachowski's comments about a dispute occurring "outside the Commission" and that he hopes the companies themselves will settle doesn't exactly scream regulatory action. This is also an FCC boss whose legacy will be that of an ambiguous political orator who tried to make everybody happy -- and as a result pleased no one. It seems unlikely that captain ambiguity is going to change his stripes, or that an agency that can't be bothered to seriously tackle competition or apply neutrality rules to wireless will suddenly want to take any serious action against AT&T and Comcast -- even if there is hard evidence of anticompetitive behavior on the part of a last mile ISP.

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Post a:
Skippy25

join:2000-09-13
Hazelwood, MO

Only 2 important questions...

1.) Why is this traffic going from L3's network to Comcast's?

2.) Where is this traffic terminating?
Skippy25

join:2000-09-13
Hazelwood, MO

Re: Only 2 important questions...

The 2 answers.

1.) Comcast customers are requesting it.

2.) Traffic is terminating at the nodes of Comcast customers.

So it is standard ISP traffic between an ISP and an internet backbone provider.

fifty nine

join:2002-09-25
Sussex, NJ
kudos:1

Re: Only 2 important questions...

The whole "comcast customers are requesting traffic" argument falls apart because the internet is packet switched, not circuit switched.

I can "request traffic" to go to some completely unknown third party. Should they pay for it?

Sending party pays. That's the way it is.

gatorkram
KaBOOM Baby
Premium
join:2002-07-22
Winterville, NC
kudos:2
Reviews:
·Suddenlink

Re: Only 2 important questions...

said by fifty nine:

The whole "comcast customers are requesting traffic" argument falls apart because the internet is packet switched, not circuit switched.

I can "request traffic" to go to some completely unknown third party. Should they pay for it?

Sending party pays. That's the way it is.

While the internet can work that way, it isn't really normal operations, and surely doesn't apply in this case.

If comcast users were not requesting the information on the level3 networks, it would have no reason to just suddenly start heading in that direction.

Some other party could do it, but it's not normal operations.
--
Give me bandwidth or give me death!
»/testhistory/661871/4f240

fifty nine

join:2002-09-25
Sussex, NJ
kudos:1

Re: Only 2 important questions...

said by gatorkram:

said by fifty nine:

The whole "comcast customers are requesting traffic" argument falls apart because the internet is packet switched, not circuit switched.

I can "request traffic" to go to some completely unknown third party. Should they pay for it?

Sending party pays. That's the way it is.

While the internet can work that way, it isn't really normal operations, and surely doesn't apply in this case.

If comcast users were not requesting the information on the level3 networks, it would have no reason to just suddenly start heading in that direction.

Some other party could do it, but it's not normal operations.

Then by your logic Level 3 shouldn't be collecting any payment for CDN services from Netflix either, since Comcast customers are requesting the traffic.
nonymous
Premium
join:2003-09-08
Glendale, AZ
Reviews:
·Callcentric
said by fifty nine:

The whole "comcast customers are requesting traffic" argument falls apart because the internet is packet switched, not circuit switched.

I can "request traffic" to go to some completely unknown third party. Should they pay for it?

Sending party pays. That's the way it is.

Well if you have an ISP with a CAP and someone is sending you unrequested traffic that goes over the cap how much do you want to bet the ISP will send you a bill ???

kpfx

join:2005-10-28
San Antonio, TX
Reviews:
·RoadRunner Cable
said by fifty nine:

Sending party pays. That's the way it is.

Makes sense. Explains the asymmetric nature of residential connections and the prices.

A10x1 connection may run about $50 but a 10x10 will usually cost you $500.
c1590

join:2010-02-28

Re: Only 2 important questions...

Also why my seedbox, which is $15/mo, regularly pushes 10tb er month on 1000x1000.
Skippy25

join:2000-09-13
Hazelwood, MO
And you are paying for that traffic you are sending per the agreement you have with your ISP.

Are they not charging you for connecting to the internet?

espaeth
Digital Plumber
Premium,MVM
join:2001-04-21
Minneapolis, MN
kudos:2
Reviews:
·Clear Wireless
said by Skippy25:

So it is standard ISP traffic between an ISP and an internet backbone provider.

Not quite.

Level(3) is looking to setup cache pools at all of the facilities in which Comcast has peering locations. (New York City/Newark NJ, Ashburn, Atlanta, Miami, Chicago, Denver, Dallas, Los Angeles, Palo Alto/San Jose, and Seattle)

Their plan was then to get free connections from Comcast to dump the Netflix traffic into Comcast's network -- completely separate from their backbone network & business.

Using your logic, Level(3) should provide me with free bandwidth for the servers that I colo because their downstream customers are paying them to access the websites hosted on my gear.
BlueC

join:2009-11-26
Minneapolis, MN
Reviews:
·Integra Telecom
·voip.ms
·T-Mobile US

Re: Only 2 important questions...

The whole issue I have with this argument is that Comcast has to accommodate the traffic regardless. Level3 is offering them a direct connection into Netflix's offerings, which benefits Comcast's customers.

If they choose to not peer with L3, the traffic will come from some other peer/transit. If there's no cost (speaking of transit costs) to dump the traffic in on their network from L3, why should they charge L3 for it? It would imply that it increases the cost on the transport side of Comcast's network, which is irrelevant given the traffic will come from some other source if they choose not to peer with L3.

This seems like a mutual benefit for Comcast and L3, yet Comcast is demanding payment to continue the relationship.

I would argue the majority of Comcast's data services comes from being the last mile ISP. Comcast would never be my first choice as a transit provider. Yes, they have a backbone, that relates more towards servicing their last mile customers.

espaeth
Digital Plumber
Premium,MVM
join:2001-04-21
Minneapolis, MN
kudos:2
Reviews:
·Clear Wireless

Re: Only 2 important questions...

said by BlueC:

The whole issue I have with this argument is that Comcast has to accommodate the traffic regardless.

Well, yes and no. My business model could certainly accommodate sending 1 metric asston more traffic if I'm getting my connections for free instead of paying for them.

said by BlueC:

If they choose to not peer with L3, the traffic will come from some other peer/transit. If there's no cost (speaking of transit costs) to dump the traffic in on their network from L3, why should they charge L3 for it?

Because in this case Comcast is the transit provider, just not in the traditional sense. They built out backbone connections from the various cities they service out to major peering exchanges across the US. This benefits the transit providers because now they don't need to build out massive capacity out to BFE, because Comcast has setup large pipes to get the traffic from multiple peer and transit networks back into that user base. Just because Comcast isn't paying a 3rd party for bandwidth use to get traffic from their service areas out to the peering exchange cities doesn't mean it's free -- the costs are just internal.

said by BlueC:

It would imply that it increases the cost on the transport side of Comcast's network, which is irrelevant given the traffic will come from some other source if they choose not to peer with L3.

Not necessarily. Say Level(3) doesn't get the free connections and they dump the traffic out to their other Tier1 peers. That will certainly cause them to bust their balanced ratios for peering if they're going to be dumping an additional 300gbps out to their peers, and will likely result in the end of SFI with one (or more) carrier(s) and leaving Level(3) to buy transit to support carrying the CDN business. If I'm a provider like Cogent who has been bent over by Level(3) in the past, I offer to take the paid transit from Level(3) and turn around and hand the connections over to Comcast for free just to get a little payback. Really in this scenario, both Level(3) and Comcast lose.

said by BlueC:

I would argue the majority of Comcast's data services comes from being the last mile ISP. Comcast would never be my first choice as a transit provider. Yes, they have a backbone, that relates more towards servicing their last mile customers.

Again, the establishment of the backbone by Comcast does more to help the carriers because it limits the cities to which they need to provide massive scaling for their infrastructure.

The pure CDN providers (Akamai / Limelight) didn't have any problem paying Comcast for connectivity because they get money from their customer to deliver bits, and they could either buy open transit for ${x}, or private peering from Comcast for ${something less than x}.

Level(3)'s goal is to collect money from their customer to deliver bits, build out a sizable LAN infrastructure to host the CDN pools, and hand off the traffic to Comcast within the same building for free. It's a great scheme if you can pull it off, and this is far from the first time this type of activity has been attempted.
BlueC

join:2009-11-26
Minneapolis, MN
Reviews:
·Integra Telecom
·voip.ms
·T-Mobile US

Re: Only 2 important questions...

said by espaeth:

Well, yes and no. My business model could certainly accommodate sending 1 metric asston more traffic if I'm getting my connections for free instead of paying for them.

How so? If you drop a peer, and that said peer has a peering agreement with one of your transit providers, won't that simply shift the load to that existing transit provider?

I'm still firm on the fact that if they were to just discontinue business with L3, that same amount of traffic will come from another source. L3 peers with a lot of other transit providers.

espaeth
Digital Plumber
Premium,MVM
join:2001-04-21
Minneapolis, MN
kudos:2
Reviews:
·Clear Wireless

Re: Only 2 important questions...

said by BlueC:

said by espaeth:

Well, yes and no. My business model could certainly accommodate sending 1 metric asston more traffic if I'm getting my connections for free instead of paying for them.

How so? If you drop a peer, and that said peer has a peering agreement with one of your transit providers, won't that simply shift the load to that existing transit provider?

The settlement-free interconnections between transit providers are based around traffic loading ratios. If Comcast and Level(3) de-peer, the traffic would indeed take another path, but that's going to put stress on the Level(3) to Carrier X interconnection in a way that Level(3) will likely have to pay settlement fees to the carrier that takes the bulk of the traffic.

Comcast has cost-favorable connections to a number of backbone providers because it built out a backbone infrastructure to meet the carriers, rather than making the carriers all buildout facilities to meet Comcast in each of their local markets. Chances are, the carrier receiving payment from Level(3) to take on the traffic would probably hand off the traffic to Comcast for free because they would be able to do so with hot potato routing in well positioned peering locations across the US. Additionally, depending on the carrier that gets used as an intermediate, that carrier might also be willing to cut Comcast in on some of the settlement fees it receives from Level(3).

said by BlueC:

I'm still firm on the fact that if they were to just discontinue business with L3, that same amount of traffic will come from another source.

Maybe eventually, but all this hubbub is over a request from Level(3) for 30x10Gig brand spankin' new connections to support this business. Of course, Level(3) likely won the bid with Netflix over Akamai and Limelight because they planned on getting the connections for free from Comcast as part of their proposal.
BlueC

join:2009-11-26
Minneapolis, MN
Reviews:
·Integra Telecom
·voip.ms
·T-Mobile US

Re: Only 2 important questions...

said by espaeth:

Comcast has cost-favorable connections to a number of backbone providers because it built out a backbone infrastructure to meet the carriers, rather than making the carriers all buildout facilities to meet Comcast in each of their local markets. .

That's complete rubbish. Any major ISP has the ease to collocate their equipment in facilities that have multiple transit providers available for cross connects. More importantly, it's easy enough to lease long haul or collocate equipment in a major peering exchange.

Most (if not all) traceroutes in the Minneapolis Comcast market tend to route through Chicago, and get handed off to another provider (common one is Level3, ironically). Comcast has simply collocated equipment in a lot of these peering exchanges throughout the country. It reduces their costs (I'd do the same) and they can form private peering agreements with many different providers.

This doesn't make them a company like Level3.

espaeth
Digital Plumber
Premium,MVM
join:2001-04-21
Minneapolis, MN
kudos:2
Reviews:
·Clear Wireless

Re: Only 2 important questions...

said by BlueC:

said by espaeth:

Comcast has cost-favorable connections to a number of backbone providers because it built out a backbone infrastructure to meet the carriers, rather than making the carriers all buildout facilities to meet Comcast in each of their local markets. .

That's complete rubbish. Any major ISP has the ease to collocate their equipment in facilities that have multiple transit providers available for cross connects. ... Most (if not all) traceroutes in the Minneapolis Comcast market tend to route through Chicago ...This doesn't make them a company like Level3.

You're missing my point. Any ISP can colo gear in a regional access point, sure, but most don't build their own transit network.

Compare Comcast to traditional Minnesota ISPs like VISI.com and USInternet.com:

traceroute to noc.visi.com (208.42.51.1), 30 hops max, 40 byte packets
 1  64.20.42.17 (64.20.42.17)  0.445 ms  0.448 ms  0.506 ms
 2  66.45.224.177 (66.45.224.177)  0.285 ms  0.330 ms  0.373 ms
 3  gi0-12.na31.b017536-1.jfk01.atlas.cogentco.com (38.105.245.49)  1.633 ms  1.786 ms  1.954 ms
 4  te8-1.3607.mpd01.jfk01.atlas.cogentco.com (38.20.42.61)  0.586 ms  0.588 ms  0.564 ms
 5  te0-3-0-7.mpd21.jfk02.atlas.cogentco.com (154.54.24.146)  0.951 ms  1.077 ms  1.140 ms
 6  te0-2-0-2.mpd21.ord01.atlas.cogentco.com (154.54.0.126)  22.082 ms  22.088 ms  22.237 ms
 7  te4-3.ccr01.ord04.atlas.cogentco.com (154.54.24.182)  22.271 ms  66.524 ms  66.389 ms
 8  te4-3.ccr01.msp01.atlas.cogentco.com (154.54.3.62)  205.800 ms  205.826 ms  148.727 ms
 9  38.109.24.162 (38.109.24.162)  32.431 ms  32.425 ms  32.398 ms
10  edge-1.mn2.visi.com (208.42.31.94)  33.310 ms  33.568 ms  33.141 ms
11  v-208-42-51-1.ip.visi.com (208.42.51.1)  32.723 ms  32.673 ms  32.693 ms
 
VISI relies on their upstream carrier to bring the traffic all the way back to MN on their infrastructure.

traceroute to www.usinternet.com (216.17.3.239), 30 hops max, 40 byte packets
 1  64.20.42.17 (64.20.42.17)  0.373 ms  0.378 ms  0.435 ms
 2  66.45.224.177 (66.45.224.177)  0.295 ms  0.335 ms  0.374 ms
 3  gi0-12.na31.b017536-1.jfk01.atlas.cogentco.com (38.105.245.49)  0.646 ms  0.801 ms  0.968 ms
 4  te8-1.3607.mpd01.jfk01.atlas.cogentco.com (38.20.42.61)  0.652 ms  0.642 ms  0.637 ms
 5  te0-3-0-7.mpd22.jfk02.atlas.cogentco.com (154.54.1.209)  0.746 ms  0.748 ms  0.866 ms
 6  te0-5-0-0.mpd22.ord01.atlas.cogentco.com (154.54.43.82)  22.285 ms  22.454 ms  22.529 ms
 7  te3-1.ccr01.ord04.atlas.cogentco.com (154.54.24.178)  22.511 ms  22.549 ms  22.615 ms
 8  te4-3.ccr01.msp01.atlas.cogentco.com (154.54.3.62)  177.019 ms  177.021 ms  177.073 ms
 9  g5-2.usi-cr02-mpls.usinternet.com (38.104.196.14)  32.560 ms  32.589 ms  32.604 ms
10  v102.usi-cr04-mtka.usinternet.com (216.17.51.22)  34.163 ms  34.167 ms  34.111 ms
11  216.17.3.186.usinternet.com (216.17.3.239)  33.265 ms  33.267 ms  33.231 ms
 
Same with US Internet

traceroute to twincities.speedtest.comcast.net (69.252.23.68), 30 hops max, 40 byte packets
 1  64.20.42.17 (64.20.42.17)  0.357 ms  0.354 ms  0.405 ms
 2  66.45.224.177 (66.45.224.177)  0.310 ms  0.357 ms  0.405 ms
 3  207.239.51.85 (207.239.51.85)  0.362 ms  0.365 ms  0.326 ms
 4  vb1010.rar3.nyc-ny.us.xo.net (216.156.0.17)  1.214 ms  1.415 ms  1.374 ms
 5  ae0d1.cir1.nyc-ny.us.xo.net (207.88.13.41)  65.599 ms  65.542 ms  65.566 ms
 6  Vlan585.icore1.NTO-NewYork.as6453.net (209.58.26.69)  4.024 ms * *
 7  Vlan577.icore1.NTO-NewYork.as6453.net (209.58.26.122)  43.574 ms  43.598 ms  43.545 ms
 8  68.86.87.225 (68.86.87.225)  43.368 ms  43.380 ms  43.472 ms
 9  pos-2-11-0-0-cr01.chicago.il.ibone.comcast.net (68.86.86.234)  60.991 ms  60.995 ms  60.956 ms
10  te-0-7-0-0-ar01.roseville.mn.minn.comcast.net (68.86.95.194)  71.561 ms  71.524 ms  71.485 ms
11  te-0-5-0-0-ar01.roseville.mn.minn.comcast.net (68.87.174.9)  70.382 ms  70.497 ms  70.545 ms
12  te-8-3-ur02.roseville.mn.minn.comcast.net (68.87.174.14)  71.917 ms  71.999 ms  72.121 ms
13  speed-upload-01.roseville.mn.minn.comcast.net (69.252.23.68)  69.888 ms  69.894 ms  69.878 ms
 
Comcast takes a regional handoff in NYC.

Same situation from the west:

traceroute to noc.visi.com (208.42.51.1), 30 hops max, 40 byte packets
 1  184.171.168.105 (184.171.168.105)  0.278 ms  0.365 ms  0.420 ms
 2  172.28.0.3 (172.28.0.3)  0.480 ms  0.534 ms  0.580 ms
 3  te1-8.na41.b023003-0.phx02.atlas.cogentco.com (38.104.116.185)  0.522 ms  0.523 ms  0.565 ms
 4  te3-3.3812.ccr01.phx02.atlas.cogentco.com (38.20.49.217)  0.621 ms  0.677 ms  0.729 ms
 5  te7-7.ccr01.sat01.atlas.cogentco.com (154.54.6.250)  20.329 ms  20.382 ms  20.430 ms
 6  te0-3-0-1.mpd22.iah01.atlas.cogentco.com (154.54.29.37)  25.205 ms  25.789 ms  25.974 ms
 7  te4-2.mpd01.dfw01.atlas.cogentco.com (154.54.25.221)  31.761 ms * *
 8  te0-2-0-1.mpd21.mci01.atlas.cogentco.com (154.54.5.218)  41.089 ms  41.276 ms  41.384 ms
 9  te0-1-0-2.mpd21.ord01.atlas.cogentco.com (66.28.4.186)  53.075 ms  53.047 ms  53.189 ms
10  te4-3.ccr01.ord04.atlas.cogentco.com (154.54.24.182)  53.667 ms  54.300 ms  54.394 ms
11  te4-3.ccr01.msp01.atlas.cogentco.com (154.54.3.62)  64.331 ms  63.984 ms  64.062 ms
12  38.109.24.162 (38.109.24.162)  60.630 ms  60.546 ms  60.533 ms
13  edge-1.mn2.visi.com (208.42.31.94)  61.624 ms  61.805 ms  61.977 ms
14  v-208-42-51-1.ip.visi.com (208.42.51.1)  60.359 ms  60.357 ms  60.352 ms
 

traceroute to www.usinternet.com (216.17.3.239), 30 hops max, 40 byte packets
 1  184.171.168.105 (184.171.168.105)  0.288 ms  0.357 ms  0.416 ms
 2  172.28.0.3 (172.28.0.3)  0.342 ms  0.403 ms  0.453 ms
 3  te-3-1.car2.Phoenix1.Level3.net (63.214.168.49)  0.513 ms  0.650 ms  0.648 ms
 4  ae-2-5.bar2.Phoenix1.Level3.net (4.69.148.122)  0.385 ms  0.382 ms  0.432 ms
 5  ae-0-11.bar1.Phoenix1.Level3.net (4.69.148.113)  0.483 ms  0.480 ms  0.474 ms
 6  ae-8-8.ebr1.Dallas1.Level3.net (4.69.133.30)  31.667 ms  27.932 ms  27.925 ms
 7  ae-92-98.ebr2.Dallas1.Level3.net (4.69.146.91)  35.547 ms  35.543 ms  32.309 ms
 8  ae-2-2.ebr1.Denver1.Level3.net (4.69.132.105)  49.893 ms  49.886 ms  49.879 ms
 9  ae-1-100.ebr2.Denver1.Level3.net (4.69.132.38)  45.861 ms  45.859 ms  45.855 ms
10  ae-5-5.car2.Minneapolis1.Level3.net (4.69.136.109)  56.017 ms  56.354 ms  56.338 ms
11  g0-2.usi-gw03-mpls.usinternet.com (4.59.66.10)  56.414 ms  57.194 ms  57.177 ms
12  v102.usi-cr03-mtka.usinternet.com (216.17.51.20)  62.244 ms  61.509 ms  61.487 ms
13  216.17.3.186.usinternet.com (216.17.3.239)  60.069 ms  60.064 ms  60.059 ms
 

traceroute to twincities.speedtest.comcast.net (69.252.23.68), 30 hops max, 40 byte packets
 1  184.171.168.105 (184.171.168.105)  0.309 ms  0.538 ms  0.606 ms
 2  172.28.0.3 (172.28.0.3)  0.283 ms  0.387 ms  0.465 ms
 3  209.188.10.138 (209.188.10.138)  15.300 ms  15.360 ms  15.417 ms
 4  4-1.r1.ph.hwng.net (69.16.190.249)  0.833 ms  0.913 ms  1.010 ms
 5  unknown.hwng.net (209.197.0.21)  15.397 ms  15.478 ms  15.559 ms
 6  be-100-pe01.600wseventh.ca.ibone.comcast.net (66.208.228.137)  11.930 ms  11.729 ms  11.785 ms
 7  pos-2-1-0-0-cr01.losangeles.ca.ibone.comcast.net (68.86.86.61)  11.891 ms  11.887 ms  11.879 ms
 8  pos-0-12-0-0-cr01.dallas.tx.ibone.comcast.net (68.86.86.118)  36.979 ms  36.965 ms  36.958 ms
 9  pos-2-10-0-0-cr01.denver.co.ibone.comcast.net (68.86.87.185)  52.948 ms  52.945 ms  52.318 ms
10  te-8-1-ar02.roseville.mn.minn.comcast.net (68.86.91.182)  97.065 ms  97.059 ms  96.411 ms
11  te-2-1-ur02.roseville.mn.minn.comcast.net (68.87.174.18)  98.277 ms  98.332 ms  98.460 ms
12  speed-upload-01.roseville.mn.minn.comcast.net (69.252.23.68)  97.992 ms  97.923 ms  97.967 ms
 

Taking inbound traffic at the nearest regional access point so it stays on the transit provider's network for the shortest distance possible is what makes Comcast act more like a transit provider than the average ISP. They're backhauling most of their user's traffic from across the country at their own expense.

Supervisor
Premium
join:2006-03-26
Marysville, PA

Re: Only 2 important questions...

said by espaeth:

Any ISP can colo gear in a regional access point, sure, but most don't build their own transit network.

Wait a minute. Who says most ISPs don't build their own transit network? I'm a tiny regional ISP and I have an internal transit network between a few cities, but that doesn't make me a transit provider. I'm quite sure that most ISPs have internal transit networks.

said by espaeth:

Lots and lots of traceroute output

Your multiple traceroutes show that Comcast has more points of interconnection compared to other providers. Nothing surprising about that given Comcast's huge size and bandwidth needs compared to other providers.

said by espaeth:

Taking inbound traffic at the nearest regional access point so it stays on the transit provider's network for the shortest distance possible is what makes Comcast act more like a transit provider than the average ISP. They're backhauling most of their user's traffic from across the country at their own expense.

The traffic we're talking about is destined for Comcast's own residential customers. Transit providers connect other ISPs to the Internet, they don't directly connect to residential customers. To say that Comcast is like a transit provider because they're hauling their own customers' traffic around long distances is stretching the definition somewhat. Of course traffic is dumped by the real transit providers onto Comcast's network as soon as possible, it's unreasonable to expect someone else to haul Comcast's customer traffic around the country, unless Comcast is paying them to do so.
BlueC

join:2009-11-26
Minneapolis, MN
Reviews:
·Integra Telecom
·voip.ms
·T-Mobile US

Re: Only 2 important questions...

said by Supervisor:

The traffic we're talking about is destined for Comcast's own residential customers. Transit providers connect other ISPs to the Internet, they don't directly connect to residential customers. To say that Comcast is like a transit provider because they're hauling their own customers' traffic around long distances is stretching the definition somewhat. Of course traffic is dumped by the real transit providers onto Comcast's network as soon as possible, it's unreasonable to expect someone else to haul Comcast's customer traffic around the country, unless Comcast is paying them to do so.

Exactly.

espaeth
Digital Plumber
Premium,MVM
join:2001-04-21
Minneapolis, MN
kudos:2
Reviews:
·Clear Wireless
said by Supervisor:

said by espaeth:

Any ISP can colo gear in a regional access point, sure, but most don't build their own transit network.

Wait a minute. Who says most ISPs don't build their own transit network?

National transit network.

said by Supervisor:

Your multiple traceroutes show that Comcast has more points of interconnection compared to other providers. Nothing surprising about that given Comcast's huge size and bandwidth needs compared to other providers.

It's only been that way since about 2008. Before that, most of the Comcast markets operated independently with their own Internet connections, the bulk of which were single homed markets that Comcast picked up when they acquired the cable broadband division from AT&T.

said by Supervisor:

The traffic we're talking about is destined for Comcast's own residential customers.

The bulk of the traffic that *ANY* network takes in is destined for its customers.

said by Supervisor:

Transit providers connect other ISPs to the Internet, they don't directly connect to residential customers. To say that Comcast is like a transit provider because they're hauling their own customers' traffic around long distances is stretching the definition somewhat.

Why is that stretching the definition? You pay a transit provider to haul bits across the country to reach interconnected networks. If you build your own network to accomplish the same goal that doesn't make it free, it just internalizes the costs of operating that network instead of paying a 3rd party.

The traditional defintions don't fully apply though. Comcast isn't a strict ISP, because they have traits that are characteristic of a transit provider. Level(3) also isn't just a transit provider, because they also fill the role of a content provider. The lines are blurred, but the agreements these companies make all come down to one thing: the balance of costs. It's much cheaper for Level(3) to handoff a few 10gig links within a colo facility than it is for Comcast to ship those bits around the country and augment their backhaul capacity to support the load.
BlueC

join:2009-11-26
Minneapolis, MN
Reviews:
·Integra Telecom
·voip.ms
·T-Mobile US
said by espaeth:

Any ISP can colo gear in a regional access point, sure, but most don't build their own transit network.

Yea, and how difficult is that? They have a large footprint, it's easy enough to colo equipment in a multiple locations and pay for long haul.

If I had customers in multiple markets, I'd do the same, and it wouldn't be all that difficult.

You're missing my point though. Compare L3's customers to Comcast's. Sure, Comcast has built out an infrastructure, but it's to benefit their residential customers, the same customers requesting traffic from Netflix (which involves L3 and other peers).

L3 has built out infrastructure for a lot of customers that meet them in the data center. Comcast does a ton of last mile service. Opposite purposes in my mind. Sure, anyone can buy transit from Comcast in the data center just like L3 (but who honestly would when you have better choices available), but that doesn't make them among the same caliber as global Tier 1s that have a much larger infrastructure.

espaeth
Digital Plumber
Premium,MVM
join:2001-04-21
Minneapolis, MN
kudos:2
Reviews:
·Clear Wireless

Re: Only 2 important questions...

said by BlueC:

said by espaeth:

Any ISP can colo gear in a regional access point, sure, but most don't build their own transit network.

Yea, and how difficult is that? They have a large footprint, it's easy enough to colo equipment in a multiple locations and pay for long haul.

My point wasn't that it was difficult. My point is that it's not free, and the costs involved in doing so are why most don't go this route.

said by BlueC:

You're missing my point though. Compare L3's customers to Comcast's. Sure, Comcast has built out an infrastructure, but it's to benefit their residential customers, the same customers requesting traffic from Netflix (which involves L3 and other peers).

I'm not sure "benefit their residential customers" is the phrasing I'd use -- quite simply, Comcast built out the network to save costs. Setting up for nationwide nearest-exit routing reduces the amount of traffic backhauled across any given peer's network, and that results in lower pricing (all the way down to $0) for the networks they interconnect with. Just like SFI between tier1 providers, just because there aren't settlement fees doesn't mean the traffic is free, it just means that the parties involved have elected to declare their costs of operating each network are close enough that an exchange of settlement fees between them would be a wash anyway.

That's the crux of this whole dispute is a balance of costs. It's generally agreed amongst the carriers with which Comcast peers that Comcast's internal costs of backhauling the traffic offsets the costs that would normally be incurred by each transit provider, and so pricing is adjusted accordingly. It's not just that they're meeting the carriers in the facility, but they're transiting the traffic cross country. Comcast could advertise each region's prefixes just out of local region peering exchange, but they take on that traffic in each peering point -- that's what makes the costs cheaper.

Here Level(3) isn't going to be sourcing the traffic from any further away than the local carrier neutral facility, so the balance of costs doesn't apply. If that were the case, I should be getting free handoffs from every carrier in the facilities where I colo servers.
Skippy25

join:2000-09-13
Hazelwood, MO
Level 3 is the biggest backbone in the world. You have no idea how it will effect the "mutually beneficial" agreement between them and any other company.

Comcast benefits by using L3 because they can service any entry point of Comcast to the internet and thus move the traffic much closer to their customers who are requesting the traffic and thus requiring Comcast to use less of it's own network to actually move it.

L3 offered to setup the new ports at their own expense for Comcast and Comcast refused. So this is not about Comcast being forced to spend money to support more traffic, they made that choice own their own.

Dillweed

@gci.com

Re: Only 2 important questions...

Espath, it's pretty obvious he is trying to troll you here. Don't bother taking the time to respond.

kpfx

join:2005-10-28
San Antonio, TX
Reviews:
·RoadRunner Cable
said by BlueC:

The whole issue I have with this argument is that Comcast has to accommodate the traffic regardless of whatever crappy provider Netflix pays. Level3 is offering them a direct connection into Netflix's offerings, which benefits Comcast's customers.

Take a look at that again. The argument that Comcast is responsible for all upstream traffic just because their end-users "want it" is crazy. On that point should Comcast give Netflix, Google, Yahoo, YouTube, Microsoft, Apple free multi-gigabit connections just because their customers want it?

On that note, I have a really popular Minecraft Server. Comcast should give me my connection for free too.
BlueC

join:2009-11-26
Minneapolis, MN
Reviews:
·Integra Telecom
·voip.ms
·T-Mobile US

Re: Only 2 important questions...

said by kpfx:

Take a look at that again. The argument that Comcast is responsible for all upstream traffic just because their end-users "want it" is crazy. On that point should Comcast give Netflix, Google, Yahoo, YouTube, Microsoft, Apple free multi-gigabit connections just because their customers want it?

Why not? Comcast is giving their customers connections to reach internet access globally. Residential ISPs have costs, transport and transit. If they can provide their customers with better routing and at the same time save money (versus paying for full routes), it's a benefit to them.

I don't view it as Comcast "giving" free connections to anyone. Their customers benefit from these connections, thus it's more negotiating for a better customer experience on their end while at the same time reducing their operating costs.

A lot of ISPs out there pay for their transit. They'd be more than happy to negotiate a settlement-free peer connection with a major transit provider. The idea of this said transit provider to pay THEM for the connection seems backwards.

If Comcast really thinks they're on the same grounds as Level3, regarding their target market, then they're not focusing on the majority of their customers. In my mind Comcast makes the majority of their money from the residential consumer market. They should be making decisions that benefits their paying customers. More reason why I would never use them at home or in the data center (and yes, I have the option to cross-connect to them as of current, and have chosen not to).

On that note, I have a really popular Minecraft Server. Comcast should give me my connection for free too.

This is very different from what we're discussing. Your server would only benefit from this free connection, while on the other side a provider is giving you free routes to millions of other IPs.

Comcast sees a benefit to millions of customers. L3 sees a benefit to more specifically, one major customer, but still shares routes to millions of others.

Regardless, you're talking about being benefited in a hosting environment. Majority of Comcast's customers are not hosting data, they're downloading.

annonymiss

@comcast.net

Re: Only 2 important questions...

Yes, Comcast should do what's best for it's customers.

And what that means is either Level 3 has to pay for the added bits being used to send TV over the internet, or the Customer should.

So, how exactly is increasing the customer's bill good for him again?
Coolbrz

join:2002-12-16
Kane, PA
said by espaeth:

said by Skippy25:

So it is standard ISP traffic between an ISP and an internet backbone provider.

Not quite.

Level(3) is looking to setup cache pools at all of the facilities in which Comcast has peering locations. (New York City/Newark NJ, Ashburn, Atlanta, Miami, Chicago, Denver, Dallas, Los Angeles, Palo Alto/San Jose, and Seattle)

Their plan was then to get free connections from Comcast to dump the Netflix traffic into Comcast's network -- completely separate from their backbone network & business.

Using your logic, Level(3) should provide me with free bandwidth for the servers that I colo because their downstream customers are paying them to access the websites hosted on my gear.

So the traffic is being dumped onto Comcast? So, as you put it that way, it sounds like Level 3 is dumping the traffic onto comcast and using comcast to deliver the traffic to other ISPs/Networks and not Comcast customers, correct?

skuv

@rr.com
1) Paying Netflix customers are requesting Netflix traffic.

That is the ONLY way to look at this.

I guess you didn't pay attention to me before when I said that there is no such thing as a backbone provider anymore. There USED to be. Until the majority of the large backbone's customers became content providers. You can't be the source of major content, and still be a backbone provider. And no, I don't mean that Level(3) is the actual source of the content, I mean that it is sourcing from their network.

gatorkram
KaBOOM Baby
Premium
join:2002-07-22
Winterville, NC
kudos:2
Reviews:
·Suddenlink

Break them all up

The best way to handle all of this, is to simply force all internet service providers, that also currently provide tv or phone, to split up and roll out new and separate companies for each of those services.

Internet service providers should be dumb pipe providers, period.
--
Give me bandwidth or give me death!
»/testhistory/661871/4f240
gorehound

join:2009-06-19
Portland, ME

Re: Break them all up

good idea i say.

fifty nine

join:2002-09-25
Sussex, NJ
kudos:1
said by gatorkram:

The best way to handle all of this, is to simply force all internet service providers, that also currently provide tv or phone, to split up and roll out new and separate companies for each of those services.

Internet service providers should be dumb pipe providers, period.

You own too much house/car/land/money etc. You need to give up some of it because you have too much.

Cheese
Premium
join:2003-10-26
Naples, FL
kudos:1

Re: Break them all up

said by fifty nine:

said by gatorkram:

The best way to handle all of this, is to simply force all internet service providers, that also currently provide tv or phone, to split up and roll out new and separate companies for each of those services.

Internet service providers should be dumb pipe providers, period.

You own too much house/car/land/money etc. You need to give up some of it because you have too much.

Um...not even in the same ballpark....

Romney2012
Defeat Obama 2012-Chg we can believe in
Premium
join:2002-03-03
USA
kudos:4

2 edits
said by gatorkram:

Internet service providers should be dumb pipe providers, period.

And backbone providers like Level 3 shouldn't be in the CDN business, period.

Why?

Based on your logic, lets also break up department stores & have separate stores for clothes, appliances, electronics, tools, etc. And also break up supermarkets so that only separate butcher stores, groceries, produce, dairy products, etc are allowed.

Going back to the 1950's isn't going to solve the issue of large size being a more efficient, cost effective method of competing nationally or internationally.
thecp

join:2004-07-15
Sacramento, CA

Re: Break them all up


Do you realize how off-base you are?

A proper comparison would be that it's more like the supermarkets and department stores also own the roads in your neighborhood, as well as all the growers and suppliers. Now you can see where problems come in.

skuv

@rr.com
said by gatorkram:

The best way to handle all of this, is to simply force all internet service providers, that also currently provide tv or phone, to split up and roll out new and separate companies for each of those services.

Yeah, that'll work out great. So then they'll have 3 times the customer service teams, 3 times the network support, 3 times the installers, and they'll have to physically separate the 3 different networks. Meaning, if it's a cable company, they'll have to split into 3, run 3 different cable nodes, one for tv, one for ISP, and one for phone. And run 3 different coax cables to everyone's house to provide separate services.

That will surely make it cost less!

Did you even give 2 seconds of thought to breaking a consolidated company apart?
hottboiinnc
ME

join:2003-10-15
Cleveland, OH

Re: Break them all up

that doesnt matter. After all we all want Comcast split up and give it to ATT and VZ since they're doing such a better job.
elray

join:2000-12-16
Santa Monica, CA
Reviews:
·SONIC.NET
·RoadRunner Cable
said by gatorkram:

The best way to handle all of this, is to simply force all internet service providers, that also currently provide tv or phone, to split up and roll out new and separate companies for each of those services.

Internet service providers should be dumb pipe providers, period.

Be careful what you wish for (especially considering your sig!).

You want dumb pipes? You'll have them.
Dumb, slow, skinny, expensive.

"Force" ISPs to divest then roll-out new services?
Today's triple-play prices may seem high, but they aren't that extreme when you factor in the feature set, labor, bandwidth, channel breadth, and lack of long distance charges.

The ~$125/month/household (3 TVs, no DVR, HBO/Showtime, Cable Phone, 10/1) we typically pay in our clan seems painful to me on the surface. But as an entertainment medium, it satisfies 4-5 household residents and a half-dozen guests per month - no Blockbuster fees or Netflix charges, no bar bills for sports, no $25 movie tickets for chick films or Disney fare. No billing fights with the phone company or litany of stupid add-on / below-the-line niggling charges. No $65 "basic" 256K internet - instead, they deliver double the promised rate.

Break it up, you think you'll pay less?
Sorry, that's not how it works.

You might succeed in killing off landlines altogether, but for the entertainment content you want, and online gaming and other streams, there is no rule that those costs will go down if you impose higher costs on the firms that deliver them.

The content owners certainly aren't going to take this lying down - you can see the squeeze on both ends with Netflix. There is nothing that prevents Uncle Sam, et al, from taxing the heck out of your service either, and/or controlling many elements of it.
hottboiinnc
ME

join:2003-10-15
Cleveland, OH
Reviews:
·WOW Internet and..
1 will NEVER happen. These companies are not in violation of any laws. And if you break them up who's going to get their networks? ATT? Verizon? LMAO! Yep! Sure! Why not! Maybe Qwest? Sprint? Okay! Sure! Lets just give it to them.

Comcast BUILT their network with their OWN money. Taking their money away from and their assets is ILLEGAL and will slap the United States with a lawsuit so fast worth so much money the Feds will be going back to China, the Swiss and the Scotts for more money to bay Comcast's legal bills and demands for illegal lawsuits.

Going after a company this site is NOT easy and the Gov't does NOT have the money nor resources to do it. What's going to happen though is Congress is going to cut the budget of the FCC (which should have been done YEARS AGO) and business will be as usual. Also what needs to be done by Congress is kick the damn FCC Chairman out. He has NO clue what his department does nor what their guidelines are in place. A regular every day run of the mill lawyer has no business being a chairman for the Feds on something he has NO clue about.

gatorkram
KaBOOM Baby
Premium
join:2002-07-22
Winterville, NC
kudos:2
Reviews:
·Suddenlink

Simple solution.

Level3 should just stop peering with Comcast, and see what happens.

Sooner or later, Comcast customers will start to complain about how slow services like netflix are.

On the other hand, lets say Comcast stops routing traffic out to Level3.. Who is going to care?

So... Yeah, tell me again why Level3 should PAY Comcast?
--
Give me bandwidth or give me death!
»/testhistory/661871/4f240

Romney2012
Defeat Obama 2012-Chg we can believe in
Premium
join:2002-03-03
USA
kudos:4

Re: Simple solution.

said by gatorkram:

Level3 should just stop peering with Comcast, and see what happens.

Sooner or later, Comcast customers will start to complain about how slow services like netflix are.

Level3 is not the only CDN. Comcast can deal with many others and if Netflix wants people to see their streaming service they will sign contracts with them.
»www.web-caching.com/cdns.html
Skippy25

join:2000-09-13
Hazelwood, MO

Re: Simple solution.

So what you are saying....

Is if another CDN wants to pay Comcast directly Comcast will allow their traffic?

So does that mean that Comcast should deny all internet traffic unless said supplier of data is willing to enter into an agreement with Comcast?

Sounds like a bunch of toll booths and intertubes to me that would not be very network neutral.
hottboiinnc
ME

join:2003-10-15
Cleveland, OH
L3 won't depeer with Comcast. Comcast will more likely de-peer with them and all will be done.
old_wiz_60

join:2005-06-03
Bedford, MA

The FCC is powerless.

The new Congress is busy working to eliminate the FCC anyway.
megarock

join:2001-06-28
Catawissa, MO
Reviews:
·Charter
·Brown Dog Networks
·Access US
·Google Voice

Re: The FCC is powerless.

The new congress is working to eliminate something all right - competition. Seriously, we don't need anything more than one phone company and one cable company and by the time those fools get done no one will have a job so no one will have money to get internet with anyway.

With all the hackers and programmers out there how hard would it be to create a end to end encryption so the ISP's can't figure out what is going through their pipe therefore can't block or throttle any of it? Right now they can tell you're connecting to Netflix, Bittorrent or a website. What happens when they can't?

BlowFish

@myvzw.com

Re: The FCC is powerless.

Easy, They cut you off.
hottboiinnc
ME

join:2003-10-15
Cleveland, OH
Reviews:
·WOW Internet and..
Congress is working at putting the FCC back in their place. NOTHING gives the FCC power to regulate the Internet except their own free will. It's the same with the FCC trying to say they have the legal right to tell property owners that they can NOT sign deals with XXX Cable company and NOT XXX Phone Company. Sorry they do NOT have that right. Nor the legal power to enforce that or the legal power/right to force anyone to let you have DirecTV or Dish Network. Sorry not a required product to live. Nor do they have legal power.
hottboiinnc
ME

join:2003-10-15
Cleveland, OH
Reviews:
·WOW Internet and..
As they should. The FCC has no legal power of the Internet. They over step their guidelines and rules all the time. Nothing is NEVER done about it. Now their Chairman and the rest of their department has to answer for it.

Time for them to make some cuts just like all the other departments. Give their budget to departments that need it- DHS, DJFS, DOJ, DOE, DOD, IRS could always use some more money to go after those that owe back taxes instead of trying to avoid paying them (those stupid law ads on TV on how to get away without paying your back taxes), and the FDA could always use some more money as well.

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