Level 3 Wants FCC to Include Interconnection in Net Neutrality

volume on the Internet,” Level 3 General Counsel Michael Mooney, CEO Jeff Storey and other executives told Clyburn’s aide Monday, said a Level 3 ex parte filing. Content providers, such as streaming video services, have “multiple competitive options for delivering their content to the ISP,” but “the ISP itself offers the only path for that content to reach the end user,” Level 3 said. Several of the largest ISPs “are leveraging that bottleneck control over access to their users, demanding arbitrary tolls from providers like Level 3 who carry the Internet content requested by the ISPs’ end users from the global Internet to the ISPs’ last mile networks,” the company said. “If Level 3 will not pay these arbitrary and discriminatory tolls, these ISPs refuse to augment interconnection capacity that is congested to a degree that any network engineer would agree must be augmented for the Internet to function properly. … These ISPs are degrading the experience of their own customers as a means to leverage the collection of arbitrary access tolls from the rest of the Internet.” Other Level 3 officials at the meeting were John Blount, president-North America; John Ryan, chief legal officer; and Scott Seab, senior corporate counsel. Broadband Internet access providers have a "terminating access monopoly over end users that gives them the incentive and ability to demand new access tolls from some parties, leaving degraded local delivery for online content and services end users want," Joseph Cavender, Level 3 assistant general counsel, and others told Rosenworcel’s aide on Tuesday, according to a Computer & Communications Industry Association ex parte filing provided by CCIA. Also advocating for interconnection regulations at the meeting, according to the filing, were Catherine Sloan, CCIA vice president-government relations; Dave Schaeffer, Cogent Communications CEO; Brian Chase, Foursquare Labs general counsel; Melanie Wyne, National Association of Realtors senior policy representative; Angie Kronenberg, Comptel general counsel; Sarah Morris, senior policy counsel at the New America Foundation’s Open Technology Institute; and Phillip Berenbroick, policy director of the Internet Freedom Business Alliance. "Absent strong FCC rules against commercial discrimination by such access providers, we indicated that realtors, social media and other tech entrepreneurs, long haul transit providers, CDNs and others who depend on an open Internet for transmission of online video are all at risk in the near future," said the filling made in docket 14-28. Level 3 and other proponents of interconnection rules are encouraged the FCC will take it up (see 1411130042).