WTA Recommends Areas of Clarification in Response to Border Gateway Protocol NPRM

Today, WTA submitted comments in response to the FCC’s Notice of Proposed Rulemaking on Border Gateway Protocol (BGP) Routing Security Risk Management Plan requirements. In its comments, WTA noted several areas in which the small, rural-based ISPs it represents need clarification. These include:

(1) the need for a clear delineation regarding the Tier 2 or Tier 3 ISP status of RLECs that primarily deliver Internet access to end customers but have some ancillary involvement in the sale or resale of Internet transit;

(2) the need for clarification of the BGP compliance responsibilities and alternatives for RLECs and other ISPs where an upstream transit provider does not provide Route Origin Authorization (ROA) registration and maintenance;

(3) the need for clarification of the requirements and responsibilities for negotiating or renegotiating provisions for the registration of ROAs in current and future transit and other interconnectivity service contracts;

and (4) the need to consider the substantial likely equipment, maintenance, monitoring and consultant costs of implementing the proposed BGP rules in addition to cursory estimates of management and BGP Routing Security Risk Management Plan development costs.