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from Dave Farber's list: Ireland to regulate peering
From: Steve Bellovin <smb () research att com>
Date: Sun, 15 Jun 2003 08:34:22 -0400
(apologies if this appears twice)
From: Alex French <alex () evilal com>
Subject: Ireland to regulate peering
In brief: New rules being put in place by the Irish telecoms regulator
will regulate IP peering between ISPs as if it were a voice interconnect.
I'd love to hear from any other IPers who know if this is being proposed
anywhere else in Europe. As far as I know, this is unprecedented.
The Irish telecoms regulator (ComReg) has announced a new set of licensing
rules for telcos. The bad part is that the rules have been greatly
expanded to include regulation of "all electronic communications
networks", including (apparently) ISP networks and VPN operators.
ComReg is planning to apply the principles of voice interconnect to all
network types; this means that "operators of public communications
networks shall have a right, and when requested by other [operators], an
obligation to negotiate interconnection with each other for the purpose of
providing publicly available electronic communications services." In
effect, IP networks will have to peer with each other on request.
Even worse, the "interconnect" (i.e. peering) prices will be subject to
review by the Irish regulator if either party feels that they're not being
offered a fair deal.
The cherry on the cake is that ISPs can be designated as having
"Significant Market Power" (this used to be defined as having 25% of a
market, but the criteria are now more nebulous). If you have SMP, you must
publish your network cost accounting as prove that the peering prices you
charge are cost-oriented (cost + a reasonable ROI)
As I see it, this will lead to the collapse of the current peering/transit
negotiation process that ISPs have successfully used all over the world
for years. I don't even see how this would benefit smaller ISPs, since the
new rules are likely to discourage larger companies from entering this
market at all. At the very least, the regulation of peering rates has got
to hurt competition.
The relevant documents are available at http://www.comreg.ie. Specific
--Steve Bellovin, http://www.research.att.com/~smb (me)
http://www.wilyhacker.com (2nd edition of "Firewalls" book)
- from Dave Farber's list: Ireland to regulate peering Steve Bellovin (Jun 15)