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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 
links are


                --Steve Bellovin, http://www.research.att.com/~smb (me)
                http://www.wilyhacker.com (2nd edition of "Firewalls" book)

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