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from Dave Farber's list: Ireland to regulate peering

  • From: Steve Bellovin
  • Date: Sun Jun 15 08:36:40 2003

(apologies if this appears twice)

>From: Alex French <[email protected]>
>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 Specific 
>links are

		--Steve Bellovin, (me) (2nd edition of "Firewalls" book)