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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@example.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)