RD286 - ETNO Reflection Document in response to ERG consultation on Regulatory Principles of IP-IC/NGN Core

The Reflection Document is a reply to the ERG consultation on IP Interconnect (ERG (08) 26 rev1). ETNO is of the opinion that:
• A strict separation of transport and service layer would not allow the required end-to-end quality of service.
• Managed NGNs are a prerequisite for the fully secure networks of the future.
• The number and location of different PoIs will emerge as networks are rolled out. Ex-ante definition could lead to an artificial and more costly network structure then needed.
• The notion of “local level of interconnection” is not meaningful category in an NGN.
• NRAs’ powers to ensure interconnection, eg by selecting standards, should not be used unless persistent problems in end-to-end connectivitiy  occur.
• Regulators should look at existing regulatory constraints on PSTN and remove these as far as they are obsolete in an IP environment.
• The best solution is to apply the Calling Party’s Network Pays logic to IP-based NGN-interconnection, at least for voice services. Mandated Bill&Keep would induce market distortions, lead to technical inefficiencies, fewer incentives to invest in QoS and would cause high transaction costs.

• A strict separation of transport and service layer as discussed in the consultation document would not allow the end-to-end quality of service necessary to provide high quality time-critical services in an NGN environment.
• Managed NGNs are a prerequisite for the fully secure networks of the future. The public Internet could not assure security and integrity of networks and services as, e.g., required by the new proposals on security of networks for the EU regulatory framework.
• The number and location of different PoIs will emerge in line with technical developments, QoS-requirements and traffic and service development and will be subject to subsequent change as operations get optimised. Defining a number of PoI ex-ante could lead to an artificial and more costly network structure then otherwise needed.
• The notion of a “local level of interconnection” appears no longer to be a meaningful category in an NGN.
• Standards ensuring interoperability of networks and services for NGNs are being developed in the international standardisation processes. NRAs’ powers to ensure interconnection should not be used unless persistent problems in end-to-end connectivitiy  occur in the future.
• In order to foster IP-NGN deployment the regulator should look at existing regulatory constraints on PSTN and remove them as far as they are obsolete in an IP environment.
• To advance NGN interconnection and create regulatory certainty for market players, the best solution is to apply the Calling Party’s Network Pays logic to IP-based NGN-interconnection, at least for voice services. A mandated Bill&Keep regime would induce market distortions, lead to technical inefficiencies and fewer incentives to invest in quality of service and would cause high transaction costs.