Response to the BEREC consultation about the draft report on IP-Interconnection practices in the context of Net-Neutrality

We responded to the consultation opened by BEREC about the draft report on IP-Interconnection practices in the context of Net-Neutrality.

What is at stake here is linking citizen rights with competition on the market. Interconnection are what enables IAPs to provide for their customers access to the content they want. If these interconnections are not fair, the quality of the citizen's access to the information is strongly harmed. We saw this with the dispute between Free and Youtube: end-users could not access properly to the content they asked for. In addition, unfair interconnections are disrupting the market: newcomers cannot compete fairly with the main players that are imposing their rules.

Our document addresses these principal topics about this report :

  • Political vision: one of the most striking elements of the text is that it lacks some political vision, especially from the citizen's point of view ;
  • Monitoring: we suggest BEREC to be vigilant about interconnections and to firmly act if necessary ;
  • Methodology: though we were pleased to read a well-documented report, the different NRAs that contributed to that document have not all mentioned their methodology and its possible biais. We warned the regulator about this, which should be improved to avoid bias in the interpretations of the reports ;
  • From on-net CDN to IXPs: IXP are for us one one of the key structures that make the Internet alive and open to fair competition. Quite surprising, our positions here are the same than ITU-T ;

 

It is written in English, as BEREC prefers the contributions in this language.

We hope these insights will help the regulator in its analysis work.

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