[AusNOG] Domestic Peering WAS: Vocus peering traffic missingfrom PIPE-IX?

[Mark Newton]

On Fri, Nov 09, 2012 at 11:29:47AM +1100, James Spenceley wrote:

 > I've been involved with a few peering disputes and the ACCC.
 > Back in 2001 (and again in 2008) we tried to have peering treated
 > as a Declared Service by the ACCC. That would have done exactly
 > what a few people have suggested on list, a set of defined
 > criteria and costs. 

I look at the USA, where peering is pervasive in spite of the fact
that there are no regulations governing it, precisely because the
carriers involved see that it's in their business' best interests
to do it.

Most of the butthurt about peering comes down to this:  Telstra and
Optus don't want to do it.  Ignore the other two members of the GoF
because they don't really matter, for the purpose of this discussion
it's about replacing domestic transit with domestic peering to reach
Telstra's and Optus' customers.

More or less the entire industry /except/ the GoF peer all over
the country.

The GoF don't, and when you ask them why not they say it's because
they're regulated, and they're peering in the way the ACCC told them
to.

That's a non-answer because the ACCC's order to peer between the GoF
has never stopped them from peering more widely with other parties:
it's a minimum standard, not a maximum.  So in 2012 the only practical
effect of the ACCC's GoF decision is to give the GoF a handy excuse
to not peer with anyone else.

So I think the best path out of this mess is to lobby the ACCC to
repeal their GoF decision, to de-regulate peering.

That'll put Australia into roughly the same boat as the United 
States:  A large number of small carriers, a small number of 
large carriers, and a selection of sites across the country where
pretty much everyone happens to be in the same building.

Once that happens, small-carrier peering will remain the same as 
it is now (because small carriers have business reasons for maintaining
it), but the discussions with large carriers will be different: They'll
no longer be able to use the GoF agreement as an excuse to not
proceed with bilateral peering with non-GoF carriers of an appropriate
scale.

I can't see them ever joining MLPAs, but at the very least it'd be
no worse than were we are now.

In the alternative:  If the ACCC won't make the GoF scheme go away, 
they should modify it to make it settlement-based instead of 
settlement-free.  That'd create a situation in which refusing to peer
with a third party service provider would cost a GoF member money
(because they'd need to pay one of the other GoF members, their
biggest competitors, to deliver the traffic).  So we'd then have
a financial incentive to peer built into the structure of the 
industry in Australia.

But that's a less preferred option, imho.  The best outcome would
be to deregulate, not reregulate.

The GoF regulations in their current form should be viewed as a 
business risk to non-GoF telcos.  It's high time for them to go
away.

  - mark