economic study cra
TRANSCRIPT
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Economic study on IP interworking:
Summary of findings
Paul Reynolds
3GSM World Congress15 February 2007
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Overview
The imminent migration to all-IP networks has raised a regulatorydebate about appropriate IP interconnection charging models
Key areas discussed:
NGN all-IP networks create the potential for large efficiency and
welfare gains
IP interconnection arrangements are critical to realise these gains
A number of policy implications flow from the analysis of IPinterconnection
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Future NGN interconnect enables economic efficiencyimprovements over current arrangements
Todays IP interconnect Future NGN IP interconnect
Best efforts quality
Packets transported along multipleblind routes without regard forcontents
Packets can only be counted at
network handoff points Interconnect pricing negotiated
bilaterally at handoff, in isolation ofretail pricing
Unlike circuit switched services, nonecessary link between retailcharging model andinterconnection model
Priority assigned by packet
Quality of service (QoS) can beguaranteed, with different quality fordifferent services
Differential charging by priority
Single party could provide virtualtunnel QoS path (e.g. IPX) forquality-critical services
VERDICT: INEFFICIENT
LARGE ECONOMIC EFFICIENCY GAINS POSSIBLE BUT HOW CAN THEY BE CAPTURED?
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IP interconnection is a critical lever for efficiency
Interconnect fees have important market effects
They impact cost recovery, and hence investment & innovation incentives
They impact retail prices, and hence consumer demand
IP interconnect therefore represents a critically important leverage point in
improving efficiency, especially in capturing the potential gains enabled byNGNs
Simply transposing a partial version of the current (inefficient) IP interconnect
arrangements into the NGN environment would be a massive lost opportunity, and wouldprobably undermine the rationale for upgrading to NGN
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What is the efficient direction of interconnect payments?
The efficient direction of interconnect payments can be derived from twofactors
The efficient retail pricing model
Network costsRETAIL PRICING MODEL
NETWORK COSTS
Efficient messageexchange
Efficient messageexchange
Efficient direction ofinterconnect fee
Efficient direction ofinterconnect fee
Efficient allocation ofcharges among
customers
Efficient allocation ofcharges among
customers
Cost distributionamong networksCost distributionamong networks
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The efficient interconnect model can be deduced if thedistribution of retail benefits and network costs are known
100%initiatingparty
100%receiving
party
100%
originating
network
100%
terminating
network
Distribution of benefits
Distr
ibution
ofcosts
BAK
i.e.Inter
conn
ectfee
=0
RPNP
IPNP Deriving the efficientwholesale model from theretail model and network costs
(assuming total cost of amessage = total benefit)
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What happens if the wrong interconnection model isimposed?
If an inefficient model is imposed, services will not be provided to an efficientextent and costs may not be covered
Networks will seek to recover their costs by distorting their behaviour e.g. by targeting onlylow cost customers, changing network design decisions or by raising other prices
These changes can lead to market outcomes that are far from efficient, includingsuboptimal network coverage and underinvestment in quality
Ultimately service offerings may be limited (e.g. retail usage caps) and overall consumerbenefits lower
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BAK is efficient in special circumstances only
BAK is only efficient under special conditions:
Where traffic is stable and balanced between peers (networks of similar size and cost)
Where the distribution of costs among networks happens to align exactly with the
distribution of benefits among retail customers
In most cases, BAK leads to market distortions and damages efficiency
By setting the interconnect price to zero, BAK requires a network to gain all of its revenuesfrom its own retail customers, which usually leads to inefficiencies in retail pricing
Because BAK is inflexible, it gives rise to network structure bias (the hot potato problem)and may lead to under-investment in quality and coverage of networks
A rational firm will not provide transit services under a BAK pricing model
These inefficiencies are likely to be amplified in an all IP-world
QoS increases the costs that need to be covered by wholesale and retail revenues, leadingto a larger cost gap if costs cannot be recovered
This might prevent the introduction of QoS in any form
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IPNP can outperform BAK
IPNP will outperform BAK in most situations
The fee should not be locked in but should instead respond to market developments
It is the model most commonly applied in telephony (already has wide consumer
acceptance)
For transit interconnection, it provides a means to cover transit costs that would otherwisebe stranded by BAK
For the most part it encourages beneficial messages and discourages spam
Works well where the sender gains the most benefit
Where the recipient gains the most benefit, repeated or returned calling patterns, or offlinerelationships, can sufficiently compensate so that beneficial messages are still sent
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RPNP can also outperform BAK
RPNP has the potential to outperform BAK on efficiency
Provided that the level of the fee responds to market developments
For transit, RPNP provides a means to cover costs that would otherwise be stranded by
BAK
However, if applied generally it would risk a massive growth in spam
The sending network and/or the sender would face zero costs, and the recipient may notbe able to prevent the messages
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There is no single best IP interconnect model;variety is necessary to optimise efficiency
Model Advantages Disadvantages Implications
BAK
Apparently simple and low costalthough requires monitoring ofretail market conditions, operator
costs and/or traffic balance
Leads to market distortions inmost cases
These are amplified in a QoS
environment and when BAK isapplied to transit
Suitable only in limitedsituations (e.g. sustainedtraffic balance between
peers) and is not flexiblewhen circumstances change
IPNP
Likely to perform well in manysituations because itdiscourages spam but it doesnot significantly impedemessages which benefit mostlythe receiving party
IPNP can provide efficient
signals to operators
Regulators have beenconcerned in some cases thatthe level of termination chargesmay not be effectivelyconstrained. Such concerns arelikely to be less relevant in anall-IP world.
Likely to be the bestperforming model in mostcommon situations
RPNP
RPNP can be efficient inparticular circumstances andcan adjust dynamically asconditions change
Encourages spam
May be suitable in somesituations, althoughdominated by IPNP in mostcases
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Policy conclusions
Proceed cautiously
Regulators should be very cautious in mandating IP interconnection charging models forthe unfolding NGN IP environment
This analysis shows that there is no justification for regulatory intervention to mandate asingle IP interconnection model at this stage. It is too early to tell what model or modelswill prevail commercially
Regulatory intervention to prescribe a particular model, such as BAK, is likely to be pre-emptive and risky
Dont mandate a single charging model
Even if a particular charging model develops commercial currency, it does not follow thatthis would be appropriate to mandate as it may inhibit the development of better models
Evidence from the IP environment to date is that the industry can work out appropriate IPinterconnection models without the need for ex ante regulatory intervention
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Policy conclusions(continued)
Dont assume bottlenecks will be replicated
The deployment of NGNs has the potential to change the way many services are delivered.A regulator should not assume that existing bottlenecks will be replicated
Use existing regulatory frameworks
Existing regulatory frameworks are generally sufficient to resolve problems should theyarise (where they are telecom sector-specific and based on an objective assessment ofmarket power and general competition powers)
Employ consumer welfare analysis Should regulators feel a need to act, they should address the particular circumstances only
When considering IP interconnection charging models that might be applied in anyintervention, a clearly defined assessment framework that reflects the drivers of consumer
welfare and broader economic efficiency should be employed
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Economic Study on IP interworking:Summary of findings
Paul ReynoldsCRA International
1 UndershaftLondon EC3A 8EE+44 (0)20 7664 3701 (ph)
+44 (0)20 7664 3998 (fax)[email protected]