INTUG Responds to BEREC Consultation on Net Neutrality

Yesterday INTUG published its response (PDF) to BEREC's consultation on net neutrality.

INTUG recognizes that one of the driving forces behind introducing traffic prioritization is the need for an improved quality of service for the Internet beyond “best efforts", and this is acknowledged as necessary for business users and therefore welcomed.

The balancing act to be performed successfully by regulators is achievement of this desirable objective, without sacrificing open access and a competitive market.

Discriminatory non-neutrality must not be allowed by disguising it as operational traffic management in situations of transient technical overload, emergency or security breach.

An issue of specific relevance to the business user market concerns ease of switching, which is identified by BEREC as an effective market measure to protect against discriminatory non-neutrality. The difficulty and cost of switching suppliers is an order or magnitude greater for a business user than for a single device end user. This factor has been largely overlooked when assessing entry barriers for new entrants seeking business customers.

It is important to recognize that full recognition is given to the different and distinct needs of private and public enterprise customers, compared to those of the mass-market consumer. The assessment of whether or not a problem exists must not be confined to analysis of individual site connections in single member states.

The multi-site, multinational connectivity requirements of enterprises demand a greater level of network neutrality. End-to-end connectivity must not be subject to denial of application use, or blockage of content, due to the actions of one service provider within the connectivity chain.

Mission-critical business processes cannot tolerate the impact of such differentiation or discrimination in the same way that an individual consumer can, since the latter can use a competitive retail market to change supplier, whereas an enterprise customer cannot, in such circumstances.

In terms of the European Union, it is essential, if a single market in ICT is to be created effectively, that the approach to net neutrality should be the same in all member states. Current levels of fragmentation and dysfunctionality guarantee that, for most enterprise customers, the present situation provides neither an open Internet nor net neutrality.

Read the full response.

Source: INTUG

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