Superloop's accc internet interconnection
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The document outlines requirements for licensed telecommunications carriers in Australia, emphasizing the need for a nationally significant network that connects major cities with high-capacity, diverse infrastructure while offering competitive wholesale services. It highlights the current high costs of domestic IP transit compared to other countries, the lack of competition, and the potential benefits of new submarine cables for transforming Australia into a competitive internet hub. Additionally, it stresses the importance of security and resilience in telecommunications networks to withstand attacks and comply with regulatory obligations.
Superloop's accc internet interconnection
- 2. Licensed Telecommunication Carriers under the Telecommunications Act which: ● National backbone connecting all five key 5 capital cities with clear channel protected 100G capacity to each; and ● Backbone must be connected to at least two (2) diverse IP PoP’s in each capital city. Each PoP in each city must be interconnected with at least 40G protected with upgrade path to 100G; and ● Offer commercial wholesale IP transit services to other carriers, retail service providers and content providers; and ● Have at least 100G aggregated clear international capacity which provides diversity between Australia, the United States and Asia; and ● Operate DDoS protection outside Australia at the major international IP gateways prior to connecting to international capacity toward Australia; and ● Have relevant approvals for data interception and data retention from the Attorney General’s department; and ● 24/7 NOC based in Australia and be a CERT Australia partner; Nationally Significant Network 2 Contents Item01Are deemed to be Nationally Significant Networks and allowed to require other NSNs to provide internet interconnections between networks. Incumbents Telstra, Optus and AAPT/TPG along with other nationally significant networks Superloop, Vocus and Vodafone would/could qualify.
- 3. Current framework has left Australia with some of the highest IP/transit domestic pricing in the world (USA $0.20, HK $1.10, SG $1.50 per mbps per month compared to Australia at $5.00 representing a 400% to 2500% increase in cost for Australian network operators) Domestic intecap transmission is around $0.30 per Mbps per protected 10G yet IP transit is ~$5. Due to lack of competition Gang of Four (GoF) domestic transit pricing almost mirrors international capacity pricing and with international pricing expected to drop soon domestic peering/transit will have a dampening impact Current arrangement often means that global carriers and content providers are “third line forced” into purchasing other services from the GoF providers to access their “eyeball” networks at a reasonable price It’s an open policy available to any network that meets the deemed peering criteria (ie. nationally significant) Why this is important - Competition GoF members get two (2) bites of the cherry as their consumers get charged internet access fees, yet also charge carriers and content providers to get access to their networks and get free ride on the originating network (often despite carrying the data to Australia at no charge to the GoF member) Australia to date has unfortunately missed a great opportunity to be an internet hub for Asia (Singapore and Hong Kong) however with the latest round of submarine cables about to land in Australia there is an opportunity for Australia to be competitive both domestically and internationally Encourages investment in telecommunications infrastructure both domestically and internationally which is made on the basis of servicing wholesale customers (RSP’s) and retail customers (corporate and residential) Having a broadly non-descriminatory policy (no-named basis) allows fluidity in the market and new entrants to become a Nationally Significant Network
- 4. SD Wan is one of the fastest growing market segments in the world and is a technology stack that overlays Software Defined Networking (SDN) on different networks to deliver a ubiquitous and secure network connection. The existing GoF will have both commercial and technical advantage over all other network providers in Australia as carriers and SD-WAN providers looking to deployed SD-WAN will at some level be required to and pay for interconnects with the GoF to deliver reliable and lower latency connectivity. Currently Telstra and Optus for example will essentially be paid to interconnect to other networks including other NSNs as full transit rate and be placed at a significant commercial advantage to others. Why is this important? Unintentional SD-WAN Tax SD Wan is one of the fastest growing market segments in the world and is a technology stack that overlays Software Defined Networking (SDN) on different networks to deliver a ubiquitous and secure network connection.
- 5. Yet ACCC think it’s OK? No action required? Only peer is Mumbai? Market is efficient? Really? Australia Transit Pricing is Uncompetitive Broad variance among cities.. Weighted Media 10 GigE IP Transit Prices in Selected Cities, Q4 2017 Source: Telegeography.com
- 6. Why this is important - National Security ● Networks with which the national IP backbone sits upon must be able to withstand certain levels of attack from internal and external parties ● Ideally these protective mechanisms should happen at the international borders *before* coming to Australia leaving Australia’s international connectivity “protected” ● Interconnection between NSN’s should happen with ports/interconnects that have scale to avoid congestion during burst events and be offloaded as locally as possible, as fast as possible, hence interconnection should ideally be at 100G and in each of the five major states/capital city. This fundamentally improves resiliency during attacks where 10G ports could become congested ● Being a licensed and commercial carrier provides obligations on the provider ● Being an NSN provides the benchmark and certainty for security agencies and the Attorney General’s Department that providers are appropriately resourced and regulated to comply with various obligations ● More NSN’s that meet this benchmark the greater the resiliency of the nations telecommunications infrastructure and the greater emphasis and optionality on service ● Without a fully competitive interconnection environment pushing pricing lower compared to peer countries within our region less content will be stored, processed and transmitted in Australia
- 7. Initiator Pays: ● Initiator Pays for establishment ● Either settlement free (SKA) or settlement basis ● Settlement basis ‘net’ average gigabit ● 10/40/100G interconnections only ● Commitment to not over-subscribe ports ● Peering in all five markets with interconnection locations to be made available at either Responders PoP locations or major neutral data centers at the Initiators discretion Interconnection Commercial Settlement (assuming no SKA) 7 Port Speed Install/Upgrade OTC MRC Interconnection Matrix 10 30 days 500 500 $500/net average gigabit per month 40/100 60 days 5000 1000 $300/net average gigabit per month
- 8. Appendix: Security is Important to be a Nationally Significant Network