Response to Oftel's Consultation:
"Effective competition review of
Internet Connectivity" (published 31
August 2001)
British Telecommunications plc
30 October 2001
BT's Response to Oftel's Consultation
"Effective Competition Review of Internet Connectivity".
CONTENTS
1 INTRODUCTION......................................................................... 2
1.1
Introduction ............................................................................................. 2
1.2
Structure of Response ............................................................................ 2
1.3
Definitions ............................................................................................... 3
1.4
BT’s Request for Modification of Regulation ........................................... 4
2 THE MARKETPLACE ................................................................. 7
2.1
Internet Connectivity................................................................................ 7
2.2
Related Services ..................................................................................... 8
2.3
Geographical Scope Of The Market ........................................................ 8
2.4
Competition in the marketplace ............................................................. 11
3 CONCLUSIONS ........................................................................ 13
4 RESPONSES TO OFTEL QUESTIONS ................................... 14
Annex A - Internet Backbones........................................................ 16
Annex B - TABLE 1 - Approximate Categorisation of LINX
Membership ................................................................................... 20
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1
1.1
INTRODUCTION
Introduction
Internet Connectivity involves the provision of access to all the feasible
destinations on the backbone networks which comprise the Internet.
Connectivity is a matter for network operators themselves and not those who
purchase their services such as end-users and VISPs. ISPs often have a dual
function serving end-users and being part of the same entity as a backbone
operator.
BT welcomes Oftel’s conclusions that this market is effectively competitive.
As stated in Oftel's Consultative Document, BT made a request to Oftel to
modify the regulatory obligations that apply to services in the markets for dial IP
call termination and Internet connectivity. The basis of the submission is to
seek relaxation in the application of BT’s licence conditions as the market is
effectively competitive.
BT appreciates that the conclusions of this consultation alone cannot form the
basis for its request to modify the regulatory obligations that apply to generic
dial-up Internet services. BT is submitting a separate response to Oftel’s
consultation entitled “Oftel’s effective competition review of dial-up Internet
access”.
This response provides BT’s views on the nature of competition in this market
and comments on some of the trends highlighted by Oftel.
Any comments, questions or requests for further information should be
addressed to:
Teresa Wright
Regulatory Affairs Department
British Telecommunications plc
3rd Floor, Dowgate Hill House
14-16 Dowgate Hill
LONDON. EC4R 2SU
Tel: (020) 7728 4186
Fax: (020) 7236 3496
E-mail – teresa.wright@bt.com
1.2
Structure of Response
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This document is structured in the following way:

Section 1 provides an overview of Internet Connectivity in relation to
BT’s portfolio of services;

Section 2 comments on the market boundaries for Internet
Connectivity and comments on relevant factors used to assess the
state of competition in the market;

Section 3 summarises BT’s main conclusions;

Section 4 provides BT’s responses to the specific questions posed in
Oftel’s Consultative Document.
This document also clarifies some of the information relating to BT services in
the Consultative Document.
1.3
Definitions
A number of terms have been defined below to assist clarification. These
definitions are essentially compatible with those of Oftel, but imply a slightly
different interpretation on the relevant market. Oftel (2.4) describes Internet
Connectivity as meaning both the intended functionality of the service (access to
all destinations) and the service provided (transport of IP traffic). However BT’s
definition is limited to the functionality of the service. We prefer not to define
transit as encompassing all Internet destinations as this does not automatically
follow from a transit arrangement. However this difference does not affect the
overall assessment as to the competitiveness of Internet Connectivity.
Internet Connectivity needs the presence of an Autonomous System (AS) and
for an operator to provide or receive Internet Connectivity, it is necessary that
they operate an AS. Some ISPs have their own numbering (addressing)
systems but do not operate an AS due to their small size. Such ISPs purchase
transit to the Internet or buy another type of service such as fixed access.
As an ISP grows, it will wish to ensure service resilience and this usually implies
multi-homing or dual supply from independent suppliers. For this to be possible
they will need to operate their own AS and be able to route traffic but prior to
this, they could not be described as present in the marketplace for Internet
connectivity as such. The same applies to end-users and VISPs who do not
purchase transit but some form of Internet access.
Oftel defines transit as offering complete Internet Connectivity. In practice,
backbone operators offer transit services for a limited range of Internet
addresses within the context of specified AS routing systems. There is no
obligation to purchase complete Internet connectivity as such from a transit
contract. For example, BT purchases European connectivity partly through
Concert but also from other sources such as peering.
Internet Connectivity is acquired by an ISP normally through a mixture of
peering and transit arrangements. Only if an operator is in the ‘Tier 1’ group will
transit not be needed. Connectivity is supplied to the totality of the customer
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base, including other ISPs who transit or peer, and to end-users of which there
could be several different kinds.
Internet. The global collection of linked computer networks controlled by the IP
suite of protocols.
Autonomous System. An Autonomous system is a set of routers under a single
technical administration using interior gateway protocols/metrics to route
packets within the Autonomous Systems, and using an exterior gateway
protocol to route packets to other Autonomous Systems.
Internet backbone operator. An operator which has an Autonomous System and
which operates a gateway to route traffic to other Autonomous Systems.
Internet Service (access) provider: Involves the provision of a service to endusers enabling them to access the Internet.
Internet Services. The provision of a basic group of services accessible via the
Internet, including email, file transfer and web browsing. Excludes advanced
services and applications.
Internet Peering. The exchange of traffic between Internet backbone operators
of roughly equivalent size. No charges are made in either direction.
Internet Transit. The supply of Internet connectivity to part, or all Internet
addresses, for which a charge is levied.
Internet Connectivity. The ability to access destinations (addresses) on the
Internet world-wide.
Market for Internet Connectivity. The commercial arrangements of peering and
transit between Internet backbone operators.
End-users. Those who purchase Internet access services.
BT Dial-up products. These include SurfPort which terminates traffic in the UK
for an ISP and WebPort which takes the traffic of end-users to the Internet
directly over BT’s IP backbone.
BT would like to clarify a point in Table 1.1 of the Consultative Document that
describes BT’s dial-up wholesale Internet access products. The reference to
Internet Call Termination for SurfPort relates to termination at the ISP and not
Internet Connectivity. Similarly, WebPort products access the Internet directly
through BT’s network and do not terminate at the ISP.
1.4
BT’s Request for Modification of Regulation
BT agrees with the conclusion in Oftel’s Consultative Document that the market
for Internet Connectivity is effectively competitive. BT is however unable to
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compete on the same basis as its competitors. In particular BT is denied pricing
flexibility as it is unable to offer bespoke prices to its customers. Similarly, BT’s
competitors are able to make use of BT’s advance publication requirements to
follow BT’s pricing policy, to adjust prices as and when BT does and thereby to
decrease the impact of BT’s service innovations. BT therefore submitted
requests to Oftel in January 2001 to modify the regulatory obligations that apply
to services in the markets for dial IP call termination and Internet Connectivity.
BT is responding separately to Oftel’s Consultation ‘Oftel’s 2000/01 effective
competition review of dial-up Internet access’.
In summary the specific requests at the time were that:

The Director General exercise his discretion set out in Condition 58.1 to
remove the requirement to notify, publish and adhere to prices, terms and
conditions as currently required under Condition 58; and

The Director General confirm that any discrimination in the provision of
the services encompassed by this submission would be unlikely to be
deemed "undue" for the purposes of assessment of discrimination under
Condition 57.
In the light of the developments that have happened since BT first submitted its
application, BT now invites Oftel to adopt a further measure in order to achieve
the appropriate level of regulation. Conditions 57 and 58, relating to undue
discrimination and price publication, apply automatically by virtue of the
obligation to supply these services, as set out in Part B of BT’s Licence,
Condition 43. Services which include Internet Connectivity, such as BT’s
WebPort service, are not services regulated under any of the various EU
Directives (i.e. the Revised Voice Telephony Directive, the Leased Lines
Directive or the Interconnect Directive), and so Parts C, D and E of the licence
do not apply. Hence they do not act as a trigger for the application of
Conditions 57 and 58.
Given Oftel’s indication, as set out in the recent consultation on Number
Translation Services1, that where a market is competitive it will lift the obligation
to supply a service in that market, and hence as a consequence disapply
Conditions 57 and 58, BT now proposes that it would be reasonable and
appropriate to adopt a similar approach in this case.
The basis of this new request is that the market for Internet Connectivity is
effectively competitive. Competition should ensure that all reasonable demand
is met such that Oftel can be satisfied that it would be reasonable to lift the
obligation to supply.
1
http://www.oftel.gov.uk/publications/numbering/nts0901.htm
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If the Condition 43 obligation were lifted, Oftel may wish to consider whether to
make a Market Influence Determination. If, as Oftel suggests, the market in
question is effectively competitive, there can be no question of BT having
Market Influence, and hence BT considers there is no need to make any such
Determination.
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2
THE MARKETPLACE
The comments in this section follow the order on market boundaries contained
in Chapter 2 of Oftel’s Consultative Document and the state of competition in
Chapter 3. The product scope of the market in this case is strongly related to
the players who are deemed to be present in the market. The latter is covered
in paragraphs 2.4-2.12 of the Consultative Document while the geographic
scope of the market is covered in paragraphs 2.13-2.22.
2.1
Internet Connectivity
BT agrees with Oftel that the relevant product scope is the provision of Internet
Connectivity which is normally acquired from a mixture of peering and transit.
In trying to establish sensible boundaries, Oftel proposes applying the
‘hypothetical monopolist test’ to the Internet. This raises a number of
conceptual and practical issues. There are two particular features of the
Internet which are important in this respect raised by Oftel:

Non-inclusion of particular market operators (2.2.1).
Oftel excludes ‘large’ ISPs and instead concentrates on ‘small and medium
sized ISPs’ (2.18). This is surprising given that Global Tier 1 US operators are
critical to the provision of complete Internet interconnectivity, and they are also
present in the UK offering end-user services and transit/peering to other ISPs.
Their transit services are essential for other ISPs and their exclusion will bias
the relevant geographical boundaries (see Section 2.3 below).
Further, Oftel’s breakdown of ISPs is not that used by most industry
commentators as for example, TeleGeography (Annex A) who distinguishes
global, regional and national ISPs. To concentrate only on a part of national
ISPs would seem to be out of step with the whole structure of the industry.

Substitutability of services by end-users (2.11).
Oftel considers that the services provided by the Internet are not substitutable
with other services. The Internet generally implies the provision of a number of
basic services (see definitions above) and the extent to which they individually
and collectively could be substituted by other services is a matter of conjecture.
While some of these services might be substitutable by other products such as
voice number translation services, BT agrees with Oftel that these are probably
at the margin.
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2.2
Related Services
While BT agrees with the general picture shown by Oftel in Figure 2.2 in the
Consultative Document, Internet connectivity in the WebPort product range and
the equivalents from other operators, do not terminate traffic at the ISP, but
rather route straight to the Internet.
The key point is that Internet Connectivity can be separated from termination
and origination for most practical purposes. Those VISPS or ISPs who
purchase WebPort for their own customers, are not in the marketplace for
Internet connectivity, as they do not run their own Autonomous Systems.
It should further be noted that at this time BT does not supply Internet transit to
third parties, only complete Internet connectivity to ISPs and end-users from its
portfolio of fixed and dial-up Internet access services.
2.3
Geographical Scope Of The Market
Oftel limits the market to being national from the a priori exclusion of large ISPs
and the supposed prohibitive cost of purchasing Internet connectivity outside of
the UK.
Even within the UK, as Oftel notes (2.15), the geographical coverage of UK
backbone networks varies considerably in terms of their spread of inter-linked
Points of Presence (PoPs). However, this does not preclude nation-wide
presence of service, as traffic from end-users can be aggregated and
transported to these PoPs.
Similarly a market much broader than the UK can be identified. Oftel states
(2.21) that the purchase of ‘Internet connectivity in the upstream international
market is not within the scope of this review’. However, the Global Tier 1
operators are strongly present in the UK offering transit and (limited) peering,
and this cannot be simply ignored.
Looking at those operators present2 at the LinX, it appears that all the
commonly quoted Tier 1 operators3 are present and active in the UK. This is
not surprising given the importance of London as a localised hub outside of the
USA.
Also present at the LinX are a very wide range of other European operators
which are either Tier 1 equivalents in their own countries such as France
Telecom and/or operate pan-European backbones such as GTS/Ebone. The
breadth of representation at LinX is indicative of the global nature of the market
and the extent of competition in the UK.
Most of the members of LinX do not offer transit themselves but peer and
purchase transit from others. In this matter we agree with Oftel that those
2
See Table 1 at Annex B in which we have undertaken an approximate classification of
operators present at the LinX on the broad lines of that in TeleGeography.
3
As far as we can tell only Sprint is absent and this is due to delay from its proposed merger with
MCI WorldCom. Since that was turned down, Sprint has rolled out a European network and we
understand applied for membership at LinX.
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offering Internet connectivity is probably about 20 in total. This list includes
Global Tier 1s and a variety of other backbone operators which includes USA
Tier 2 players for example.
Transit and complete Internet Connectivity do not need to be wholly acquired in
the UK. We believe that for many ISPs in the UK, it is economically feasible to
have a mixture of peering in the UK with transit purchased in US/Europe.
For example, as shown in Figure 1 below, BT arranges Internet connectivity as
combination of:



Public peering at LinX/Manap
Private peering with a variety of other UK backbones.
Transit purchased in US using BT’s own transatlantic capacity.


Transit purchased from US Tier 1 using their transatlantic capacity.
Transit for Europe using the facilities of Concert.
Figure 1
BTnet Peering and Transit Connectivity Map
INS
M a na p
5378 CW C
5551
Cable Internet
5462 V ia.net Networks
5669
Sprint
AS 4000
AS 1239
Manchester
UUNet
AS 701
UKERNA
AS 786
Planet
AS5388
Scotix
New York
Abovenet
AS 6461
BTnet
AS 2856
GTEi
AS 1
London
Washington
ATT
AS 7018
Thus (Demon)
AS2529
C&W
AS 3561
UUNet
AS702
Legend
Public Peering
Private Peering
Transit Connexion
Concert
AS 5400
Exodus
AS 8709
Issue 1.1 Draft 1: 14.9.01
Oftel justifies a national market on the basis of the high cost of purchasing
transit outside the UK. However, BT considers that Oftel’s indicative exercise
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combining price data from BandX4 (as the lowest spot prices for Internet transit)
plus the additional costs of transport from the UK to Europe/USA, is probably
not a reliable guide to how most ISPs would acquire complete Internet
connectivity.
Other regulatory authorities have come to different conclusions from Oftel
regarding the market boundaries. While merger cases do not form precedent
for the delineation of markets for example under Article 82, nevertheless they
give some indication of the manner in which boundaries might be drawn in an
ex-ante setting of regulation, as for example is applied to BT.
The relevant product and geographical boundaries for Internet connectivity were
exhaustively examined by the European Commission in the MCI/WorldCom
merger5, the proposed MCI WorldCom/Sprint merger6, and to a lesser extent in
the proposed merger7 of Telia/Telenor.
The key points from these Decisions include the following:

The market for Internet connectivity was defined as global in all three
cases.

This was in spite of the fact that in the Telia/Telenor case, neither of
these operators would have been classified as a Tier1 operator.
Telenor‘s business as an internet transit provider was described as
‘marginal’ and Telia ‘stronger at a European level, but still small on a
global basis’ (paragraph 106).

The Tier 1 operators were considered to be in a position of unique market
power, but it was difficult to ascertain precisely the extent of this market
power given the complexity of peering arrangements and the fact that
transit might be purchased by a Tier 1 out of choice and not necessity.
The Commission applied the hypothetical monopoly test to Tier 1 operators and
argued8 that the impact of the price increase would be felt world-wide and so
‘there is thus effectively one global market’ .
These conclusions have been subsequently quoted by Commission officials.
For example, Ungerer9 argues that ‘..the major issue that emerged during this
investigation was the finding that the Internet was controlled by a highly
4
Note that since publication of the Consultative Document, BandX has announced the closure of
its operations in France, Germany and Holland, see http://www.totaltele.com. It appears that they
had very few customers if any in these locations.
5
Case IV/M.1069 Decision of 8 July 1998.
6
Case COMP/M.1741 Decision of 28 June 2000.
7
Case COMP/M.1439 Decision of 13 October 1999.
8
MCI/WorldCom case paragraph 82.
9
Acce3ss Issues under EU regulation and anti-trust law, International Journal of
Communications Law and Policy, summer 2000. Quote relates to MCI/WorldCom case.
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concentrated group of providers dominating that market, quite independent from
the geographical location of their physical backbones’. (underlining added)
Our key conclusions regarding market boundaries are as follows:

Given the influence of Tier 1 operators in the UK, including for example
C&W, we cannot see how Oftel can try to restrict the product or geographical
boundaries to be a sub-set of the marketplace.

In parallel, at least some UK backbone operators adopt a strategy of UKpeering (both public and private) but also directly purchase transit in the US.
The UK and USA cannot be separated for purposes of assessment of state
of competition.
2.4
Competition in the marketplace
There are a large number of providers of Internet transit in the UK and the
growth of peering adds to the general competitiveness of market dynamics by
putting pressure on all backbone operators to expand in size. Quantitative
evidence on market structure is however extremely difficult to acquire.
In line with the European Commission10, we believe that it is impossible to
derive meaningful revenue data in this market, given its distributed and
hierarchical structure and with the problem of how to treat peering (for ‘free’)
and transit (paid for). There are inevitable problems of potential double
counting of revenues and also of distinguishing Internet traffic from VoIP for
example, and VPN.
There are also acute problems of trying to get information on other indicators of
size, such as the network capacity of different operators, as this may carry other
packet switched traffic, the fibres may be unlit or not fully commissioned.
Regarding Oftel’s survey on UK backbone capacity (Figure 3.1), we suspect that
operators have not taken the same basis for measuring Internet traffic volumes
and we are very surprised to see one operator almost 3 times greater than the
nearest rival. Our impression is that there is likely to be a group of at least 4-5
backbones of roughly equal size in the UK and host of slightly smaller ones.
Concerning the structure and level of prices for Internet Connectivity, BT’s
Submission in January provided evidence of the rapidly falling prices both of
transit and of transatlantic bandwidth. These trends are broadly in line with the
picture which Oftel provides of prices in the ‘spot market’ of BandX (Figures 3.2
and 3.3). We are anticipating further very substantial falls in the cost of
transatlantic bandwidth over the new few years confirming Oftel’s view that there
is significant over-capacity in the sector as a whole.
BT features as a very modest player in this marketplace. To put this into
perspective, BT advertises less than 200 routes at LinX while the Tier 1
operators such as Sprint are advertising over 25 thousand routes. Tier 2
operators such as KPNQwest advertise in excess of 11 thousand routes at LinX.
10
MCI/WorldCom case op. cit.
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BT does not rank particularly highly in pan-European terms either and we feel
that some of the Analysys information is inaccurate and misleading in this
regard. Recently for example, France Telecom refused to peer with BT.
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3
CONCLUSIONS
BT is in broad agreement with the methodology and conclusions of this
Consultation namely that:

it is possible to define a separate market for Internet connectivity; and

this market should be regarded as effectively competitive.
As a consequence, BT has no competitive advantage or market power justifying
regulation of its services from the provision of Internet connectivity to third
parties or end-users.
However BT considers that the market for Internet connectivity cannot be limited
to consideration of the position of small and medium-sized ISPs alone. As a
consequence, it should not be defined as a UK market but as a Global one. This
is in line with findings of other regulatory authorities.
This conclusion is based on the following factors:

the strong market presence of the US-based Tier 1 ISPs;

the presence of other equivalent national Tier 1 European backbone
operators/ISPs;

the economic feasibility of acquiring Internet connectivity from a
mixture of UK peering and purchase of transit in the US itself; and

the likelihood of a chain of substitutability in the whole Internet
hierarchy.
However, BT does accept that widening the scope of the market will not affect
the conclusions drawn by Oftel which are relevant to this particular study.
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4
RESPONSES TO OFTEL QUESTIONS
Question 1 Do you agree with Oftel’s definition of the Internet connectivity
market?
BT's Response
BT considers that scope of the market should be widened to include Global
Tier1 and other large backbone operators and consequently the geographical
dimension of the market should also be broadened. Some small ISPs are not in
the marketplace for Internet connectivity. However these differences are
unlikely to alter radically the conclusions drawn regarding the state of
competition.
Question 2 Do you agree that despite limited information, this analysis provides
a fair assessment of the relative position of operators in this market?
BT's Response
BT believes that the analysis underestimates the strength of competition in the
marketplace even taking into account operators’ traffic missing from the survey.
Question 3 Do you agree that there appear to be no insuperable barriers to
entry and new entrants may be able to enter the market by using spare capacity
on existing networks?
BT's Response
In broad terms BT agrees with this proposition. In principle it would be possible
for an integrated ISP/backbone operator to set up with a network of only a small
number of PoPs and to purchase transit capacity (to the USA) from one or more
of the Tier 1 operators present in the UK.
Question 4 Do you agree that there appears to be active competition in terms
of quality, innovation and efficiency?
BT's Response
Yes, different operators provide a variety of products of differing standards to
suit individual needs.
Question 5 Do you agree that customers (ISPs) have a good choice of
competitively priced products?
BT's Response
Yes, a variety of products are available to suit differing needs.
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Question 6 Do you agree that customers (ISPs) have access to sufficient
information about suppliers and that they are able to take advantage of this
information?
BT's Response
Yes. ISP's have access to a variety of information from the established players
in the market on their products and services. Such information is made
available at trade fairs/industry events, in publicity material, general industry
publications and websites. Additionally designated account teams address the
particular needs of their customers.
Question 7 Do you agree that switching suppliers of Internet connectivity is
straight forward?
BT's Response
Yes. It is relatively simple to change suppliers or multi-source, subject to the
terms and conditions of an existing contractual agreement and any technical
issues surrounding network re-configuration required in order to change
supplier. These however are not difficult.
Question 8 To what extent does the bundling of Internet connectivity introduce
switching barriers and are these barriers a threat to the effectiveness of
competition in Internet connectivity?
BT's Response
By definition Internet connectivity has to be bundled to some degree for it to be
sold to a retail facing ISP, such as the provision of an interconnect link. This is
however incidental to the provision of the service itself. If complete Internet
connectivity is sold as a package to a retail facing ISP with additional service
features, it is not going to be a barrier to switching where the ISP has freely
contracted to take such a service. There are sufficient options open to both
backbone operators and ISPs for bundling not to be an issue.
Switching barriers are not significant at the technical level as distinct from
commercial level and mainly revolve around routing and addressing issues.
Question 9 Do you agree that even though the evidence is incomplete, it is
sufficient to conclude that competition in the market for Internet connectivity is
effective and that no operator has market power?
From the perspective of BT we consider that the market is competitive, taking
account of the Global position of Tier 1 operators.
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ANNEX A - INTERNET BACKBONES
Extract from TeleGeography 2001 (Electronic Edition) produced by
TeleGeography, Inc. in Washington, DC11.
What is an Internet backbone? And when is it
international? The questions are not as
straightforward as they might seem. International
cross
Internet backbones are private data links which
international political borders, run the Internet
Protocol (IP), are reachable from other parts of the
Internet, and carry general Internet traffic: e-mail,
Web pages, and most of the other popular services
which have come to define today’s Internet.
The Players
Approximately 300 International Internet Service
Providers (IISPs) own, lease, or otherwise get hold of
transborder network capacity; place routing
computers at either end; and use these segments to
cobble together logical networks that, together, form
hundred
the Internet’s international backbone. Three
may seem like a lot. Not all backbones are equal,
controlled
however: in mid-2000 the ten largest IISPs
three-quarters of international Internet bandwidth.
Some observers try to make sense of the Internet’s
four
11
snarl of networks by dividing them into three or
(Website : http://www.telegeography.com/)
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tiers. Under that framework, "Tier Ones" are the
handful of global backbone operators who have rich
significant
interconnection relationships with all other
providers; "Tier Twos" are the not-quite-Tier-One
their
backbones who end up having to pay for some of
direct backbone connectivity; and "Tier Threes" and
"Fours" are the national/regional and local ISPs,
depending on the context and topology, in question.
Those definitions are somewhat fuzzy–and for good
reason. As a whole, the Internet service provider
so
world is not segmented into hierarchical divisions,
hard-and-fast typologies just aren’t possible on a
global scale. The same is true, perhaps more so, of
the IISP segment. Instead, we have identified four
groupings around which IISPs cluster. However
imperfect, these markings on the IISP spectrum help
understand which way they lean:
Global IISP. Two kinds of IISPs engage in activities
which place them in the "global" range. One is a set
of very large players who have strong historical roots
in the U.S. Internet, either in origin (AT&T/Concert,
Genuity, WorldCom, PSINet, Sprint) or by osmosis;
Cable & Wireless acquired much of MCI’s Internet
backbone as a result of the MCI-WorldCom merger.
The other group of IISPs are providers who feature
point)
portfolios,
managed IP bandwidth over bent-pipe (point-tosatellite as important parts of their services
typically Intelsat signatories like Telecom Italia,
whose Seabone offering connects many countries
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BT's Response to Oftel's Consultation
"Effective Competition Review of Internet Connectivity".
around the world, or service providers like
Interpacket. The effort to move from the second set
of global IISPs into the first–Teleglobe attempted this
during the late 1990s–is a key dynamic within this
grouping.
Regional IISP. A regional IISP specializes in
operating backbone connectivity between different
countries in a single region, like GTS E-Bone in
Europe, Pacific Century CyberWorks or Telstra in
Asia, and Africa Online. Because of the impressive
build-out in Europe during the past two years,
Western Europe is probably the best example of the
impact that regional IISPs can have on reconfiguring
a single region’s topology map. At the other end of
the spectrum, a number of IISPs continue to vault
smaller,
into the regional area by purchasing existing
nationally-based IISP networks; once, these were
dominated by former incumbents, but an increasing
number of new entrants have borrowed this strategy
venture
as well, fuelled by the international spread of
capital and Initial Public Offerings.
National IISP. Typically, this is an Internet provider
part
increasingly
have
which has acquired international connectivity as
of a national or local service; which acts
as an upstream provider for other providers who
little or no international connectivity; and which
2000,
moves to expand into neighboring countries. In
this sector actually shrunk, as existing players
federated or were bought up to form regional IISPs.
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BT's Response to Oftel's Consultation
"Effective Competition Review of Internet Connectivity".
Academic IISP. Research networks, including those
operated by academic institutions, often act as
international connectivity providers alongside
commercial IISPs. In many environments, they
operate high-capacity, leading-edge systems,
catalyzing Internet development–examples are
Europe’s DANTE TEN-155 and GÉANT projects–but
they are increasingly specializing in exclusively
academic and research traffic as part of the
advanced
international coordination of Internet2 and
research applications.
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BT's Response to Oftel's Consultation
"Effective Competition Review of Internet Connectivity".
ANNEX B - TABLE 1 - APPROXIMATE CATEGORISATION OF LINX MEMBERSHIP
(Revised 30 10 01)
Global
Tier 1
USA
Tier 2
Pan
European
AT&T
Globix(GBX)
Carrier1 (CR1)
Cable and
Wireless
(CWC)
Exodus (EXD) Concert (CNT)
Global One
(GLS)
Abovenet
GTE bbn
(TPL)
(Genuity)
Level3 (LV3)
UK
Tier 1
BTnet (BTN)
Other
European
National
Tier 1
Belbone (BEB)
UK
Tier 2/3/rest
Other Specialist
(e.g. Content
Distribution)
1A Networks Ltd
(1AN)
BBC
Thus (Demon) BT Ignite
(DIL)
Germany (Viag)
(VIA)
Akhter Computers
(AHT)
Digital Island (DIL)
Deutsche
Telecom (DT)
Energis
Dialnet (DLN)
Astra Associates Ltd Microsfot(MIC)
(EUX)
Ebone (EBN)
NetKonect
(NK)
Eircom (TER)
Atlas (ATL)
INSnet (INS)
(CWC)
France Telecom
(FTC)
Euronet (ERN)
Avensys Networks
(Gemsoft) (GMS)
UUNET
(UUN)
KPN/Qwest
(Eunet) (KPN)
Sunrise (SRS)
Belgacom Skynet
(BEL)
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Yahoo! (YAH)
BT's Response to Oftel's Consultation
"Effective Competition Review of Internet Connectivity".
Global
Tier 1
USA
Tier 2
Pan
European
UK
Tier 1
Other
European
National
Tier 1
UK
Tier 2/3/rest
XO
Communicati
ons (GX
Networks)
(GXN)
Nacamar
Swisscom (SWC) Cable Internet (CI)
Verio
Telecom Italia
(TIT)?
Tele Dk (TDK)
Cerbernet (CER)
Teleglobe(TG
B)
Telia (TEL)
Telecom Italia
(TIT)
Claranet (CLR)
Equant (equ)
Thus (Demon)
(DIL)
Blixer (BLX)
Comdisco (COM)
Interoute (INT)
Chello
Broadband
Compuserve (CIS)
COLT (CLT)
ConXion
(Speedport) (VER)
Cubecom (CUB)
Datagrama (DAT)
Dialnet (DLN)
Easynet (ESY)
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Other Specialist
(e.g. Content
Distribution)
BT's Response to Oftel's Consultation
"Effective Competition Review of Internet Connectivity".
Global
Tier 1
USA
Tier 2
Pan
European
UK
Tier 1
Other
European
National
Tier 1
UK
Tier 2/3/rest
Eclipse Networking
Ltd (ECL)
Note FT, Equant SITA,Global One all
linked/part of one organisation/partnership
ECRC (ECR)
Esat net (EST)
Exodus (EXD)
FDD Ltd (FDD)
Firstnet (1ST)
Flag Telecom
Ireland (FLG)
Freedom 2 Surf
(FTS)
Frontier (FRN)
GA Telecom (GAT)
Globalcenter (GCN)
Globix (GBX)
HighSpeed Office
Limited (hsp)
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Other Specialist
(e.g. Content
Distribution)
BT's Response to Oftel's Consultation
"Effective Competition Review of Internet Connectivity".
Global
Tier 1
USA
Tier 2
Pan
European
UK
Tier 1
Other
European
National
Tier 1
UK
Tier 2/3/rest
HighwayOne (HW1)
Iaxis (IAX)
ICLnet (ICL)
I-NAP (VSS)
Intelideas (INT)
Interpacket (IPK)
Inweb (INW)
iPcenta (IPC)
Ipergy (ISD)
IPULSYS (IPS)
ISION Internet AG
(ISI)
Jippii (JIP)
Korea Telecom
(KOR)
Madge (MAD)
Mannesmann
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Other Specialist
(e.g. Content
Distribution)
BT's Response to Oftel's Consultation
"Effective Competition Review of Internet Connectivity".
Global
Tier 1
USA
Tier 2
Pan
European
UK
Tier 1
Other
European
National
Tier 1
UK
Tier 2/3/rest
(MAN)
MediaWays (MWY)
Mistral (MTL)
NetBenefit (NB)
Netcom (NET)
Netscalibur (Direct
Connection) (DIR)
NewNet Plc (NEW)
Nextra (TLN)
Nildram (NIL)
Nominum (NOM)
NTLI (NTL)
NTT (NTT)
Onyx (ONX)
Opal Telecom
(OPL)
Pilot (PLT)
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Other Specialist
(e.g. Content
Distribution)
BT's Response to Oftel's Consultation
"Effective Competition Review of Internet Connectivity".
Global
Tier 1
USA
Tier 2
Pan
European
UK
Tier 1
Other
European
National
Tier 1
UK
Tier 2/3/rest
Priority Telecom
(CGC)
PSInet (PSI)
REDNET (RDN)
Research Machines
(RM)
Roka (Topnet)
(TOP)
Singtel (SIN)
Song Networks AB
(sng)
Supportnet (SPN)
Tele2 (TL2)
Telefonica Data
(TFN)
Teleglobe (TGB)
Teletext (TXT)
Torch Telecom
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Other Specialist
(e.g. Content
Distribution)
BT's Response to Oftel's Consultation
"Effective Competition Review of Internet Connectivity".
Global
Tier 1
USA
Tier 2
Pan
European
UK
Tier 1
Other
European
National
Tier 1
UK
Tier 2/3/rest
Other Specialist
(e.g. Content
Distribution)
(TOR)
UKERNA (JNT)
VBCnet (vbc)
Versatelecom (VST)
Via.Net Works (VIA)
Wirehub! (WRH)
XTML (XTM)
Zoo (ZOO)
Note: No attempt has been made to identify/suggest exactly what individual companies may be doing at the LINX
because of the complexity of the industry. The breakdown is merely an attempt to show the type and quality of
organisations involved.
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