PLDT: Proposed IP policy to harm Internet services

MANILA, Philippines -  The proposed circular on Internet protocol (IP) peering policy of the National Telecommunications Communications (NTC) may lead to the degradation rather than the improvement of Internet services in the country, according to telecommunications leader Philippine Long Distance Telephone Co. (PLDT).

In a position paper, PLDT said that compelling Internet service providers (ISPs) to connect via a single Internet exchange as proposed in the draft NTC order may create a bottleneck that could hamper rather than raise the service quality of the ISPs.

“This is a case where the proposed solution may just compound the problem,” PLDT head for public affairs Ramon Isberto said.

Under the draft circular, all ISPs shall be required to connect with the IP exchange of the Department of Science and Technology-Advanced Science and Technology Institute (DOST-ASTI) with respect to their domestic Internet traffic.

In its position paper, PLDT said Internet service levels could suffer because the NTC circular does not provide for rigorous and robust arrangements for IP peering.

For example, there are no clear safeguards in the draft circular to ensure that the DOST-ASTI IP exchange can operate efficiently or securely, more so after the DOST-ASTI said it cannot be compelled to operate at a prescribed service level.

It added that the proposed NTC order does not define clearly the roles, duties, responsibilities and liabilities of the IP exchange administrator, which raises concerns on the accountability of the DOST-ASTI exchange.

PLDT said further that the absence of well-defined security features in the DOST-ASTI exchange unduly exposes the personal and other confidential information of customers to possible security breaches.

Also, the lack of provisions for compensation creates a disincentive for ISPs to invest in Internet infrastructure and would ultimately lead to a deterioration of service levels.

PLDT officials said proponents of IP peering such as Globe Telecom have erroneously compared this to interconnection for voice calls and SMS between phone carriers, except that in this case, interconnection applies to Internet traffic.

“That is comparing apples and oranges,” PLDT technology group head Roland Pena pointed out. “IP peering is much more complex than conventional interconnection.”

Unlike conventional phone systems where calls are handled using carefully planned routing tables downloaded into switching systems, the routers of Internet use a self-discovery process to determine the connectivity of the network and decide themselves where to send traffic, Pena explained.

Rather than use direct high-usage peering or redundancy throughout the network which is the rule for telephone systems, the Internet achieves reliability via a mesh network rich in alternate routes.

“This is why IP peering has to be managed much more intensively to ensure that service quality, resilience and security are properly maintained,” Pena said. “The absence of rigorous technical specifications in the proposed IP peering arrangements raise the likelihood that service quality will suffer.”

PLDT added that the lack of any provision for compensation in the proposed peering arrangement compounds that danger.

The draft NTC order would enable some ISPs to “free-ride” on other ISPs, like PLDT and Smart, who have invested heavily in its facilities. In the long run, this becomes a disincentive for ISPs to further invest in upgrading, improving and expanding their networks.

As a result, studies have found that in forced peering arrangements service quality eventually suffers from congestion due to low levels of investments in infrastructure.

PLDT also warned that requiring all ISPs to establish a peering point such as the DOST-ASTI Exchange can hinder growth by removing the incentives for an ISP to competitively grow beyond a single exchange.