Will Interconnection Fee Regime Change to Include All Traffic Sources?

“All segments of the internet ecosystem should have the opportunity to make fair returns in a competitive marketplace,” says the GSMA. Translation: a few hyperscale app providers who represent a majority of the traffic on ISP networks should pay interconnection fees as do telcos. 

The basic interconnection payment principle is that terminating traffic uses network resources, and receiving networks are therefore entitled to compensation. The idea is fundamentally that traffic sources (sending networks) owe money to traffic sinks (receiving networks). 

source: Researchgate 

What does this remind you of? Former SBC chairman Ed Whitacre said in 2005, referring to VoIP providers: “Now what they would like to do is use my pipes free, but I ain't going to let them do that because we have spent this capital and we have to have a return on it.”By the end of the year SBC had completed its acquisition of AT&T. 

“So there's going to have to be some mechanism for these people who use these pipes to pay for the portion they're using,” he said. 

Separately, Whitacre also said “Nobody gets a free ride, that’s all.” Also, he said “I think the content providers should be paying  for the use of the network.” 

Nearly two decades later, it appears app provider payments to telcos for use of access networks might expand from South Korea to Europe and then possibly elsewhere. 

One needs patience in the global connectivity business. Some developments take decades to reach fruition, whether that is artificial intelligence, the metaverse, cloud computing, the end of network neutrality or replacement of copper access with fiber facilities.

Are Disaggregated or Vertically Integrated Models Ahead for "Telecom?"

One unknown about private equity investments in digital infrastructure is who winds up owning those assets. The PE business model entails selling assets after they have been restructured in some way that boosts the financial value of the assets. 

In principle, buyers could be operators of digital infrastructure businesses, such as mobile operators, bigger data centers, other connectivity providers or even other investment entities. Institutional investors, for example, might be attracted to the stability of long-term cash flows from assets that are complementary to other asset classes. 

source: CFA Institute 

Private equity, almost by definition, involves “fix and flip,” as returns are earned only when assets are sold. In that sense, PE operates as does venture capital, where returns are earned only when assets are sold. 

But none of that suggests any particular preordained form of exit. Whether public or private sales happen, assets often are sold to operating rather than financial buyers. Smaller data centers are acquired by larger data centers; smaller fiber networks are bought by larger networks; smaller tower networks are purchased by larger tower operators and retail internet service providers are purchased by larger ISPs. 

But assets might also be purchased on a longer-term basis by financial entities such as pension funds, more interested in predictable cash flows than operations, per se. The pattern of purchases can inform us whether something fundamental in the business model is changing. 

Among the bigger potential changes is a shift from monolithic, vertically-integrated service provider models to more loosely-coupled models used in the computing industry. Wholesale access network regimes and mobile virtual network operator models provide early examples, as do wholesale tower companies. 

Vodafone Portugal, for example, is buying Llorca JVCO Limited, parent company of MasMovil.

MasMovil was taken over by private equity funds Providence, Cinven and KKR two years ago, so those assets might return to service provider ownership. 

In a typical PE deal, an investment manager (the general partner, or GP) pools money from investors (limited partners, or LPs) to purchase an operating company. After a certain number of years, the PE fund exits its stake from the company by selling it in either the public or the private market. 

“Who” the buyers are matters in terms of industry structure. It matters whether business models are wholesale or retail, and whether ownership patterns are relatively short term or long term. Wholesale PE assets might be sold to new owners who operate using wholesale models (business to business), selling only to other businesses in the ecosystem (such as radio sites for mobile operators). 

Similarly, PE assets might be sold to wholesale-focused providers of internet access and other communication services. That is a different long-term model than if assets are sold to a retail-focused service provider using an integrated model (owning both infra and supplying services). 

All that matters since the decisions move the industry more in the direction of a disaggregated model (where roles are separated) or maintain the traditional integrated model (where roles are combined). 

In a broad sense, digital infra ownership models might then range from a “computing” model (almost everything separated into layers or functions) to a traditional “telco” model (all essential elements are vertically integrated). 

Where all the PE assets ultimately wind up will tell us quite a lot about the future direction of digital infra. 

The Willie Sutton Rule and Taxes on App Providers to Support Access Networks

Some might be tempted to argue that efforts to add application providers to funding of access networks is bandied about as an example of the Willie Sutton rule: that's where the money is. 

Willie Sutton famously was asked why he robbed banks. Though untrue, he is said to have responded “because that is where the money is.” 

That has led to the Willie Sutton rule, which is that, when trying to solve a problem or gain an outcome, it is best to choose the most-obvious route. 

source: Market Business News 

For a variety of reasons, ranging from competition to the economics of bandwidth growth and charging for consumption, the internet access business model is strained. In some regions, government regulations also play a part, as in Europe, where regulators have forced price reductions on service providers in various ways. 

For regulators and internet service providers, finding new ways to fund infrastructure is simply an application of the Willie Sutton Rule: take the easiest route to solving the problem.

Raising prices on business and consumer users seems to them not to be the easiest route. Tying consumption to prices also seems not to be the easiest route. Convincing the government to levy taxes on some app providers is an application of the Willie Sutton Rule.

Genie's Coming Out of the Bottle: Net Neutrality is Dead

Communications policymakers are about to let the genie out of the bottle. Once they feared the possible impact of internet service providers charging some app providers for using their networks. That gave us network neutrality. 

Now, some appear more worried about a few hyperscale app providers, to the extent that they are willing to gut network neutrality entirely. 

It is hard to know just what else might also change. As with any tax, the firms affected by the tax will not “pay” it. Customers, shareholders or business partners will do so. The only question is which sets of stakeholders see higher costs. 

And, as with any tax, once the principle is established, other sets of payees might emerge later. And tax rates will tend to grow. 

But network neutrality will be an early casualty. 

One might well argue the whole net neutrality policy was wrong from the beginning. We may someday look back and argue the “sending party pays” policies for app providers were equally wrong. 

Some might argue that new taxes on a few hyperscalers shed more light on broken business models of some ISPs, in some regions. Almost always, such taxes bear the mark of attempted industrial policy as well: efforts to protect domestic suppliers from foreign suppliers. 

Ironically, many of the same people and policymakers who touted the value of network neutrality now are appearing to kill network neutrality. Net neutrality was supposed to protect app providers from internet service providers. 

The overturning of net neutrality will happen to protect ISPs from hyperscalers. Never was it more clear that every act of public policy has private consequences; winners and losers. 

The new policies--similar to taxes levied in South Korea--would charge fees on a few hyperscale app and content providers, and represents a shift in funding of universal service and access networks in general.

Basically, customers and taxpayers have funded universal service and, by extension, universal service. For the most part, customers have paid the costs of the access networks. The new policies proposed for EU countries would add taxation of a few large app providers to that mix. 

This will kill the logic behind network neutrality. Once governments accept the principle that the big providers of apps ISP customers use must pay to use the access networks, the door is open to charge other app providers. 

The door is open to effectively subsidize some apps and not others; to allow some apps expedited access or higher quality of service, as has been true for business grade services, even where network neutrality rules are applied. 

It is difficult to see all the potential ramifications. Once the notion of taxing traffic sources gains traction, how might other business practices change? And what traffic sources might be taxed next? Large data centers? Content delivery and edge network providers? 

Will peering relationships return to the older transit model, at least where traffic imbalances exist? 

The debate over how to fund access networks, as framed by some policymakers and connectivity providers, relies on how access customers use those networks. The argument is that a disproportionate share of traffic, and therefore demand for capacity investments, is driven by a handful of big content and app providers. 

But the list of “traffic sources” is larger than that. The South Korean and proposed EU regulations distinguish between traffic sources and traffic sinks (senders and receivers). In pre-internet days, that traffic was considered to be voice traffic between telcos. At the end of the true, firms would “true up” payments to cover any unequal traffic flows. 

The new principles essentially apply that same sort of logic to some traffic sources. But if “sources” are broadened, why would the category of sources not be later broadened further?

It is a novel argument, in the area of communications regulation. Business partners (other networks) have been revenue contributors when other networks terminate their voice traffic, for example. 

But some point to South Korea as an example of cost-sharing mechanisms applied to hyperscale app providers.

South Korean internet service providers levy fees on content providers representing more than one percent of access network traffic or have one million or more users. Fees amount to roughly $20/terabyte ($0.02/GB).

Some might argue it is inevitable that European connectivity providers will get government sanction to levy fees on a few hyperscale app and content providers as a matter of industrial policy and faltering economics. The measures are protectionist in that all the proposed app payers are based in the United States. 

Opponents--especially the hyperscalers--view it as an internet app tax. It arguably is all of the above. 

Yet others might note that such a policy undermines the argument for network neutrality regulations, at its core. The fundamental argument for net neutrality was to prevent unequal treatment of bits, no matter who the owner. 

Can Lumen Increase Consumer FTTH by 10X?

Lumen Technologies is expanding its fiber to home expansion activity, expecting to boost the availability of fiber-to-premises beyond the 27 percent of homes it already supports.  With the caveat that Lumen’s future success rests more with its enterprise portfolio than its consumer broadband business (all mass markets revenue is about 25 percent of total), the fiber upgrades should boost subscription rates. 

Where the fiber access network gets about 27 percent adoption, the copper access network gets about 14 percent take rates. In other words, FTTH gets almost double the adoption of the copper access product, with FTTH average revenue per account of about $59 a month. 

source: Lumen 

In principle, Lumen should be able to gain a price advantage over its key cable TV competitors, at least if most customers on all the networks buy the advertised products at the advertised prices (ignoring promotional or bundle pricing). Whether that is the case in practice is far from clear. 

source: Lumen 

Nor is it always completely clear that 5G and 4G mobile networks are outclassed to the point that they cannot gain significant market share. The early evidence suggests that a significant portion of the consumer market is content with lower-speed service (up to 200 Mbps), and will buy a fixed wireless service. That value segment could represent about 33 percent of the present market. 

As always, that value segment will be offered higher speeds over time, for about the same price (less than $50 a month). 

Some of us would argue that the real advantage over cable will lie in symmetrical broadband features, not price per bit or downstream speed. 

The issue is how fast cable companies will move to boost upstream speeds; how fast Lumen can upgrade its home broadband access facilities and how fast both Lumen and the cable firms can boost downstream speeds. 

Of these three, the first two are likely going to be crucial, as the salient performance advantage Lumen will be able to claim, once facilities are upgraded to fiber, is upstream speed. Lumen believes it will be able to build the network for $1,000 per passing or less, with incremental capital required to activate each customer location. 

The issue then will become the penetration rate (customer adoption rate): can Lumen relatively quickly boost its customer share from 27 percent up closer to 40 percent? Possibly equally important, can Lumen get a higher share of the performance-oriented segment of the market, willing to pay more? 

Much could hinge on whether Lumen can hit its own goal of upgrading to a total of about 12 million FTTH  locations over the next six years, at the expected capital investment cost, at the expected take rate.

Shift from Multicast to Unicast Underlies Access Network Economics

The debate over how to fund access networks, as framed by some policymakers and connectivity providers, relies on how access customers use those networks. The argument is that a disproportionate share of traffic, and therefore demand for capacity investments, is driven by a handful of big content and app providers. 

It is a novel argument, in the area of communications regulation. Business partners (other networks) have been revenue contributors when other networks terminate their voice traffic, for example. 

But some point to South Korea as an example of cost-sharing mechanisms applied to hyperscale app providers.

South Korean internet service providers levy fees on content providers representing more than one percent of access network traffic or have one million or more users. Fees amount to roughly $20/terabyte ($0.02/GB).

The principle is analogous to the bilateral agreements access providers have with all others: when a traffic source uses a traffic sink (sender and receiver), network resources are used, so compensation is due. 

Such agreements, in the past, have been limited to access provider networks. What is novel in South Korea is the notion that some application sources are equivalent to other historic traffic sources: they generate remote traffic terminated on a local network. 

So far, such claims are not officially bilateral, which is how prior arrangements have worked. The South Korean model is sender pays, similar to a “calling party pays” model. 

Those of you with long memories will recall how the vested interests play out in any such bilateral agreements when there is an imbalance of traffic. Any payment mechanisms based on sender pays (calling party pays) benefit small net sinks and penalize large net sources. 

In other words, if a network terminates lots of traffic, it gains revenue. Large traffic generators (sources) incur substantial operating costs. 

Of course, as with all such matters, it is complicated. There are domestic content implications and industrial policy interests. In some quarters, such rules might be part of other strategies to protect and promote domestic suppliers against foreign suppliers. 

At the level of network engineering, the imbalances and costs are a direct result of choices about network architectures, namely the shift of content delivery from broadcast or multicast to unicast or “on demand” delivery. 

This is a matter of physics. Some networks are optimized for multicast (broadcast). Others are optimized for on-demand and unicast. Satellite networks, TV and radio broadcast networks are optimized for multicast: one copy to millions of recipients. 

Unicast networks (the internet, voice networks) are optimized to support one-to-one sessions. 

So what happens when we shift broadcast traffic (multicast) to unicast and on-demand delivery is that we change the economics. In place of bandwidth-efficient delivery (multicast or broadcast), we substitute bandwidth “inefficient” delivery.

In place of “one message, millions of receivers” we shift to “millions of messages, millions of recipients.” Instead of launching one copy of a TV show--send to millions of recipients-- we launch millions of copies  to individual recipients. 

Bandwidth demand grows to match. If a multicast event requires X bandwidth, then one million copies of that same event requires 1,000,000X. Yes, six orders of magnitude more bandwidth is needed. 

There are lots of other implications. 

Universal service funding in the United States is based on a tax on voice usage and voice lines. You might argue that made lots of sense in prior eras where voice was the service to be subsidized. 

It makes less sense in the internet era, when broadband internet access is the service governments wish to subsidize. Also, it seems illogical to tax a declining service (voice) to support the “now-essential” service (internet access). 

The point is that what some call “cost recovery” and others might call a “tax” is part of a horribly complicated shift in how networks are designed and used.

Home Broadband Costs Keep Falling

In the twelve months to the close of the second quarter of  2022, global fixed-line home broadband subscribers saw their average monthly charges decrease by four percent on copper, cable and fiber-to-home based tariffs, says Point Topic.

source: Point Topic 

Across the three technologies the average bandwidth increased by 22 percent year-on-year. 

source: Point Topic 

Still, the typical cost of each megabit-per-second unit of capacity was markedly lower on hybrid fiber coax and fiber to home networks, compared to slower copper-access networks. In substantial part, that is because of the vast difference in capacity between copper and other networks. 

As speed climbs, cost-per-bit falls.