[cooperation-wg] Berec network neutrality consultation - reminder

Dear colleagues, 

Thank you, Gordon, for this alert. We at the RIPE NCC have also been quite late to this process, but following discussions internally and with some community members over recent days, we have made the following submission on behalf of the RIPE NCC. 

The imminent deadline unfortunately made it impossible to share this with the Cooperation WG and obtain further comments ahead of submitting. And as it is a submission from the RIPE NCC, the scope of our comment is necessarily quite narrow - in short, please ensure that there is clear guidance from BEREC that nothing in the Regulation should be interpreted as hindering or restricting IPv6 deployment. 

This is a public consultation, so I’d suggest that if others who have made submissions felt able to share them here, it would be useful to this group’s discussion of the issue. 

Best regards,
Chris

———

> Begin forwarded message:
> 
> From: Chris Buckridge <chrisb at ripe.net>
> Subject: RIPE NCC Submission on BEREC Guidelines on Net Neutrality Rules
> Date: 18 July 2016 at 11:39:48 GMT+2
> To: Serge Radovcic <sr at ripe.net>
> 
> Dear colleagues, 
> 
> The RIPE NCC would like to submit the following comment and suggestion on the BEREC Guidelines on the Implementation by National Regulators of European Net Neutrality Rules. 
> 
> The deployment of IPv6 by European network operators has been identified as a priority for the European Commission and for many national regulatory authorities. It is therefore important that the European Net Neutrality Rules not be misinterpreted as hindering or discouraging network operators from deploying IPv6. 
> 
> The case of network operators running both IPv4 and IPv6 services is noted in Paragraph 16 of the current draft:
> 
> 16. Where restrictions to reach end-points stem from the use of two different internet addressing schemes, IPv4 and IPv6, this typically does not mean the services cannot be defined as an IAS. While it is not possible to connect two different types of addresses without any translation function, BEREC considers that the term “virtually all end points” should, at present, not be interpreted as a requirement on ISPs to offer connectivity with both IPv4 and IPv6. 
> 
> The RIPE NCC would like to suggest that a final sentence be added to this paragraph, as follows: 
> 
> ***
> However, we do not believe anything in this Regulation should discourage or restrict the practices or technologies used by operators to facilitate their deployment of IPv6. 
> 
> ***
> 
> The RIPE NCC would be happy to provide further commentary or advice on this issue should it be useful. 
> 
> Best regards,
> 
> Chris Buckridge
> External Relations Manager
> RIPE NCC
> 
> 
> 
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> 
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> 
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> 
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