Republika Kosova-Republic of Kosovo s1

Request for Stakeholder Comments on Establishing an IXP in Kosovo

Republika e Kosovës

Republika Kosova-Republic of Kosovo

Autoriteti Rregullator i Telekomunikacionit

Telecommunications Regulatory Authority

Regulativni Autoritet Telekomunikacije

Request for Stakeholder Comments on Establishing an Internet Exchange Point (IXP) in Kosovo

April 01, 2010

The address for responses to this document is:
Telecommunication Regulatory Authority (TRA)
Qyteza Pejton, Street Pashko Vasa No. 12
Prishtina 10000
Alternatively, e-mail responses may be sent to the Authority’s e-mail address at
The deadline for responses is 4:00 pm on Monday, April 16, 2010

Purpose: Request for Stakeholder Comments on Establishing an IXP in Kosovo

Table of Contents

1. Introduction 3

1.1 Background 3

1.2 Scope of this Request for Comments 4

2. Request for Comments 5

2.1 General Questions 5

2.2 Organizational Questions 5

2.3 Technical Questions 7

2.4 Financial Questions 8

2.5 Peering Questions 10

Appendix 1. Glossary of Terms 11

Appendix 2. References 14

1. Introduction

1.1 Background

The Internet is an essential tool for communication, commerce, and development of a “knowledge-based” society in today’s globalized world. A strong ICT sector is particularly important to Kosovo’s future growth and development. Development of Kosovo’s ICT sector depends on the ability of the national Internet infrastructure to provide reliable and affordable access to high quality broadband capacity. An IXP is a key component of a country’s Internet infrastructure that can help to increase the affordability and quality of Internet services.

At present all Internet traffic transmitted between Kosovo ISPs must enter the Internet cloud using international transit links to other countries. These include links to Serbia, Macedonia, and Albania, among others. An IXP is a simple, resource-efficient means of achieving interconnection among ISPs. It keeps local Internet traffic “local,” by enabling ISPs to exchange local Internet traffic directly instead of using international links.

In other markets, an IXP has been shown to have a number of benefits:

· Cost – Direct traffic exchange lowers an ISP's average per-bit delivery cost of service;

· Technical Quality – Direct traffic exchange makes a faster and more direct route from one local Internet location to another, reducing latency and other technical quality defects;

· Security and Privacy – Keeping local traffic “local” within national boundaries reduces privacy and security risks inherent in sending sensitive data across national borders over multiple hops;

· Resiliency – An IXP facilitates establishment of routing arrangements among ISPs to reduce congestion and provide redundant back-up paths in the event of upstream network outages;

· Response and Restoration – An IXP also helps coordinate local security (e.g., intrusion detection), infrastructure protection, and emergency response activities (e.g., CERT);

· Market Development – An IXP can promote local ICT service market development for co-location services (e.g., hosting, cached services, etc.) and services that require high bandwidth and low latency (e.g., real-time and multimedia services); and

· Services to ISPs – An IXP can provide services to its members (e.g., traffic reporting)

· Community – An IXP can provide a nexus for education and research projects that help develop the local Internet community and advance the ICT market.

The 2007 Telecommunications Sector Policy of the Government of Kosovo, as approved and adopted by Government Decision No. 02/255 of June 13, 2007 (the Sector Policy), directs the TRA at the earliest possible date to take the necessary initiatives for the creation of an Internet Exchange Point (IXP) in Kosovo (see Sector Policy, §§ 3.1.3.a2, 3.1.3.a3, and 3.6.3.b) and to coordinate its efforts with the policies of Government and the Ministry of Transport and Communications (MTC) (section 3.6.1.d). Government, through the Ministry, initially represented to the European Commission that an IXP would be established in Kosovo by 2009. Completion of an Internet Exchange Point by the end of calendar 2010 is part of the TRA’s 2010 Annual Work Plan approved by Parliament.

Accordingly, the TRA has determined that an Internet Exchange Point should be established in Kosovo by the end of 2010.

The Authority believes this may be a regional opportunity for Kosovo since in the region only Bulgaria, Croatia, Hungary, and Slovenia have established IXPs. See table, below:

Structure of Existing IXPs in SEE
Country / IXP / Structure
Bulgaria / 4 BIX.BG (Bulgarian Internet eXchange) / 4 Operator-neutral commercial and for-profit company (BIX.BG Ltd.)
Croatia / 4 CIX (Croatian Internet eXchange) / 4 Non-profit service operated by University Computing Centre of the University of Zagreb; open to all: i) ISPs, ii) non-commercial networks that provide ISP services, and iii) private networks that provide ISP services in Croatia; founding members: AT&T Global Network Services Croatia, Croatian Academic and Research Network (CARNet), Croatian Radio and Television, Croatian Telecom, ISKON Internet and VIP-NET GSM
Hungary / 4 BIX (Budapest Internet eXchange) / 4 Sponsored by the Council of Hungarian Internet Service Providers (Internet Szolgáltatók Tanácsa or ISzT), a nonprofit industry associations of ISPs
Slovenia / 4 SIX (Slovenian Internet Exchange) / 4 Non-profit service managed by the Academic and Research Network of Slovenia (ARNES), a public academic institute with a Board appointed by government; open to all licensed ISPs and registered Internet content providers in Slovenia
Albania / No IXP
Serbia / No IXP
Macedonia / No IXP
Bosnia / No IXP

1.2 Scope of this Request for Comments

A key TRA role under section 4.1 of the 2002 Telecommunications Law, as amended, is to implement the national telecommunications sector policy establishment by the Government.[1] Additionally, this document is based on section 10; paragraph (1) of the Telecommunications Law.

A stakeholder meeting, to which all the Internet Service Providers licensed by the TRA to establish international links in Kosovo were invited, was held by the TRA at its offices on Tuesday, March 2, 2010. Further to that meeting, and in fulfillment of its consultative obligations, the TRA has adopted and hereby has issued this Request for Stakeholder Comments on Establishing an Internet Exchange Point (IXP) in Kosovo.

The TRA invites comments from all interested stakeholders on the following questions, the answers to which will help the Authority identify and refine the relevant policy and regulatory issues that must be addressed to establish an IXP.

The contents of individual submissions will be held in confidence but the answers may be summarized and included by the TRA in other publications. Please see the notes following Questions 3.1.1 and 3.1.2.

2. Request for Comments

2.1 General Questions

2.1.1 Please estimate in Mbps the total Internet traffic that your company carried in calendar 2009 and what portion (reported in Mbps or as a percentage) of that traffic was intra-Kosovo traffic (i.e., where the originator and recipient of the message were located at Internet locations within Kosovo).

[N.B. – Please be aware that the TRA will not publicly report individual answers to this question but will compile this data for the entire market and release or disclose it only in the aggregate.]

2.1.2 With respect to the international links maintained by your company, please identify the:

(a) Destination countries,

(b) Technology employed,

(d) Capacity in use.

2.1.3 Describe any potential economic, technical, security or other benefits to your company that you foresee will happen when you connect to an IXP?

2.1.4 Describe any potential economic, technical, security or other benefits or costs that you foresee that an IXP could bring for the Internet market and broader ICT sector in Kosovo.

2.1.5 What potential risks are there with the creation of an IXP?

2.1.6 Describe the preferred circumstances and conditions under which your company would participate in an IXP.

2.1.7 Should the TRA mandate that ISPs be required to participate in the IXP? If not, why not?

2.1.8 If so, should the mandate apply to:

(a) All ISPs;

(b) All ISPs licensed to establish international links;

2.2 Organizational Questions

There are a variety of institutional models that have been adopted to create and operate IXPs worldwide.[2] These include:

· Nonprofit industry associations of ISPs

· University or academic institutes

· Government bodies (e.g., regulator)

· Operator-neutral commercial for-profit companies

2.2.1 In your view, what is the optimal organizational model for the establishment of an IXP in Kosovo?

2.2.2 Why?

2.2.3 With respect to the entity that would manage and operate an IXP in Kosovo:

(a) What type of entity is most appropriate to manage and operate an IXP in Kosovo; (such may be government, association, university (public or private), or private company)

(b) Do you have a recommendation for an appropriate candidate entity?

2.2.4 Do you believe that the TRA by rule or regulation should set the basic principles and minimum requirements for the structure and operation of an IXP?

2.2.5 Do you agree that an IXP in Kosovo should function based upon the basic principles listed below:

(a) Inclusive (open to all qualifying ISPs)?

(b) Technically reliable?

(d) Based on agreed-upon, open standards

(e) ISP users participate in governance?

If you answer to the question is “no” for any of the bulleted items above, why not?

2.2.6 Do you believe there are additional basic principles to those listed in 3.2.5 that should be included? If you do, what are they?

2.2.7 What eligibility criteria should be established for ISP participation in an IXP, and why?

2.2.8 Should the IXP web site be public or for ISP members-only?

2.2.9 With respect to the operating policies of an IXP:

(a) Should interconnection rules to define the terms and conditions under which an ISP is permitted to route their Internet traffic to another ISP's network via the IXP be set:

· by the IXP

· by the ISPs per bilateral agreements

· by the TRA

(b) Should routing control over the traffic to the IXP be performed by IXP or by ISPs (or both)?

(d) Should an IXP be limited exclusively to capturing only the content of a member’s data traffic that is required for the conduct of traffic analysis and control?

(e) What additional confidentiality rules should apply to the IXP?

(f) Should the IXP collect and report technical information to members? If so, what type (e.g., ASN paths, looking-glass sites)?

(g) What types of technical information collected by the IXP should be reported to the TRA?

(h) Should any, and if so what types, of technical information collected by the IXP should be made publicly available?

(i) What should traffic filtering policies be for the IXP?

(j) Who should set those policies? (e.g. TRA, IXP, ISPs, other?)

(k) What should the IXP role be in the event of security problems, infrastructure failures, routing equipment failures, or software configuration mistakes?

(l) What additional security response services should the IXP provide to the ISP participants?

(m) What limitations of liability should there be for IXP operations?

(n) What are appropriate access rules for ISP member staff access to the IXP premises, if any?

(o) What additional technical support services should the IXP provide to the ISP participants?

2.3 Technical Questions

2.3.1 What technical model should be used –

(a) Layer 3, in which ISP members exchange traffic inside the router located on the IXP, or

(b) Layer 2, in which IXP provides switching connectivity and ISP members retain full control over routing policy?

Please state the reasons for your answer.

2.3.2 What protocols should be used (e.g., BGP, other)?

3.3.3 Should the IXP be connected to the Internet other than through its ISP members?

2.3.4 What should be the content of the Internet Routing Registry (IRR) set up at the IXP?

2.3.5 What are the optimal means of establishing physical connectivity between IXP and each ISP?

· Fibre, wireless, etc.

· Existing ISP platforms or new facilities

2.3.6 Are there any circumstances where bandwidth and/or download restrictions should be imposed on ISP participation in an IXP?

2.3.7 Should a minimum bandwidth be required for ISP links to the IXP?

2.3.8 Should the IXP be required to provide redundancy and increased fault tolerance (e.g., each ISP connects to a single switch/router or, to provide fault tolerance, to multiple switches/routers located at IXP)?

2.3.9 Should the IXP be required to implement a denial of service (DOS) attack detection system at the IXP switch(es)/router(s)?

2.3.10 For IXP address space, should the IXP obtain separate address space (e.g., /24 network) or use address space from an existing ISP(s)?

2.3.11 What are the key required elements and their specifications for physical security of the IXP space?

· 24h CCTV,

· Locks,

· Controlled access for IPX members,

· Space requirements for cabling, racks and equipments,

· Fire control,

· Air-conditioning,

· Power supply/backup,

· Other (please specify).

2.3.12 Should a time server or other services for ISPs be provided by the IXP (please specify)?

2.4 Financial Questions

2.4.1 Based on your understanding of the intra-Kosovo traffic volumes generated by Kosovo ISPs, do you believe an IXP would lead to a cost savings, increased cost, or be cost neutral for your company? (Please specify the basis for your answer in financial figures.)

2.4.2 Do you believe that at present there is a market in Kosovo for more than one IXP?

2.4.3 Based on your previous answers, please estimate the capital costs required to establish an IXP?

a. Cost of equipment for the core of the IXP (refer to section 3.3)

b. Preparing the space

c. Furnishing the space:

i. Backup power,

ii. Air-conditioning,

iii. Equipment cabinets, and

iv. Relevant security fixtures.

d. Link provision from ISP to IXP

i. Router,

ii. Fiber or other link.

e. Other (please specify)

2.4.4 How many staff do you estimate the IXP will require?

2.4.5 Would your company consider providing technical advice and assistance to the IXP at no cost?