CENTR Board of Directors contribution to the Public Consultation on the draft BEREC Guidelines on implementation of net neutrality rules
Draft BEREC Guidelines on implementation by National Regulators of European net neutrality rules
We welcome the Body of European Regulators for Electronic Communications' (BEREC) recognition of the importance of filtering to protect the security of internet services and users. However, while most types of filtering identified in paragraph 80 of the draft guidelines can be implemented in response to a particular threat to a network, this is not true for filtering to protect other networks from threats created by the filtering network’s own users.
BEREC's draft guidelines identify one such class of filtering – spoofed addresses. This type of filtering can only be done by the networks that originate traffic (see more detail in Jisc’s statement). The Internet Engineering Task Force has long considered it Best Current Practice against denial of service attacks, as documented in their BCP-38. This recommends that all networks be permanently configured to detect and block packets with spoofed source addresses, before they leave the originating network. This recommendation is promoted by network operators (for example the FENIX group in the Czech Republic) and regulators (for example FICORA in Finland). We are concerned that the draft regulations, by stating that permanent filtering should be considered a breach of network neutrality, would seriously harm these efforts to protect the security and stability of networks and services.
For any additional questions regarding our response, please contact Peter Van Roste, General Manager of CENTR at This email address is being protected from spambots. You need JavaScript enabled to view it..
PDF version of the CENTR BoD contribution
