RIPE 66

Wednesday, 15 May 2013, 09:00 – 10:30

A. Administrative Matters

Gert Doering welcomed attendees to the “No More Addresses Working Group” and introduced himself and Sander Steffann, as co-Chairs of the Address Policy Working Group (APWG).

Gert explained that in the original meeting plan, the APWG had two sessions allocated to it, but one session was subsequently donated to the RIPE NCC Services Working Group. He then presented the agenda and added that in addition to the listed items, there would also be a few words from himself as Working Group co-Chair on consensus and IPv6 PI allocations.

The minutes from RIPE 65 were approved without comment.

B. Current Policy Topics

- Emilio Madaio, Policy Development Officer, RIPE NCC

The presentation is available at:
https://ripe66.ripe.net/presentations/187-Current_Policy_Update-RIPE66.pdf

There were no questions.

C. Feedback From NCC Registration Services

- Andrea Cima, Registration Services Manager, RIPE NCC

The presentation is available at:
https://ripe66.ripe.net/presentations/176-Address_Policy_WG_RIPE_66.pdf

Andrea said he had three topics on the agenda:

1. Reassigning referenced AS Numbers (ASNs)
2. Member requests to change the status of PI assignments to PA allocations
3. Sharing some RIPE NCC perspective on the current transfer policy

1. Reassigning referenced AS Numbers

Andrea explained that the over the years the RIPE NCC had accumulated around 1,400 returned 16-bit ASNs that are all referenced in the RIPE Database. He said that for this reason, the RIPE NCC had not been redistributing these AS numbers. He added that because 16-bit AS numbers had become a scarce resource, the RIPE NCC would like to do something with those numbers.

Andrea said that the RIPE NCC saw a few potential solutions, and he invited attendees to let him know if there were others. The solutions were:

1. Not reassign referenced ASNs
2. Reassign ASNs even if referenced
3. Clean up the RIPE Database from references and then reassign the AS numbers:
   1. ‘Silent update'; or
   2. Informing the object holder of the update

Andrea asked if anyone had feedback on how the RIPE NCC should handle this issue.

Gert said he didn't like A or B and C-i also had problems. He said that the RIPE NCC should inform people they were referencing something that was no longer active and, if there was no response in four weeks time, the RIPE NCC could do the update for them. He finished by saying that if people re-add the reference later, there was nothing the RIPE NCC could do, but it would give the LIR a chance to get their records in order.

Kurtis Lindqvist, Netnod, said that B was clearly out of the question. He said that A could work, as ASNs were not running out and they could always re-visit the issue later. He finished by saying that he preferred doing the clean-up now and so agreed with Gert in supporting C.

Rob Evans, Janet, said he agreed and supported C-ii.

Randy Bush, IIJ, said that it was like returning a rental car – before leaving the car, the keys should be left inside and any personal possessions removed, and before the owner accepts the car back it should be clean.

Gert replied that Registration Services already asked people to remove references from any ASNs they are returning. He asked what they should do if someone they have no ties with was referencing the ASN. He added that it was not just route objects, it was also somebody else's import statement.

Randy said that in this case the person should let the reference remain. He said that if someone wanted to leave garbage in the car, let them leave garbage in the car.

Gert replied that this was the situation currently and somebody needed to clean it up.

Randy compared this to “do-gooder” software that tries to cover errors. He said that if it worked, no one ever says thanks, but if you make one mistake you get hell.

Christain Kaufmann, Akamai, said he supported A, as ASNs were not running out. He added that some people may have an emotional attachment to certain ASNs and could get confused when people come back with different ones. He said that if a clean-up was necessary, C-ii was the preferable option.

Raymond Jetten, Elisa Oyj, agreed with C-ii but with a different approach. He suggested publishing a list of returned ASNs and informing LIRs that they should remove any references to the listed numbers.

Gert said that he thought Andrea had received clear direction from the community and the RIPE NCC had something to work on.

Sander Steffann, APWG co-Chair, added that it was very clear nobody liked B. He said to put it in Randy's terms: no one wants the rental company to give out the car while it's still dirty.

Andrea thanked the room and moved to the next point on the agenda.

2. Changing the status of Assigned PI to Allocated PA

Andrea highlighted that the RIPE NCC received requests to change the status of assigned PI space to allocated PA. He presented two potential solutions:

1. Allow LIRs to change the status of their PI assignments into PA allocations (if equal or larger than the minimum allocation size)
2. Do not allow LIRs to change the status of their PI assignments into PA allocations

Sander said that he had talked to Wilfred Woeber about this (who was not at the session). He said that Wilfred had reminded him that in the beginning the difference between PA and PI was not clear. He said that Wilfred had personally been involved in cases in the 1990s where the status was changed from PA to PI and vice versa. He said that while they certainly had to consider the issue as it related to the present situation, it wasn't a new idea.

Andrea agreed that this was correct. He said that in the past these changes had been made on a case-by-case basis, but this was a long time ago and the RIPE NCC was getting a lot of these requests now and so wanted clear guidance from the community.

Eric Bais, A2B Internet, said that the difference between PA and PI should be removed altogether. He said that the distinction created difficulties, particularly regarding making specific choices or policies about it. He said he wanted to make it as easy as possible for people that wanted to change the status of PA or PI space to do so. He added that so long as PI space existed, he was in favour of option A.

Kurtis asked if they were talking about both IPv4 and IPv6, or just IPv4.

Gert clarified that the discussion was related to only IPv4.

Kurtis said that in this case he felt that they were just rearranging the deck chairs on the Titanic and it didn't really matter. He said that people could label this space whatever they wanted.

Gert replied that it does matter. He said under current rules, people with large blocks of PI address space are unable to use this space to number their customers, apart from giving each customer an address. He said that if people wanted to properly document their assignments, they would be prevented from doing so by the RIPE Database. He said that in order to be honest about what they do, people needed to be able to change the status of their PI space.

Kurt clarified by saying that he wasn't objecting and thought people should be able to do this. He added that it's better to have this data up-to-date.

Sasha Luck, speaking for himself, said his understanding was that under current policy if people were to renumber their PI address space it would just go back into the general PA pool. He asked why they should be forced to renumber this space if they could just convert it into PA anyway.

Gert said that he wasn't sure he understood the question. He said that this was not about renumbering but rather was about relabelling. He said it was so that if someone with a /16 of PI address space decided they want to use that for PA purposes, they could formally request to have the status changed.

Sasha replied that if it were not allowed, they would have to renumber, which would give them PA space but at the cost of a lot more hassle.

Gert said that actually if they were to return their PI space, they would get a /22 PA or nothing, so they couldn't just trade it in. He said that either people are able to document what they are doing, or they do it behind the scenes, or they lose their address space. He said that there is no obvious way forward unless changing the status was allowed.

Randy asked Gert to clarify who he meant when he said “they” have PI space. He asked if he was referring to the PI holder or the LIR.

Gert replied that they could be the same entity.

Andrea added that in this case they were the same entity. He said that they were talking about LIRs that had allocations from the RIPE NCC but who also had PI addresses assigned to them.

Randy asked if the LIRs were the PI holders.

Andrea said yes, they were talking about the LIR as the PI holder.

Ruediger Volk, Deutsche Teleckom, said that in many cases this was old stuff that could include formerly independent organisations that had been absorbed by the LIR.

Andrea replied that this was correct. Andrea pointed the audience to his slide where he mentioned that usually these were LIRs that had received their PI address space prior to becoming members, as well as LIRs that had taken over an end user organisation.

Randy said that this was what had confused him. He said that they were referring to LIRs that had received PI space when it was actually the end user that reserved the PI address space under an LIR.

Gert gave the example of a DSL provider getting PI space on their name and giving single IP addresses to their customers. He referred to a loophole in the PI policy that said the transit network to the end customer was considered to be the LIR's. He said that this was an edge case, but it happened.

Sander added that this happened a lot.

Randy replied that PI space meant the end user could have taken this address space somewhere else.

Gert replied that the end user was actually the LIR in this specific edge case and that they were trying to clean this up.

Hans Petter Holen, Visma, said he thought that Randy was highlighting a very important point: who was holding the address space? He said there could be border cases where this was not clear and asked how they could be sure the LIR wasn't taking address space from one of its customers. He said this could be a disaster to get into. He added that he thought it was worth getting rid of the distinction between PI and PA altogether and thought this was the end solution to the problem. He said he had no problem with re-labelling address space but reiterated that he thought it was important to be certain who was the legitimate holder of the address space.

Lars-Johan Liman, Netnod, said he failed to see the downside with allowing this change. He asked who saw a negative impact as a result and why it should be prevented.

Gert replied that there was not necessarily a downside and that it was merely an area where the policy offered no guidance. He said that the RIPE NCC could go forward with re-labelling address space as it had done in the past, but it was now raising the issue with the community so that they could be aware that it was happening and could inform the RIPE NCC if they saw a downside.

Gert summarised the discussion by saying that there was a risk stemming from unclear ownership of the PI address block and that he thought the 2007-01 contractual work should give the RIPE NCC a clear statement of who was the legitimate holder of the PI block.

Andrea said that before making any changes in a range, the RIPE NCC verifies documentation to ensure that the person holding the resources is their legitimate holder.

Ruediger said it seemed that in many cases the question of who was the rightful holder was triggered when the PI space was picked up for processing to get the contractual relationship in place. He said that pointing at the contractual relationship being in place was of missing some of the interesting cases and that this applied to address space that came from early distribution by the RIPE NCC.

Filiz Yilmaz said that there used to be a requirement in the IPv4 policy which stated that any assignment or allocation was valid so long as the original criteria was still held. She asked if it was still there.

Andrea confirmed that it was. He said that currently PI assignments could only be used for their original purpose. He said that this was one of the reasons LIRs with PI address space wanted to change the status to PA, as it gave the holder more freedom.

Filiz replied that this was not simply a case of labelling and that there was a change there. She asked if the RIPE NCC should evaluate needs in those cases.

Erik said that he would like to comment on what Filiz said. He said that most of the policies relating to PI space had come from a time where fair distribution purposes were a concern but that game was now over. He said that now it was about keeping the RIPE Database up-to-date and this was a good thing.

Gert brought the discussion to a close. He recommended that the RIPE NCC come back with a proposal outlining how it would approach the issue and present it to the mailing list. He said that would allow the APWG to examine the issue and see if any edge cases were being missed.

Gert then passed back to Andrea to present on his third item.

3. Transferring allocations that are in use

Andrea said his last topic was to highlight the issue of organisations that received a PA assignment from an LIR and later became an LIR themselves. He said the issue appeared when the new LIR wanted to transfer the address space from their upstream provider. He explained that such cases were prevented by the current transfer policy, which does not allow allocations that are in use to be transferred.

Gert asked for comments from the audience. He added that there were currently loopholes that would allow people to de-register address space and transfer the now seemingly empty block and re-register it. He said that this was lying to get around policy shortcomings and was not the best approach.

Donal Cunningham, Airspeed, asked how common this issue was.

Andrea replied that, officially (when considering the number of transfers that had not been approved) there was only one case. However, he added that he had talked to around 30 organisations in the past three months that wanted to make these kinds of transfers but they had not made the request as they knew it would not be allowed under the current policy.

Aled Morris, Visa Europe, said that back in the old days there was a lot of policy about not breaking up the PA space. He added that while this was laudable, he wanted to refer back to the earlier speaker that the aim now was to get the documentation right and the database correct, because they were at the stage of managing deck chairs.

Gert replied that the RIPE NCC could not just do this, as the policy was very clear on the subject. He said they needed somebody to volunteer with a policy proposal and that he would bring this to the mailing list and ask for volunteers to help.

Gert thanked Andrea and moved on to the next presentation.

D. APWG Steering Slides

- Gert Doering, APWG co-Chair

This presentation is available at:
https://ripe66.ripe.net/presentations/178-wg.pdf

There were no questions.

E. No Need

- Tore Anderson, Redpill Linpro

The presentation is available at:
https://ripe66.ripe.net/presentations/188-Anderson-NoNeed.pdf

Hans Petter Holen, Visma, said he thought this was a dramatic change in the policy and they should do it. He said that if the cost of implementing the policy was that it blocked an inter-RIR transfer policy with ARIN this wouldn't be a problem. He added that if an organisation was out of addresses, it could open a subsidiary in the ARIN region. He noted that a lot of Norwegian venture companies were doing that anyway, and could apply using normal ARIN procedures. He said that RFC 2050 was developed many years ago and all of the address policy in the RIPE NCC service region had been created after that. He said that this had been developed with the RIPE community's interpretation of RFC 2050, and not ARIN's. He finished by saying they should focus on the policy they wanted for their region for the next couple of years.

Guangliang Pan, APNIC, said he wanted to outline how APNIC managed IPv4 transfers. He said their policy allowed transfers between members and with other regions. He said there was a 24-month needs requirement, and members who had their request to transfer pre-approved could be listed on the APNIC website. He added that that they also provided a transfer listing service where companies could post requests or offers, and the service could also be used by brokers. In addition, APNIC provided a mailing list for people offering or requesting transfers. He said that so far there had been 146 IPv4 transfers in the APNIC region, of which 11 were inter-RIR transfers from the ARIN region.

Guangliang continued by saying they had not seen any problems stemming from keeping the needs-based requirements and that they did not see organisations trying to circumvent policy or purchasing address space on the black market. He finished by saying that there was discussion to remove the needs-based requirements in the APNIC region.

Tore replied by saying the fact that APNIC had only received 11 transfers from the ARIN region strengthened his belief that transfers were not the biggest concern. He said he had reviewed the APNIC transfer policy and as far as he was able to see, it only mandated need for its own region. He said that even if 2013-03 passed and the inter-RIR policy passed, they would still be able to trade with the APNIC region. He said an APNIC recipient would be subject to the evaluation that APNIC enforces, whereas for transfers going in the other direction, no RIPE NCC LIR would need to provide any justification. He said that this would still be compatible.

Rob Blokzijl, RIPE Chair, said he thought 2013-03 was an excellent proposal. He said it was worthwhile cleaning up a lot of the regulation that remained from when the RIPE NCC handled distribution. He said those days were over and the regulations were no longer needed. Rob continued by saying that for the progress of the policy, it was important not to get caught up in considering its impact on transfer policies. He said it was more important to remove bureaucratic overhead and that this would make it easier to consider small add-on transfer policies.

Bill Woodcock, Packet Clearing House, said that policies to simplify existing documentation and remove cruft were the right way forward. However, he continued by saying that the goal of conservation was not about preserving the free pool of addresses, but rather was about maximising the lifetime of addresses in use by the community. He said that with the buffer of unallocated addresses now gone, the need for conservation was greater than ever. He added that while this buffer existed, a failure to follow RFC 2050 would not have had immediate negative consequences, as people could still be bailed out from the free pool. He said that without needs-based requirements, speculators could have an immediate effect on the market.

Tore said that people would continue to conserve their addresses as best they could.

Bill replied that this assumes that people have a need for these resources. He said that without a needs requirement, people could be driven by the market instead, which removed need as a factor.

Tore answered by saying that LIRs in the region will have a limited amount of address space left and so will continue to conserve resources.

Bill asked if an LIR needed money more than it needed addresses – wouldn't that trump need?

Tore replied that if an LIR needed money more than addresses, the basic function of a market meant that others who needed addresses more than money would pay to get them.

Bill said that there were a few economists who took this view, but they were on the fringes of economic thought.

Tore admitted there could be an imbalance between people's need and their ability to pay.

Sander said that due to time constraints that they should move this part of the discussion to the mailing lists in order to give others a chance to speak.

Chris Grundemann, speaking for himself, said he was surprised that the centre of Tore's argument seemed to be that because didn't want to fill-out forms, all of the policy should be deleted. He added that there were a lot of things he didn't like doing but that were necessary to keep things running. He said that filling out a form was easy if he was tracking what he was doing on his network. He also reiterated Bill's earlier comments that IPv4 was a limited community resource regardless of whether it sat in an RIR's free pool or in people's networks. He said the argument that conservation was no longer a goal because the free pool was exhausted didn't make any sense to him. He said LIRs could purchase addresses to block competitors from being able to access them, and that this would be bad for the Internet.

Tore said that conservation would come automatically once the free pool was gone and that there was no need to have it mandated in the policy anymore.

Michele Neylon, Blacknight, said that while removing needs might save on the overhead of dealing with forms, it would open the system up to gaming. He said that as a result, smaller companies would be unable to find address space and would be unable to expand.

Gert said he didn't buy that argument, as the system was already open to gaming. He said that people could already transfer their address space to whoever offers to pay them the most because everyone could demonstrate need today.

Michele said that if barriers to transfers in the region were removed, ARIN would lock down their policies and would not allow transfers to the RIPE region.

Gert replied that ARIN doesn't allow transfers to the RIPE region anyway.

Michele said that's because ARIN doesn't have a policy on transfers.

Gert said that there was no real interest in the RIPE region to permit transfers from ARIN anyway. He said that there was already an inter-RIR transfer policy proposal that no one was interested in. He said the whole argument of transfers from the ARIN region was something that he considered as rough consensus and would not be following. He also said that he was surprised to hear so much argument coming from Americans in the ARIN region and that he would like to hear more from those in the RIPE region.

Tore responded to Michele's comment by saying that people were going to abuse the system no matter what policies were in place. He gave the example of a company paying an LIR to not transfer address space to its competitors. He said he couldn't see how they could pretend a RIPE Policy document was going to prevent abuse from happening.

Michele replied that it was about raising the bar.

John Curran, ARIN (via remote participation) said that he wanted to make a point regarding an earlier comment about setting up a subsidiary in the ARIN region to obtain address space. He said he wanted to point out that this was only possible if a substantial amount of the address space was intended for infrastructure located in the ARIN region. He added that this was not a statement for or against the proposal, he was merely providing clarification for the community.

Dimitri Burkov, RIPE NCC Executive Board, said he wanted to remind people that RFC 2050 was written ten years ago and simply described how they lived at the time. He added that the document was not law.

Sander said that many of the comments that came from the room had already been addressed by Tore in his slides. He said that there was obviously still some confusion, and that this should be taken to the mailing list.

Louis Sterchi, Kalorama Group, said that contrary to the earlier argument, he thought that doing away with needs based requirements actually helped, rather than hurt, smaller organisations. Being able to demonstrate need allowed huge companies to demonstrate an incrementally larger need than smaller organisations, which gave them a competitive advantage. He thought that removing needs gave them a more level playing field than they had currently.

Gert thanked the audience for their comments.

F. Closing Comments

Gert said he had one more thing that he wanted to quickly bring up, which was the idea of unifying IPv6 PA and PI policies so that there were one single type of address. He said he had initially hoped to have something prepared about eight months earlier but had other things to deal with. He said he was going to ask for volunteers to help him with this on the mailing list. He said the topic was interesting and relevant and he wouldn't have the time to do it properly himself, and so he would need volunteers to help.

Gert closed the Address Policy Working Group session and thanked the audience for giving their feedback.