[address-policy-wg] 2007-08 Review Period extended until 9 July 2008 (Enabling Methods for Reallocation of IPv4 Resources)

Dear colleagues

Regarding the policy proposal 2007-08: strong arguments in favour and against this policy proposal have been raised by a large number of members of the Address Policy working group mailing list. ETNO has raised a number of issues, including significant concerns regarding the possible impact of this proposal. 
 
ETNO's main concerns relate to:
 
1) the potential impact of an IPv4 market; and,
2) ensuring the stability of the IP addressing bottom-up policy development processes. 
 
In particular ETNO has mentioned that facilitating a market that attaches an intrinsic "value" to an IP address would engage competition authorities, policymakers.  The emergence of market forces on addressing policy will raise legal issues that could have detrimental impact on the successful bottom-up processes that keep the Internet community from being engaged in discussions regarding intervention or new models of governmental control.
 
ETNO is convinced that allowing for transfers within a single RIR region will not result in the release of significant -- or, long-term -- blocks of address space available for new entrants in the addressing community. Even so, it is important to maintain the transfer policy that addresses the situation where addresses are being transferred between organisations in situations such as mergers or acquisitions. 
 
ETNO believes that any transfer policy should provide a number of safeguards. Specifically, ETNO believes that several of the criteria set currently for allocation of IPv4 addresses should be implemented during transfers, e.g. all IP address transfer requests "should be approved by the regional registry. If any assignment is found to be based on false information, the registry may invalidate the request and return the assigned addresses back to the pool of free addresses for later assignment". 
 
The proposed policy 2008-07 does not provide according to ETNO sufficient safeguards and therefore ETNO could not support the 2007-08 Policy Proposal, Enabling Methods for Reallocation of IPv4 Resources, as it stands.

Christina Kelaidi
ETNO Naming Addressing and Numbering Issues WG Chairperson