[address-policy-wg] 2007-08: response to ETNO position

> Let me first rephrase what 2007-08 is about, before 
> responding to ETNO's position. 2007-08 is about setting up a 
> framework for (IPv4) resource transfers between LIRs. Nothing 
> more, nothing less. No IPv6, no ASNs. No PI, no ERX. It is a 
> framework in the sense that, in my opinion, it encompasses 
> the absolute minimum set of policy changes required for this 
> to happen without immediately shooting ourselves in the foot. 
> It is a starting point, not an end point for transfer policies. 

However, we already have a framework for IP address transfers between
LIRs which works substantially the same in all RIR regions. If it
involves a change in corporate ownership, you simply need to show
proof of the change and that the network is still operating under
the new entity. The RIR then updates all records showing the new
ownership. Or you give the address block back to the RIR because
you no longer need it, and some other LIR will get those addresses
at some point in the future.

This framework works. There is no reason to believe that it would
cease working as IPv6 deployment picks up. Most network operators
are undertaking some form of audit of their internal use of IP addresses
in preparation for the shortage, which means that as IPv6 picks up, they
should know when they have surplus IPv4 addresses and can return them
to RIPE or whatever RIR they came from. If it is not broken, then
why would we want to change this framework?

You claim that this will speed up the process of transfers but I cannot
see how adding a new set of transfer rules will speed up anything.
Even though you claim that this is an LIR-to-LIR transfer without
RIPE involvement, this is not true since there are various rules
which RIPE must administer and RIPE can disallow a transfer if,
for instance, an LIR has received a re-allocation within the
past 24 months.

> 1) Identification of legitimate use
>
> While I agree that we need to keep track on who has rights on 
> what - it is one of the key points of 2007-08 - doing it 
> globally would mean abandoning all RIR databases for a global 
> registry. 

Huh? I can't see where you get this idea. This ETNO point is in
full support of the existing RIR system, where every IP address
range is under the authority of one of the RIRs, and where the
identity of the "legitimate user" can be authoritatively discovered
in the RIR's database (or whois directory).

In this point ETNO is supporting the existing transfer framework
in which all IP address transfers must go through one of the 
5 RIRs. Under 2007-08 it is possible that some LIRs will transfer
addresses which an RIR will not register in the database. You then
have two parties (transferor and transferee) claiming that a transfer
has taken place, and one party (RIPE, etc.) claiming that it has not.
Instead of a clear statement of the legitimate user, you need to
go to some kind of adjudication panel to sort the mess out.

> 2) Transparency

> I fully agree on transparency. What I fail to see is what is 
> meant with 'public way' and why 2007-08 would fall short of 
> that mark.

Because under 2007-08 two LIRs can secretly negotiate and execute
a transfer or addresses under some secret set of terms which may
or may not include payments of cash. RIPE only gets involved at
the end of the process to update the database, and the terms of
the exchange are never disclosed.

> When 
> IPv4 space moves hands because of a merger or acquisition 
> this doesn't happen either. That's all current bottom-up policy.

During M&A activity, it is public who receives the functioning network
assets, and that is the criteria (technical justfication) for allocating
IP addresses to the new network owner. The IP addressing aspects are
still open and public.

> 3) Fair and neutral reuse
>  
> All recovered address space should be recycled in a globally 
> synchronized fashion. RIRs should work harder recovering IPv4 space.
>  
> I think that this is a good idea, but let's not overestimate 
> what IANA and the RIRs are able to recover.

Under 2007-08, you are right that the RIRs will not recover much. 
But if we leave the transfer framework as it currently is, then
most IPv4 addresses that become surplus due to IPv6 deployment,
will go back to the RIRs. Here ETNO is supporting the current
framework because it provides fair and neutral terms for reuse
of addresses. 

To get addresses, everyone must provide a technical justification.
When that justification goes away, everyone must return the 
addresses to RIPE unless there is some imminent new technical
justification in their own organization, for instance shutting
down dialup services in a company who is still growing VPN or 
Internet access or broadband business. Reuse, happens naturally
and no new policies are needed.

It would be nice for RIPE to remind LIRs about returning IP addresses
and set some guidelines such as don't bother until you have more
than a /24, if you expect an adjacent block to become free within
6 months then wait before returning, etc. That could be done without
making fundamental changes to the transfer framework.

> I find it curious that ETNO puts significant effort into 
> writing position papers such as this one and not join us in 
> that bottom-up process, but that's a different matter.

ETNO is just a bunch of people, much like RIPE. Different people
have different working styles and that's OK. Note that more people
from ETNO companies are starting to get involved in RIPE as they 
learn and understand RIPE's working practices. May I suggest that
RIPE could help by offering to present a session at ETNO's next 
annual conference in November. 

> 5) No connection between IPv4 and IPv6
>  
> Policies we make for the 'afterlife' of IPv4 should not 
> affect any policy with regard to IPv6.
>  
> Yes. 2007-08 is in compliance with that.

Unfortunately, 2007-08 will lead many to think that selling
address blocks is OK in the RIPE region. As a result, this does
affect IPv6 since if an IPv4 address block is a saleable asset
then IPv6 addresses are also saleable assets.

> In describing transfers, ETNO argues that transfers are the 
> first step towards a market. That is false. It is the first 
> step towards a market under the control of the RIRs and the 
> current bottom-up policy process we all know and love. A 
> market will evolve whether we accommodate it or not.

Focussing just on the last sentence it is clear that you 
believe a market will evolve, and that 2007-08 "accomodates"
a market. That is precisely where ETNO disagrees. ETNO believes
that a market can be prevented from evolving if RIPE takes the
correct actions, and that "accomodating" a market is a wrong
action for RIPE to take. 

Remember that collectively, ETNO members have a huge number of
IPv4 addresses allocated. If they do not participate in any
attempts at forming a market, then the market will be stunted,
and lack liquidity. In addition, when the shift to IPv6 begins
in earnest, because vendors have fixed the problems which are
still blocking it, ETNO member companies will be deploying
IPV6 rather quickly. This will result in a significant percentage
of their IPv4 addresses returning to RIPE for reallocation.
That event will kill any existing market for IPv4 addresses.

So the best possible scenario for an IPv4 market will be a trickle
of transactions put on for show then a runout of IANA's free pool followed
by a sharp increase in small block transactions by some players trying
out the market. At this point prices will sharply increase causing
buyers to back out of the market unless they are in desperate straits.
Then IPv6 deployers will begin giving some addresses back to RIPE
at which point the market collapses.

Frankly, it would be better for this to play itself out in a
black market scenario without RIPE involvement. 

> Inaction is not a sign of good stewardship. So we need to be 
> seen doing something, preferably something that will make a 
> difference. 

You are right. It is time for RIPE to take more action to help
LIRs audit their supply of addresses and to set some reasonable
guidelines for returning unused IPv4 addresses. Since addresses
are only usable in aggregate, and since LIRs could potentially
increase those aggregate block sizes with sensible internal processes,
it is time for RIPE to work on a best practices document for
IPv4 addressing.

> I would urge ETNO to become part of this discussion and work 
> with the community in our prized bottom-up policy process, 
> rather than setting limits to what can and can not be 
> discussed an not coming up with solutions themselves.

Note that Mark McFadden, who presented an ETNO document a couple
of RIPE meetings ago, and myself, both work for an ETNO member.
I agree that it would be nicer to see more ETNO members join in
the discussion, but please recognize that ETNO deals with far more
issues and policy organizations than just RIPE. I suspect that many
ETNO members see RIPE as a functioning organization that is mostly 
doing good work for the network, and therefore RIPE doesn't need as
much attention as some other organizations that make laws and 
regulations (which have almost the same force as a law).

--Michael Dillon