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

Hi Michael,

Just browsing through your response one item immediately sticks out: is there a commitment from ETNO in here that their members would immediately return unused IPv4 space ? That'd be great - if IPv6 were to be deployed fully by all ETNO members in the next 2 years, which you think is easily achievable, we'd never run out of space.

I'm asking because it is exactly the opposite of what representatives of a lot of ETNO members have been telling me in private.

Kind regards,

Remco van Mook
(again no hats)

> -----Original Message-----
> From: address-policy-wg-admin at ripe.net 
> [mailto:address-policy-wg-admin at ripe.net] On Behalf Of 
> michael.dillon at bt.com
> Sent: woensdag 4 juni 2008 12:59
> To: address-policy-wg at ripe.net
> Subject: RE: [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
> 
> 
> 
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