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[address-policy-wg] 2007-08: response to ETNO position
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Remco van Mook
Remco.vanMook at eu.equinix.com
Wed Jun 4 13:36:33 CEST 2008
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 > > > > > Any opinions expressed in the email are those of the > individual and not necessarily of the company. This email and > any files transmitted with it are confidential and solely for > the use of the intended recipient and do not constitute an > offer or acceptance by Equinix, Inc., Equinix Europe Ltd or > any of their group entities to buy or sell any products or > services in any jurisdiction. If you have received this email > in error please delete this email immediately and notify the > IT manager. > > This communication is sent on behalf of one of the European > entities in the Equinix, Inc. Group. The ultimate holding > company in Europe is Equinix Europe Ltd whose registered > address is Quadrant House, Floor 6, 17 Thomas More Street, > Thomas More Square, London E1W 1YW and the Company's > registered number is 6293383. The registration details of > other Group entities are available at www.eu.equinix.com >
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