[BULK] Re: [address-policy-wg] 2007-08 New Draft Document Published (Enabling Methods for Reallocation of IPv4 Resources)

> It doesn't.  IP addresses are still used to number things on 
> the Internet.

Right now IP address allocations/assignments are tied to a hierarchy
with RIPE (or another RIR) at its root. RIPE gives blocks to LIRs who
give blocks to end users. When an end user or LIR no longer needs the
block, it is returned back up the hierarchy.

This proposal changes that and allows address block holders to transfer
them to some other organization. This makes addresses more like physical
property which is passed from one person to another without any prior
relationships. And I believe that it is inevitable that once this is
allowed,  transfers will be made without following RIPE rules. If the
recipient runs into difficulty in using their new addresses and
perceives RIPE to be the problem, then lawsuits will be raised against
RIPE for interfering in the trading of addresses.

I know that the proposal does not discuss selling addresses like
property, however this RIPE proposal is just one of several which are
before APNIC and ARIN. The people who have originated the ideas behind
this proposal, have talked about an open IP address market for several
years. So even though this proposal is only a first step, and does not
fully create an open IP address trading market, I believe that it is
important to consider where this may lead, before accepting the
proposal.

If, like me, you do not want to go all the way towards an open market
for buying and selling IP addresses, then you might want to make the
same decision as I have made, and oppose this proposal as unneccessary.

I have no doubt that my company, and many others, will return their
unused IPv4 allocations to RIPE when the IPv6 rollout makes these IPv4
addresses unneccessary. To do otherwise would pose a significant risk of
legal action because it would constitute restraint of trade, i.e.
punishing smaller competitors by witholding IPv4 addresses that those
competitors would use. I don't believe that my company, or most of the
other large European telecoms companies, would see any significant
incentive in being able to charge a fee for transfering an IPv4
allocation to a 3rd party. The real incentive is to avoid the risk of
regulatory and legal action by returning the unneeded resources, and
competing based on the quality of our services. I believe that this
incentive has a much larger financial impact than any trading system
could possibly have, to the extent that I expect larger ISPs to bend
over backwards to help IPv4-dependent ISPs use the inevitably small
block sizes that will be available.

I do NOT speak for the ETNO, however I am aware that the large European
telecoms companies who form ETNO, have come to a consensus that the
development of a market for IP addresses whould be discouraged.  Anyone
who was at RIPE 55 will have seen this presentation:
http://www.ripe.net/ripe/meetings/ripe-55/presentations/mcfadden-etno.pd
f

I believe that allowing the transfer of allocation directly between LIRs
is a step in development of a market for IP addresses, and for this
reason we should reject the proposal entirely.

Currently RIPE plays a unique and trusted role in the area of IP address
management, where companies who compete vigorously in the marketplace
can fairly and openly cooperate with each other, and with non-comercial
users of the resource (IP addresses) on which their networks depend. We
trust RIPE. There is no need to enable transfers that do not have RIPE
as an intermediary. In particular, as IPv4 exhaustion begins to pinch
us, it is highly likely that there will be two or more organizations
that want to receive the free address block. We don't want to be making
decisions on who receives the addresses that we free up. We would rather
return them to RIPE and have those decisions made impartially.

--Michael Dillon