[address-policy-wg] IP Addressing in a post IPv4 World - Principles - Contribution from ETNO

Dear colleagues 

ETNO (European Telecommunications Network Operators' Association) is
representing 40 major companies from 34 European countries, providing
electronic communications networks over fixed, mobile or personal
communications systems. ETNO's primary purpose is to establish a
constructive dialogue between its member companies and actors involved
in the development of the European Information Society to the benefit of
users. More information on ETNO can be found at: www.etno.be. 

ETNO has prepared and presented its Common Position regarding the
exhaustion of the IPv4 address space to both RIPE and ICANN (CP082
2007/10). This Expert Contribution on "IP Addressing in a post IPv4
World - Principles" provides initial thoughts to the questions asked of
ETNO with regard to the principle that there marketplace should not be a
determination of IPv4 address exhaustion management.  ETNO continues to
develop its thoughts on this issue.

Christina Kelaidi
ETNO Naming Addressing and Numbering Issues (NANI) WG Chairperson


ETNO Expert Contribution IP Addressing in a post IPv4 World - Principles

1. Introduction

The IP addressing community asked ETNO to make more precise and
complement its position regarding the Post IPv4 World, specifically with
respect to its stated principle of "no markets". That is, the time when
IPv4 addresses are no longer available from the Internet's Regional
Internet Registries in the way (volume and quality) they are today. 

It is now well-understood that the globally available pool of IPv4
addresses will be depleted at some future point. For the purposes of
this paper ETNO uses the timeframe of 2010-2012. ETNO has previously
urged the community to adopt a basic set of principles guiding policy
development, allocation and processes regarding IP addressing in that
context and that remains an important issue for ETNO.

ETNO's members also feel strongly about the IP addressing environment in
the period after the remaining free pool is allocated from the five
RIRs. This paper identifies some assumptions regarding that environment
and establishes some principles (based on those assumptions) for
management of the IPv4 address space in the period following exhaustion
of the free pool. In particular, it urges that due emphasis is placed on
IPv6 implementation, and that fairness and transparency in any
activities relating to IPv4 addresses which  seek to extend the
availability of IPv4 addresses is of paramount importance.


2. Assumptions

ETNO asserts that the following statements are fundamental to
understanding the IPv4 addressing environment in the next ten years.

*	The available free pool of "allocatable" IPv4 addresses will run
out - quite likely by 2012.
*	The existing IPv4 network will continue to operate for many
decades to come.
*	There will still be demand for IPv4 addresses.
*	After the available pool of IPv4 addresses is exhausted, needs
(even limited) will continue to appear that are provided with other
options (e.g. the widespread deployment of NAT -- even if this could
lead to extra costs and impact on the development of some services).
*	The only long-term solution to the "unavailability" of IPv4
addresses is the widespread adoption and deployment of IPv6
infrastructure, transport and client services. 



3. ETNO Principles

Underpinning any future activity with regard to the use and management
of IPv4 addresses is the fact that the stability of the Internet must be
maintained.

In support of the above statement, and the previously stated
assumptions, ETNO believes that the fundamental principles that should
apply in a post-IPv4 world are fairness in access, transparency in
management and that there must be no impact on existing operations and
current allocations.


3.1	Identification of Legitimate Use

A global mechanism for asserting the right to allocate, use and announce
address blocks in the public Internet. 

A fundamental feature of a stable Internet in post 2012 is to be able to
identify those parties who have genuine rights of use over IPv4 address
prefixes. These rights of use need to be globally identified and could
include the rights to allocate, use and advertise routes associated with
IPv4 address prefixes. ETNO believes that a common, global approach to
certifying the authentic allocation of address blocks should be adopted
by the existing RIRs. Regional approaches to address block certification
will be unworkable. Multiple, inconsistent approaches to address block
certification would require the Internet's infrastructure to adopt more
mechanisms than necessary to ensure that routing table entries were
genuine and authentic. Having multiple approaches would result in
unacceptable overhead in the routing infrastructure for the Internet. A
global approach must be in place long before the period in which IPv4
depletion makes it significantly difficult to get address blocks from
the RIRs. 

3.2	Transparency in management

Decisions on management (allocations and assignments must be public and
transparent). 

To engender confidence and security post 2012 any decision regarding
allocation or assignment must be done in a transparent, public way, and
be consistent with policies enacted through the bottom-up processes in
the RIRs. This transparency of this activity must apply globally. 

Any deficiencies in such policies need to be identified and action taken
to ensure that they are harmonised and resolved by 2012.

3.3	Fair and Neutral Reuse

Where IPv4 addresses are recovered from historic, experimental or
IANA-reserved allocations, there needs to be a globally synchronized
"recycling" of those blocks for Post-IPv4 allocation. Also, RIRs are
further encouraged to more strictly reclaim allocated, but unused IPv4
address space.

ETNO believes in a two tiered approach when it comes to IPv4 address
recovery: a global IANA oriented process and regional RIR oriented
processes.

ETNO believes that IPv4 address space may be recovered through the
examination of historic, experimental and IANA-reserved allocations. In
these cases the redistribution of this address space must be fair,
neutral and global. Global fairness requires that the IPv4 addresses
recovered in this way are available to all users globally based on the
existing justification models for allocation from IANA to RIRs. In
particular, just as IANA and RIRs announce allocation of address blocks
to the RIRs, so should the recovery, for future use, of address blocks
be advertised.

Furthermore, ETNO would like to encourage the RIRs to put still greater
effort in to the reclaiming of allocated, but unused IPv4 address space.
Such unused address space could e.g. result from LIRs that ceased to
exist - or do not respond to any inquiries by the RIR any longer at
least - or from mergers between LIRs. RIRs are also invited to seriously
consider the incentives that could be provided to operating LIRs to
consider returning unused address space by e.g. a rebate on the
membership fees. IPv4 address space reclaimed by such means is to be put
back into the allocation pool of the respective RIR to be reallocated
later, according to its regular allocation policies.

ETNO believes that there is a lower limit to prefix length for such
recovery of IPv4 address space, though. IANA and the RIRs should make no
attempt to recover for future use historic, experimental and
IANA-reserved allocations where the prefix length of the allocated space
is longer than the minimum allocation size for RIRs. Likewise, RIRs - in
collaboration with LIRs - should make no attempt to recover (parts of)
allocations where the prefix length of the allocated space is longer
than the minimum allocation size for LIRs.

3.4 	Self-Regulation of the Post-IPv4 Environment 

The allocation and of IPv4 addresses should - at all times - be guided
and regulated by the bottom-up processes in place in the existing
Regional Internet Registries.

In a post 2012 environment, ETNO believes that the current bottom up
stakeholder approach to manage the use of IPv4 public addresses should
be maintained. No intervention is needed or desired by the industries
who utilize and manage IPv4 addresses. This includes regional and
sovereign entities as well as those treaty organizations or economic
coalitions who might hope to affect IPv4 utilization for local or
regional advantage - regardless of historical circumstance.

3.5	No Connection between IPv4 and IPv6

The environment for the allocation of IPv6 addressing must remain
separate from the environment that manages the Post-IPv4 World.

While there can be no doubt that IANA and the RIRs will continue to play
an important role in both IPv4 and IPv6 in the future, ETNO believes
that the environments are separate and distinguishable.

In particular, decisions and policies regarding the allocation of IPv4
addresses to an organization, provider or user should not affect - in
any material way - their eligibility for IPv6 address space. Similarly,
an organization with IPv6 address space in the Post-IPv4 World has no
inherent right to IPv4 address space - except under the existing,
bottom-up processes that already guide IPv4 allocations to organizations
and LIRs globally.

ETNO has identified the following aspects that need to be factored into
any discussion.

4. Post 2012 Environment
Two broad options that might exist in the post 2012 IPv4 environment
that could assist in extending the continued assignment of IPv4
addresses have been identified , namely 
*	reclamation and reissue, and 
*	transfer. 

In discussing each of the options, ETNO has considered the implications
on a number of different levels. These include the entities involved
such as the Local Internet registries, Regional Internet Registries etc,
the legal framework, both nationally and regionally, and the interaction
that may exist between these levels.

Reclamation/Release and Reissue

Description
Reclamation/Release and reissue requires proactive action to be
undertaken, either by the RIRs or by LIRs. Independent of who undertakes
the action, reclamation is based upon the identification of unused IPv4
address space returning to the RIR. If proactive action is undertaken by
the RIRs, then it would be reclamation, and if the action was taken by
the LIRs it would be release. 

No assumption is made as to what size of block may be reclaimed, other
then to say it is likely to be smaller then that originally allocated,
and therefore no assumption regarding the value of the size reclaimed is
made.

Issues
For the RIRs to be proactive and to treat all allocations in an
equitable manner a global coordinated and consistent approach is
required. It is clear that there have been variances in approaches to
reclamation, across the five RIRs, in both recent and in legacy
allocations. Such an approach will need for the RIRs and their
membership to decide on a higher priority than today on that activity.

For the LIRs, reclamation will mean allowing some form of auditing to
occur, either directly with the RIR perhaps undertaking an audit of the
LIR. In either case the policies applied to already allocated addresses
must remain stable. There should be recognition that not all address
space that remains unassigned or unannounced is free for return to the
RIR. 

Regarding the legacy space there is an unresolved issue concerning the
legal basis on which the RIRs could take action to recover unused IP
addresses without any contractual arrangement with the holders.

Transfer 

Description
With the term transfer we refer to the transfer of an IPv4 address block
from one entity to another under contractual agreement between the two
of them. Such an entity can be both, an LIR or an address space
assignee, effectively creating four potential "classes" of transfers:

-	From one LIR to another
-	From one assignee to another
-	From an assignee to an LIR
-	From an LIR to an assignee of another LIR

Any such assignee could already have obtained address space from "its"
LIR according to the assignment policies, or might become an entirely
new assignee as a result of the transfer.

Issues

Future arrangements to meet on-going demand
ETNO believes that the existence of transfer would be a first step to
the creation of a market. This first would be a fundamental change to
the manner in which IPv4 addresses are currently managed.

In order to consider the impact of the creation of market for IPv4
addresses the following issues should be considered:

-	RIRs have been authorised to provide Internet Number resources
as a result of earlier decisions and the internet community has made
substantial effort to ensure appropriate bottom-up processes that are
open, transparent and equitable. This approach must be maintained.
-	Other Internet governance organisations (IETF, ICANN) in
collaboration with RIRs, ensure the robustness, security and stability
of the Internet, through bottom-up processes that involve all the
community.
-	According to the Internet Best Current Practice RFC 2008
Implications of Various Address Allocation Policies for Internet Routing
it is the Internet service environment and its continued operation which
gives an IP address its intrinsic value. Address allocation and
management policies for IP addresses that assume unrestricted address
ownership have an extremely negative impact on the scalability of the
Internet routing system and are almost certain to exhaust the
scalability of the Internet routing system well before the ultimate
exhaustion of the IPv4 address space. The recommendation is to formally
add the "address lending" policy to the set of address allocation
policies of the Public Internet. 

It is these successful bottom-up processes that keep the Internet
community from being engaged in discussions regarding intervention or
new models of governmental control and therefore it is the Internet
community that should take all the appropriate measures in order to
adhere to the current governance model. Facilitating a market based on
the principle that attaches an intrinsic "value" to an IP address would
engage competition authorities, policymakers and will raise legal
issues. This should be carefully considered before introducing policies
that will facilitate a market.

Moreover, IP addresses are allocated according to RFC 2050 Internet
Registry IP Allocation Guidelines "Initial allocation will not be based
on any current or future routing restrictions but on demonstrated
requirements."... "All IP address requests are subject to audit and
verification by any means deemed appropriate 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". Based on the
above principle RIPE assigns addresses based on clearly defined criteria
. There are also rules for the transfer of custodianship in all RIRs. 

Therefore if one entity sells an IP address to another, which is
completely different than existing transfer of custodianship procedures,
this directly implies that the assignment made is based on information
that is not valid, since the entity that is selling the IP address did
not make use for a specific purpose or the purpose no longer exists.
Therefore according to existing policy principles this IP address space
should be returned.

One could also possibly argue that a transfer is very similar to a
"reclamation/release and reissue" scheme - in the latter case the
gaining LIR or assignee is "just" not yet known, but still to be
determined by the usual allocation and assignment policies. However,
this predetermination in the case of a transfer bears the possibility
that the gaining LIR or assignee is allowed to jump the queue of other
LIRs (and assignees "behind" them) waiting to get a new allocation - and
by such would entirely distort the well established "first come, first
served and based on needs" scheme. Ultimately as the worst case, the
RIRs might even lose their capability to enforce the allocation and
assignment policies in case the assumption that policies will always be
correctly applied by all parties becomes null and void.

Based on the above considerations, ETNO has some strong concerns
regarding the possible impacts of the introduction of a transfer option
or an open market option. This does not mean that ETNO fails to
recognise the possibility that future transactions that will involve
transfers of IP addresses between entities for profit. It means that
internet community will need to carefully consider the implications of
assisting such a process, taking as a starting point that the Internet
community wants to preserve the current internet governance bottom-up
processes. If a market emerges, future developments relating to IPv4
addresses must not undermine the viability of the Internet.

Evolution

ETNO believes that ensuring the continued availability of IPv4 addresses
needs to exist as a global approach. As part of the global approach that
would need to exist, it is imperative that the coherence of the internet
is maintained. Underpinning the discussions is the principle that the
viability is a major cornerstone that needs to be considered in
discussing the options that exist.