[address-policy-wg] 2013-03 New Draft Document and Impact Analysis Published (No Need - Post-Depletion Reality Adjustment and Clean up)

Hi Malcom, and thank you for your detailed feedback!

I'll be trimming your message heavily in order to try to respond to your
main points in order to avoid doubling the size of the message - if you
feel I have neglected to respond to something I ought to have, please
let me know.

> if we abandon the core objective, as 2013-03 would do,
> we're basically closing the door on any discussion of what those
> alternatives might be.

I do not agree with this at all. The IPv4 policy document is a living
thing, and anyone may suggest changes to it at any time. For example,
the possible addition of a section describing "Principles" has been
discussed earlier, and 2013-03 would not prevent this in any way.
Indeed, such a proposal could be proposed and adopted independently of
2013-03.

> Finally, as noted by the RIPE NCC, this takes away a key message the
> RIRs have used to justify their independence from government. That may
> not be sufficient reason to oppose the policy if it is otherwise
> necessary, but it does seem to me to indicate caution and counsel
> against acting precipitously.

This is one of those things where I feel the message needs to be updated
to match the new realities on the ground. Regardless of any change
brought by 2013-03, the RIPE NCC's role in IPv4 address distribution is
pretty much over, the "last /8" policy being its final death cramp, so
to speak.

It was claimed earlier that the proposal would change the NCC into a
"pay here to buy your IPv4 block today" type of outlet, and I don't
doubt that some government could potentially make similar claims in an
attempt to undermine the NCC's role in IPv4 address distribution.
However I have full faith in the NCC's ability to adjust its
argumentation to explain that this is simply not the case, as its role
in IPv4 address distribution is pretty much unchanged by 2013-03.

That said, I would be more concerned about keeping or making certain
policies for the purpose of "staying in power" instead of due to a
belief it is "the right thing to do". If anything would undermine the
community's validity, IMHO, it would be this.

> However this argument is fallacious. The Conservation policy, even as
> stated, expresses *two separate* policy objectives: 'fair distribution',
> and maximising the lifetime of the public address pool. Depletion means
> that reality has superseded the second objective, but not necessarily
> the first.
> 
> So my first question to Tore is: "Why should 'fair distribution' of
> addresses between users no longer be considered an overarching objective
> of IPv4 address management?"

For NCC->LIR and NCC->End User delegations, it has already been
abandoned. For example:

- LIR A requires an allocation to serve 10000000 nodes
- LIR B requires an allocation to serve 1000 nodes
- End User C requires an assignment to serve 1000 nodes

These would (both with current and 2013-03 policy) get 1024, 1024, and 0
addresses, respectively - even though the NCC currently has enough
addresses to give all three every single address they requested. In my
view, this is clearly unfair to A and C, but it's what we have today.

For LIR->End User delegations, I question that 'fair distribution' has
ever existed, or if it ever did - if it does now. I'll demonstrate with
another example: Your LIR has a /23 left of unassigned address space.
Three End Users are knocking on your door, requesting a /24, a /23, and
a /22. All fully justified. How does our current policy guide your LIR
to be "fair", let alone *enforce* this fairness?

> 2. "Fair distribution" establishes a basic goal for IPv4 address
> management policy. Other policies exist to pursue that goal.
> If we abolish the goal, we not only abolish those other, secondary
> policies (which may indeed be out of date)

How does the secondary mechanisms (I'm guessing you're referring to
things like the AW, 80% rule, and "documented need") actually ensure
"fairness", these days?

Going back to the previous argument with the three End Users - the only
way "fairness" could work in the first place, is that your LIR could
just give out everything that was asked by covering their "expenses"
with fresh allocations from the NCC's free pool. But that doesn't work
anymore.

> but we also deny ourselves the right to introduce new, updated policies
> to pursue that goal.
>
> 3. The proponents of 2013-03 have argued on this list that the existing
> policy is unsupportable because, in a post-depletion world, RIPE NCC has
> lost the means of enforcing it. It is certainly true that post-depletion
> it will have lost the means by which it has traditionally enforced it.
> But that doesn't necessarily mean that the policy should be abolished:
> it might alternatively suggest that the required "reality adjustment" is
> that the community develop new policies that would give the RIPE NCC
> alternative means of enforcing it in the post-depletion world, where
> IPv4 addresses continue to be an important resource.

I just don't buy the argument that 2013-03 makes the IPv4 policy
immutable. This isn't APNIC prop-103. If 2013-03 turns out to be a
terrible mistake, it could even be reverted word by word. Last year, I
reverted 2009-03 *precisely* in this manner (proposal 2012-06).

If you believe that the current policy provisions that are responsible
for enforcing "fairness" are no longer effective (if they ever were),
then we might as well take them out completely. If we come up with a
clever replacement, then we can discuss that in a separate proposal, but
if we fail to come up with an effective replacement, what good will it
do us to keep the inefficient stuff around? (Surely not the bureaucratic
overhead?)

> Certain governments are keen to end the independence of the RIRs and
> move them from being run by and on behalf the community to being made
> directly answerable to governments. In practice, this would mean the
> abolition of RIPE (or at least, its policy making function) and perhaps
> having the RIPE NCC board appointed by an intergovernmental body, likely
> the ITU.

2013-03 is specific to IPv4, and does not make any difference to other
number resources such as IPv6 and ASNs. While I have no difficulty
understanding that governments would have liked to have  the RIR role, I
guess I fail to see how they could possibly get that role in IPv4
address distribution now. I mean - what addresses would they be
distributing? :-)

Tore