Comments on " Guidance in the Assignment of Internet Numbers"

Dear colleagues serving as targets (e.g. IAB),

a happy, successful and healthy new year to you all!

A few comments on "Guidance in the Assignment of Internet Numbers"
from a practitioner follow.

First of all let me read back to you what I think you want to say:

	"The existence of private address space (RFC1597) 
         shall not prevent any enterprise to obtain public 
	 address space according to the allocation criteria
         (currently RFC1466) if they wish to."

I will work from the assumption that this is true.
If there is any other specific and inportant point 
that you want to make I would be interested to hear it. 

Unfortunately in saying this more verbosely, you say some things 
that will make the registries' life in delegating and assigning 
address space efficiently and CIDRised more difficult than necessary.
I would like you to realise this. It might be wise to reduce 
the number of words to something closer to the above.

Detailed comments:

  > Abstract
  > 
  >    The IAB suggest that while RFC 1597 establishes reserved IP address
  >    space for the use of private networks which are isolated and will
  >    remain isolated from the Internet, any enterprise which anticipates
  >    external connectivity to the Internet should apply for a globally
  >    unique address from an Internet registry, or a service provider.

This should read: ".... isolated from the Internet, any enterprise should
obtain globally unique addresses for all those hosts which are anticipated
to have direct network layer connectivity external to the enterprise."

I also do not like the distinction between "Internet registry" and
"service provider". We prefer to talk about Internet registries only.
The RIPE NCC is a Regional Registry whereas service providers can become
Local Registries if they wish. 

(Ceterum censeo: The InterNIC RS in my view is just another Regional Registry
which also happens to do some administrative things for IANA. 
Regional Registries operate under the authority of IANA and not the
InterNIC's.)

  >    Regional Registries have agreed to comply with the guidelines
  >    established by RFC 1466 and therefore, if an organization meets the
  >    size requirement for the requested address(es) and submits an
  >    engineering plan, the organization has fulfilled the necessary
  >    requirments. The Regional Registry will make the allocation based on
           typo
  >    the established criteria.

Do you really want to say that the following qualifies for 512Cs:

"Hi,

I represent DFK MegaNetwork Ltd. etc. pp.

We are going to implement an enterprise network with 508 subnetworks
which we have conveniently divided among our 50 sites in 10 countries
as follows:

	country a 	0-99
		site aa 	0-9
		site ab 	10-19
		site ac 	20-29
		...
	country b	100-199
		site ba		100-109
		...
	...

	test lab		500-507
		
Each network has 0 hosts now and will have 20 hosts operational on it 
on average within 1 month from now. We are buying all those
hosts at the moment. Some of the subnets will have close to 200
hosts on it.

For technical reasons we cannot use VLSMs or subnetting.

We need public address space because all of the hosts might
have external connectivity in the future.

We are starting implementation in 10 days and would appreciate
an assignment of 512 class C network numbers before then.

Kind Regards

S.T. and A.R.D. Text
Consultants"

I would at least say that "... submits an engineering plan documenting
reasonable attention to conservation of address space and a realistic
deployment schedule."

Also what is missing is that use of currently assigned address space
should be documented. Otherwise they can do this twice a year.

What this really shows is that RFC1466 needs a rework.
I am still prepared to lay the groundwork to this, but it
should be done by IANA and all Regional Registries *together*.

  >    The preconditions defined in RFC 1466 are limited to number of hosts
  >    and subnets as well as an engineering plan if the request deviates
  >    from the standard criteria. There is no requirment that an applicant
  >    must have selected a network service provider prior to applying for
  >    an IP address. The lack of being the customer of a network service
  >    provider is insufficient reason for a Regional Registry to deny an
  >    applicant's request for an IP address.  The Internet registries must
  >    honor an enterprise's request for a globally unique IP address
  >    provided that the request meets the other conditions used to
  >    deterimine the appropriate size of address block to allocate.

That is fine with me. 
As an undertone I hear an implication that this has happened.
This is not good to leave in.
Is the RIPE NCC accused of this?

Of course there may be a charge associated with processing the request.

The way I see it going in Europe is that free assignment of address
space will rapidly go away. You will have to pay for the service.
The standard way will be thru a Local Registry. These usually are
service providers. They will have a choice to offer address space 
assignment service without IP serice associated with it. The NCC 
(Regional Registry) will also offer this service at a high cost 
to set a ceiling price and to prevent is from being innundated with 
small transactions. This is my personal vision. Consensus building
is in progress.

  >    RFC 1597 establishes reserved IP address space for the use of private
  >    networks which are isolated and will remain isolated from the
  >    Internet. Any enterprise which anticipates external connectivity to
  >    the Internet should apply for a globally unique address from an
  >    Internet registry, or a service provider.

See above (language about expected network layer connectivity).

  >    RFC 1597 documents a way that private enterprises may assure that
  >    their networks will remain segregated from the Internet.  The
  >    addresess designated in RFC 1597 will not be routed by the Internet.
  > 
  >    The IP addresses of RFC 1597 are not meant to be used as temporary
  >    addresses for enterprises which plan to connect to the Internet at a
  >    later date when the enterprises have selected network service
  >    providers.  

See above (language about expected network layer connectivity).

  > If an enterprise desires a unique IP address, the
  >    registries are instructed to assign such an address without
  >    conditions with regard to service provider selection.
  > 
  >    Any organization which anticipates having external connectivity is
  >    encouraged to apply for a globally unique IP address.  Whereas the

See above (language about expected network layer connectivity).

  >    globally unique address is insufficient to guarantee global
  >    connectivity, globally unique addresses are necessary to
  >    differentiate between destinations on the Internet.

(Un)fortunately in a few hours I am leaving for two weeks of vacation to
a place without telephone service.  There is no Internet either in the
whole country which is not large enough to appear on Larry's maps.  It
would be coloured green if it was.  I am glad such places do still
exist. ;-)

I would apreciate if the draft was updated in the direction of my
comments.  I would certainly be disturbed if the RFC was published
before February and the next RIPE meeting.

Daniel