- address-policy-wg - mailman.ripe.net

(no subject)
by Milton L Mueller 10 Jul '08

10 Jul '08

Dear Kelaidi: In the course of preparing the analysis of transfer markets I carefully reviewed the ETNO paper. I must confess that the primary substantive argument in it seems to be "we have never done it this way before, therefore it is bad." Let me engage with the idea that allowing transfers somehow brings in governments and governmentality. This is a very strange argument, and I am not sure I understand it. The RIRs maintain a private sector-based, contractual model of governance. Governments are currently involved, via the courts, as enforcers and interpreters of the contracts. I am sure you would agree with this. Now, if the terms of RIR contracts are modified to allow transfers, I do not see any fundamental change in the character of the relationship between RIRs and governments. Nor do I see any big change in the way the RIRs set address policies. I just see a different policy. When you talk about competition policy, perhaps you mean that acquisition or use of addresses could be abused by a market participant in an attempt to exclude competitors. But if that turns out to be true, then what is wrong with competition law being applied? It is also true that if government authorites believed that _current_ RIR policies were somehow discriminatory or anti-competitive then they could intervene. For example, suppose there is no transfer market, and telephone companies or other ISPs used their control of increasingly scarce IPv4 address pools in a way that competition authorities believed prevented competitive entry into the market. If they could make a case for that under existing law, they could intervene in RIR activities. Nothing stops competition policy authorites from scrutinizing what RIRs and ISPs do now. If your peering agreements, or your mergers and acquisitions, or your price-setting activities run afoul of competition law you will be dealing with government. nothing the RIRs can do can change that. In short, the presence or absence of a transfer policy has nothing to do with the propensity of governmental authorities to intervene. What _might_ make them more likely to intervene in the new environment is the increasing _scarcity_ of address resources, which makes access to addresses more contentious. That scarcity will exist whether or not we adopt a transfer policy. From: "Kelaidi Christina" <kelaidi(a)ote.gr> To: <address-policy-wg(a)ripe.net> Dear colleagues Regarding the policy proposal 2007-08: strong arguments in favour and against this policy proposal have been raised by a large number of members of the Address Policy working group mailing list. ETNO has raised a number of issues, including significant concerns regarding the possible impact of this proposal. ETNO's main concerns relate to: 1) the potential impact of an IPv4 market; and, 2) ensuring the stability of the IP addressing bottom-up policy development processes. In particular ETNO has mentioned that facilitating a market that = attaches an intrinsic "value" to an IP address would engage competition = authorities, policymakers.=A0 The emergence of market forces on = addressing policy will raise legal issues that could have detrimental = impact on the successful bottom-up processes that keep the Internet = community from being engaged in discussions regarding intervention or = new models of governmental control. =A0 ETNO is convinced that allowing for transfers within a single RIR region = will not result in the release of significant -- or, long-term -- blocks = of address space available for new entrants in the addressing = community.=A0Even so, it is important to=A0maintain=A0the transfer = policy that addresses the situation where addresses are being = transferred between organisations in situations such as mergers or = acquisitions.=20 =A0 ETNO believes that any transfer policy should provide a number of = safeguards. Specifically, ETNO believes that several of the criteria set = currently for=A0allocation of IPv4 addresses should be implemented = during transfers, e.g. all IP address transfer requests = "should=A0be=A0approved 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".=20 =A0 The proposed policy 2008-07 does not provide according to ETNO = sufficient safeguards and therefore ETNO could not support the 2007-08 = Policy Proposal, Enabling Methods for Reallocation of IPv4 Resources, as = it stands. Christina Kelaidi ETNO Naming Addressing and Numbering Issues WG Chairperson --__--__-- Message: 2 Date: Thu, 10 Jul 2008 09:28:31 +0200 From: Gert Doering <gert(a)space.net> To: Ana Matic <anamatic(a)ripe.net> Cc: address-policy-wg(a)ripe.net Subject: Re: [address-policy-wg] Revised 2007-01 moved back to Review Period (Direct Internet Resource Assignments to End Users from the RIPE NCC) Hi APWG folks, this proposal keep being difficult for our processes. We got a rebound from the WG chair collective, because they felt that there was no explicit consensus for version *2* of the proposal, which had some signficant changes (inclusion of ERX in the text). Now this is v3, trying to work out the last wrinkles, and get it through the process properly, and we got *NO* comments on it. "No comments" does not mean "consensus". It means "nobody is interested, leave us alone with this". I think that this is a very important milestone, and it needs good backing by the community (or if you don't want it, it should be explicitely torn down). The main difference v2 -> v3 is that ERX space has been completely taken out [because RIPE has no legal basis to enforce anything - we'll come back to this with a new proposal], and that there is a *new* document that describes what to do with existing end-user assignments - which has exactly the same intent as v2, but we can't put requirements for existing assignments into a "new assignments" documents, so this needed cleaning up. So - please read the documents, as referenced in Ana's mail below, and then explicitely voice agreement or disagreement with 2007-01 v3. thanks, Gert Doering, APWG Chair On Thu, Jun 26, 2008 at 04:22:44PM +0200, Ana Matic wrote: > PDP Number: 2007-01 > Direct Internet Resource Assignments to End Users from the RIPE NCC > > Dear Colleagues, > > The new version of the proposal described in 2007-01 has now been published > and is moved back to Review Period. > > Also, the new draft document "Contractual Requirements for Provider > Independent Resource Holders in the RIPE NCC Service Region" has been > published. This document describes the contractual requirements necessary > for End Users > of provider independent resources and also speaks to the status of > pre-existing assignments. > > You can find the full proposal at: > > http://ripe.net/ripe/policies/proposals/2007-01.html > > and the draft documents at: > > http://ripe.net/ripe/draft-documents/ripe-424-draft-2007-01-v3.html > http://ripe.net/ripe/draft-documents/ripe-421-draft.html > http://ripe.net/ripe/draft-documents/ripe-389-draft.html > http://ripe.net/ripe/draft-documents/ripe-new-draft-2007-01-v3.html > > We encourage you to review this revised policy proposal and the draft > documents and send your comments to address-policy-wg(a)ripe.net before 24 > July 2008. > > Regards, > > Ana Matic > RIPE NCC > Gert Doering -- NetMaster -- Total number of prefixes smaller than registry allocations: 110584 SpaceNet AG Vorstand: Sebastian v. Bomhard Joseph-Dollinger-Bogen 14 Aufsichtsratsvors.: A. Grundner-Culemann D-80807 Muenchen HRB: 136055 (AG Muenchen) Tel: +49 (89) 32356-444 USt-IdNr.: DE813185279 --__--__-- Message: 3 From: Florian Weimer <fw(a)deneb.enyo.de> To: address-policy-wg(a)ripe.net Subject: Re: [address-policy-wg] Revised 2007-01 moved back to Review Period (Direct Internet Resource Assignments to End Users from the RIPE NCC) Date: Thu, 10 Jul 2008 10:11:59 +0200 * Ana Matic: > http://ripe.net/ripe/policies/proposals/2007-01.html What's the status of EARLY-REGISTRATION space with regards to sub-assignment and the establishment of contracts? > http://ripe.net/ripe/draft-documents/ripe-new-draft-2007-01-v3.html I don't think recovering resources from unwilling end users is a good way to spend the membership fees. (I don't speak for any member, though.) And unless there is a clear incentive (which I don't see--the thread of revoking the assignment is not particularly convincing), a lot of end users will be unwilling. --__--__-- Message: 4 Date: Thu, 10 Jul 2008 11:06:44 +0200 From: Gert Doering <gert(a)space.net> To: Florian Weimer <fw(a)deneb.enyo.de> Cc: address-policy-wg(a)ripe.net Subject: Re: [address-policy-wg] Revised 2007-01 moved back to Review Period (Direct Internet Resource Assignments to End Users from the RIPE NCC) Hi, On Thu, Jul 10, 2008 at 10:11:59AM +0200, Florian Weimer wrote: > > http://ripe.net/ripe/policies/proposals/2007-01.html > > What's the status of EARLY-REGISTRATION space with regards to > sub-assignment and the establishment of contracts? Well, the "new document" draft very clearly states this: > > http://ripe.net/ripe/draft-documents/ripe-new-draft-2007-01-v3.html ----------- quote ---------- 1.1 Scope This policy document describes the contractual requirements for End Users of provider independent resources which have been assigned either directly by the RIPE NCC or through a Local Internet Registry in the RIPE NCC Service area. ----------- quote ---------- As ERX space has not been assigned by the RIPE NCC or a RIPE LIR, it is not covered by v3 of the 2007-01 proposal. We will come up with a new proposal how to handle ERX space (which is not yet written and thus cannot be discussed yet). Regarding sub-assignments of ERX space: I'm not sure exactly how the policy is right now, but since we're not going to touch ERX anyway, so nothing would change there. > I don't think recovering resources from unwilling end users is a good > way to spend the membership fees. (I don't speak for any member, > though.) And unless there is a clear incentive (which I don't see--the > thread of revoking the assignment is not particularly convincing), a lot > of end users will be unwilling. One of the incentives would be "without a clear contractual relationship, we can't give out a certificate for this resource". The main focus for the implementation is "new resource assignments", of course, but for consistency reasons it's important to have a plan how to tackle existing stuff. Gert Doering -- NetMaster -- Total number of prefixes smaller than registry allocations: 110584 SpaceNet AG Vorstand: Sebastian v. Bomhard Joseph-Dollinger-Bogen 14 Aufsichtsratsvors.: A. Grundner-Culemann D-80807 Muenchen HRB: 136055 (AG Muenchen) Tel: +49 (89) 32356-444 USt-IdNr.: DE813185279 --__--__-- Message: 5 Date: Thu, 10 Jul 2008 11:14:11 +0200 From: Marcus Stoegbauer <ms(a)man-da.de> To: address-policy-wg(a)ripe.net Subject: Re: [address-policy-wg] Revised 2007-01 moved back to Review Period (Direct Internet Resource Assignments to End Users from the RIPE NCC) Ana Matic wrote: > PDP Number: 2007-01 > Direct Internet Resource Assignments to End Users from the RIPE NCC > > Dear Colleagues, > > The new version of the proposal described in 2007-01 has now been > published and is moved back to Review Period. > > Also, the new draft document "Contractual Requirements for Provider > Independent Resource Holders in the RIPE NCC Service Region" has been > published. This document describes the contractual requirements > necessary for End Users > of provider independent resources and also speaks to the status of > pre-existing assignments. > > You can find the full proposal at: > > http://ripe.net/ripe/policies/proposals/2007-01.html > > and the draft documents at: > I fully support the meaning of this proposal and think it is the right way to make sure that the RIPE DB reflects the real world. However, I think I noticed a small problem in http://ripe.net/ripe/draft-documents/ripe-424-draft-2007-01-v3.html The new text in "9.0 PA vs. PI Address Space" states: |The policies stated above about the PI address space covers all non PA |address space maintained in the RIPE database, except address space |marked as Early Registration (ERX) and address space marked as NON-SET. This somewhat conflicts with: |1.1 Scope | |This document describes the policies for the responsible management of |globally unique IPv4 Internet address space in the RIPE NCC service |region. The policies documented here apply to all IPv4 address space |allocated and assigned by the RIPE NCC. Take 130.83.0.0/16 for example. It is "ASSIGNED PI" now, but it has never been assigned by the RIPE NCC (see RFC 1117, the assignment is first mentioned there). Of course this can easily be fixed, for example by changing the first sentence of the above quoted new text to: The policies stated above about the PI address space covers all non PA address space allocated or assigned by the RIPE NCC and maintained in the RIPE database, ... Marcus -- man-da.de GmbH, AS8365 Phone: +49 6151 16-6956 Petersenstr. 30 Fax: +49 6151 16-3050 D-64287 Darmstadt e-mail: ms(a)man-da.de Geschäftsführer Dr. Jürgen Ohrnberger AG Darmstadt, HRB 94 84 --__--__-- Message: 6 Date: Thu, 10 Jul 2008 11:58:42 +0200 From: Shane Kerr <shane(a)time-travellers.org> To: Florian Weimer <fw(a)deneb.enyo.de> Cc: address-policy-wg(a)ripe.net Subject: Re: [address-policy-wg] Revised 2007-01 moved back to Review Period (Direct Internet Resource Assignments to End Users from the RIPE NCC) Florian, [ I realize the contents of this post may be somewhat controversial. In fact, I expect most people to oppose the basic ideas. ] On Thu, Jul 10, 2008 at 10:11:59AM +0200, Florian Weimer wrote: > > > http://ripe.net/ripe/draft-documents/ripe-new-draft-2007-01-v3.html > > I don't think recovering resources from unwilling end users is a > good way to spend the membership fees. (I don't speak for any > member, though.) And unless there is a clear incentive (which I > don't see--the thread of revoking the assignment is not particularly > convincing), a lot of end users will be unwilling. I also don't speak for any member, but I think revoking assignments is a fantastic idea. In fact, I don't see how it makes sense to do otherwise. Someone claims to be the authorized user of some addresses. *Nobody* has any relationship wth this person. The only evidence you have is that at one time in the past someone was assigned the addresses. Sure, I can call the people peering with the originator of the advertisement, and see why they are carrying the traffic. They might or might not be willing to give me that information, or privacy or business reasons. Also, all because it is convenient for them to carry the advertisements does not mean somebody else won't do the same thing for the same space for a different originator. And finally, we have a perfectly workable system so I don't *have* to go through this kind of nonsense: the RIR system. If people are unwilling to sign a contract which basically says, "I am using this address space", then take their space back. It's not scary, really. Revokation is a good thing. -- Shane End of address-policy-wg Digest

1 0

Re: [address-policy-wg] 2007-08 Review Period extended until 9 July 2008 (Enabling Methods for Reallocation of IPv4 Resources)
by Milton L Mueller 06 Jul '08

06 Jul '08

Colleagues: I have prepared a paper on address transfer policy which will be released soon. It is now being reviewed. Due to RIPE's impending July 9 comment deadline I am sending the abstract of the paper to this list. Anyone interested in receiving a copy of the paper can contact me privately and I will send a copy when it is finished. If you have expertise in the economics of addressing or other virtual resources I'd be happy to send an advance draft for review. Of course, we can also discuss and elaborate here on some of the conclusions presented. Dr. Milton Mueller, Professor, Syracuse University School Of Information Studies XS4All Professor, Delft University of Technology IPv4 Address Markets and the Regional Internet Address Registries. Abstract We are running out of Internet addresses. This paper evaluates address transfer policies that Internet governance agencies are considering as a response to the depletion of the IPv4 address space. The paper focuses on proposals to allow organizations holding IPv4 addresses to sell address blocks to other organizations willing to buy them. This paper analyzes the economics of the proposed transfer policies, and conducts a systematic comparison of the policies proposed in the three main world Internet regions. It concludes that: * Address transfer markets offer a pragmatic solution to the problem of reclaiming a substantial amount of unused IP address space and of re-allocating addresses to their most efficient uses * The risks of instituting well-designed address transfer policies are small when compared to the potential benefits. The change is less radical than it appears. * A failure to legitimize address transfer markets would create substantial risks of the institutionalization of gray or black markets in IPv4 address resources, leading to a deterioration of accurate registration and administration of the legacy address space. This could have severe negative implications for Internet security. * The need for a transfer policy stands on its own and should not be considered part of a transition plan to the new Internet version protocol version 6. We do not know how long or even whether the global Internet will succeed migrating to IPv6. It would therefore be irresponsible to base IPv4 management policies on an assumption that such a migration will take place. * The proposed address transfer policies being considered by RIPE and APNIC are more liberal than ARIN's. Most of the legacy IPv4 address space is in North America; thus, the policies ARIN adopts have the most importance and should be formulated with the good of the global Internet in mind. RIPE, ARIN and APNIC should strive to harmonize their transfer policies and (in the longer term) make inter-regional transfers possible.

1 0

RIPE NCC will begin allocating from 188/8
by Alex Le Heux 03 Jul '08

03 Jul '08

Dear Colleagues, The IANA and the RIRs are working on an ongoing basis to verify and correct registration data of legacy address space to identify free space in these blocks. As a result of this work the RIPE NCC will begin allocating from 188/8 in future. The minimum allocation size for 188/8 has been set at /21. You may wish to adjust any filters you have in place accordingly. More information on the IP space administered by the RIPE NCC can be found at: https://www.ripe.net/ripe/docs/ripe-434.html Please also note that three "pilot" prefixes will be announced from 188/8. These prefixes are: 188.0.0.0/16 188.0.0.0/21 188.0.0.0/24 They will all originate in AS12654. The following pingable addresses will available in these blocks: 188.0.8.1 188.0.1.1 188.0.0.1 More information on this "pilot" activity is available in the document "De-Bogonising New Address Blocks", which can be found at: http://www.ripe.net/ripe/docs/ripe-351.html Best regards, Alex Le Heux RIPE NCC

1 0

2007-08 Review Period extended until 9 July 2008 (Enabling Methods for Reallocation of IPv4 Resources)
by Filiz Yilmaz 15 Jun '08

15 Jun '08

PDP Number: 2007-08 Enabling Methods for Reallocation of IPv4 Resources Dear Colleagues, The Review Period for the proposal 2007-08 has been extended until 9 July 2008. You can find the full proposal at: http://www.ripe.net/ripe/policies/proposals/2007-08.html We encourage you to review this policy proposal and send your comments to address-policy-wg(a)ripe.net. Regards Filiz Yilmaz RIPE NCC Policy Development Officer

24 60

2007-08 Review Period extended until 9 July 2008 (Enabling Methods for Reallocation of IPv4 Resources)
by Erics 13 Jun '08

13 Jun '08

We do not support the 2007-8 proposal! We have a clear policy that obligates LIRs to give back unused address blocks to RIPE-NCC. This is a clear procedure. If we open a kind of address-market we establish some more abuse possibilities. All in all we endore Per´s statement given below on June 11th. Eric Schmidt Deutsche Telekom Technischer Service Central Services | LIR de.telekom

2 1

Re: 2007-08 Review Period extended until 9 July 2008 (Enabling Methods for Reallocation of IPv4 Resources)
by Sander Steffann 13 Jun '08

13 Jun '08

Hello everyone, In the last two days there have been a lot of messages about proposal 2007-08. We have seen support, but also some concerns. To be able to reach consensus, these concerns have to be discussed. Here is a summary: Randy Bush: http://www.ripe.net/ripe/maillists/archives/address-policy-wg/2008/msg00355… - Transfering address space still assigned to end users - Inter-region transfers Per Heldal: http://www.ripe.net/ripe/maillists/archives/address-policy-wg/2008/msg00354… - Keep demonstrated need criteria for address space by receiving LIR - Legal implications for RIPE NCC - Viable plans for reclaiming space to continue with current policies for a significant time? http://www.ripe.net/ripe/maillists/archives/address-policy-wg/2008/msg00365… - Possiblity of setting up LIRs for hoarding Jay Daley: http://www.ripe.net/ripe/maillists/archives/address-policy-wg/2008/msg00366… - Seller can choose who to sell to, not transparent - Discrimination of LIRs in developing countries in the RIPE region - Reclaim/reuse could be more efficient than transfering - Faster depletion because of hoarding - Legal implications for RIPE NCC - Degradation of RIPE DB because of rival trading exchange databases Eric Schmidt: http://www.ripe.net/ripe/maillists/archives/address-policy-wg/2008/msg00381… - Breaks the current policy that unused address blocks return to RIPE NCC - Transfers open up more possibilities for abuse ETNO: http://www.ripe.net/ripe/maillists/archives/address-policy-wg/2008/msg00293… - A transfer system can not ensure a process that is open, transparent and equitable - Negative impact on routing tables - Keep demonstrated need criteria for address space by receiving LIR I want to thank everyone for voicing their support and concerns. At this point in the process, please focus the discussion on the open issues. Sander Steffann APWG co-chair

1 0

2008-03 Review Period extended until 26 June 2008 (Global Policy for the Allocation of the Remaining IPv4 Address Space)
by Filiz Yilmaz 12 Jun '08

12 Jun '08

PDP Number: 2008-03 Global Policy for the Allocation of the Remaining IPv4 Address Space Dear Colleagues, The Review Period for the proposal 2008-03 has been extended until 26 June 2008. You can find the full proposal at: http://www.ripe.net/ripe/policies/proposals/2008-03.html We encourage you to review this policy proposal and send your comments to <address-policy-wg(a)ripe.net>. Regards Filiz Yilmaz RIPE NCC Policy Development Officer

3 2

Re: [address-policy-wg] 2007-08 Review Period extended until 9 July 2008 (Enabling Methods for Reallocation of IPv4 Resources)
by Marco Hogewoning 11 Jun '08

11 Jun '08

On 11 jun 2008, at 13:03, Gert Doering wrote: > Hi, > > On Wed, Jun 11, 2008 at 12:46:14PM +0200, Marco Hogewoning wrote: >> I agree > > Please be specific: do you agree to the proposal, or to the request > that > people voice their support? > > (Off-List, but this is important when the question "who was in > favour of > it, and who opposed it" is going to be asked) > ed) Sorry for the confusion. I support this proposal. Groet, MarcoH

1 0

Re: [address-policy-wg] 2007-08 Review Period extended until 9 July 2008 (Enabling Methods for Reallocation of IPv4 Resources)
by Niall Murphy 11 Jun '08

11 Jun '08

I support this proposal. Niall > Dear all, > > Following up on Filiz' announcement, I would like to ask people > supporting 2007-08 to let their voices be heard on this mailing list; we > can only move it forward if the wg chairs see enough support for it (and > so far there has been a lot of informal support). > > Thank you, > > Remco van Mook > > > -----Original Message----- > From: address-policy-wg-admin(a)ripe.net > [mailto:address-policy-wg-admin@ripe.net] On Behalf Of Filiz Yilmaz > Sent: woensdag 11 juni 2008 10:32 > To: policy-announce(a)ripe.net > Cc: address-policy-wg(a)ripe.net > Subject: [address-policy-wg] 2007-08 Review Period extended until 9 July > 2008 (Enabling Methods for Reallocation of IPv4 Resources) > > PDP Number: 2007-08 > Enabling Methods for Reallocation of IPv4 Resources > > Dear Colleagues, > > The Review Period for the proposal 2007-08 has been extended until 9 > July 2008. > > You can find the full proposal at: > > http://www.ripe.net/ripe/policies/proposals/2007-08.html > > We encourage you to review this policy proposal and send your > comments to address-policy-wg(a)ripe.net. > > Regards > > Filiz Yilmaz > RIPE NCC > Policy Development Officer > > > > > 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 >

1 0

2007-08: response to ETNO position
by Remco van Mook (Virtu) 04 Jun '08

04 Jun '08

Dear all, and in particular the representatives of ETNO, Let me first thank ETNO for taking the effort, twice, to make a valuable contribution to the discussion surrounding the 'Afterlife' of IPv4 in the form of position papers. It is good to see that we all seem to agree on the following fundamentals: - 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 - The only long-term solution to the "unavailability" of IPv4 addresses is the widespread adoption and deployment of IPv6 infrastructure, transport and client services. (This is pretty much a literal copy from the ETNO position; I could have used my presentations on the subject as a source as well) The other point that most of us will readily agree with, is that we don't like markets. Markets for IPv4, of course. I'm not particularly fond of the idea, either. I would encourage anyone who is completely in favor of an IPv4 market to establish to visit the next ICANN meeting and see first hand what a thriving market has arisen in the domain name space. But there the agreement stops. 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. It does not create a market. We don't stop making policies right after passing this one; the proposed framework can be adapted, altered, even abandoned if we see as a community see fit. The point about moving on urgently with 2007-08 is that it does make a significant impact on how the RIRs run their shop. Implementing and testing 2007-08 takes time, probably a lot of time. Having it in place before the RIRs run out means that we at least have policy we can execute when we run out. Current policy would even allow a single request for a large block of addresses to completely clean out the reserves a RIR might still have in smaller available blocks. But I digress. ETNO, in its position paper, provides a number of principles that a 'post-IPv4' (ETNO's term, not mine) world should obey. I'll mention them shortly and then reply. 1) Identification of legitimate use ETNO would like, in short, to be able to identify parties that have genuine rights of use over IPv4 address prefixes. It is also argued that this can only be done globally, not regionally because that 'will be unworkable'. This global approach must also be in place long before the period in which IPv4 is harder to get. 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. And this global registry is required as of today. As you all know, IPv4 is already harder to get; policy has changed last year so LIRs can only get enough for a 1 year period rather than a 2 year period. In my opinion, this is a 'pie in the sky' idea. It is unlikely for a global policy to establish itself within any reasonable time if that policy would abandon the single most significant asset of any RIR; their database. 2) Transparency Any decision regarding allocation or assignment must be done in a transparent and public way and consistent with the bottom-up policy process. Any deficiencies should be removed from policy before then. And globally, of course. 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. The RIRs don't currently make the arguments based on which an LIR receives an allocation public, either. When IPv4 space moves hands because of a merger or acquisition this doesn't happen either. That's all current bottom-up policy. 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. Current global demand is among the lines of 13 /8s a year. Taking low-hanging fruit that has already been recovered into account we can perhaps recycle another dozen /8s. Recovering those will take years. The same goes for re-tasking any experimental or reserved space to 'global unicast'. It would take years to accomplish and only have a very limited impact. As I've said in one of my presentations, even if we were to find a brand new and completely empty IPv4 space somewhere (which will not happen) we'd probably use that up in a decade as well. The fundamental issue is consumption, not lack of production. 4) Self-regulation Allocation of IPv4 addresses should always be guided and regulated by the bottom-up process of the RIRs. Fully agreed. What we probably do not agree upon is what comes out of this process. In addition, one of my main reasons for pushing 2007-08 is that I would very much like that the RIRs stay relevant and the process stays in place. Removing IPv4 from the grasp of the RIRs (and therefore also from the bottom-up policy process) is the single most significant risk of not facing the 'afterlife' in a timely fashion. The moment the RIRs say 'no you can't have more space and you're not allowed to get it anywhere else' is the moment the world turns to another place for that resource. 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. 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. In another chapter, ETNO also addresses a few aspects they think should be taken under consideration. In their point of view, we can either get a reclaim/reuse model or a transfer model. I think we can get both, provided we change allocation policy so that a single request can not wipe out carefully built-up reserves. This falls outside of 2007-08 or any other current policy proposal but I'd expect a proposal sooner rather than later. 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. The report also reiterates that by adopting transfers we abandon that bottom-up policy process. I don't remember putting that in my proposal - perhaps I should read it again. To finish up, the ETNO paper worries about the options RIRs might have to enforce policies in a transfer situation. I'll let you in on a secret: how many times has a conflict been brought to the RIPE NCC arbitration council? Once. Just one. That either means that we all gladly and completely abide set policy or that the real world options RIRs have to enforce policy are limited in the first place. I'll let you choose. In summary: Thanks for bearing with me - this is quite a bit longer than I anticipated it to be. The ETNO position paper gives us a fascinating view of the 'afterlife' and tells us that none of the options we currently have will be an acceptable substitute for the IANA free pool from the ETNO perspective. It also tells us that we should abandon regional policy while at the same time keeping the current bottom-up policy process. This puzzles me. The one reason I could find in the entire paper why ETNO does not like 2007-08 is that it does not like the idea of a market. Neither do I. But 2007-08 is not about a market. It is a fallacy to think that any of us can either create a market or prevent one from being created. That is particularly so in an environment that will have global demand and (potentially) supply. 2007-08 is about staying relevant in an environment where a market evolves. I am fully aware that an evolving market will bring all sorts of interest, not in the last place from regulators. But it's not the regulators we should fear; letting it all slip through our hands is what we should worry about. Creating a transfer policy shows that we as a community can be part of a solution and show good stewardship, not just part (and cause) of the problem. People who are part of the solution will have a seat at the table - the people who merely caused the problem will not. Inaction is not a sign of good stewardship. So we need to be seen doing something, preferably something that will make a difference. So let's consider the alternatives: either we enable transfers or we prevent running out of IPv4 space. I can come up with a policy proposal for that as well - I'm positive you're going to like it even less than this one. If we would only allow justification for new v4 allocations to be based on servers and network infrastructure and not on 'eyeballs' we'd see our consumption rate evaporate overnight and the IANA free pool will last us at least a decade longer, while at the same time forcing the 'eyeballs' to move to IPv6. Think that's a better idea? Personally, I think not. 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. I thank you for your time and look forward to your responses. Best, Remco van Mook (no hats)

4 4