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.