[address-policy-wg] (no subject)

["Milton L Mueller" mueller@localhost]

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@localhost

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


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Message: 2
Date: Thu, 10 Jul 2008 09:28:31 +0200
From: Gert Doering gert@localhost
To: Ana Matic anamatic@localhost
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@localhost 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@localhost
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@localhost
To: Florian Weimer fw@localhost
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@localhost
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@localhost
Geschäftsführer Dr. Jürgen Ohrnberger             AG Darmstadt, HRB 94 84


--__--__--

Message: 6
Date: Thu, 10 Jul 2008 11:58:42 +0200
From: Shane Kerr shane@localhost
To: Florian Weimer fw@localhost
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




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