[address-policy-wg] ETNO Contribution on IP Addressing in a Post IPv4 World Reallocation of resources

Dear colleagues

I am forwarding ETNO Position on the RIPE 2007-08 Policy Proposal. ETNO
supports this Policy Proposal, but requests for a clarification to be
included.

Christina Kelaidi
ETNO Naming Addressing and Numbering Issues (NANI) WG Chairperson

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ETNO has considered the new version of the RIPE 2007-08 Policy Proposal
Enabling Methods for Reallocation of IPv4 Resources, submitted for
discussion in the RIPE Address Policy Working Group mailing list. ETNO
believes this revised version that provides for additional criteria to
demonstrate the need for an LIR to receive IPv4 addresses trough
transfer, is significantly improved. Therefore ETNO will support this
Policy Proposal. 

Still there are outstanding considerations regarding the extent and
effect of this proposal that should be addressed by the community.

1.	Introduction
ETNO members have carefully reviewed the new version of the RIPE Policy
Proposal 2007-08 related to the "Enabling Methods for Reallocation of
IPv4 Resources", which proposes to use inter-LIR transfer mechanisms.

This new version of the proposal has been examined in light of the
principles expressed in the two previous ETNO position papers circulated
in the RIPE Address Policy Working Group mailing list (CP082 - 2007/10,
and EC097 2008/05 publicly available also at www.etno.be, Position
Papers 2007/2008).

ETNO welcomes the opportunity to provide comments on this new version.

2.	ETNO analysis and comments

The major change between Version 2 and Version 3 of the policy proposal
is the requirement for the receiving LIR to have their need evaluated by
the RIPE-NCC before a transfer can be completed. ETNO believes that this
requirement is necessary in order to avoid speculative behaviours.

Based on the above ETNO will support RIPE 2007-08 "Policy Proposal
Enabling Methods for Reallocation of IPv4 Resources", but would like to
propose for a clarification to be included in the proposal. ETNO
suggests that following the text of the proposal: "An LIR may only
receive a transferred allocation after their need is evaluated by the
RIPE NCC", the following text should be inserted: "The transfer should
be formally approved by the RIPE-NCC".

3.	Outstanding considerations

ETNO has outstanding considerations regarding the extent and effect of
this proposal that should be addressed by the community. It should be
mentioned that these considerations do not impact the approval of the
current policy proposal.

1.	ETNO believes that reclamation by the RIRs of allocated but
unused addresses can offer a way to reuse IPv4 blocks of addresses. In
the future, what impact will this new policy have on any reclamation
activity? Is it possible to reconcile the reclamation activity from
historic, legacy space and the procedures for inter-LIR transfer? 

2.	Since the significant volume of allocated but unused addresses
resides in the historic, legacy space and these addresses are generally
not maintained by Local Internet Registries, what will be the impact of
this policy proposal? In the future will it be a requirement that the
donor be an LIR even in the situation where legacy space is being
transferred? Such a requirement could be counter productive to
reintroduce unused legacy space in the RIR/LIR management.

3.	Given the limited scope of the policy, does this proposal have a
significant impact on the availability of additional IPv4 addresses
prior to exhaustion of the pools of "fresh" IPv4 addresses from IANA?

4.	Conclusion

ETNO is positive to any flexibility that could provide a limited amount
of IPv4 addresses, and can help the transition to IPv6, but believes
that this will not solve the broad issue if IPv4 exhaust and should not
distract ISPs and operators from finding appropriate and long term
solutions to maintaining a stable Internet.

Based on the above ETNO will support RIPE 2007-08 "Policy Proposal
Enabling Methods for Reallocation of IPv4 Resources", but has requested
for a clarification to be included.