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.
However, we already have a framework for IP address transfers between LIRs which works substantially the same in all RIR regions. If it involves a change in corporate ownership, you simply need to show proof of the change and that the network is still operating under the new entity. The RIR then updates all records showing the new ownership. Or you give the address block back to the RIR because you no longer need it, and some other LIR will get those addresses at some point in the future. This framework works. There is no reason to believe that it would cease working as IPv6 deployment picks up. Most network operators are undertaking some form of audit of their internal use of IP addresses in preparation for the shortage, which means that as IPv6 picks up, they should know when they have surplus IPv4 addresses and can return them to RIPE or whatever RIR they came from. If it is not broken, then why would we want to change this framework? You claim that this will speed up the process of transfers but I cannot see how adding a new set of transfer rules will speed up anything. Even though you claim that this is an LIR-to-LIR transfer without RIPE involvement, this is not true since there are various rules which RIPE must administer and RIPE can disallow a transfer if, for instance, an LIR has received a re-allocation within the past 24 months.
1) Identification of legitimate use
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.
Huh? I can't see where you get this idea. This ETNO point is in full support of the existing RIR system, where every IP address range is under the authority of one of the RIRs, and where the identity of the "legitimate user" can be authoritatively discovered in the RIR's database (or whois directory). In this point ETNO is supporting the existing transfer framework in which all IP address transfers must go through one of the 5 RIRs. Under 2007-08 it is possible that some LIRs will transfer addresses which an RIR will not register in the database. You then have two parties (transferor and transferee) claiming that a transfer has taken place, and one party (RIPE, etc.) claiming that it has not. Instead of a clear statement of the legitimate user, you need to go to some kind of adjudication panel to sort the mess out.
2) Transparency
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.
Because under 2007-08 two LIRs can secretly negotiate and execute a transfer or addresses under some secret set of terms which may or may not include payments of cash. RIPE only gets involved at the end of the process to update the database, and the terms of the exchange are never disclosed.
When IPv4 space moves hands because of a merger or acquisition this doesn't happen either. That's all current bottom-up policy.
During M&A activity, it is public who receives the functioning network assets, and that is the criteria (technical justfication) for allocating IP addresses to the new network owner. The IP addressing aspects are still open and public.
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.
Under 2007-08, you are right that the RIRs will not recover much. But if we leave the transfer framework as it currently is, then most IPv4 addresses that become surplus due to IPv6 deployment, will go back to the RIRs. Here ETNO is supporting the current framework because it provides fair and neutral terms for reuse of addresses. To get addresses, everyone must provide a technical justification. When that justification goes away, everyone must return the addresses to RIPE unless there is some imminent new technical justification in their own organization, for instance shutting down dialup services in a company who is still growing VPN or Internet access or broadband business. Reuse, happens naturally and no new policies are needed. It would be nice for RIPE to remind LIRs about returning IP addresses and set some guidelines such as don't bother until you have more than a /24, if you expect an adjacent block to become free within 6 months then wait before returning, etc. That could be done without making fundamental changes to the transfer framework.
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.
ETNO is just a bunch of people, much like RIPE. Different people have different working styles and that's OK. Note that more people from ETNO companies are starting to get involved in RIPE as they learn and understand RIPE's working practices. May I suggest that RIPE could help by offering to present a session at ETNO's next annual conference in November.
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.
Unfortunately, 2007-08 will lead many to think that selling address blocks is OK in the RIPE region. As a result, this does affect IPv6 since if an IPv4 address block is a saleable asset then IPv6 addresses are also saleable assets.
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.
Focussing just on the last sentence it is clear that you believe a market will evolve, and that 2007-08 "accomodates" a market. That is precisely where ETNO disagrees. ETNO believes that a market can be prevented from evolving if RIPE takes the correct actions, and that "accomodating" a market is a wrong action for RIPE to take. Remember that collectively, ETNO members have a huge number of IPv4 addresses allocated. If they do not participate in any attempts at forming a market, then the market will be stunted, and lack liquidity. In addition, when the shift to IPv6 begins in earnest, because vendors have fixed the problems which are still blocking it, ETNO member companies will be deploying IPV6 rather quickly. This will result in a significant percentage of their IPv4 addresses returning to RIPE for reallocation. That event will kill any existing market for IPv4 addresses. So the best possible scenario for an IPv4 market will be a trickle of transactions put on for show then a runout of IANA's free pool followed by a sharp increase in small block transactions by some players trying out the market. At this point prices will sharply increase causing buyers to back out of the market unless they are in desperate straits. Then IPv6 deployers will begin giving some addresses back to RIPE at which point the market collapses. Frankly, it would be better for this to play itself out in a black market scenario without RIPE involvement.
Inaction is not a sign of good stewardship. So we need to be seen doing something, preferably something that will make a difference.
You are right. It is time for RIPE to take more action to help LIRs audit their supply of addresses and to set some reasonable guidelines for returning unused IPv4 addresses. Since addresses are only usable in aggregate, and since LIRs could potentially increase those aggregate block sizes with sensible internal processes, it is time for RIPE to work on a best practices document for IPv4 addressing.
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.
Note that Mark McFadden, who presented an ETNO document a couple of RIPE meetings ago, and myself, both work for an ETNO member. I agree that it would be nicer to see more ETNO members join in the discussion, but please recognize that ETNO deals with far more issues and policy organizations than just RIPE. I suspect that many ETNO members see RIPE as a functioning organization that is mostly doing good work for the network, and therefore RIPE doesn't need as much attention as some other organizations that make laws and regulations (which have almost the same force as a law). --Michael Dillon