|
DOCUMENT ID: NRO17
15 November 2004
On 21 October
2004, the Director of ITU TSB published a memorandum, “ITU and Internet
Governance” for public comment. The Number Resource Organization
(NRO) respectfully offers this public response on behalf of the Regional
Internet Registries: APNIC, ARIN, LACNIC and RIPE NCC.
This response is limited to section 4.2(b), titled
"Management of Internet Protocol (IP) addresses". This focus
is consistent with the purview of the RIRs, and should not be interpreted
as agreement with the remainder of the ITU memorandum.
Note: Throughout this memo the terms "number"
and "address" will be
used interchangeably to denote network layer addresses. In particular
the term "Internet address" does not refer to a domain name,
URL, URI
or mailbox name.
Summary
The ITU memorandum has proposed a new IPv6 address
space distribution process, based solely on national authorities. This
proposal appears to be based on certain assumptions about the history
and status of IPv4 address space and the current allocation principles
for allocating IPv6 address space, and an attempt to safeguard what the
memorandum terms the “sovereignty connected to the registration
of addresses”.
It also appears that behind the proposal is an assertion
of primacy of public sector interest in the administration of address
resources for the Internet. Since the inception of the Regional Internet
Registry (RIR) system in the early 1990s, the RIRs have recognized not
only the legitimacy of this public sector interest but also that of the
private sector. The RIRs believe that the balance of these two interests
requires careful consideration. The RIRs work within a broad spectrum
of stakeholders in Internet address administration, and have developed
open regional policy development processes that include the active participation
of both public and private sector bodies as well as civil society.
The IPv6 address space distribution proposal in the
ITU memorandum overlooks the success of the RIRs in including public and
private sector considerations in open regional policy development processes.
It also disregards the widely accepted and long-held views that IP addresses
are endpoint network identifiers that intrinsically have no national attributes,
and that allocation principles regarding their distribution must be guided
primarily by technical considerations relating to the viability of the
operation of the Internet.
In addition, the memorandum makes assertions about
IPv4 and IPv6 address space which are inconsistent both with authoritative
statistics about IP address space and with the established consensus-based
allocation principles developed by the global Internet community.
Rather than addressing the diversity of requirements
of the global Internet community or the body of experience already gained
in the operation of the global IP address distribution function, the ITU
memorandum proposes a uniform model of Internet address distribution as
a public sector activity within autonomous national boundaries. The memorandum
ignores any consideration of the technical impacts of its proposal on
the global Internet (specifically on address space routability) and simply
suggests that considerations of “details and constraints, in particular
issues related to routing table size” should be postponed until
an unspecified time in the future.
This proposal, if adopted, would disrupt the stable,
proven mechanisms for IP address space distribution on which the success
of the Internet has been founded and on which the global Internet community
relies for future operational stability and continued growth.
Internet
Number Resource Distribution
Internet number resource distribution is an engineering
function co-ordinated between Internet operators under consensus agreements.
The development and execution of address allocation principles are organised
on a regional level by four (shortly to be five) RIRs: APNIC, serving
the Asia-Pacific region; ARIN, serving Northern America, parts of the
Caribbean, and continental Africa south of the equator; LACNIC, serving
Latin America and portions of the Caribbean; and RIPE NCC, serving Europe,
the Middle East, Central Asia, and continental Africa north of the equator.
AfriNIC will soon be formally recognised as the fifth RIR, to manage Internet
number resources in Africa under an autonomous self-governing framework.
These RIRs are funded and governed by over 8000 organizations
worldwide, representing the users of the Internet number resources. Allocation
principles and procedures are developed in regional fora which are open
not only to the RIR members, but to all interested parties including Government.
This long standing, open policy-making structure
has been implemented since the early 1990s and has been a tremendous success.
The fairness and efficiency of Internet number distribution is very widely
recognised, as is the openness and accessibility of the associated allocation
principles. In particular this structure has demonstrated repeatedly that
it can adapt quickly to the rapid changes that take place in the Internet
environment.
Diversity
The RIRs recognise that today different national
environments feature a wide variety of models of regulation, public sector
activity, private sector investment profiles, participatory frameworks,
cultural considerations and technology deployment models. Such a broad
diversity of profile across national communities does not readily lend
itself to the uniform imposition of a particular administrative model
for network infrastructure elements. The current RIR system can and does
accommodate this diversity, while avoiding the inherent shortcomings of
a uniformly imposed public sector approach, based solely on national address
distribution models. It also avoids pitting the public and private sector
in direct competition at a regional or national level. Coordination functions
such as these are not enhanced by allowing the operation of competitive
markets to dictate polices and services. Where there is a strong coordination
component of the activity, in order to ensure address routability, aggregation,
fairness of access and ultimately considerations of viability of the Internet
itself, competitive supply practices tend to undermine the orderly operation
of responsible administration of such infrastructure elements.
The RIR system encompasses both private and public
sectors within its global framework. The RIR system as a whole has specifically
not mandated one model or the other, but has allowed regional and national
communities to determine what is in their best interests in terms of structure
of participation. For example, in several nations there are National Internet
Registries with direct public sector involvement. In some cases this is
a public sector activity, while in other cases this is a private sector
activity within a national context.
Therefore, there is no valid reason to impose a single
uniform administrative model upon each regional community that implicitly
scripts a leadership role to either the public or private sector. To impose
a level of uniformity to this sector at an international level by asserting
the primacy of participation of either the public or private sector is
not an accurate or helpful characterization of the Internet as a truly
international facility. Nor are there grounds to set up public and private
sector activities that engage in openly competitive frameworks for infrastructure
administrative services. The RIRs accurately reflect the diversity of
the international environment, and the outcome of their framework is a
stable administrative service that is performed efficiently and effectively,
and in which diversity is a strength and asset. The RIR system, with its
diversity of models for national community participation, is one of the
more eloquent expressions of today’s richly diverse environment.
IPv4 Address Space: Allocated Globally
According to Regional Needs
It is important to understand the issue of historical
allocation of IPv4 address space. The ITU memorandum refers to “geographic
imbalances and an excessive possession of the address space by early adopters”,
but recognises correctly that the current Regional Internet Registry system
has successfully addressed that problem. However since the historical
imbalance is sometimes described as a failing of the current system, this
issue will be addressed specifically.
During the 1980s and early 1990s, early adopters
of the Internet were able to receive IPv4 address space under the allocation
policies that existed at the time. These early adopter organizations were
allocated and often still hold many more addresses than they would be
allocated under present allocation principles, placing them in a relatively
advantaged position today. This enduring imbalance is not a result of
the current principles but rather a reflection that different allocation
principles were in place in the past. Those principles reflected certain
technological constraints of the time, and assumptions about the limited
function and future of the Internet itself, which together promoted a
relatively lax approach to address consumption.
Fortunately, technology has improved since the early
days of the Internet, as have the systems under which addresses are allocated.
Indeed, today’s Regional Internet Registry system was proposed in
1992 specifically to address the administrative problems evident at that
time, and is recognised widely as an outstandingly successful solution.
Today, it is clear that sufficient IPv4 addresses
are available to be allocated on a fair and equal basis to all users for
many years to come. Through the current system of IP address administration,
IP addresses are allocated according to immediate need wherever that need
is demonstrated, in accordance with well-known allocation principles.
The distribution of this global resource is organised in an efficient
and very widely accepted manner.
While there are many issues in the management of
IP address space, the transformation of IP addresses into a nationalised
management regime has never emerged as a relevant solution. On the contrary,
such a move is widely regarded as a significant step towards stockpiling
and unfair distribution of Internet number resources. Under the current
system, sufficient IPv4 addresses are available to all network users,
on a fair and equal basis. The distribution of this resource is organised
in an efficient and very widely accepted manner.
IPv6 Address Space Distribution
The ITU proposal is founded on the premise that transforming
IP addresses to a national resource will ensure that IPv6 distribution
would somehow avoid the problems that are allegedly experienced with IPv4
distribution.
Under the current distribution scheme IPv6 service
providers receive address space following current allocation principles,
established through open self-regulatory industry processes. These principles
have been developed not in isolation, but by building on the extensive
experience of developing the IPv4 system. They use the already established
and globally recognised framework of the Regional Internet Registries
for developing and executing the associated allocation principles. The
distribution of IPv6 address space is not only building on what has been
already developed, but is starting with a playing field which is level
from the outset. In addition, there is also allowance for future changes
in allocation principles.
The ITU memorandum proposes a new, independent and
unproven process for IPv6 address space distribution, based solely on
national authorities. This disregards the fact that IP addresses have
no national attributes and that there is no compelling reason for specific
national policies regarding their distribution. Unlike other number spaces
such as E.164, IP addresses are not structured along national boundaries.
IP addresses are also invisible to the Internet user, unlike E.164 numbers
that are visible to the user and thus also serve as "names".
Naming, addressing and routing are separate functions in the Internet.
Languages are visible in Internet domain names and a large part of the
domain name space is indeed structured along national boundaries. This
has led to the development and implementation of national policies through
appropriate local mechanisms. This works well because separate parts of
the Internet domain name space can be administered and operated totally
independently from each other. However this model does not apply to IP
addresses, which are useful because of their uniqueness and require global
coordination, which would be disrupted, not aided, by competition. While
competition is a good mechanism in many areas, it is hard to see how different
systems can compete meaningfully in the distribution of a global resource.
Conclusion
The RIRs observe that the ITU is proposing a model
of IP address space distribution that is based on a limited set of considerations
and has not adequately considered the need to ensure stable, fair and
consistent distribution of a global resource. The ITU proposal has no
means to guarantee stable mechanisms for IP address space distribution,
and for the benefit of the Internet (including the ITU’s own constituency),
we urge the ITU to carefully reconsider this proposal.
There are many issues within the area of what has
come to be known as "Internet Governance", particularly issues
of fairness and a level playing field on a global level that accommodates
public and private sector interests The Regional Internet Registry system
has evolved over more than a decade to become one of the successes in
this area. Internet number resource distribution is fair and accessible
to all. Its policy development process is open and transparent.
The NRO welcomes the opportunity to contribute to
this memorandum, and looks forward to further discussion with the ITU
TSB on these important matters.
Signed
NUMBER RESOURCE ORGANIZATION
_____________________________
Paul Wilson
Chair, Executive Council
ASIA PACIFIC NETWORK INFORMATION CENTRE
_____________________________
Paul Wilson
Director General
AMERICAN REGISTRY FOR INTERNET NUMBERS
_____________________________
Raymond A. Plzak
President and Chief Executive Officer
LATIN AMERICAN AND CARIBBEAN INTERNET ADDRESSES REGISTRY
_____________________________
Raul Echeberria
Executive Director CEO
RÉSEAUX IP EUROPÉENS NETWORK COORDINATION CENTRE
_____________________________
Axel Pawlik
Managing Director
|
