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DOCUMENT ID: NRO18
15 November 2004
Introduction
On 21 October 2004, the Director of ITU TSB published
a memorandum, “ITU and Internet Governance” for public comment.
The text below is a summary of the Number Resource Organization’s
(NRO) public response on behalf of the Regional Internet Registries: APNIC,
ARIN, LACNIC and RIPE NCC. These Regional Internet Registries are funded
and governed by over 8,000 organizations worldwide, representing the users
of the Internet number resources
The full text of the Number Resource Organization’s
public response is available at:
http://www.nro.net/documents/nro17.html
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.
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.
More information
The full text of the Number Resource Organization’s
public response is available at:
http://www.nro.net/documents/nro17.html
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