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DOCUMENT ID: NRO19
15 February 2005
Name of the
paper: Draft
WGIG Issue Paper on the Administration of Internet Names and IP Addresses
(pdf)
1. General Comments
We appreciate the efforts that have been put into
the production of this draft document. It appears to be a useful first
step towards a comprehensive coverage of these issues in the final WGIG
reports. The fact that it was produced under remarkable time pressure
is reflected by a number of inconsistencies and factual errors, some of
which will be addressed in this comment.
We suggest that it is important to analyse the various
aspects of Internet management separately in order to fully address the
issues that are distinct to these areas. In addition, we propose that
there is also a need for a WGIG paper that deals specifically with the
overall coordination of the various, diverse aspects of Internet management.
(1)
We strongly agree with the comments from APNIC regarding
the need to separate the issues of IP address and DNS management and to
cover them in two distinct documents, or at the very least in two distinct
sections that fully cover the separate issues. There are fundamental differences
between these systems, which result in almost entirely distinct sets of
governance issues related to each. To deal with them at the same time
is counterproductive and contributes to the confusion regarding the technical
coordination and management of the two systems. There are several key
areas where there are significant differences which warrant the separation
of these two subjects.
a. Organization model.
1) Numbers are administered by not-for-profit, non-competitive
organizations (the Regional Internet Registries) which are deployed to
serve geographical regions. Fees are charged for services and not for
the numbers. The Regional Internet Registries function as stewards, husbanding
a finite resource. The ability of an entity to obtain number resources
is dependent on it establishing a need for the resource. Distribution
of the resource is not driven by the market.
2) Names are administered by both not-for-profit
and for-profit, competitive
organizations. Names organizations are distributed on a market basis,
where they compete for their share of the market. The ability of an entity
to obtain a name is dependent on its ability to pay and on occasion to
establish a legal claim to the name.
b. Policy Development.
1) Numbers are administered in accordance with policies
developed in bottom up policy fora in which the public sector, the private
sector, and civil societies participate. The fora are conducted via both
public meetings and e-mail discussion lists. There are no requirements
or pre-requisites for any person or entity to participate.
2) Names are administered in accordance with policies
that are evolved from general business principles, ethics and practices.
There are significant legal considerations involved, such as intellectual
property, which play a big part in the administration of names.
Consequently the two systems have divergent needs
and issues. While there may be some commonality between names and numbers
such as the use of the same terms, the terms often have different meanings.
The application of law, such as that dealing with privacy or spam, is
different in the two systems and can cause divergent outcomes when applied
in an identical manner for both names and numbers.
Thus names and numbers are two characteristically
different and distinct
enough systems to warrant being addressed as separate papers by the WGIG.
In the following notes we will highlight the major
concerns we have regarding the accuracy of the SWOT analysis in the WGIG
paper. We will focus on issues that are relevant to IP addressing.
2. The SWOT Analysis
We find examples throughout the SWOT analysis of
statements that have little or no connection with the observations made
earlier in the paper regarding the distributed nature of Internet operations.
There is a clear example of this in the “Weaknesses” section
which notes the need for a “common hierarchical structure”.
There is no analysis of whether such a hierarchical structure is appropriate
or what it might entail and there is no attempt to reconcile this statement
with earlier observations about the current, distributed nature of Internet
operations.
For the sake of clarity, the following sections will
comment on the statements in the SWOT analysis in the order they appear
in the WGIG paper.
3. Strengths
This section concludes with the following brief statement:
“The RIR system is also a successful self regulation model.”
It is important to note here that the current Regional
Internet Registry (RIR) system is a successful model of industry self-regulation
that predates the establishment of ICANN by more than seven years and
has developed independently from ICANN. The RIRs have been coordinating
on a global scale through the Number Resource Organization (NRO). The
NRO has signed a Memorandum of Understanding (MoU) with ICANN to establish
and define the tasks of the Address Supporting Organization. The existence
of this MoU documents the commitment of the RIRs and their communities
to ICANN as an embodiment of functioning, bottom-up, industry self-regulation.
The RIR system is open to all interested parties,
and includes the active participation of both public and private sector
bodies, as well as civil society. The process for developing IP address
related policies utilises open, public meetings and mailing lists. The
policy development process used in the RIR system is inclusive, transparent
and, most importantly in the context of the WGIG paper, accountable.
4. Weaknesses
In this section, there is reference to the “lack
of political and corporate accountability in relation to the administration
of Internet names and IP addresses, even though there are parts of the
system where accountability exists.” However, earlier in the document,
accountability is both observed and described. This is also another example
of the confusion generated by trying to tackle issues relating to Internet
names or IP addresses in the same paper. This is all the more evident
in the footnote that accompanies the above quotation which admits, “not
all do agree that there is a lack of accountability, especially when it
comes to the administration of IP addresses.”
The statements which call into question the accountability
of the technical coordination of IP address space distribution by the
RIRs have not presented any evidence, either direct or anecdotal, that
substantiate their claims. In fact the system is both accountable and
also extremely transparent. The policies that are used to manage the address
space are developed in open fora in which any party from the public sector,
private sector or civil societies are able to, and do, participate. The
execution of that policy is done through open, transparent procedures.
The governing boards of the RIRs are elected in open elections and minutes
of their meetings are publicly available on the RIRs’ websites.
The budgets of the RIRs are published and their financial reports are
audited.
This section also states that it is difficult “to
integrate public policy concerns in the considerations of the various
technical organizations.” This statement is not based on any of
the earlier observations, and is not applicable to the RIR model where
governments can actively participate so that public policy concerns are
included in the development of IP address policy.
5. Opportunities
The first paragraph of this section notes that “it
would seem opportune to develop principles for a broad framework of accountability,
that will be subscribed to by all organizations active in the area of
Internet Domain Names and IP addressing…” The preceding text
in the WGIG paper contains no detailed descriptions of what is deficient
in this area or what specifically needs to be addressed.
6. Threats
The first point in this section states that the “uncertainty
of the structure of the future administration of Internet names and IP
addresses and lack of global participation may result in the division
of the Internet into more than one ‘net’.” While this
uncertainty is assumed in the WGIG paper, it is not described anywhere.
This “uncertainty” needs to be specified in more detail for
any meaningful discussion to take place.
The second point in this section claims that the
“problem of spam, overloading the Internet, is one of the serious
and apparent threats to the DNS system.” This statement is entirely
untrue, as spam is not a threat to the DNS system. It rather is an application
level problem and has no discernible impact on the functioning of the
DNS system.
The third point in this section discusses “the
lack of transition from IPv4 to IPv6 and lack of the implementation of
IPv6, so that IP addresses in practice become a scarce resource in certain
parts of the world.” This assumed lack of transition is neither
described nor properly analysed. In fact, the RIRs currently see clear
signs of increased interest in IPv6 resulting in increased uptake as reflected
in the resource statistics available from the RIRs. There is also no mention
of how a change of Internet administration and co-ordination could affect
this issue.
On the topic of address “scarcity”, there
have been several comments which allude or directly state that there is
a scarcity of IP addresses. This is not the correct term to apply to the
available pool of IP addresses, whether they are IPv4 or IPv6. These resources
are not scarce. There is, however, a finite amount of them. One of the
principles guiding the administration of IP address space is conservation.
Conservation ensures that there will be addresses available for those
who need them when they need them. Even though there are less IPv4 addresses
than IPv6 addresses, recent studies have shown that IPv4 address space
should be available for those who need them for at least the next 20 years.
Similar stewardship is being practiced for IPv6 address space. Thus one
should not speak of the scarcity of IP addresses, but rather should speak
of them as finite resources, which through good stewardship will always
be available for anyone who needs them, when they need them.
The final point in this section states that the “largest
and most significant threat” at the moment is that the global Internet
infrastructure will fracture “almost inevitably along national boundaries
or regional blocks.” The reasons for this are neither described
nor analysed. Moreover, there is no analysis of how Internet administration
and coordination could contribute to such a fracture or help to prevent
it
7. Future WGIG Documents
The Number Resource Organization, on behalf
of the Regional Internet Registries, would be pleased to assist the WGIG
in any way to improve the draft documents so that they can be used as
a solid basis for further discussions of the WSIS. We would strongly recommend
that issues of IP address and DNS management be covered in distinct documents
or sections, and that the WGIG consider the creation of a new WGIG document
that includes an analysis of the overall coordination of diverse aspects
such as the Regional Internet Registries, name registries and root server
operations.
(1.) We suggest that this proposed
WGIG paper include an analysis of the coordination of diverse aspects
such as the Regional Internet Registries, name registries and root server
operations.
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