[arin-ppml] Draft Policy 2011-1 - Inter-RIR Transfers - Shepherd's Inquiry
Regarding "Draft Policy 2011-1: Inter-RIR Transfers"
and the proviso that:
"Address resources may be transferred.... in or out of the ARIN region
to those who demonstrate need and plan to deploy them for a networking
purpose within 3 months. Such transfers will take place between RIRs who
share compatible, needs-based policies on behalf of entities agreeing to
the transfer and which otherwise meet both RIR's policies. Transferred
resources will become part of the resource holdings of the recipient RIR
unless otherwise agreed by both RIRs."
I am opposed to inter-RIR transfer policies, including this one. Let me
mention just a few reasons why.
I. Resource Firebreak Issues.
In thinking about this and similar policies, consider where addresses would
likely come from and where addresses would probably go given current
circumstances (and assuming that all RIRs agreed to participate in the
RIRs with remaining IPv4 address resources ("supplier RIRs")
RIRs with a likely immediate-term demand for additional IPv4 addresses
-- RIPE NCC
Thus the flow of address space would thus likely be *from* the developing
nations of the southern hemisphere (except Australasia) *to* the developed
nations of the northern hemisphere.
Countries in the southern hemisphere (which have historically been handicapped
by the high price of connectivity) have just recently begun to see improved
fiber access and a resulting drop in market prices. With their large areas
and large populations, they will likely have a substantial demand for number
resources in most forseeable medium-term scenarios. If the critical resources
they will eventually require will have been "exported" piece meal to Asia,
Europe, or North America, our southern-hemisphere neighbors will find it hard
to realize their full potential as Internet citizens.
The existing region-based RIR system thus serves as a "firebreak" of sorts,
protecting each RIR's resources from being treated as one common comingled
pool that can be (effectively) drawn down in its entirity by any region
willing to do so.
I don't want to see that "firebreak," small though it may be, breached. I
think it serves an important purpose when it comes to protecting resources
in developing regions such as AFRINIC and LACNIC.
II. Additional Resources Should Not Be Allowed to Potential Feed Regions
with Unchecked Abuse Issues.
Some have also argued that RIRs vary substantially when it comes to
their interest in policing number resource misue and abuse. An interesting
exercise when it comes to measuring one dimension of that issue is to go to
Spamhaus and see how many SBL listings are associated with each of
the RIRs. At the time I checked just now:
I quote, "has far too many records to list. This ISP has an extremely
serious spam problem."
Although I've looked at a LOT of SBL listings over the years, this is
absolutely the first and ONLY time I've EVER seen a "too many to list"
response from the Spamhaus by-ISP SBL listings.
Thus, I would also oppose inter-RIR transfers if those transfers might
potentially serve to enable further messaging abuse by supplying "raw
materials" to areas where number resources are apparently experiencing
rampant abuse. (If all or many of those issues have been taken care of,
and Spamhaus is just running behind on removals, my apologies)
III. Tracking and Documenting Address Usage Becomes Harder.
Currently it is possible to track address usage because we know (at
a /8 granularity) which regions have a given block. If we suddenly
begin allowing /16s here and /19s there to be carved off and transfer
out or transfered in, our ability to track usage by region will quickly
be lost (or become a tiresome and highly granular bookkeeping exercise).
Moreover, IP whois currently relies on that assignment by /8s to
direct IP whois queries to an appropriate RIR whois server. If inter
region transfers are allowed, whois queries will now potentially need
to support still more redirection, and protection against whois
redirection loops will likely even become necessary. And do we want
the RIRs to need to update their whois to deal with (redirect) thousands
or tens of thousands of tiny blocks that may be transfered out of region?
Jeez, again, what a bookkeeping mess!
For all these and other reasons, I oppose inter-RIR transfers, including
the current proposed policy.
Thanks for considering these comments,
Disclaimer: all opinions expressed are strictly my own and do not
necessarily represent the opinion of any other organization or entity.