insight 

I wrote previously about the discussions starting on establishing trading markets as a way of dealing with the impending exhaustion of IPv4 addresses.  Well things have now moved on a bit and we have a policy proposal being discussed (proposal 2008-07) at RIPE that is the first key step to enabling a market in the RIPE region to form.  It doesn’t mention money but it does allow for simple address transfer between registered holders of IP addresses.

To save you having to look it up, this the key text being added:

Any LIR is allowed to re-allocate complete or partial blocks of IPv4 address space that were previously allocated to them by either the RIPE NCC or the IANA. Such address space must not contain any block that is assigned to an End User.

Address space may only be re-allocated to another LIR that is also a member of the RIPE NCC. The block that is to be re-allocated must not be smaller than the minimum allocation block size at the time of re-allocation. Demonstration of need for the address space by the receiving LIR to the RIPE NCC is not required during transfers.

Re-allocation must be reflected in the RIPE Database. This re-allocation may be on either a permanent or non-permanent basis.

LIRs that receive a re-allocation from another LIR cannot re-allocate complete or partial blocks of the same address space to another LIR within 24 months of receiving the re-allocation.

The re-allocation will be notified to the RIPE NCC, who will record the change of allocation. Please note that the LIR always remains responsible for the entire allocation it receives from the RIPE NCC until the re-allocation is transferred to another LIR or returned. The LIR must ensure that all policies are applied.

Re-allocated blocks will be signed to establish the current allocation owner.

Re-allocated blocks are no different from the allocations made directly by the RIPE NCC and so they must be used by the receiving LIR according to the policies described in this document.

A number of people have expressed support for the proposal but not ETNO, the influential voice of the European Telecoms industry.  We are another refusenik, for similar reasons.  Rather then go through them again, here is the text of the objection I wrote to the working group:

I do not support this proposal for the following reasons:

* It breaks the policy of providing addresses to those who need them in a
fair and non-discriminatory fashion because it allows LIRs to choose who
gets spare addresses for arbitrary and secret reasons rather than through
the open and transparent process of the RIR.

* It is discriminatory to those LIRs in developing countries (within this
RIR region) who have fewer IPv4 addresses than other countries for
historic reasons and will now have to pay considerably more for addresses
by buying them from other LIRs.  This will only exacerbate an already
difficult global position where some countries are pushing for a change in
the global management of the Internet driven by a perception of exclusion.

* It is only a partial solution to the problem.  Many LIRs believe that
much more can be achieved by a determined and well implemented policy on
reclaim/reuse.  However this policy only addresses the potential transfer
solution to the problem, not the potential reclaim/reuse solution.
Furthermore, it is likely that this policy, if implemented before a proper
reclaim/reuse policy will render such a policy unachievable and
unworkable.

* It will create a landrush of false or exaggerated allocation requests
from people who wish to profit by arbitrage, leading to far faster
exhaustion of IPv4 addresses.  In other words there will now be a
significant difference in the price that IP addresses can be ‘bought’ from
RIPE NCC compared to that at which they can be sold on the open market.
This difference in price, the arbitrage opportunity, will lead to an
influx of speculators who will work out how to play the system and so lead
to many more addresses being allocated than otherwise.

* It takes RIPE NCC into the business of a regulator of a secondary
market, which is something it has no expertise in and brings considerable
risk.  RIPE NCC has to develop into this role because the nature of the
proposal requires policing to check transfers have happened within the
rules.  However, with the potential for transfers to have commercial and
financial implications there is far greater possibility of costly and
complex challenges to RIPE NCCs decisions.  This in turns brings with it
the risks of scrutiny from competition authorities.

* It will lead to rapid degradation of the IPv4 LIR database and loss of
control for RIPE NCC in the registration of IPv4 addresses.  If LIR A
sells a block of IPv4 addresses to LIR B then the legal ownership is
adequately covered by the contract that exists between the two and so
there is no incentive to register the transfer with RIPE NCC other than
when peering with people that make strict use the LIR database.  Rival
databases, based around IPv4 trading exchanges, will spring up.

There is still until 9th July left to comment on this proposal and given just how important it is then if you have strong views one way or the other then now is that time to let the working group know.

The Security and Stability Advisory Committee (SSAC) of ICANN have reported the results of their investigation into Domain Name Front Running (DNFR).  The conclusion, after a pretty thorough analysis, concurs with our findings that there are no provable cases of DNFR.  It also highlights the major issue that there is widespread confusion amongst registrants as to how the domain name industry works and their expectations are very different from reality.

One other very interesting part of the report is the figures given for the volumes of certain lookups done in the .com and .net.  For example in July 2007 there were 3.9 billion  WHOIS lookups for .com and .net !

Yesterday ICANN announced that they are proposing to remove their five-day ‘Add Grace Period’ which previously allowed registrars to rectify errors when registering new domain names without cost. Due to serial abuse of this facility by speculators testing the profitability of domain names through advertising revenues, ICANN will instead debit the payment as soon as the domain name is registered.

Although this change will clearly deter tasters from registering high volumes of domains speculatively, it will also make the process of registering less flexible for registrars. It remains to be seen exactly how the new process will work, but it is probably safe to assume that if the registrar has to pay these costs upfront they will ultimately be passed to their customers.

When we took steps against domain tasting in August 2006, we decided to introduce limits on the number of domains a registrar could delete. Our limit for deletions to rectify spelling errors etc is five domains or 5% of the total number of domains registered but not yet invoiced (whichever is higher) but the limit for practices such as domain tasting is zero, and the limits form part of our registrar agreement, the formal contract that all our registrars sign up to. We believe this solution is neater, as it effectively counters the practice of domain tasting but at the same time allows some flexibility for registrars where genuine errors have occurred.

In a separate move, Google announced last week that they will start to monitor domain names that are repeatedly registered and dropped within the current five-day grace period, and exclude them from their AdSense program. Such a move would clearly strike at the heart of the problem. If tasters stop receiving revenues for pay-per-click ads associated with the domains they are testing, they will soon stop trying.

Both proposals have their merits, and it is encouraging to see that concerted efforts are being made from various sectors within the industry that could herald the beginning of the end of this practice.

We’ve just released a position paper on signing the root. There is quite a lot to this but I thought I would attempt to summarise the paper for those of you who don’t want to read the full seven pages.

Read more

I see that there have been a few stories in the press regarding ICANN investigating the practice of registering a domain name based on the search someone has done on that domain name. As far as we are aware this practice is not widespread in the UK. Read more

This is just a quick reminder that Nominet’s second consultation on corporate governance closes next Wednesday, 31 October. We currently have had only 16 responses. If you have any comments you would like to make about the proposals please do let us know by completing the questionnaire or emailing us governanceconsultation@nominet.org.uk.

On Thursday we held an interactive workshop about the key issues on Internet governance from a UK perspective. It was a surprisingly well-attended and really productive session. Several key messages emerged from the discussions which we will now be sharing alongside several examples of best practice in Internet governance from the UK at the next IGF in Rio in November. Read more

I noticed with interest that NASK, the .pl Polish registry has made an announcement regarding a domain name tasting service. Read more