David,
One concern I have about the current 2007-01 draft is the lack of arguments opposing the proposal mentioned under the 'Rationale' section of the document. While many such arguments were raised and discussed extensively on this mailing list, the draft itself raises only one such argument and proceeds to immediately dismiss it.
ok, point noted, although I confess that it would have been more helpful if you had raised this before - 2007-01 has been around since June last year.
In the current draft, some of the following objections may still be relevant to varying extent:
- Given the diversity of legal systems the RIPE NCC service region, the success of contractually binding existing resource holders to a new contract and fee is uncertain, and might be the beginning of a long and expensive exercise in futility.
Possibly. Ultimately, the decision about whether or not the retroactive nature of the proposal will actually be put into practice is up to the RIPE NCC board, because that's an operational matter. My understanding is that the RIPE NCC board is taking legal advice on the matter, and if the legal advice is to stay away from the retroactive assignments clean-up, then that is probably what they will do. As regards process length, my understanding is that everyone in the RIPE NCC expects this to be long and probably troublesome. There is 16 years of accumulated detritus in the database, and cleaning it up is neither going to be cheap nor quick. The fee will be set using the normal RIPE NCC budgeting process. There will probably be some adjustment to the fee calculation model that is used for PA resource holders, but again that's operational.
- By attempting to levy a new fee on existing end users of directly assigned resources, RIPE NCC risks creating widespread dissent from these very same end users which had no voting right on this matter and were likely unaware of the proceedings of this WG; in the worst case scenario, this might result in end users utilizing resources regardless of their status in the WHOIS database.
I want a pony! What you're really pointing out is that people have got used to the idea that they were getting something for free and that they are going to whinge about this regime coming to an end. Unfortunately, the free model is broken - number resources cost money to manage and right now, other people are footing the bill for this management. It also creates an environment where PI addresses are actually a more attractive proposition than PA address space, which flies in the face of RIPE's current and past number resource management policies. Both of these issues are serious problems. 2007-01 requests that this model change and that PI resource holders begin to assume some of the responsibilities which they are not currently obliged to. Do I need to talk about rights and responsibilities being different sides of the same coin? Probably not, but it's relevant here. Resource hi-jacking out of contempt could happen, yes. But a PI resource database cleanup will probably help prevent other hijacking vectors. Overall, my gut feeling is that it will improve things. The bottom line is: there ain't no such thing as a free lunch. And much as I want a pony, I'm not going to get one. Actually, I'd prefer free multi-gig ethernet to my house instead of a pony and will gladly accept any offers for same. Please reply to the email address above; serious offers only, if you wouldn't mind.
- Previous experience (domain reg. world) suggests that by putting an explicit price tag on number resources, the "sponsoring LIR" approach in its currently presented form might result in the rise of "discount LIRs". These LIRs would process the bulk of the assignments with no accountability to keep costs low, turning direct assignments into a revenue source and laying waste to many potential benefits which could result from this proposal.
This could happen, yes - I don't believe that it's happened to any huge extent in other RIR catchment areas, but it's not an impossible scenario. Sponsoring LIRs will be charged for PI resources, probably at a different rate for end-users who wish to interface with the RIPE NCC directly. Call it retail vs. wholesale, if you wish, although those are probably not very good terms given the context here. The RIPE NCC does not have any authority to dictate to the sponsoring LIR what the price to the end-user should be, so there will be effectively an open market for sponsoring LIRs to charge what they want for acting as a sponsoring LIR. As there's lots of competition in the ISP marketplace, prices will tend to converge on the price that LIRs are charged. Probably discount LIRs will appear. If they do, so what? They will have to follow the same rules as anyone else. The RIPE NCC doesn't have the resources to micromanage 38000 resource allocations down to the last detail, and we need to acknowledge this (and if they did, they would be an appalling organisation to deal with). There is trust required here, and a realisation that while some abuse will occur, it should be minimised by appropriate means. But again, operational stuff.
- The issue of resource reclamation when resources fall into disuse can potentially be addressed at significantly lower cost and complexity through technological solutions similar to those employed by e-retail outfits for customer account management (automated verification of electronic and snail-mail contacts, IVR verification of phone contacts, regular re-verification).
Indeed, this is correct. However, your proposal doesn't deal with the problem that PI resource holders are getting a free lunch paid for by someone else. Conversely, there's nothing to stop the RIPE NCC from implementing direct PI assignments using something like this, but one way or another, money will be involved. Again, it's outside the scope of 2007-01 to specify to the NCC how to deal with the issue. I don't want to sound like I'm sweeping your concerns about implementation under the carpet by yacking out the "not my problem" line. But, this is the way that the RIPE NCC operates: policy is policy, and operations are operations. Ultimately, the implementation will be done by them and them alone, and given their track record in dealing with registration issues over the past 16 years, I'm pretty happy to see them being given a good degree of latitude to decide how best to implement the policy. After all, they know a lot more about how to manage this sort of stuff than I do. If it turns out that they do things that people don't like, then they will be complained at, which action has historically helped things to improve (e.g. at various stages, hostmaster turnaround times, complexity of forms, etc). There's nothing like a brightly flashing red LED to grab someone's attention. As part of this feedback process, it would be useful to get updates from the NCC at RIPE meetings about how the process turns out in practice. While this isn't the forum to dictate operational matters, that doesn't mean that people aren't interested. And again, given their past history, I would say that it's likely that we'll hear about it from time to time. There are lots of people in RIPE who take pride in their work, and there are few ways to express professional pride better than to tell others about what you do and why it's important to them. Nick