On 27 Oct 2025, at 16:12, Wade, Clara via address-policy-wg wrote:

Following the suggestion of the RIPE NCC, we are seeking early feedback on an upcoming policy proposal we currently have in draft status.

I have some observations to make, which I think will need attention
before or during the passage of the eventual proposal through the PDP.

• Language "proposal to clarify the non-transferability of legacy status"
  in draft seems inappropriate to me. This is an innovation; it should
  not be disguised as anything else. Perhaps "clarify the" should read
  "introduce declaration of".

• Making this declaration may be at odds with legacy-resource holders'
  understanding of the rights included in the original grant of the
  resources. If so, I believe that principled, as well as pragmatic
  arguments will be needed as a foundation for the proposal.

• As others have pointed out, care will be needed to find an
  appropriate balance between the advantage of unburdening the NCC,
  and the disadvantage of potentially losing accuracy.

• Decomposing the problem, along the lines Randy suggests, seems to be
  worth doing in order to simplify our discussions. He seems to me to
  have identified what I call "onboarding" and "transfer" as the main
  sub-problems.

  Prompted by the durations mentioned upthread corresponding to
  different kinds of transfer request, I suggest a slightly more
  detailed decomposition.

  • Onboarding (know your customer) of either or both of the intending
    donor and recipient of the transfer, unless they are already
    sufficiently known to the NCC;
  • Onboarding (proof of title) of the legacy resource to be
    transferred, if this is not already known to the NCC;
  • The actual transfer.

  It seems to me that the burdensome elements are the first and second
  ones mentioned.

I also have some disclosures to make as to my interest in this.

• Almost my entire career was spent in the employment of a legacy
  resource holder; I am still on their (pension) payroll.

• I was one of the co-authors of RIPE policy proposal 2012-07,
  accepted on 6 Feb 2014, saved as RIPE document RIPE-605,
  and subsequently obsoleted by RIPE document RIPE-639.

• For the time being, and until I have refreshed my understanding of
  the relevant existing RIPE policy proposals and documents, I reserve
  my personal position on this draft and on the eventual policy proposal.

I hope this helps.

Niall

---