Re: [address-policy-wg] 2014-02 New Policy Proposal (Allow IPv4 PI transfer)
Dear address-policy-wg, With such a policy in place, IP address broker needs to offers potential IP space buyers only a marginally lower price than the cost of being a LIR for the expected duration of use of the IPv4 PI space in question (and requesting this IP space from the last /8 or realizing an inter-LIR PA transfer) in order to create a perverse incentive for IPv4 address buyers to line the pockets of IP address brokers instead of stepping up and becoming members of the RIPE NCC. This policy appears to fail the most basic economic incentive test, and will in practice create a secondary and desirable 'asset class' from which IP transfer brokers benefit considerably more than the community as a whole. To deconstruct the arguments which purportedly support this proposal: a) "Currently the policy for PA and PI space isn’t the same and people don’t understand the difference between the various types of IP Space." Ignoring that this is a superfluous argument which goes in the face of nearly two decades of policy, this appears to argue that letting PI space be sold would somehow eliminate this distinction. This, of course, is disingenuous. If this is indeed the goal, a policy should be introduced to allow PI space to be converted into PA space and assigned to a LIR - this will enable its "transferability" and eliminate many of the concerns raised above by ensuring that all holders of "transferred" IPv4 space are first rate LIRs who contribute financially toward the operation of the RIPE NCC and fall under all obligations imposed on such. b) "There is already some trade in PI space, however it is not documented or registered, which doesn’t help to keep the registry updated." This is also disingenuous, as every IPv4 PI space holder has a contract with the sponsoring LIR (and indirectly, with the RIPE NCC). This LIR can, and should, regularly verify and update these details in cooperation with the registrant. c) "A lot of current PI space holders are more than happy to have their assignments re-assigned to other parties, but due to the current policy it is not possible. The same goes for the documentation provided to the RIPE NCC during mergers or acquisitions of infrastructure with PI space. Due to the current policy, some changes in company names are marked as mergers or acquisitions when they are actually a transfer of IP space with added documentation to make it look like an merger or acquisition of infrastructure." If a legitimate transfer has occurred as part of legitimate organizational restructuring, there is no disincentive to document it. The disincentive only exists if the registrant fears the transfer's legitimacy may be questioned, which is exactly the intention for non-transferable, end-user assigned PI space. Such transferred allocations could, and should, per current policy, be simply reclaimed. d) "We want to have an open and honest communication to the RIPE NCC from the community and we need to make sure that the registry is up to date, without having to fluff up the procedures, bend the rules and truth in communication to the RIPE NCC to be able to transfer the IP space." Alternatively, elements which "bend the rules and truth" could be identified, and, within reason, have their resources reclaimed. Certainly, such enforcement can never be perfect - but speed traps also do not catch 100% of speeding cars. With a few documented instances, this would create tremendous uncertainty and disincentive to engage in such practices from the buy side, as it will mean that any resources acquired in this manner may very suddenly get written off. e) "The goal of this policy change is to get PI space on-par with PA space in respect to the ability to transfer it." See (a). It seems very disingenuous to make PI and PA "equal for purposes of transferability" but maintain the distinction in all other aspects. To summarize, I strongly object to this policy in its current form. I concur that the mobility of IPv4 PI space toward those who value it most is desirable - on the condition that this mobility occurs as part of a wider reform to eliminate the distinction between PA and PI status of IPv4 resources. This should result in equitable burden for all resource holders toward the RIPE NCC instead of lining the pockets of IP address brokers by helping address space speculators which presently hoard IPv4 PI assignments against policy realize profits at the expense of the community. -- Respectfully yours, David Monosov
Hi David, On 17/04/14 22:02, David Monosov wrote:
Dear address-policy-wg,
With such a policy in place, IP address broker needs to offers potential IP space buyers only a marginally lower price than the cost of being a LIR for the expected duration of use of the IPv4 PI space in question (and requesting this IP space from the last /8 or realizing an inter-LIR PA transfer) in order to create a perverse incentive for IPv4 address buyers to line the pockets of IP address brokers instead of stepping up and becoming members of the RIPE NCC.
This policy appears to fail the most basic economic incentive test, and will in practice create a secondary and desirable 'asset class' from which IP transfer brokers benefit considerably more than the community as a whole. There is already a market of IP addresses. Nobody will care about the
color of the IP addresses once they will really need those numbers. > To deconstruct the arguments which purportedly support this proposal: > > a) "Currently the policy for PA and PI space isn’t the same and people don’t > understand the difference between the various types of IP Space." > > Ignoring that this is a superfluous argument which goes in the face of nearly > two decades of policy, this appears to argue that letting PI space be sold would > somehow eliminate this distinction. > > This, of course, is disingenuous. If this is indeed the goal, a policy should be > introduced to allow PI space to be converted into PA space and assigned to a LIR > - this will enable its "transferability" and eliminate many of the concerns > raised above by ensuring that all holders of "transferred" IPv4 space are first > rate LIRs who contribute financially toward the operation of the RIPE NCC and > fall under all obligations imposed on such. Are you saying that every holder of PI space should become an LIR before they could transfer it? Why would they pay €3600 (1600 for the yearly membership and 2000 for the sign-up fee) to the RIPE NCC when they could just do it in a contract?
b) "There is already some trade in PI space, however it is not documented or registered, which doesn’t help to keep the registry updated."
This is also disingenuous, as every IPv4 PI space holder has a contract with the sponsoring LIR (and indirectly, with the RIPE NCC). This LIR can, and should, regularly verify and update these details in cooperation with the registrant. let's think about this scenario..You are an LIR and you have 500 PI customers for which you are Sponsoring LIR, you will probably call the PI holder or send him an e-mail to verify that they still exist because at least once a year you will be paying a fee to the RIPE NCC for the
c) "A lot of current PI space holders are more than happy to have their assignments re-assigned to other parties, but due to the current policy it is not possible. The same goes for the documentation provided to the RIPE NCC during mergers or acquisitions of infrastructure with PI space. Due to the current policy, some changes in company names are marked as mergers or acquisitions when they are actually a transfer of IP space with added documentation to make it look like an merger or acquisition of infrastructure."
If a legitimate transfer has occurred as part of legitimate organizational restructuring, there is no disincentive to document it. The disincentive only exists if the registrant fears the transfer's legitimacy may be questioned, which is exactly the intention for non-transferable, end-user assigned PI space. Such transferred allocations could, and should, per current policy, be simply reclaimed. Who will give up their address space? The numbers are now considered assets and may be worth a buck or two... Or would you rather see PI never transferable and the RIPE NCC reclaiming it when it's no longer needed? d) "We want to have an open and honest communication to the RIPE NCC from the community and we need to make sure that the registry is up to date, without having to fluff up the procedures, bend the rules and truth in communication to the RIPE NCC to be able to transfer the IP space."
Alternatively, elements which "bend the rules and truth" could be identified, and, within reason, have their resources reclaimed. Certainly, such enforcement can never be perfect - but speed traps also do not catch 100% of speeding cars. Please come up with a proposal for this reclamation process; I'd really love to see it on the mailing list. With a few documented instances, this would create tremendous uncertainty and disincentive to engage in such practices from the buy side, as it will mean that any resources acquired in this manner may very suddenly get written off. So, once the RIPE NCC would reclaim something that was transferred without it's approval, it should tell the whole world? What about the
e) "The goal of this policy change is to get PI space on-par with PA space in respect to the ability to transfer it."
See (a). It seems very disingenuous to make PI and PA "equal for purposes of transferability" but maintain the distinction in all other aspects. There will no longer be many distinction between PI and PA. The only one I can think of is that PA can be further assigned. Maybe we should come up with a policy proposal to allow PI sub-assignments and remove the differences between PA and PI in that process? I only see a problem, the same one I faced with IPv6 unification, the fee unification. To summarize, I strongly object to this policy in its current form.
I concur that the mobility of IPv4 PI space toward those who value it most is desirable - on the condition that this mobility occurs as part of a wider reform to eliminate the distinction between PA and PI status of IPv4 resources. This policy proposal is the first step, you could try and make the next step and propose a bigger change. From my experience (just last year)
This should result in equitable burden for all resource holders toward the RIPE NCC instead of lining the pockets of IP address brokers by helping address space speculators which presently hoard IPv4 PI assignments against policy realize profits at the expense of the community. IP brokers can and are already helping others to get the address space
Or are you saying that PI holders should just give their PI to the friendly LIR which can then convert it to PA and transfer it? Who will make the buck then? Should the PI holder retain any rights once the address is transferred to the 'friendy' LIR or will the LIR be allowed to just transfer the new allocation to whoever they want? maintenance of that PI. If the PI holder says that he still has the same contact details and the IP addresses are still used, what resources will you invest to verify that the holder of the address space is still the one documented in the RIPE Database? - do not forget, you (as LIR) pay €50/year for the maintenance of the resource to the RIPE NCC and probably make (in average) €25-50/year/resource yourself... I think that bringing in the registry/database all the PI transfers that currently happen without proper registration/update is the most important goal which this proposal will achieve. privacy of the communication that the RIPE NCC is so proud of? How would you document such an instance? the community gets scared when you start talking about big changes (I was trying to unify IPv6 PA and PI, without even having all the conspiracy theory about brokers flying around my ears). These big changes will never work. they need by brokering PA transactions. Why do you think that enabling IPv4 PI transfers will be the benefit of only the Brokers? I think this policy proposal is in the benefit of us all: - cleaner registry - all holders of address space (PA or PI) can monetize it equally ;) - remove any temptations to 'bend the rules' PS: I hope you do know that a transfer can happen without brokers having to be involved. Actually, I am under the impression that most of the transfers (in numbers of transfers and not of IPs) have been made by LIRs mutually agreeing to the transfer via the Listing Service and not via brokers/escrow. When it comes to large blocks and a lot of money, some prefer to have a broker in the middle, for the safety of both parties.
-- Respectfully yours,
David Monosov
Kind regards, Elvis -- <http://v4escrow.net> Elvis Daniel Velea Chief Business Analyst Email: elvis@V4Escrow.net <mailto:elvis@v4escrow.net> US Phone: +1 (702) 475 5914 EU Phone: +3 (161) 458 1914 Recognised IPv4 Broker/Facilitator in: This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received this email in error, please notify the sender immediately and delete the original.Any other use of this email is strictly prohibited.
Dear address-policy-wg, Elvis, On 04/18/2014 12:59 AM, Elvis Daniel Velea wrote: > Hi David, > > On 17/04/14 22:02, David Monosov wrote: >> Dear address-policy-wg, >> >> With such a policy in place, IP address broker needs to offers potential IP >> space buyers only a marginally lower price than the cost of being a LIR for the >> expected duration of use of the IPv4 PI space in question (and requesting this >> IP space from the last /8 or realizing an inter-LIR PA transfer) in order to >> create a perverse incentive for IPv4 address buyers to line the pockets of IP >> address brokers instead of stepping up and becoming members of the RIPE NCC. >> >> This policy appears to fail the most basic economic incentive test, and will in >> practice create a secondary and desirable 'asset class' from which IP transfer >> brokers benefit considerably more than the community as a whole. > There is already a market of IP addresses. Nobody will care about the color of > the IP addresses once they will really need those numbers. I concur, which is why I don't see why any IP address buyer would have a problem with registering as a LIR and becoming part of the RIPE NCC with all that entails before receiving IPv4 space of any color. >> To deconstruct the arguments which purportedly support this proposal: >> >> a) "Currently the policy for PA and PI space isn’t the same and people don’t >> understand the difference between the various types of IP Space." >> >> Ignoring that this is a superfluous argument which goes in the face of nearly >> two decades of policy, this appears to argue that letting PI space be sold would >> somehow eliminate this distinction. >> >> This, of course, is disingenuous. If this is indeed the goal, a policy should be >> introduced to allow PI space to be converted into PA space and assigned to a LIR >> - this will enable its "transferability" and eliminate many of the concerns >> raised above by ensuring that all holders of "transferred" IPv4 space are first >> rate LIRs who contribute financially toward the operation of the RIPE NCC and >> fall under all obligations imposed on such. > Are you saying that every holder of PI space should become an LIR before they > could transfer it? > Why would they pay €3600 (1600 for the yearly membership and 2000 for the > sign-up fee) to the RIPE NCC when they could just do it in a contract? That is exactly what I am suggesting. Since getting new IPv4 PI space from the RIPE NCC is no longer possible, and since those IPv4 PI addresses were assigned specifically with the condition that they are used by a specific end user for numbering a specific infrastructure which they declared at the time of the request - there is no reason why existing IPv4 PI space assignees would suddenly find themselves in the possession of a valuable commodity to dispose of as they please when it is no longer of use to them in the original capacity of the assignment. There is no "just do it in a contract", this is explicitly against the terms set forth by both the PI assignment policies, and by the End User contract which every end user has signed. PI space transferred in this manner is in violation of the contract and is subject to revocation. There may be some lack of policing of this issue from the side of RIPE NCC, but that's just a question of time and will. The infrastructure, policy, and contractual basis are well established. > > Or are you saying that PI holders should just give their PI to the friendly LIR > which can then convert it to PA and transfer it? Who will make the buck then? > Should the PI holder retain any rights once the address is transferred to the > 'friendy' LIR or will the LIR be allowed to just transfer the new allocation to > whoever they want? >> b) "There is already some trade in PI space, however it is not documented or >> registered, which doesn’t help to keep the registry updated." >> >> This is also disingenuous, as every IPv4 PI space holder has a contract with the >> sponsoring LIR (and indirectly, with the RIPE NCC). This LIR can, and should, >> regularly verify and update these details in cooperation with the registrant. > let's think about this scenario..You are an LIR and you have 500 PI customers > for which you are Sponsoring LIR, you will probably call the PI holder or send > him an e-mail to verify that they still exist because at least once a year you > will be paying a fee to the RIPE NCC for the maintenance of that PI. If the PI > holder says that he still has the same contact details and the IP addresses are > still used, what resources will you invest to verify that the holder of the > address space is still the one documented in the RIPE Database? > - do not forget, you (as LIR) pay €50/year for the maintenance of the resource > to the RIPE NCC and probably make (in average) €25-50/year/resource yourself... Let us indeed think about this scenario. 2007-01 introduced a set of contractual specifics which the end user must agree to in order to continue holding an assignment. A model contract is available at http://www.ripe.net/lir-services/resource-management/independent-resources/independent-assignment-request-and-maintenance-agreement-1 If you review the items in article 4: - Terms a, b, and c specifically establish that the resources are to be used only by a specific user, for a specific purpose, and are never the property of the end user, and are non-transferable. - Term e requires specifically that the end user provides up to date information about the resource and end user. - Article 4.4 explicitly allows RIPE NCC to revoke assignments if these terms are not met. A variation of this contract including these terms is signed by every single PI holder. This means every LIR is already under the obligation to ensure compliance, and every end user is already subject to having the assigned resources revoked for violating the terms laid out in the contract. What the LIR chooses to charge in order to fulfill these obligations in overhead is completely at the discretion of the LIR. It stands to reason that as the scarcity of IPv4 addresses becomes more pressing, additional effort would be placed into auditing and resource reclamation by the RIPE NCC, and thus additional costs will be passed by LIRs to their customers to ensure on-going compliance - costs which customers will undoubtedly be willing to bear to avoid risking the loss of the assigned resource. > > I think that bringing in the registry/database all the PI transfers that > currently happen without proper registration/update is the most important goal > which this proposal will achieve. The existing contracts between the RIPE NCC, the LIR, and the End User already require this, and there is an explicit clause that enables revocation if this obligation is not met. >> c) "A lot of current PI space holders are more than happy to have their >> assignments re-assigned to other parties, but due to the current policy it is >> not possible. The same goes for the documentation provided to the RIPE NCC >> during mergers or acquisitions of infrastructure with PI space. Due to the >> current policy, some changes in company names are marked as mergers or >> acquisitions when they are actually a transfer of IP space with added >> documentation to make it look like an merger or acquisition of infrastructure." >> >> If a legitimate transfer has occurred as part of legitimate organizational >> restructuring, there is no disincentive to document it. The disincentive only >> exists if the registrant fears the transfer's legitimacy may be questioned, >> which is exactly the intention for non-transferable, end-user assigned PI space. >> Such transferred allocations could, and should, per current policy, be simply >> reclaimed. > Who will give up their address space? The numbers are now considered assets and > may be worth a buck or two... > Or would you rather see PI never transferable and the RIPE NCC reclaiming it > when it's no longer needed? Not everyone are quite as eager to throw years of policy work under a bus at the first sight of financial incentive. I have personally returned several PI assignments over the past few years under various hats. I'm positively sure I am not alone in this. >> d) "We want to have an open and honest communication to the RIPE NCC from the >> community and we need to make sure that the registry is up to date, without >> having to fluff up the procedures, bend the rules and truth in communication to >> the RIPE NCC to be able to transfer the IP space." >> >> Alternatively, elements which "bend the rules and truth" could be identified, >> and, within reason, have their resources reclaimed. Certainly, such enforcement >> can never be perfect - but speed traps also do not catch 100% of speeding cars. > Please come up with a proposal for this reclamation process; I'd really love to > see it on the mailing list. There is no need for this. The grounds for reclamation are already clearly outlined in article 4.4 of the contract signed by each end user as mentioned above. The rest is an operational matter. >> With a few documented instances, this would create tremendous uncertainty and >> disincentive to engage in such practices from the buy side, as it will mean that >> any resources acquired in this manner may very suddenly get written off. > So, once the RIPE NCC would reclaim something that was transferred without it's > approval, it should tell the whole world? What about the privacy of the > communication that the RIPE NCC is so proud of? How would you document such an > instance? Once the RIPE NCC has reclaimed something transferred without its approval, it can publish an aggregate statistics on the number of addresses revoked, perhaps as part of its annual report. This will not in any way infringe on anyone's privacy but serve as an obvious deterrent by demonstrating that this does, in fact, happen, when policy is blatantly disregarded. >> e) "The goal of this policy change is to get PI space on-par with PA space in >> respect to the ability to transfer it." >> >> See (a). It seems very disingenuous to make PI and PA "equal for purposes of >> transferability" but maintain the distinction in all other aspects. > There will no longer be many distinction between PI and PA. The only one I can > think of is that PA can be further assigned. Maybe we should come up with a > policy proposal to allow PI sub-assignments and remove the differences between > PA and PI in that process? I only see a problem, the same one I faced with IPv6 > unification, the fee unification. >> To summarize, I strongly object to this policy in its current form. >> >> I concur that the mobility of IPv4 PI space toward those who value it most is >> desirable - on the condition that this mobility occurs as part of a wider reform >> to eliminate the distinction between PA and PI status of IPv4 resources. > This policy proposal is the first step, you could try and make the next step and > propose a bigger change. From my experience (just last year) the community gets > scared when you start talking about big changes (I was trying to unify IPv6 PA > and PI, without even having all the conspiracy theory about brokers flying > around my ears). These big changes will never work. >> This should result in equitable burden for all resource holders toward the RIPE >> NCC instead of lining the pockets of IP address brokers by helping address space >> speculators which presently hoard IPv4 PI assignments against policy realize >> profits at the expense of the community. > IP brokers can and are already helping others to get the address space they need > by brokering PA transactions. Why do you think that enabling IPv4 PI transfers > will be the benefit of only the Brokers? > > I think this policy proposal is in the benefit of us all: > - cleaner registry > - all holders of address space (PA or PI) can monetize it equally ;) > - remove any temptations to 'bend the rules' > I think this policy will accomplish exactly two things: - Introduce a bureaucratic nightmare requiring the changing of all existing end user contracts, as what it proposes is a direct violation of the terms set out in article 4 of the model contract (and the contractual requirements the RIPE NCC imposed on LIRs who created their own end user contracts as part of 2007-01). - Reward those in the community who have chosen to hoard IPv4 PI assignments in instead of return them in blatant disregard of the policy they have agreed to during the initial assignment, and again upon signing the end user contract. Neither of these things is desirable. > PS: I hope you do know that a transfer can happen without brokers having to be > involved. Actually, I am under the impression that most of the transfers (in > numbers of transfers and not of IPs) have been made by LIRs mutually agreeing to > the transfer via the Listing Service and not via brokers/escrow. When it comes > to large blocks and a lot of money, some prefer to have a broker in the middle, > for the safety of both parties. >> -- >> Respectfully yours, >> >> David Monosov >> > Kind regards, > Elvis > -- > <http://v4escrow.net> > > > Elvis Daniel Velea > > > Chief Business Analyst > > Email: elvis@V4Escrow.net <mailto:elvis@v4escrow.net> > US Phone: +1 (702) 475 5914 > EU Phone: +3 (161) 458 1914 > > Recognised IPv4 Broker/Facilitator in: > > This message is for the designated recipient only and may contain privileged, > proprietary, or otherwise private information. If you have received this email > in error, please notify the sender immediately and delete the original.Any other > use of this email is strictly prohibited. > -- Respectfully yours, David Monosov
Dear David, everyone,
(sorry for the top-posting, it's going to be my conclusion in this thread)
what you are suggesting is to say... you want to sell your PI, pay
sign-up fee and one year membership to the RIPE NCC and then you can
sell/transfer it and close shop. This is already possible today...
I don't think your proposed way of action would be a better alternative
than the current policy proposal, it would just include an additional
hop preventing data accuracy. You can talk about contracts as much as
you want, these will never be enforced, nobody has the manpower and/or
the tools to enforce them. Not the LIR and not even the RIPE NCC.
The world is moving towards removing all the limitations imposed by
policy. I don't think adding your suggested limitation will help the
development of IPv4 policies.
my 2 cents,
Elvis
PS: I fully understand your reasoning and in a perfect world, all the
IPs not needed would return to the RIPE NCC for re-allocation.
Unfortunately, we do not live in a perfect world :(
On 18/04/14 02:17, David Monosov wrote:
> Dear address-policy-wg, Elvis,
>
> On 04/18/2014 12:59 AM, Elvis Daniel Velea wrote:
>> Hi David,
>>
>> On 17/04/14 22:02, David Monosov wrote:
>>> Dear address-policy-wg,
>>>
>>> With such a policy in place, IP address broker needs to offers potential IP
>>> space buyers only a marginally lower price than the cost of being a LIR for the
>>> expected duration of use of the IPv4 PI space in question (and requesting this
>>> IP space from the last /8 or realizing an inter-LIR PA transfer) in order to
>>> create a perverse incentive for IPv4 address buyers to line the pockets of IP
>>> address brokers instead of stepping up and becoming members of the RIPE NCC.
>>>
>>> This policy appears to fail the most basic economic incentive test, and will in
>>> practice create a secondary and desirable 'asset class' from which IP transfer
>>> brokers benefit considerably more than the community as a whole.
>> There is already a market of IP addresses. Nobody will care about the color of
>> the IP addresses once they will really need those numbers.
> I concur, which is why I don't see why any IP address buyer would have a problem
> with registering as a LIR and becoming part of the RIPE NCC with all that
> entails before receiving IPv4 space of any color.
>
>>> To deconstruct the arguments which purportedly support this proposal:
>>>
>>> a) "Currently the policy for PA and PI space isn’t the same and people don’t
>>> understand the difference between the various types of IP Space."
>>>
>>> Ignoring that this is a superfluous argument which goes in the face of nearly
>>> two decades of policy, this appears to argue that letting PI space be sold would
>>> somehow eliminate this distinction.
>>>
>>> This, of course, is disingenuous. If this is indeed the goal, a policy should be
>>> introduced to allow PI space to be converted into PA space and assigned to a LIR
>>> - this will enable its "transferability" and eliminate many of the concerns
>>> raised above by ensuring that all holders of "transferred" IPv4 space are first
>>> rate LIRs who contribute financially toward the operation of the RIPE NCC and
>>> fall under all obligations imposed on such.
>> Are you saying that every holder of PI space should become an LIR before they
>> could transfer it?
>> Why would they pay €3600 (1600 for the yearly membership and 2000 for the
>> sign-up fee) to the RIPE NCC when they could just do it in a contract?
> That is exactly what I am suggesting.
>
> Since getting new IPv4 PI space from the RIPE NCC is no longer possible, and
> since those IPv4 PI addresses were assigned specifically with the condition that
> they are used by a specific end user for numbering a specific infrastructure
> which they declared at the time of the request - there is no reason why existing
> IPv4 PI space assignees would suddenly find themselves in the possession of a
> valuable commodity to dispose of as they please when it is no longer of use to
> them in the original capacity of the assignment.
>
> There is no "just do it in a contract", this is explicitly against the terms set
> forth by both the PI assignment policies, and by the End User contract which
> every end user has signed. PI space transferred in this manner is in violation
> of the contract and is subject to revocation. There may be some lack of policing
> of this issue from the side of RIPE NCC, but that's just a question of time and
> will. The infrastructure, policy, and contractual basis are well established.
>
>> Or are you saying that PI holders should just give their PI to the friendly LIR
>> which can then convert it to PA and transfer it? Who will make the buck then?
>> Should the PI holder retain any rights once the address is transferred to the
>> 'friendy' LIR or will the LIR be allowed to just transfer the new allocation to
>> whoever they want?
>>> b) "There is already some trade in PI space, however it is not documented or
>>> registered, which doesn’t help to keep the registry updated."
>>>
>>> This is also disingenuous, as every IPv4 PI space holder has a contract with the
>>> sponsoring LIR (and indirectly, with the RIPE NCC). This LIR can, and should,
>>> regularly verify and update these details in cooperation with the registrant.
>> let's think about this scenario..You are an LIR and you have 500 PI customers
>> for which you are Sponsoring LIR, you will probably call the PI holder or send
>> him an e-mail to verify that they still exist because at least once a year you
>> will be paying a fee to the RIPE NCC for the maintenance of that PI. If the PI
>> holder says that he still has the same contact details and the IP addresses are
>> still used, what resources will you invest to verify that the holder of the
>> address space is still the one documented in the RIPE Database?
>> - do not forget, you (as LIR) pay €50/year for the maintenance of the resource
>> to the RIPE NCC and probably make (in average) €25-50/year/resource yourself...
> Let us indeed think about this scenario. 2007-01 introduced a set of contractual
> specifics which the end user must agree to in order to continue holding an
> assignment. A model contract is available at
> http://www.ripe.net/lir-services/resource-management/independent-resources/independent-assignment-request-and-maintenance-agreement-1
>
> If you review the items in article 4:
>
> - Terms a, b, and c specifically establish that the resources are to be used
> only by a specific user, for a specific purpose, and are never the property of
> the end user, and are non-transferable.
>
> - Term e requires specifically that the end user provides up to date information
> about the resource and end user.
>
> - Article 4.4 explicitly allows RIPE NCC to revoke assignments if these terms
> are not met.
>
> A variation of this contract including these terms is signed by every single PI
> holder. This means every LIR is already under the obligation to ensure
> compliance, and every end user is already subject to having the assigned
> resources revoked for violating the terms laid out in the contract.
>
> What the LIR chooses to charge in order to fulfill these obligations in overhead
> is completely at the discretion of the LIR. It stands to reason that as the
> scarcity of IPv4 addresses becomes more pressing, additional effort would be
> placed into auditing and resource reclamation by the RIPE NCC, and thus
> additional costs will be passed by LIRs to their customers to ensure on-going
> compliance - costs which customers will undoubtedly be willing to bear to avoid
> risking the loss of the assigned resource.
>
>> I think that bringing in the registry/database all the PI transfers that
>> currently happen without proper registration/update is the most important goal
>> which this proposal will achieve.
> The existing contracts between the RIPE NCC, the LIR, and the End User already
> require this, and there is an explicit clause that enables revocation if this
> obligation is not met.
>
>>> c) "A lot of current PI space holders are more than happy to have their
>>> assignments re-assigned to other parties, but due to the current policy it is
>>> not possible. The same goes for the documentation provided to the RIPE NCC
>>> during mergers or acquisitions of infrastructure with PI space. Due to the
>>> current policy, some changes in company names are marked as mergers or
>>> acquisitions when they are actually a transfer of IP space with added
>>> documentation to make it look like an merger or acquisition of infrastructure."
>>>
>>> If a legitimate transfer has occurred as part of legitimate organizational
>>> restructuring, there is no disincentive to document it. The disincentive only
>>> exists if the registrant fears the transfer's legitimacy may be questioned,
>>> which is exactly the intention for non-transferable, end-user assigned PI space.
>>> Such transferred allocations could, and should, per current policy, be simply
>>> reclaimed.
>> Who will give up their address space? The numbers are now considered assets and
>> may be worth a buck or two...
>> Or would you rather see PI never transferable and the RIPE NCC reclaiming it
>> when it's no longer needed?
> Not everyone are quite as eager to throw years of policy work under a bus at the
> first sight of financial incentive. I have personally returned several PI
> assignments over the past few years under various hats. I'm positively sure I am
> not alone in this.
>
>>> d) "We want to have an open and honest communication to the RIPE NCC from the
>>> community and we need to make sure that the registry is up to date, without
>>> having to fluff up the procedures, bend the rules and truth in communication to
>>> the RIPE NCC to be able to transfer the IP space."
>>>
>>> Alternatively, elements which "bend the rules and truth" could be identified,
>>> and, within reason, have their resources reclaimed. Certainly, such enforcement
>>> can never be perfect - but speed traps also do not catch 100% of speeding cars.
>> Please come up with a proposal for this reclamation process; I'd really love to
>> see it on the mailing list.
> There is no need for this. The grounds for reclamation are already clearly
> outlined in article 4.4 of the contract signed by each end user as mentioned
> above. The rest is an operational matter.
>
>>> With a few documented instances, this would create tremendous uncertainty and
>>> disincentive to engage in such practices from the buy side, as it will mean that
>>> any resources acquired in this manner may very suddenly get written off.
>> So, once the RIPE NCC would reclaim something that was transferred without it's
>> approval, it should tell the whole world? What about the privacy of the
>> communication that the RIPE NCC is so proud of? How would you document such an
>> instance?
> Once the RIPE NCC has reclaimed something transferred without its approval, it
> can publish an aggregate statistics on the number of addresses revoked, perhaps
> as part of its annual report.
>
> This will not in any way infringe on anyone's privacy but serve as an obvious
> deterrent by demonstrating that this does, in fact, happen, when policy is
> blatantly disregarded.
>
>>> e) "The goal of this policy change is to get PI space on-par with PA space in
>>> respect to the ability to transfer it."
>>>
>>> See (a). It seems very disingenuous to make PI and PA "equal for purposes of
>>> transferability" but maintain the distinction in all other aspects.
>> There will no longer be many distinction between PI and PA. The only one I can
>> think of is that PA can be further assigned. Maybe we should come up with a
>> policy proposal to allow PI sub-assignments and remove the differences between
>> PA and PI in that process? I only see a problem, the same one I faced with IPv6
>> unification, the fee unification.
>>> To summarize, I strongly object to this policy in its current form.
>>>
>>> I concur that the mobility of IPv4 PI space toward those who value it most is
>>> desirable - on the condition that this mobility occurs as part of a wider reform
>>> to eliminate the distinction between PA and PI status of IPv4 resources.
>> This policy proposal is the first step, you could try and make the next step and
>> propose a bigger change. From my experience (just last year) the community gets
>> scared when you start talking about big changes (I was trying to unify IPv6 PA
>> and PI, without even having all the conspiracy theory about brokers flying
>> around my ears). These big changes will never work.
>>> This should result in equitable burden for all resource holders toward the RIPE
>>> NCC instead of lining the pockets of IP address brokers by helping address space
>>> speculators which presently hoard IPv4 PI assignments against policy realize
>>> profits at the expense of the community.
>> IP brokers can and are already helping others to get the address space they need
>> by brokering PA transactions. Why do you think that enabling IPv4 PI transfers
>> will be the benefit of only the Brokers?
>>
>> I think this policy proposal is in the benefit of us all:
>> - cleaner registry
>> - all holders of address space (PA or PI) can monetize it equally ;)
>> - remove any temptations to 'bend the rules'
>>
> I think this policy will accomplish exactly two things:
>
> - Introduce a bureaucratic nightmare requiring the changing of all existing end
> user contracts, as what it proposes is a direct violation of the terms set out
> in article 4 of the model contract (and the contractual requirements the RIPE
> NCC imposed on LIRs who created their own end user contracts as part of 2007-01).
>
> - Reward those in the community who have chosen to hoard IPv4 PI assignments in
> instead of return them in blatant disregard of the policy they have agreed to
> during the initial assignment, and again upon signing the end user contract.
>
> Neither of these things is desirable.
>
>> PS: I hope you do know that a transfer can happen without brokers having to be
>> involved. Actually, I am under the impression that most of the transfers (in
>> numbers of transfers and not of IPs) have been made by LIRs mutually agreeing to
>> the transfer via the Listing Service and not via brokers/escrow. When it comes
>> to large blocks and a lot of money, some prefer to have a broker in the middle,
>> for the safety of both parties.
>>> --
>>> Respectfully yours,
>>>
>>> David Monosov
>>>
>> Kind regards,
>> Elvis
>>
> --
>
> Respectfully yours,
>
> David Monosov
>
--
<http://v4escrow.net>
Elvis Daniel Velea
Chief Business Analyst
Email: elvis@V4Escrow.net <mailto:elvis@v4escrow.net>
US Phone: +1 (702) 475 5914
EU Phone: +3 (161) 458 1914
Recognised IPv4 Broker/Facilitator in:
This message is for the designated recipient only and may contain
privileged, proprietary, or otherwise private information. If you have
received this email in error, please notify the sender immediately and
delete the original.Any other use of this email is strictly prohibited.
Hi Dave, First of all thanks for your lengthy response and let me reply on it.
With such a policy in place, IP address broker needs to offers potential IP space buyers only a marginally lower price than the cost of being a LIR for the expected duration of use of the IPv4 PI space in question (and requesting this IP space from the last /8 or realizing an inter-LIR PA transfer) in order to create a perverse incentive for IPv4 address buyers to line the pockets of IP address brokers instead of stepping up and becoming members of the RIPE NCC.
Brokers don't own IP address. Same as that your house if you sell it, will never transfer ownership into the hands of the house broker, IP addresses are transferred between offering and receiving parties. The broker doesn't set the price, the offering party decides what the price is and has the final say if they want to agree on a bid that the receiving party is making.
This policy appears to fail the most basic economic incentive test, and will in practice create a secondary and desirable 'asset class' from which IP transfer brokers benefit considerably more than the community as a whole.
This policy isn't about economic incentives. I don't hold PI space, although I have a lot of customers that do. The policy goal is to provide a way to officially register PI transfer (which are already being done) to be correctly reflected into the registry in order to keep the registry accurate.
To deconstruct the arguments which purportedly support this proposal:
a) "Currently the policy for PA and PI space isn't the same and people don't understand the difference between the various types of IP Space."
Ignoring that this is a superfluous argument which goes in the face of nearly two decades of policy, this appears to argue that letting PI space be sold would somehow eliminate this distinction.
This, of course, is disingenuous. If this is indeed the goal, a policy should be introduced to allow PI space to be converted into PA space and assigned to a LIR - this will enable its "transferability" and eliminate many of the concerns raised above by ensuring that all holders of "transferred" IPv4 space are first rate LIRs who contribute financially toward the operation of the RIPE NCC and fall under all obligations > imposed on such.
Not all are created equal ... not everyone who has PI space or want PI space (and not PA space due to the requirement of becoming a member to that scary group of internet hippies that talk about bits and bytes or other legal reasons.. and have secret meeting with people attending like Randy Bush, yourself or Job Snijders ... ). Some entities can't, due to legal restrictions, can't become a part of a membership association ... So their only option is to either obtain PI space or ERX space. And PI space is the only of those 2 that is non-transferrable currently. Asking my customers to hand over their PI space into our LIR, would make us the owner .. Asking them to become an LIR themselves, import the PI space and convert the space to PA, is just a detour, without any added value to the parties involved .. The offering party, the receiving party, RIPE ... We are trying to make things easier .. and accurate ...
b) "There is already some trade in PI space, however it is not documented or registered, which doesn't help to keep the registry updated."
This is also disingenuous, as every IPv4 PI space holder has a contract with the sponsoring LIR (and indirectly, with the RIPE NCC). This LIR can, and should, regularly verify and update these details in cooperation with the registrant.
c) "A lot of current PI space holders are more than happy to have their assignments re-assigned to other parties, but due to the current policy it is not possible. The same goes for the documentation provided to the RIPE NCC during mergers or acquisitions of infrastructure with PI space. Due to the current policy, some changes in company names are marked as mergers or acquisitions when
There are a few exceptions, but can you name me 10 LIR's out of the 10.000 which have more than 10 PI objects .. all documents approved and which do regular (once every 2 years ?) checks with their customers if their PI contracts are up to date ? I think that you might need to take of your pink glasses to this world ... We both go a long way back and I have you in high regards, but your view to this is too optimistic imho. I've seen documents been signed between 2 companies as side letters because they wanted to transfer the PI space and policy didn't let them ... I've been asked by interested parties who were ready to sign on the dotted line to purchase IP space and asked me for a second pair of eyes before they did.. And people have no idea, no clue. ( No offence .. it is my personal observation ) We spend a LOT of time explaining to customers the differences between the various types of IP space if they ask us what the status is if they want to purchase of transfer IP space. they are actually a transfer of IP space with added documentation to make it look like an merger
or acquisition of infrastructure."
If a legitimate transfer has occurred as part of legitimate organizational restructuring, there is no disincentive to document it. The disincentive only exists if the registrant fears the transfer's legitimacy may be questioned, which is exactly the intention for non-transferable, end-user assigned PI space. Such transferred allocations could, and should, per current policy, be simply reclaimed.
d) "We want to have an open and honest communication to the RIPE NCC from
Simply reclaimed ... that doesn't happen .. as it would simply go to the pool, while there are people that are currently offering money for the space ..Either in currently non-approved sales or long term leases etc. None of them are correctly documented in the registry ... Which is the end-goal .. to have a proper registry of who the current holder and user is.. If people are not properly registered in the RIPE Registry with the space they have, they will never be able to certify their resources under RPKI for instance .. as the maintainers don't match, the legitimate holder isn't correct etc etc. The long-term goal is to have the registry correctly updated, (fair) distribution isn't a role or goal of RIPE anymore. The market will deal with that themselves. the community and we need to make sure that the registry is up to date, without having to fluff up the procedures, bend the rules and truth in communication to the
RIPE NCC to be able to transfer the IP space."
Alternatively, elements which "bend the rules and truth" could be identified, and, within reason, have their resources reclaimed. Certainly, such enforcement can never be perfect - but speed traps also do not catch 100% of speeding cars. With a few documented instances, this would create tremendous uncertainty and disincentive to engage in such practices from the buy side, as it will mean that any resources acquired in this manner may very suddenly get written off.
The RIPE NCC and her staff isn't the internet police .. and the policies should reflect the current status ... Which is to be able to maintain a proper Internet Resource Registry. There is currently no requirement anymore to document need or documentation requirement anymore .. The idea that fair distribution is still in place is obsolete. There is currently a reservation for new LIR's that they can obtain a single /22 via the NCC, but they can't get more space. There are still some checks which the NCC will do even with this policy in place, to see if the original (legal) documentation to which the PI was provided was correct at the moment of assignment. But for the rest, the process should be fairly similar as with the current PA Transfers.
e) "The goal of this policy change is to get PI space on-par with PA space in respect to the ability to transfer it." See (a). It seems very disingenuous to make PI and PA "equal for purposes of transferability" but maintain the distinction in all other aspects.
If we would work around this via the loop-hole you suggested, import the PI space into an LIR and transfer it to PA and then transfer the space.. how would that make it different to what we are proposing ? The proposed proposal to allow PI space to be transferred will make it a lot easier.
To summarize, I strongly object to this policy in its current form.
I concur that the mobility of IPv4 PI space toward those who value it most is desirable - on the condition that this mobility occurs as part of a wider reform to eliminate the distinction between PA and PI status of IPv4 resources.
This should result in equitable burden for all resource holders toward the RIPE NCC instead of lining the pockets of IP address brokers by helping address space speculators which presently hoard IPv4 PI assignments against policy realize profits at the expense of the community.
Your missing the point Dave. People who hoarded are not brokers, brokers make a fee on a transaction ... Your so called hoarders are offering parties, but I doubt that you can show in numbers, a substantial number of hoarders as you call them, that would make a substantial amount of money which would justify not doing the policy and not allow a proper registration in the registry for those that have legitimate reasons. Regards, Erik Bais
Hi! Thank you for your extensive and thoughtful reply; I've expanded on several of these points already in my reply to Elvis, who also contributed a few thoughtful comments, but here are a few additional notes: On 04/18/2014 12:24 PM, Erik Bais wrote:
Hi Dave,
First of all thanks for your lengthy response and let me reply on it.
With such a policy in place, IP address broker needs to offers potential IP space buyers only a marginally lower price than the cost of being a LIR for the expected duration of use of the IPv4 PI space in question (and requesting this IP space from the last /8 or realizing an inter-LIR PA transfer) in order to create a perverse incentive for IPv4 address buyers to line the pockets of IP address brokers instead of stepping up and becoming members of the RIPE NCC.
Brokers don't own IP address. Same as that your house if you sell it, will never transfer ownership into the hands of the house broker, IP addresses are transferred between offering and receiving parties. The broker doesn't set the price, the offering party decides what the price is and has the final say if they want to agree on a bid that the receiving party is making.
By changing the status of PI to transferable, an incentive is created for brokers to identify existing PI holders willing to sell assignments, and match them with the highest bidder independently of the RIPE NCC and the RIPE NCC listing service - as that service presently only deals with PA transfers between LIRs. Additionally, since neither the seller not the buyer are required, under this policy, to be LIRs, a "friendly LIR" (once again, presumably, the broker) is required to facilitate the transfer vis-a-vis the RIPE NCC, while the RIPE NCC sees nothing but added administrative burden, the cost of which is spread between paying LIRs which were no part of this transaction nor benefited from it in any way. I'm all in favor of allowing existing PI holders to become LIRs themselves and transfer the space from PI to PA status, at which point it will fall under existing rules, fees, listing structure, etc; I see no reason to create an extra "asset class" with custodial fees of 50 EUR/year (instead of 2,000 EUR/year for a LIR) and encourage PI space to be bought as a speculative investment with the RIPE NCC provided a very accurate registrant information of the buyer, and a completely fabricated infrastructure which justifies a non-existent "need".
This policy appears to fail the most basic economic incentive test, and will in practice create a secondary and desirable 'asset class' from which IP transfer brokers benefit considerably more than the community as a whole.
This policy isn't about economic incentives. I don't hold PI space, although I have a lot of customers that do. The policy goal is to provide a way to officially register PI transfer (which are already being done) to be correctly reflected into the registry in order to keep the registry accurate.
There is no reason for a way to officially register a PI transfer to exist because a PI transfer is a non-existent construct. PI space, by policy, has been designed to be specifically assigned to a single end user and a specific infrastructure, and returned once this ceases to be the case.
To deconstruct the arguments which purportedly support this proposal:
a) "Currently the policy for PA and PI space isn't the same and people don't understand the difference between the various types of IP Space."
Ignoring that this is a superfluous argument which goes in the face of nearly two decades of policy, this appears to argue that letting PI space be sold would somehow eliminate this distinction.
This, of course, is disingenuous. If this is indeed the goal, a policy should be introduced to allow PI space to be converted into PA space and assigned to a LIR - this will enable its "transferability" and eliminate many of the concerns raised above by ensuring that all holders of "transferred" IPv4 space are first rate LIRs who contribute financially toward the operation of the RIPE NCC and fall under all obligations > imposed on such.
Not all are created equal ... not everyone who has PI space or want PI space (and not PA space due to the requirement of becoming a member to that scary group of internet hippies that talk about bits and bytes or other legal reasons.. and have secret meeting with people attending like Randy Bush, yourself or Job Snijders ... ). Some entities can't, due to legal restrictions, can't become a part of a membership association ... So their only option is to either obtain PI space or ERX space. And PI space is the only of those 2 that is non-transferrable currently. Asking my customers to hand over their PI space into our LIR, would make us the owner .. Asking them to become an LIR themselves, import the PI space and convert the space to PA, is just a detour, without any added value to the parties involved .. The offering party, the receiving party, RIPE ... We are trying to make things easier .. and accurate ...
Becoming a LIR to receive any additional IPv4 assignments, in any form, is a fair and balanced requirement which puts everyone seeking IPv4 address space on equal footing. The shortage of IPv4 space does not disproportionately affect end users, why would they enjoy a different set of rules and different price card? In fact, it would be easier to argue that ISPs (which sell services to end users) have a much stronger incentive to achieve optimal utilization of address space as it directly contributes to their revenue, whereas an end user that acquired an assignment and paid it in full has no further incentive in regards to efficient use as the end user's business outcome may have no direct relation to efficient IPv4 address space utilization. There already are exemptions carved out for organizations for which this is not an option for legal/independence reasons, and simply adding RIPE NCC direct assignees as PA transfer recipient candidates solves this problem instantly.
b) "There is already some trade in PI space, however it is not documented or registered, which doesn't help to keep the registry updated."
This is also disingenuous, as every IPv4 PI space holder has a contract with the sponsoring LIR (and indirectly, with the RIPE NCC). This LIR can, and should, regularly verify and update these details in cooperation with the registrant.
There are a few exceptions, but can you name me 10 LIR's out of the 10.000 which have more than 10 PI objects .. all documents approved and which do regular (once every 2 years ?) checks with their customers if their PI contracts are up to date ? I think that you might need to take of your pink glasses to this world ... We both go a long way back and I have you in high regards, but your view to this is too optimistic imho.
Seeing how we've managed to get tens of thousands of independent resource holders to sign an end user agreement, none of this seems like "mission impossible", it just requires will and focus - both of which are not currently targeted at curtailing this behavior. When 2007-01 came around, I was equally sure that the situation is hopeless, and the level of involvement it requires from both LIRs and PI holders is impossible. Yet here we are.
I've seen documents been signed between 2 companies as side letters because they wanted to transfer the PI space and policy didn't let them ... I've been asked by interested parties who were ready to sign on the dotted line to purchase IP space and asked me for a second pair of eyes before they did.. And people have no idea, no clue. ( No offence .. it is my personal observation ) We spend a LOT of time explaining to customers the differences between the various types of IP space if they ask us what the status is if they want to purchase of transfer IP space.
That's perfectly fine. The answer is "no", current policy does not allow PI transfers, you do not own these resources, and you should let them be reclaimed by the RIPE NCC if they are no longer in use. As a LIR, you should know this and be able to communicate it with conviction. You may charge consulting fees in the process ;-)
c) "A lot of current PI space holders are more than happy to have their assignments re-assigned to other parties, but due to the current policy it is not possible. The same goes for the documentation provided to the RIPE NCC during mergers or acquisitions of infrastructure with PI space. Due to the current policy, some changes in company names are marked as mergers or acquisitions when they are actually a transfer of IP space with added documentation to make it look like an merger or acquisition of infrastructure."
If a legitimate transfer has occurred as part of legitimate organizational restructuring, there is no disincentive to document it. The disincentive only exists if the registrant fears the transfer's legitimacy may be questioned, which is exactly the intention for non-transferable, end-user assigned PI space. Such transferred allocations could, and should, per current policy, be simply reclaimed.
Simply reclaimed ... that doesn't happen .. as it would simply go to the pool, while there are people that are currently offering money for the space ..Either in currently non-approved sales or long term leases etc.
None of them are correctly documented in the registry ... Which is the end-goal .. to have a proper registry of who the current holder and user is..
As I mentioned in my mail to Elvis, this can be mostly rectified by creating an effective deterrent.
If people are not properly registered in the RIPE Registry with the space they have, they will never be able to certify their resources under RPKI for instance .. as the maintainers don't match, the legitimate holder isn't correct etc etc. The long-term goal is to have the registry correctly updated, (fair) distribution isn't a role or goal of RIPE anymore. The market will deal with that themselves.
d) "We want to have an open and honest communication to the RIPE NCC from the community and we need to make sure that the registry is up to date, without having to fluff up the procedures, bend the rules and truth in communication to the RIPE NCC to be able to transfer the IP space."
Alternatively, elements which "bend the rules and truth" could be identified, and, within reason, have their resources reclaimed. Certainly, such enforcement can never be perfect - but speed traps also do not catch 100% of speeding cars. With a few documented instances, this would create tremendous uncertainty and disincentive to engage in such practices from the buy side, as it will mean that any resources acquired in this manner may very suddenly get written off.
The RIPE NCC and her staff isn't the internet police .. and the policies should reflect the current status ... Which is to be able to maintain a proper Internet Resource Registry. There is currently no requirement anymore to document need or documentation requirement anymore .. The idea that fair distribution is still in place is obsolete. There is currently a reservation for new LIR's that they can obtain a single /22 via the NCC, but they can't get more space. There are still some checks which the NCC will do even with this policy in place, to see if the original (legal) documentation to which the PI was provided was correct at the moment of assignment. But for the rest, the process should be fairly similar as with the current PA Transfers.
e) "The goal of this policy change is to get PI space on-par with PA space in respect to the ability to transfer it." See (a). It seems very disingenuous to make PI and PA "equal for purposes of transferability" but maintain the distinction in all other aspects.
If we would work around this via the loop-hole you suggested, import the PI space into an LIR and transfer it to PA and then transfer the space.. how would that make it different to what we are proposing ? The proposed proposal to allow PI space to be transferred will make it a lot easier.
A PI->PA conversion (and subsequent transition to another LIR) will assure that anyone who receives IPv4 resources in any form from the moment the last /8 policy kicked in is a LIR, and would have received them under the same set of rules, with the same cost basis, and the same conditions and obligations. All those addresses will be eligible for listing under the same listing service, and the recipient of such a transfer would be subject to constant outreach by the RIPE NCC, as would any LIR, continuously encouraging the recipient to have an effective IPv6 transition and eventual phase-out strategy for IPv4. It will also make all space transferred in such a way sub-assignable (as it is now PA, not PI) - thus removing any remaining deterrent to inefficient use due to sub-assignment restrictions. In the process, the community benefits as the cost of operating the RIPE NCC is spread across an increased base of LIRs, and the ties between the RIPE NCC and the resources become much stronger, since for a variety of reasons its considerably more difficult to be an absentee LIR than it is to be an absentee end user.
To summarize, I strongly object to this policy in its current form.
I concur that the mobility of IPv4 PI space toward those who value it most is desirable - on the condition that this mobility occurs as part of a wider reform to eliminate the distinction between PA and PI status of IPv4 resources.
This should result in equitable burden for all resource holders toward the RIPE NCC instead of lining the pockets of IP address brokers by helping address space speculators which presently hoard IPv4 PI assignments against policy realize profits at the expense of the community.
Your missing the point Dave. People who hoarded are not brokers, brokers make a fee on a transaction ... Your so called hoarders are offering parties, but I doubt that you can show in numbers, a substantial number of hoarders as you call them, that would make a substantial amount of money which would justify not doing the policy and not allow a proper registration in the registry for those that have legitimate reasons.
I don't believe there is a legitimate reason for end users to unilaterally decide to violate policy, capitalize on an assignment made to them with specific restrictions, and walk away - in the process, not contributing more than 50 EUR/year to the RIPE NCC while realizing an arbitrary amount of profit. Nor do I believe that we should encourage this behavior by suddenly accepting it in the interest of database accuracy. The database accuracy need was already addressed by 2007-01, and the lack of teeth in terms of revocation of resources which are found no longer to be compliant with the terms of the assignment is an operational matter that can be resolved by re-focusing the RIPE NCC to deal with it. For anyone who is currently a LIR, pays LIR fees, engages in policy development, and expects the community to abide by the policy this work group creates, the argument "lets change it because some elements decided to violate it anyway in the name of profit" should be outright insulting. ... and none of this deals with the fact that this policy goes completely in the face of the actual wording of every single end user contract, which as per 2007-01 must include wording that explicitly prohibits the behavior this proposal aims to enable, yet makes no mention of this fact, or any legal review of the consequences (see mail on this subject to Elvis for more detail).
Regards, Erik Bais
-- Respectfully yours, David Monosov
Hi David,
current policy does not allow PI transfers, you do not own these resources, and you should let them be reclaimed by the RIPE NCC if they are no longer in use. As a LIR, you should know this and be able to communicate it with conviction. You may charge consulting fees in the process ;-)
Actually, that's not quite what the policy says. Perhaps I'm nitpicking, but I think that the difference is significant, even if it is small. For reference, policy says: «All assignments are valid as long as the original criteria on which the assignment was based are still valid and the assignment is properly registered in the RIPE Database. If an assignment is made for a specific purpose and that purpose no longer exists, the assignment is no longer valid. If an assignment is based on information that turns out to be invalid, the assignment is no longer valid.» My point is that «no longer in use» isn't the only thing that would invalidate an assignment. It might still be very much in use, but as long as it isn't used for the same purpose it originally was, then the assignment is invalid, according to policy. This is echoed by the suggested PI contract, which mandates: «The End User shall use the assigned Independent Internet Number Resources solely for the purpose as specified in the request on the basis of which the Independent Internet Number Resources have been assigned.» These requirements are in my opinion out of touch with operational reality; networks evolve and change over time, and given enough time, pretty much all assignments made will end up being used in a different way than what the original criteria was. The PI assignment request form asked for an very detailed criteria, with a breakdown of each individual subnet in the network, and a listing of all the equipment that would be used, including the manufacturer name and model numbers. So if you in the 1990s received an assignment that you had said was for a dozen brand new Sun UltraServers, you better not have replaced those with modern x86 hardware, or you have invalidated your assignment! :-O Some NCC staffers have told me that the way they've logically "solved" this impossible requirement was to consider that whenever the criteria/purpose changed, the original assignment was returned, and a new one consisting of the same block was issued for the new purpose. Then they could just "optimise out" the middle steps where the assignment was removed and re-added. That approached worked (up until Sep 2012 anyway), but I think it would be much better if the policy didn't worry so much about the "original criteria", but rather focus on whether or not the assignment conforms to the address policy in effect at any given time. If it does, there is no reason to call it invalid. Tore
On Mon, Apr 21, 2014 at 11:34 AM, Tore Anderson <tore@fud.no> wrote:
These requirements are in my opinion out of touch with operational reality; networks evolve and change over time, and given enough time, pretty much all assignments made will end up being used in a different way than what the original criteria was. The PI assignment request form asked for an very detailed criteria, with a breakdown of each individual subnet in the network, and a listing of all the equipment that would be used, including the manufacturer name and model numbers. So if you in the 1990s received an assignment that you had said was for a dozen brand new Sun UltraServers, you better not have replaced those with modern x86 hardware, or you have invalidated your assignment! :-O
Some NCC staffers have told me that the way they've logically "solved" this impossible requirement was to consider that whenever the criteria/purpose changed, the original assignment was returned, and a new one consisting of the same block was issued for the new purpose. Then they could just "optimise out" the middle steps where the assignment was removed and re-added. That approached worked (up until Sep 2012 anyway), but I think it would be much better if the policy didn't worry so much about the "original criteria", but rather focus on whether or not the assignment conforms to the address policy in effect at any given time. If it does, there is no reason to call it invalid.
Well said. When specifying a purpose for a use, it is quite difficult to provide something that is generic enough to last for the lifetime of operations, rather than the lifetime of something else entirely. -- Jan
participants (5)
-
David Monosov -
Elvis Daniel Velea -
Erik Bais -
Jan Ingvoldstad -
Tore Anderson