Re: [address-policy-wg] 2012-02 New Draft Document Published (Policy forInter-RIR Transfers of IPv4 Address Space) (Tore Anderson)
3. Re: 2012-02 New Draft Document Published (Policy for Inter-RIR Transfers of IPv4 Address Space) (Tore Anderson) ------------------------------ Message: 3 Date: Sat, 01 Dec 2012 12:57:07 +0100 From: Tore Anderson <tore.anderson@redpill-linpro.com> Subject: Re: [address-policy-wg] 2012-02 New Draft Document Published (Policy for Inter-RIR Transfers of IPv4 Address Space) To: address-policy-wg@ripe.net Message-ID: <50B9F093.9040700@redpill-linpro.com> Content-Type: text/plain; charset=ISO-8859-1
From the Impact Analysis:
This policy proposal requires the RIPE NCC LIRs to be in compliance with the RIPE NCC's policies. The RIPE NCC will conduct an audit to ensure that this is the case prior to completing a transfer.
I think that this is an excessively strict interpretation of the policy, one which I suspect isn't the intention of the proposer. In my opinion, an LIR should be assumed to be in compliance with the RIPE NCC's [sic] policies; the mere act of participating in an inter-RIR transfer should not cause an automatic LIR Audit. Mandatory LIR Audits would only serve to increase the amount of hassle and bureaucracy involved in completing such transfers, and might well discourage LIRs from participating in them at all. Given that this is the NCC's interpretation of 2012-02, I don't support the proposal as it is currently worded, and hope it could be modified so that it will not cause mandatory or automatic LIR Audits. -- Tore Anderson Redpill Linpro AS - http://www.redpill-linpro.com/ Can someone explain more about what is involved in the audit? I was picturing more of a needs justification process where the applicant would illustrate that current IP's were 80% utilized. Is that the same as an audit? Also, Tore's last point on 2012-03 should be applied to the passing of 2012-02. In the event that 2012-03 is agreed to, and needs justification is extended from 3 months to 24 months, then 5.5 will have new wording to accommodate the change. Further, if 2012-02 is passed to allow for inter-RIR transfers to-from RIR's with like-policies, then Chapter 5.5 “Transfers of Allocations” of “IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region”; will require an additional wording change. Specifically, the second paragraph of 5.5 says: "...address space may only be re-allocated to another LIR that is also a member of the RIPE NCC. " and if Inter-RIR transfers are approved this will change to LIR's of another RIR. Sandra Brown President IPv4 Market Group sandrabrown@ipv4marketgroup.com 716-348-6768 www.ipv4marketgroup.com
Dear Tore,
This policy proposal requires the RIPE NCC LIRs to be in compliance with the RIPE NCC's policies. The RIPE NCC will conduct an audit to ensure that this is the case prior to completing a transfer.
I think that this is an excessively strict interpretation of the policy, one which I suspect isn't the intention of the proposer. In my opinion, an LIR should be assumed to be in compliance with the RIPE NCC's [sic] policies; the mere act of participating in an inter-RIR transfer should not cause an automatic LIR Audit.
Mandatory LIR Audits would only serve to increase the amount of hassle and bureaucracy involved in completing such transfers, and might well discourage LIRs from participating in them at all.
Given that this is the NCC's interpretation of 2012-02, I don't support the proposal as it is currently worded, and hope it could be modified so that it will not cause mandatory or automatic LIR Audits.
The "audit" that is referred to here is the small audit that we have always done when evaluating an additional allocation request. It is not the full LIR audit that we conduct as part of our Audit Activity, nor is it something new. It mostly concerns cleaning up exsting records such as: - LIR contact details that are out of date - PA approvals that are no longer in use - Direct assignment customers for whom the LIR is no longer the sponsoring LIR - Invalid assignments in the RIPE DB Experience shows that in the vast majority of such evaluations, there are at least a few records and registrations that are out of date and have to be corrected and that this is rarely a lot of work. The RIPE NCC has always considered this to be part of the basic due-dilligence required to keep records correct and up to date. Best regards, Alex Le Heux Policy Implementation and Co-ordination RIPE NCC
* Alex Le Heux
The "audit" that is referred to here is the small audit that we have always done when evaluating an additional allocation request. It is not the full LIR audit that we conduct as part of our Audit Activity, nor is it something new.
Alex, Thank you for clarifying this. As long as the auditing activities does not exceed those that would normally take place during an in-region transfer, or before issuing an additional allocation, I have no objections. Best regards, -- Tore Anderson Redpill Linpro AS - http://www.redpill-linpro.com/
participants (3)
-
Alex Le Heux -
sandrabrown＠ipv4marketgroup.com -
Tore Anderson