@EXT: FW: 2023-04 Review Phase (Add AGGREGATED-BY-LIR status for IPv4 PA assignments)
Dear all, Thanks for the various points provided after my last message of the 13th December. we are assessing them with our colleagues of the police forces and we have shared with cybersecurity actors the EU.
From Law enforcement perspective, we would consider highly reasonable that RIPE organises a full consultation with relevant stakeholder groups that use RIPE data basis, to fully assess the impact and their needs.
Such consultation would be necessary and legitimate as considering the official agreement signed on 2016 between RIPE NCC and EUROPOL that states that both parties, in accordance with their respective mandates, inform each other about the implementation of their respective mandates in the area of cybercrime, inform each other of programmes of potential interest in order to identify possibilities for joint activities and mutual contributions. As already mentioned, we were informed only recently about the proposal that would need full assessment that takes time. Any new loss of information linked with aggregation of IPV4, would mean less criminals identified and more victims targeted or in life danger. Such losses of information would also conflict with current EU regulatory activities against the "going dark matter" (loss of access to information for LE authorities for judicial purposes). This problem is highly identify at EU level, and I would also prefer to prevent any future misunderstanding between actors in RIPE and EU actors, would the measure be adopted in an hasty way...
From reading your points, I observe that beyond text, is the matter of the real implementation by LIRs and others...we need to clarify and ensure that.
Thanks for your understanding and constructive spirit. Regards Emmanuel KESSLER Emmanuel KESSLER Head of Team - Prevention/Outreach Europol - O3 European Cyber Crime Centre (EC3) Eisenhowerlaan 73, 2517 KK The Hague, The Netherlands Phone: [Moderated] / mobile [Moderated] www.europol.europa.eu<http://www.europol.europa.eu/> [cid:image001.png@01D8169D.5B765D70] -----Original Message----- From: denis walker <ripedenis@gmail.com> Sent: 15 December 2023 15:05 To: Jeroen Lauwers <jlauwers@a2b-internet.com> Cc: RIPE Address Policy Working Group <address-policy-wg@ripe.net>; Gert Doering <gert@space.net>; Kessler, Emmanuel <Emmanuel.Kessler@europol.europa.eu> Subject: Re: [address-policy-wg] 2023-04 Review Phase (Add AGGREGATED-BY-LIR status for IPv4 PA assignments) This email originated from outside Europol. Do not click links or open attachments unless you recognize the sender and know the content is safe. The external address that sent the message is: denis1@gmail.com Hi Jeroen Looking back over this email, there are two things that really stand out to me. "Do you already use AGGREGATED-BY-LIR when registering IPv6 assignments? Would you find it convenient and useful to be able to register IPv4 assignments in the same way?" "the statement <When an End User has a network using public address space this must be registered separately with the contact details of the End User> found in the current policy (and removed by 2023-04 in order to bring the wording in line with that of the IPv6 policy)" These two statements that you made basically sum up this policy proposal. You are suggesting we fundamentally change IPv4 address policy for the 'convenience' of operators and to 'align' some words between two different policies regardless of the consequences. When you add to this a comment Gert made at RIPE 87 when he said that after 30 years we have no clue as to what the "admic-c:" attribute means or why anyone would want to contact them or what they would expect to get from such contact. We have maybe 5 or 6 million inetnum objects in the RIPE Database, a few million inet6num objects and probably tens of thousands of aut-num objects. They all have a mandatory admin-c and we don't know why it is there. All we have is a 30 year old definition that says it must be an on-site contact for the End User in the case of assignment and ASNs. This is a dreadful situation to be in. I suggest that 2023-04 is withdrawn. Then we have a wide reaching consultation with many stakeholder groups who use the RIPE Database. Determine what their needs are for a public registry. What information they need and would like to have in the RIPE Database. Basically do what I expected the last database task force to do, produce a business requirements document for the RIPE Database as a public registry. Then see where we go from there. cheers denis On Wed, 13 Dec 2023 at 19:14, Jeroen Lauwers <jlauwers@a2b-internet.com> wrote:
Dear colleagues,
Though we recognise that most of you are probably busy preparing for the upcoming holidays, we would like to ask you to share your opinion on proposal 2023-04. Remember that Policy Development Process requires any comments made during the Discussion phase must be repeated during the Review phase in order to count towards or against rough consensus, as your views can now take the RIPE NCC's Impact Analysis into account.
Here are some questions for the WG to get the discussion started: Do you already use AGGREGATED-BY-LIR when registering IPv6 assignments? Would you find it convenient and useful to be able to register IPv4 assignments in the same way? Does 2023-04 address this use case well in its current form, or could you think of any potential improvements?
We hope you will find the time to let your voice be heard!
The Policy Development Process requires the proposers to adequately address any suggestions for changes or objections to the proposal in each phase, which we will do below.
1. Does 2023-04 change the contact registration requirements for assignments?
The argument made is that the statement <When an End User has a network using public address space this must be registered separately with the contact details of the End User> found in the current policy (and removed by 2023-04 in order to bring the wording in line with that of the IPv6 policy), implicitly requires LIRs to register non-delegated/outsourced contact information for the End User in the RIPE database, not necessarily in the mandatory <admin-c> or <tech-c> attributes, but possibly in an optional attribute like <descr>, <org> or <remarks>.
Proposers' response:
We do not believe so, for the following reasons, and keeping the current practice and policies in consideration:
The RIPE NCC does not consider that 2023-04 changes the contact registration requirements in any way[1][2][3]. Absent any (rough) consensus in the Working Group to the contrary, we defer to the RIPE NCC's judgement on this point. The practice of creating assignments with all contact information delegated is already widespread. If this was a policy violation made possible due to the RIPE NCC implementing RIPE policy incorrectly, we would have expected the community to take action to correct this situation. However, no such policy proposal has been put forward by the community. Outsourcing and delegation of contact information is a common practice across many industries, including in networking and information technology. There is no policy language that explicitly prohibits this for IPv4 assignments. Absent that, we believe any implicit prohibition found "between the lines" is essentially <void for vagueness>[4]. An obligation to publish the End User's contact information in the RIPE database will constitute a violation of Article 6(3) of the RIPE Database Terms and Conditions[5] and Article 6(1)(a) of the GDPR[6], if the End User's contact person has not given explicit consent to such publication. We believe that the RIPE policy cannot reasonably be interpreted to require LIRs to break EU law (and even if it explicitly did require that, EU law would still take precedence). The policy's stated goal of registering assignments is <to ensure uniqueness and to provide information for Internet troubleshooting at all levels>[7]. Requiring LIRs to publish the contact information of End Users who often will not have any knowledge or capability to aid with troubleshooting does work towards this attaining goal. On the contrary, delegating the contact information to the LIR/ISP may well be the only way to attain this goal.
[1] https://www.ripe.net/ripe/mail/archives/address-policy-wg/2023-Septemb er/013856.html [2] https://www.ripe.net/participate/policies/proposals/2023-04#impact-ana lysis [3] https://www.ripe.net/ripe/mail/archives/address-policy-wg/2023-Novembe r/013892.html [4] https://www.law.cornell.edu/wex/void_for_vagueness [5] https://www.ripe.net/manage-ips-and-asns/db/support/documentation/term s [6] https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0 679#d1e1888-1-1 [7] https://www.ripe.net/publications/docs/ripe-804#3
2. The <assignment-size> attribute should be a CIDR prefix length
Leaving it undefined could result in some LIRs using it to represent an IPv4 address count, while others would use it to represent a CIDR prefix length.
Proposers' response:
We agree <assignment-size> should be a CIDR prefix length. We understand that, if proposal 2023-04 would be accepted, the RIPE NCC could implement the <assignment-size> attribute for IPv4 inetnum objects to be a CIDR prefix length, and document it as such. Therefore we do not believe it is necessary to spell this out explicitly in the policy document (it is not spelled out in the IPv6 policy document either).
Thank you for your attention and enjoy your holidays!
Best regards, Jeroen and Tore
Op 21 nov. 2023, om 11:13 heeft Angela Dall'Ara <adallara@ripe.net> het volgende geschreven:
Dear colleagues,
Policy proposal 2023-04, "Add AGGREGATED-BY-LIR status for IPv4 PA assignments", is now in the Review Phase.
The goal of this proposal is to introduce the AGGREGATED-BY-LIR status for IPv4 PA assignments to reduce LIR efforts in registration and maintenance.
This proposal has been updated and it is now at version 2.0. The proposed policy text did not change, the only difference is that the section "Arguments opposing the proposal" includes a reference to the last round of discussion.
The RIPE NCC has prepared an impact analysis on this proposal to support the community's discussion.
You can find the proposal and impact analysis at: https://www.ripe.net/participate/policies/proposals/2023-04 https://www.ripe.net/participate/policies/proposals/2023-04#impact-ana lysis And the draft document at: https://www.ripe.net/participate/policies/proposals/2023-04/draft
As per the RIPE Policy Development Process (PDP), the purpose of this four-week Review Phase is to continue the discussion of the proposal taking the impact analysis into consideration, and to review the full draft RIPE Policy Document.
At the end of the Review Phase, the Working Group (WG) Chairs will determine whether the WG has reached rough consensus. It is therefore important to provide your opinion, even if it is simply a restatement of your input from the previous phase.
We encourage you to read the proposal, impact analysis and draft document and to send any comments to address-policy-wg@ripe.net before 20 December 2023.
Kind regards, Angela Dall'Ara Policy Officer RIPE NCC
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Dear Emmanuel KESSLER, Thank you for participating in the RIPE community. You referenced the 2016 MoU between RIPE NCC and EUROPOL in your most recent comment. It's important to note that this Working Group is a RIPE community activity and not a RIPE NCC activity. The RIPE community is open to participation by anyone and is not a legal entity. The RIPE NCC is the legal entity that provides secretariat services to the RIPE community. We welcome your participation in RIPE's Policy Development Process and input on the current proposal. Kind regards, Leo Vegoda, for the Address Policy WG co-chairs On Wed, 20 Dec 2023 at 03:07, Kessler, Emmanuel <Emmanuel.Kessler@europol.europa.eu> wrote:
Dear all,
Thanks for the various points provided after my last message of the 13th December. we are assessing them with our colleagues of the police forces and we have shared with cybersecurity actors the EU.
From Law enforcement perspective, we would consider highly reasonable that RIPE organises a full consultation with relevant stakeholder groups that use RIPE data basis, to fully assess the impact and their needs.
Such consultation would be necessary and legitimate as considering the official agreement signed on 2016 between RIPE NCC and EUROPOL that states that both parties, in accordance with their respective mandates, inform each other about the implementation of their respective mandates in the area of cybercrime, inform each other of programmes of potential interest in order to identify possibilities for joint activities and mutual contributions. As already mentioned, we were informed only recently about the proposal that would need full assessment that takes time.
Any new loss of information linked with aggregation of IPV4, would mean less criminals identified and more victims targeted or in life danger.
Such losses of information would also conflict with current EU regulatory activities against the "going dark matter" (loss of access to information for LE authorities for judicial purposes). This problem is highly identify at EU level, and I would also prefer to prevent any future misunderstanding between actors in RIPE and EU actors, would the measure be adopted in an hasty way…
From reading your points, I observe that beyond text, is the matter of the real implementation by LIRs and others...we need to clarify and ensure that.
Thanks for your understanding and constructive spirit.
Regards
Emmanuel KESSLER
Emmanuel KESSLER
Head of Team - Prevention/Outreach
Europol - O3 European Cyber Crime Centre (EC3)
Eisenhowerlaan 73, 2517 KK The Hague, The Netherlands Phone: [Moderated] / mobile [Moderated]
www.europol.europa.eu
-----Original Message----- From: denis walker <ripedenis@gmail.com> Sent: 15 December 2023 15:05 To: Jeroen Lauwers <jlauwers@a2b-internet.com> Cc: RIPE Address Policy Working Group <address-policy-wg@ripe.net>; Gert Doering <gert@space.net>; Kessler, Emmanuel <Emmanuel.Kessler@europol.europa.eu> Subject: Re: [address-policy-wg] 2023-04 Review Phase (Add AGGREGATED-BY-LIR status for IPv4 PA assignments)
This email originated from outside Europol. Do not click links or open attachments unless you recognize the sender and know the content is safe. The external address that sent the message is: denis1@gmail.com
Hi Jeroen
Looking back over this email, there are two things that really stand out to me.
"Do you already use AGGREGATED-BY-LIR when registering IPv6 assignments? Would you find it convenient and useful to be able to register IPv4 assignments in the same way?"
"the statement «When an End User has a network using public address space this must be registered separately with the contact details of the End User» found in the current policy (and removed by 2023-04 in order to bring the wording in line with that of the IPv6 policy)"
These two statements that you made basically sum up this policy proposal. You are suggesting we fundamentally change IPv4 address policy for the 'convenience' of operators and to 'align' some words between two different policies regardless of the consequences.
When you add to this a comment Gert made at RIPE 87 when he said that after 30 years we have no clue as to what the "admic-c:" attribute means or why anyone would want to contact them or what they would expect to get from such contact. We have maybe 5 or 6 million inetnum objects in the RIPE Database, a few million inet6num objects and probably tens of thousands of aut-num objects. They all have a mandatory admin-c and we don't know why it is there. All we have is a 30 year old definition that says it must be an on-site contact for the End User in the case of assignment and ASNs.
This is a dreadful situation to be in. I suggest that 2023-04 is withdrawn. Then we have a wide reaching consultation with many stakeholder groups who use the RIPE Database. Determine what their needs are for a public registry. What information they need and would like to have in the RIPE Database. Basically do what I expected the last database task force to do, produce a business requirements document for the RIPE Database as a public registry. Then see where we go from there.
cheers denis
On Wed, 13 Dec 2023 at 19:14, Jeroen Lauwers <jlauwers@a2b-internet.com> wrote:
Dear colleagues,
Though we recognise that most of you are probably busy preparing for the upcoming holidays, we would like to ask you to share your opinion on proposal 2023-04. Remember that Policy Development Process requires any comments made during the Discussion phase must be repeated during the Review phase in order to count towards or against rough consensus, as your views can now take the RIPE NCC’s Impact Analysis into account.
Here are some questions for the WG to get the discussion started: Do you already use AGGREGATED-BY-LIR when registering IPv6 assignments? Would you find it convenient and useful to be able to register IPv4 assignments in the same way? Does 2023-04 address this use case well in its current form, or could you think of any potential improvements?
We hope you will find the time to let your voice be heard!
The Policy Development Process requires the proposers to adequately address any suggestions for changes or objections to the proposal in each phase, which we will do below.
1. Does 2023-04 change the contact registration requirements for assignments?
The argument made is that the statement «When an End User has a network using public address space this must be registered separately with the contact details of the End User» found in the current policy (and removed by 2023-04 in order to bring the wording in line with that of the IPv6 policy), implicitly requires LIRs to register non-delegated/outsourced contact information for the End User in the RIPE database, not necessarily in the mandatory «admin-c» or «tech-c» attributes, but possibly in an optional attribute like «descr», «org» or «remarks».
Proposers’ response:
We do not believe so, for the following reasons, and keeping the current practice and policies in consideration:
The RIPE NCC does not consider that 2023-04 changes the contact registration requirements in any way[1][2][3]. Absent any (rough) consensus in the Working Group to the contrary, we defer to the RIPE NCC’s judgement on this point. The practice of creating assignments with all contact information delegated is already widespread. If this was a policy violation made possible due to the RIPE NCC implementing RIPE policy incorrectly, we would have expected the community to take action to correct this situation. However, no such policy proposal has been put forward by the community. Outsourcing and delegation of contact information is a common practice across many industries, including in networking and information technology. There is no policy language that explicitly prohibits this for IPv4 assignments. Absent that, we believe any implicit prohibition found “between the lines” is essentially «void for vagueness»[4]. An obligation to publish the End User’s contact information in the RIPE database will constitute a violation of Article 6(3) of the RIPE Database Terms and Conditions[5] and Article 6(1)(a) of the GDPR[6], if the End User’s contact person has not given explicit consent to such publication. We believe that the RIPE policy cannot reasonably be interpreted to require LIRs to break EU law (and even if it explicitly did require that, EU law would still take precedence). The policy’s stated goal of registering assignments is «to ensure uniqueness and to provide information for Internet troubleshooting at all levels»[7]. Requiring LIRs to publish the contact information of End Users who often will not have any knowledge or capability to aid with troubleshooting does work towards this attaining goal. On the contrary, delegating the contact information to the LIR/ISP may well be the only way to attain this goal.
[1] https://www.ripe.net/ripe/mail/archives/address-policy-wg/2023-Septemb er/013856.html [2] https://www.ripe.net/participate/policies/proposals/2023-04#impact-ana lysis [3] https://www.ripe.net/ripe/mail/archives/address-policy-wg/2023-Novembe r/013892.html [4] https://www.law.cornell.edu/wex/void_for_vagueness [5] https://www.ripe.net/manage-ips-and-asns/db/support/documentation/term s [6] https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0 679#d1e1888-1-1 [7] https://www.ripe.net/publications/docs/ripe-804#3
2. The «assignment-size» attribute should be a CIDR prefix length
Leaving it undefined could result in some LIRs using it to represent an IPv4 address count, while others would use it to represent a CIDR prefix length.
Proposers’ response:
We agree «assignment-size» should be a CIDR prefix length. We understand that, if proposal 2023-04 would be accepted, the RIPE NCC could implement the «assignment-size» attribute for IPv4 inetnum objects to be a CIDR prefix length, and document it as such. Therefore we do not believe it is necessary to spell this out explicitly in the policy document (it is not spelled out in the IPv6 policy document either).
Thank you for your attention and enjoy your holidays!
Best regards, Jeroen and Tore
Op 21 nov. 2023, om 11:13 heeft Angela Dall'Ara <adallara@ripe.net> het volgende geschreven:
Dear colleagues,
Policy proposal 2023-04, “Add AGGREGATED-BY-LIR status for IPv4 PA assignments”, is now in the Review Phase.
The goal of this proposal is to introduce the AGGREGATED-BY-LIR status for IPv4 PA assignments to reduce LIR efforts in registration and maintenance.
This proposal has been updated and it is now at version 2.0. The proposed policy text did not change, the only difference is that the section "Arguments opposing the proposal" includes a reference to the last round of discussion.
The RIPE NCC has prepared an impact analysis on this proposal to support the community’s discussion.
You can find the proposal and impact analysis at: https://www.ripe.net/participate/policies/proposals/2023-04 https://www.ripe.net/participate/policies/proposals/2023-04#impact-ana lysis And the draft document at: https://www.ripe.net/participate/policies/proposals/2023-04/draft
As per the RIPE Policy Development Process (PDP), the purpose of this four-week Review Phase is to continue the discussion of the proposal taking the impact analysis into consideration, and to review the full draft RIPE Policy Document.
At the end of the Review Phase, the Working Group (WG) Chairs will determine whether the WG has reached rough consensus. It is therefore important to provide your opinion, even if it is simply a restatement of your input from the previous phase.
We encourage you to read the proposal, impact analysis and draft document and to send any comments to address-policy-wg@ripe.net before 20 December 2023.
Kind regards, Angela Dall'Ara Policy Officer RIPE NCC
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participants (2)
-
Kessler, Emmanuel -
Leo Vegoda