Re: [address-policy-wg] [policy-announce]2014-05 New Draft Document and ImpactAnalysis Published (Policy for Inter-RIR Transfers of InternetResources) (Erik Bais)
* steve.r.wright@bt.com
Hi all, I support the goals of 2014-15, the suggestion below seems to be a practical solution, if acceptable to all parties.
Agreed. I would have ideally preferred to see language that was sufficiently generic to accommodate for any condition (i.e., not just limited to ARIN's "needs-based" requirement) imposed by another RIR region on the RIPE region entities engaging in inter-region transfers with that RIR region. However, I see that accomplishing this might be more trouble than it's worth, especially when taking into account that ARIN doesn't consider the attempt currently in 2014-05 adequate. So it would seem that a "KISS" approach would be better, explicitly putting in a "needs-based" requirement as mandated by ARIN. John, thank you for suggesting text, it's very helpful to have a starting point that we know that ARIN will consider compatible. I have some comments on your suggested text, though: * John Curran
"For transfers from RIR regions which require needs-based policies, recipients must provide a plan to the RIPE NCC for use of the transferred resource within 24 months." (for example)
1) «RIR regions which require needs-based policies» might be too broad. APNIC requires needs-based for intra-region transfers but not for inter-region transfers. As they already have (IMHO) misinterpreted the current "interop clauses" in 2014-05 to apply to them even though there is no need for that, we need to make it clearer that it only applies for regions which require *the RIPE region* to have needs-based policies. 2) Hard-coding 24 months is a risk. If for example the ARIN community changes their transfer policy to have different need period, then we would find ourselves with incompatible policies again. So I think that we should instead just refer to whatever need period the other RIR has. 3) I think it would be more flexible to not require the usage plan to be presented to the NCC, but that it could be presented to the other RIR instead. My reasoning is that the other RIR might already have the forms and criteria ready for performing need evaluation in a way that's (obviously) "compatible" with that RIR's own policies, while the NCC might not. Therefore it could potentially be easier for all involved parties if the other RIR performs the required need evaluation (if that RIR and the NCC agrees on such a transfer procedure, that is). It might also help prevent possibly complaints from the other region that the NCC doesn't perform stringent enough evaluation, and so on. Suggested new text that takes the above into account below. It would replace the second paragraph in section 2.0 of 2014-05. (Also, the last sentence of section 3.0 should be removed.) «For transfers from RIR regions which require the RIPE region to have needs-based policies, recipients must provide a plan to the RIPE NCC or the other RIR for the use of the transferred resource within the time period defined by the transfer policy of the other RIR». It would be good if you could confirm that this variant would also be regarded as "compatible" by ARIN, John. Tore (who feels somewhat guilty for this stuff being tricky in the first place...)
On Oct 21, 2014, at 10:28 AM, Tore Anderson <tore@fud.no> wrote:
* steve.r.wright@bt.com
Hi all, I support the goals of 2014-15, the suggestion below seems to be a practical solution, if acceptable to all parties.
Agreed.
I would have ideally preferred to see language that was sufficiently generic to accommodate for any condition (i.e., not just limited to ARIN's "needs-based" requirement) imposed by another RIR region on the RIPE region entities engaging in inter-region transfers with that RIR region. However, I see that accomplishing this might be more trouble than it's worth, especially when taking into account that ARIN doesn't consider the attempt currently in 2014-05 adequate.
So it would seem that a "KISS" approach would be better, explicitly putting in a "needs-based" requirement as mandated by ARIN. John, thank you for suggesting text, it's very helpful to have a starting point that we know that ARIN will consider compatible.
I wanted to make that this community understood the reason for the incompatibility, since it did not appear to be a mismatch in actual policy intent. Glad it was helpful.
I have some comments on your suggested text, though: ... 2) Hard-coding 24 months is a risk. If for example the ARIN community changes their transfer policy to have different need period, then we would find ourselves with incompatible policies again. So I think that we should instead just refer to whatever need period the other RIR has.
To be clear, ARIN policy for inter-RIR transfers does not require any specific need period - my text was solely to be an example. There must be policy text that refers to needs-based (i.e. some operational need for the address space), but any change in ARIN's policy for transfers within the ARIN region should not require a change to RIPE policy for needs-based compatibility in any circumstance.
3) I think it would be more flexible to not require the usage plan to be presented to the NCC, but that it could be presented to the other RIR instead. My reasoning is that the other RIR might already have the forms and criteria ready for performing need evaluation in a way that's (obviously) "compatible" with that RIR's own policies, while the NCC might not.
Once the RIPE Inter-RIR transfer policy is determined to be needs-based and compatible, then processing of individual requests can easily be handled by RIPE NCC without any need for sharing of requesters information with other parties. This works quite well quite Inter-RIR transfers between APNIC and the ARIN region today, whereas there are likely to be potential implementation issues with your proposed approach that would need to be carefully explored; for example, ARIN has no relationship to a requestor in the RIPE region, no non-disclosure agreement, etc.
Therefore it could potentially be easier for all involved parties if the other RIR performs the required need evaluation (if that RIR and the NCC agrees on such a transfer procedure, that is). It might also help prevent possibly complaints from the other region that the NCC doesn't perform stringent enough evaluation, and so on.
I believe that all of the RIRs must rely on each other for faithful implementation of policy, but again, this has not been a problem for other Inter-RIR transfers to/from the ARIN region. FYI, /John John Curran President and CEO ARIN
Hi John, * John Curran
On Oct 21, 2014, at 10:28 AM, Tore Anderson <tore@fud.no> wrote:
2) Hard-coding 24 months is a risk. If for example the ARIN community changes their transfer policy to have different need period, then we would find ourselves with incompatible policies again. So I think that we should instead just refer to whatever need period the other RIR has.
To be clear, ARIN policy for inter-RIR transfers does not require any specific need period - my text was solely to be an example. There must be policy text that refers to needs-based (i.e. some operational need for the address space), but any change in ARIN's policy for transfers within the ARIN region should not require a change to RIPE policy for needs-based compatibility in any circumstance.
Really? I would have thought that the periods would need to be the same for the policies to be compatible. Otherwise, we could have set a ridiculously long period like 1000 years. Even if it that would be compatible with the letter of the ARIN policy I highly doubt it would be compatible with the spirit. :-) By ensuring identical periods are used, there can be no argument that differing periods cause incompatibility or any form of loopholes. Maybe that's not a concern for compatibility with ARIN today, but it might be tomorrow with another RIR. In any case, it shouldn't hurt compatibility with ARIN's policy, right?
3) I think it would be more flexible to not require the usage plan to be presented to the NCC, but that it could be presented to the other RIR instead. My reasoning is that the other RIR might already have the forms and criteria ready for performing need evaluation in a way that's (obviously) "compatible" with that RIR's own policies, while the NCC might not.
Once the RIPE Inter-RIR transfer policy is determined to be needs-based and compatible, then processing of individual requests can easily be handled by RIPE NCC without any need for sharing of requesters information with other parties. This works quite well quite Inter-RIR transfers between APNIC and the ARIN region today, whereas there are likely to be potential implementation issues with your proposed approach that would need to be carefully explored; for example, ARIN has no relationship to a requestor in the RIPE region, no non-disclosure agreement, etc.
Good point about the NDA. You're right, let's not go there. Then I have: «For transfers from RIR regions which require the RIPE region to have needs-based policies, recipients must provide a plan to the RIPE NCC for the use of the transferred resource within the time period defined by the transfer policy of the other RIR». Like I said before, it would be good to have an indication from you or another ARIN official on whether or not this would indeed be deemed as compatible with ARIN's inter-region transfer policy. That way, hopefully this WG won't have to do too many iterations of 2014-05 before settling on a piece of text that works for everyone involved.
Therefore it could potentially be easier for all involved parties if the other RIR performs the required need evaluation (if that RIR and the NCC agrees on such a transfer procedure, that is). It might also help prevent possibly complaints from the other region that the NCC doesn't perform stringent enough evaluation, and so on.
I believe that all of the RIRs must rely on each other for faithful implementation of policy, but again, this has not been a problem for other Inter-RIR transfers to/from the ARIN region.
I was not really referring to ARIN-the-RIR here, but rather individuals participating in the ARIN community, who might end up with an impression (misguided or not) that the starving RIPE region ISPs are looting ARIN's fat IPv4 stores while the RIPE NCC looks the other way... Tore
On Oct 21, 2014, at 11:39 AM, Tore Anderson <tore@fud.no> wrote:
To be clear, ARIN policy for inter-RIR transfers does not require any specific need period - my text was solely to be an example. There must be policy text that refers to needs-based (i.e. some operational need for the address space), but any change in ARIN's policy for transfers within the ARIN region should not require a change to RIPE policy for needs-based compatibility in any circumstance.
Really? I would have thought that the periods would need to be the same for the policies to be compatible. Otherwise, we could have set a ridiculously long period like 1000 years. Even if it that would be compatible with the letter of the ARIN policy I highly doubt it would be compatible with the spirit. :-)
I imagine that ARIN community would propose a policy change in the face of such antics, but ARIN's existing Inter-RIR transfer policy language is intentionally not proscriptive in this regard.
By ensuring identical periods are used, there can be no argument that differing periods cause incompatibility or any form of loopholes. Maybe that's not a concern for compatibility with ARIN today, but it might be tomorrow with another RIR. In any case, it shouldn't hurt compatibility with ARIN's policy, right?
Actually, that is not clear, as ARIN's Inter-RIR transfer policy language requires that an RIR have needs-based policy in order to be compatible for transfers to/from ARIN, and having solely a reference to the another RIR's policy could be argued (by some) to not be actual needs-based policy for RIPE. Specific needs-based language in RIPE's policy would be much cleaner, as well as having RIPE NCC implementing something defined by the RIPE community rather than criteria that may change at any time without RIPE community involvement.
Once the RIPE Inter-RIR transfer policy is determined to be needs-based and compatible, then processing of individual requests can easily be handled by RIPE NCC without any need for sharing of requesters information with other parties. This works quite well quite Inter-RIR transfers between APNIC and the ARIN region today, whereas there are likely to be potential implementation issues with your proposed approach that would need to be carefully explored; for example, ARIN has no relationship to a requestor in the RIPE region, no non-disclosure agreement, etc.
Good point about the NDA. You're right, let's not go there.
Indeed, a tad messy...
Then I have:
«For transfers from RIR regions which require the RIPE region to have needs-based policies, recipients must provide a plan to the RIPE NCC for the use of the transferred resource within the time period defined by the transfer policy of the other RIR».
Like I said before, it would be good to have an indication from you or another ARIN official on whether or not this would indeed be deemed as compatible with ARIN's inter-region transfer policy. That way, hopefully this WG won't have to do too many iterations of 2014-05 before settling on a piece of text that works for everyone involved.
Even noting the consideration noted above, I do believe your proposed text above to be compatible, needs-based policy for purposes of ARIN's NRPM 8.4 Inter-RIR transfers. Thanks, /John John Curran President and CEO ARIN
Hi, * John Curran
Actually, that is not clear, as ARIN's Inter-RIR transfer policy language requires that an RIR have needs-based policy in order to be compatible for transfers to/from ARIN, and having solely a reference to the another RIR's policy could be argued (by some) to not be actual needs-based policy for RIPE.
I see.
Specific needs-based language in RIPE's policy would be much cleaner, as well as having RIPE NCC implementing something defined by the RIPE community rather than criteria that may change at any time without RIPE community involvement.
Another issue that could hypothetically arise from having a hard-coded 24 month limit is if the ARIN community increases their limit. Considering that the purpose of adding the limit to 2014-05 in the first place is only be to appease the ARIN community, it would be an odd outcome if 2014-05 ends up being more strict than ARIN's policy (even if this situation only lasts for the policy cycle necessary for us to catch up with you). So, perhaps it would be better with something like «within 24 months or the corresponding period defined in the transfer policy of the other RIR, whichever is greater»?
«For transfers from RIR regions which require the RIPE region to have needs-based policies, recipients must provide a plan to the RIPE NCC for the use of the transferred resource within the time period defined by the transfer policy of the other RIR».
Even noting the consideration noted above, I do believe your proposed text above to be compatible, needs-based policy for purposes of ARIN's NRPM 8.4 Inter-RIR transfers.
Excellent. Thank you! Tore
participants (2)
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John Curran -
Tore Anderson