Re: [address-policy-wg] [policy-announce]2014-05 New Draft Document and ImpactAnalysis Published (Policy for Inter-RIR Transfers of InternetResources) (Erik Bais)
Hi,
Thank you for the analyses.
You can find the full proposal and the impact analysis at: https://www.ripe.net/ripe/policies/proposals/2014-05
I see some issues that aren't consistent in the wording of the policy, especially in terms of Legacy and PI space holders (non-members) and:
Address space may only be re-allocated to another resource holder who is a member of an RIR that allows transfers.
Both PI space holders and Legacy holders are not always members of an RIR. I'm speaking with my RIPE region community member experience here. So it could be that in for instance ARIN or APNIC all resource holders are members of the RIR, but here in the RIPE region that isn't (always) the case.
When Internet number resources are transferred from another RIR, the RIPE
NCC will work with the resource holder to fulfil any requirements of the sending RIR.
Suggested wording: When Internet number resources are transferred from another RIR to the RIPE Region, the RIPE NCC will work with the receiving party and the resource holder and the sending RIR to confirm the qualification requirements in order to complete transfer.
As Tore noted, the PI transfer section 6.4 was added recently, and since the Impact Analysis makes it clear that PI transfers will be permitted, this doesn't justify a version 3.0 of the inter-RIR transfer policy, in my mind. However, your comments are correct, and duly noted.
It is more specific to the intend, however as the RIPE NCC is put in a position to check if the receiving party qualifies following a needs assessment according to the policy of another RIR, the RIPE NCC needs to be in contact with the receiving party, the resource holder and the sending RIR.
On the part of arbitration, the policy as it is described in the Summary of the Proposal is a nightmare I think..
The Summary of the proposal states :
If another RIR has a different policy, the RIPE NCC should create an operational procedure that satisfies the requirements of both RIRs in order to allow transfers to and from its service region
I understand the intend of what it stated, but I don't think that the NCC should be put in a position where Axel would come opposite from the board of ARIN or APNIC and have them sort out the procedure, without a proper arbitration procedure in place outside the RIR's ... What if a transfer isn't going as planned and it does pass the arbitration in the RIPE region ... the sending RIR doesn't agree with the arbitration out-come ... And what is next ? Will the NCC take the other RIR to court ? Or is there an arbitration process for RIR's ?
Personally I think that the policy should state that the party in the RIPE Region should deal with the arbitration in the RIPE region and that the sending or receiving party in the other RIR should convert to the arbitration in their respective RIR. Or agree by agreement which of the 2 RIR's their arbitration will be used (and with that choice to apply their policy) if we keep the policy as it is currently on the table..
If the intent of the policy, as it is currently, is that the RIPE NCC should adhere to the policy of the more strict assignment policy of the other RIR, state in the policy specifically that the other RIR needs to do the need justification checking with the receiving party and approve the transfer prior to submitting the transfer for processing to the RIPE NCC. They have the best knowledge of the policy in that specific RIR and if they don't agree with the justification or qualification of the receiving party, their arbitration can also be used, without getting the RIPE NCC in a squeeze between a rock and a hard place or putting a requirement in place for the RIPE NCC staff that they should get intimately familiar with other RIR their addressing policy.
If the other RIR approves the transfer based on their current policy at that time (as if it is an intra-rir transfer ) it can be submitted to the RIPE NCC for administrative processing, as the RIPE NCC has a more liberal addressing policy towards transfers than any other RIR.
The model proposed in the policy is intended to mimic the existing policy between APNIC and ARIN whereby the arbitration topic is not needed. When two RIR's have like needs assessment, this topic goes away. As noted, however, in the Impact Assessment, ARIN staff does not see the policy to be compatible with theirs. I am surprised that they say that explicit needs justification is not stated, and must be. The policy states that the requirements of the sending RIR will be met. If the requirement of the sending RIR is needs justification, then needs justification will be performed. But as Tore, says, it opens the door, and in my mind, the door is opened for a next step. Interestingly, ARIN34 seemed to be pushing for removal of needs justification on blocks sized /16 and smaller.
I hope that I've made my point on the topic and with that also suggested a way forward.
I really don't like a policy that has too many open ends or topics that we haven't addressed enough and already know up-front that the other RIR's don't agree with.
This is the nature of negotiation in the global community. Sandra
Regards, Erik Bais
Hi Sandra, On Wed, 15 Oct 2014, sandrabrown@ipv4marketgroup.com wrote: <snip>
The model proposed in the policy is intended to mimic the existing policy between APNIC and ARIN whereby the arbitration topic is not needed. When two RIR's have like needs assessment, this topic goes away.
As noted, however, in the Impact Assessment, ARIN staff does not see the policy to be compatible with theirs. I am surprised that they say that explicit needs justification is not stated, and must be. The policy states that the requirements of the sending RIR will be met. If the requirement of the sending RIR is needs justification, then needs justification will be performed. But as Tore, says, it opens the door, and in my mind, the door is opened for a next step. Interestingly, ARIN34 seemed to be pushing for removal of needs justification on blocks sized /16 and smaller.
Well, a conversation has been and is taking place. There is an ARIN Draft Policy (ARIN-2014-14) that proposes this. The phrase "ARIN34 seemed to be pushing" works fine as optimism, but may suggest progress that, IMHO, has not yet been made. At best, feedback on the matter seems deeply polarized. John Springer Primary shepherd for 2014-14, and NOT speaking for ARIN, ARIN34, the ARIN AC or anybody besides myself
I hope that I've made my point on the topic and with that also suggested a way forward.
I really don't like a policy that has too many open ends or topics that we haven't addressed enough and already know up-front that the other RIR's don't agree with.
This is the nature of negotiation in the global community.
Sandra
Regards, Erik Bais
Hi Sandra,
The model proposed in the policy is intended to mimic the existing policy between APNIC and ARIN whereby the arbitration topic is not needed. When two RIR's have like needs assessment, this topic goes away.
I noticed that the existing policy proposal doesn't have the arbitration point and the fact is, that the policies between RIPE and APNIC and RIPE and ARIN aren't the same. That in combination with the remark in the current policy summary :
RIPE NCC should create an operational procedure that satisfies the requirements of both RIRs in order to allow transfers to and from its service region.
That is an issue in my view. That in combination with what is stated in the Impact Assessment that the ARIN staff does not see the policy to be compatible with theirs .. are the points that I wanted to address. By having the other RIR pre-approve the transfer (either receiving or sending transfers) based on their view and interpretation of their own policy, they can do the need justification. Adjustments in their policy won't affect compatibility of the inter-RIR policy. And when the transfer is then submitted for processing to RIPE, it will always be compatible, the RIPE staff doesn't have to cram up on all policy changes, arbitration isn't an issue and you will have a policy that will work. If one of the other RIR's is going to change to a no needs justification policy, they can just pre-approve the transfer, and the RIPE NCC can still just process the transfer ... Personally I think that having the other RIR (not RIPE NCC) do the local policy checking and need justification if they have it for the transfer, makes this a lot easier, without having the RIPE NCC to line up on both the ARIN and APNIC policies. As an example: What if Registration Services (RS) from RIPE NCC would approve a certain justification according to their policy interpretation and ARIN or APNIC RS would not approve the same logic ? Policy interpretation and the justification checking, should be done at the RIR who has the most strict policy. It doesn't make sense to me, to have RIPE IPRA's try to do a justification check based on interpretation of the APNIC or ARIN policy ...
This is the nature of negotiation in the global community.
Perhaps, but a policy for the benefit of the global community, should have some kind of arbitration clauses in there or at least define where arbitration should be done. It is good stewardship to have a RIPE policy that wouldn't open up the doors for long international discussions without a clear view on who the 'problem-owner' is .. and for future customers it should be clear where they can take their complains if they are not happy with the outcome. Regards, Erik Bais
participants (3)
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Erik Bais -
John Springer -
sandrabrown＠ipv4marketgroup.com