Daniel Stolpe wrote:
On Sun, 3 Feb 2013, Nick Hilliard wrote:
On 24/01/2013 13:33, Emilio Madaio wrote:
The text of the policy proposal 2012-07, "RIPE NCC Services to Legacy Internet Resource Holders", has been revised based on the community feedback received on the mailing list. We have published the new version (version 2.0) today. As a result a new Discussion Phase is set for the proposal.
ok, I'll bite.
in general, this is a vast improvement on v1.0 and I think it could feasibly form the basis of a working policy, but there are still some shortcomings and omissions which need to be dealt with.
In general yes. Well done so far.
LRH == legacy resource holder
minor nits:
- 1.0 introduction: some legacy resources were assigned by the InterNIC after the creation of the RIPE NCC, so it is incorrect to define LRHs as those who "were granted internet resources before the creation of the RIPE NCC". A similar comment applies to the definition given in 1.1.
Might seem minor but the definition certainly has to be correct.
True. I propose to turn the logic around, i.e. resources not obtained by way of an RIR, because the initial set of 3 RIRs were not born on the same date :-) Incidentally, the RIPE NCC was the first one to exist.
- section 3.0: contractual requirements: I don't understand why there is a suggested contractual requirement to acknowledge that the terms and conditions of the original assignment are outside the scope of the new contractual arrangement, unless (straw man) someone can provide a copy of those T&Cs. I.e. this is probably unenforceable. I dunno. Looks odd to me.
- 4.0: "in cast the situation corresponds to section 2.5 above" - perhaps the authors may have omitted section 2.6?
larger grievances:
- I don't believe that there is a requirement for section 2.4. Disregarding that the RIPE NCC has ended the possibility of directly assigned resources for general PI holders (which I think has direct relevance to this), I don't accept that a legacy resource holder couldn't find one out of the current 8800 RIPE NCC members that wouldn't be appropriate for a sponsorship contract.
Well, the LRHs are a mixed crowd out there, and some will indeed have (legal and logistical) problems to sign a contract with an LIR (or the NCC)
It does sound odd that when we are going away from the direct relation between the RIPE NCC and end users we are suggesting new relationships of the same kind.
Find an LIR or become one. That should be enough.
Yes, in the vast majority of cases, but we may be faced with a few deadlock cases. Thus I do support the escape path.
- section 2.5: you can't be serious? "due to specific enduring or temporary circumstances"?? This is a carte-blanche for any LRH to ignore this policy until the heat death of the universe.
Yes, in this version. But let us take the initial steps into the right direction asap and then have a look at where we got, and how quickly.
I feel a bit lost here. What circumstances are we talking about?
- there is probably a requirement for the LRHs to provide some form of formal identification about who they are and why they have a claim on the resources they claim to hold. For sure, the RIPE NCC cannot certify resources without a reasonable level of due diligence.
Yes, although in reality, the -technically- most credible proof of existence and identity is to look at the connectivity and use for those resources. We are trying to roll back transactions that happened 20+ years ago. Back then, the "documentation" and/or "proof of existence" were a phone call, an email over a set of protocols that didn't even use IP(v4) yet,... :-)
This is usually the biggest obstacle in my experience. We regularly help LRH:s with these matters and I think there should be clearer definitions of the paper work needed for identification. We are often talking about events 15-20 years back and since many LRH:s are large corporate groups they have often changed names and structure a few times since and now they have no idea what documentation to provide to prove they are acually the same entity.
The NCC will need a good deal of flexibility and accept different types of "indications", rather than a complete trail of legal paperwork. In some cases it simply will not exist.
- the proposed policy does not touch on the subject of transfer of resources to third parties. I think this should be dealt with, and that the RIPE NCC should be required to accept any transfer of resources to third parties.
- I'd like to see a requirement for publication of sponsorship details.
This seems like a good idea, and iirc is dicussed already under a different headline.
- the proposed policy does not touch on the subject of deregistration. I believe that it is important to deal with this, as otherwise the RIPE community has no mechanism for garbage collection of resources. The alternative is for the RIPE community to believe that the current set of LHRs will continue to exist until the fall of civilisation and that in this period, they will continue to be the canonical holders of the relevant resources. Not credible.
As a subset of this issue, the following sub-issues arise:
- there are no terms to deal with what the RIPE NCC should do with the resources in the situation where they are deregistered via whatever mechanism. I would suggest the IANA free pool.
- there are no terms to deal with the eventuality that a LRH might want to voluntarily deregister the resources.
- there are no terms to deal with the eventuality that all LRHs will eventually cease to exist, whether through bankruptcy, being forgotten, death, winding up, petition, etc.
- the root contention with this policy still remains: what happens to those organisations who decline to pay a registration payment and who decline to sign any contract? This policy proposal fails to establish a quid pro quo in this situation. The RIPE NCC does not operate on a zero cost basis, and it is only fair that those who depend on its registration services be required to pay for this. I can understand that many LRHs will have an idealogical objection to this but as King Lear said, "nothing will come of nothing".
suggestions:
- the RIPE NCC understands PA & PI address blocks. Would it be sensible from a service atomicity/equivalence point of view to suggest that LRHs who are RIPE NCC members receive exactly the same services as PA address holders (after due diligence on identity performed), and that LRH resources handled by sponsoring LIR be provided with the same services as PI address space?
- ASNs are the same for everyone, so it would probably be useful to declare that any LRH ASN will receive the same service level as any RIPE NCC-assigned ASN (obviously given suitable contractual link between resource holder and the RIPE NCC).
Nick
On the whole, very well put Nick.
Best Regards,
Daniel Stolpe
[ Wearing my hats as LIR manager and employeein the IT department of a University which is itself an LHR ]: While there are still minor improvements to make, I support the proposal. I'd also like to suggest to deal with the management of deregistered or voluntarily returned resources form a higher vantage point, rather than within the framework of a/this special purpose policy. Best regards, Wilfried.