Policy for Inter-RIR transfers of IPv4 address space

Summary of Proposal:

This policy proposal describes how transfers of IPv4 address space between LIRs of different Regional Internet Registries will occur. It also adapts the local transfer policy to allow compatibility in inter-RIR transfers.

Policy text:

Current

[Following text will be modified from the RIPE Policy Document “IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region”, if the proposal reaches consensus. This will result in a new policy section]

5.5 Transfers of Allocations

Any LIR is allowed to re-allocate complete or partial blocks of IPv4 address space that were previously allocated to them by either the RIPE NCC or the IANA. Such address space must not contain any block that is assigned to an End User.

Address space may only be re-allocated to another LIR that is also a member of the RIPE NCC. The block that is to be re-allocated must not be smaller than the minimum allocation block size at the time of re-allocation. An LIR may only receive a transferred allocation after their need is evaluated and approved by the RIPE NCC, following the policies set for receiving further allocations within RIPE region (see the Section 5.3 Additional Allocations of this document).

[…]

New

[Following text will replace section 5.5 in the RIPE Policy Document “IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region”, if the proposal reaches consensus. This will result in a new policy section. NOTE: rephrased the first sentence of the second paragraph]

5.5 Transfers of Allocations

Any LIR is allowed to re-allocate complete or partial blocks of IPv4 address space that were previously allocated to them by either the RIPE NCC or the IANA. Such address space must not contain any block that is assigned to an End User.

Address space may only be re-allocated to another LIR that is also a member of the RIPE NCC or a member of an RIR with a compatible inter-RIR transfer policy. The block that is to be re-allocated must not be smaller than the minimum allocation block size at the time of re-allocation. An LIR may only receive a transferred allocation after their need is evaluated and approved by the RIPE NCC, following the policies set for receiving further allocations within RIPE region (see the Section 5.3 Additional Allocations of this document).

[…]

 [Following text will result in a new RIPE Policy Document “Policy for Inter-RIR Transfers of IPv4 address space”, if the proposal reaches consensus.]

Abstract:

This policy describes the transfers of IPv4 address space between LIRs of different Regional Internet Registries.

1.0 Introduction

Apart from transfers of address space within the service region of the RIPE NCC, this policy defines the framework that outlines what specific rules apply to IPv4 address space transfers in between the different RIR regions. Because of its multi-regional nature and the geographical scope of RIPE policy, this policy also refers to policies for transfer of IPv4 address space as defined by other regions.

1.1 Scope

This document describes the policy for transferring IPv4 address space to or from the RIPE NCC service region. This policy applies only to IPv4 address space and not to any other number resources. This document does not describe any rules about transfers of IPv4 address space within the RIPE NCC service region; instead it refers to those rules to maintain a single set of rules for all IPv4 address space transfers as much as possible.

1.2 Definitions

1.2.1 Originating LIR: The LIR that the IPv4 address space is transferring away from;

1.2.2 Originating RIR: The RIR responsible for the service region in which the Originating LIR is present;

1.2.3 Originating Policy: The current and relevant address policies within the Originating RIR service region at the time of the transfer;

1.2.4 Destination LIR: The LIR that is receiving the transferred IPv4 address space;

1.2.5 Destination RIR: The RIR responsible for the service region in which the Destination LIR is present;

1.2.6 Destination Policy: The current and relevant address policies within the Destination RIR service region at the time of the transfer;

2.0 Transferring IPv4 address space to the RIPE NCC service region

RIPE NCC shall accept any IPv4 address space transferred to the RIPE NCC service region, provided:

1. The Originating LIR and the IPv4 address space transferred are in compliance with the Originating Policy;
2. The Destination LIR and the IPv4 address space transferred are in compliance with the Destination Policy;
3. The Destination LIR is qualified to receive the transferred IPv4 address space as outlined in the policy for transfers within the RIPE NCC service region, as defined in Chapter 5.5 “Transfers of Allocations” of “IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region”;
4. There must be an inter-RIR IPv4 transfer policy in effect in the Originating RIR service region at the time of transfer.

3.0 Transferring IPv4 address space from the RIPE NCC service region

RIPE NCC shall accept any IPv4 address space transferred from the RIPE NCC service region, provided:

1. The Originating LIR and the IPv4 address space transferred are in compliance with the Originating Policy;
2. The Destination LIR and the IPv4 address space transferred are in compliance with the Destination Policy;
3. Originating LIR and the IPv4 address space transferred are in compliance with the policy for transfers within the RIPE NCC service region, as defined in Chapter 5.5 “Transfers of Allocations” of “IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region”;
4. There must be an inter-RIR IPv4 transfer policy in effect in the Destination RIR service region at the time of transfer.

Rationale:

Given the original geographical distribution of IPv4 address space and the geographical distribution of current needs for IPv4 address space, it stands to reason that no IPv4 address space should be ‘locked up’ within the RIR service region they were originally allocated to. With a transfer policy already in place for use within the RIPE NCC service region, it doesn’t make much sense to devise a completely separate set of rules for transfers to or from the RIPE NCC service region, so this policy merely refers to the rules set out in the policy for transfers within the RIPE NCC service region. In order to prevent conflict, it also refers to policy for transfers of the region the address space is being transferred to or from. Furthermore, section 5.5 of the IPv4 Address Allocation and Assignment Policy currently refers to allocations to LIR members of the RIPE NCC and must therefore be changed to refer to LIRs that are members of any RIR with a like inter-RIR transfer policy.

a. Arguments Supporting the Proposal

• Provides a minimal framework for Inter-RIR IPv4 address space transfer that doesn’t set any new rules on either party or the address space involved, other than current policy as is applied within the relevant RIR service regions.
• Increases the supply of IPv4 addresses available to RIPE NCC LIRs;
• Maintains the integrity of RIPE's whois database and ensures they are part of the approval and transfer process;
• Allows European companies to participate in a market already available to ARIN and APNIC LIRs;
• Will allow RIPE NCC LIRs with excess IPs to transfer to companies in other RIR regions;
• Defines the condition of compatibility for inter-RIR transfer policies between RIRs.

b. Arguments Opposing the Proposal

Unequal needs based policies between RIRs may create regional inequities.

Note: in order to provide additional information related to the proposal, details of an impact analysis carried out by the RIPE NCC are documented below. The projections presented in this analysis are based on existing data and should be viewed only as an indication of the possible impact that the policy might have if the proposal is accepted and implemented.

A. RIPE NCC's Understanding of the Proposed Policy

In addition to what was outlined in the previous impact analysis, the RIPE NCC deems it important to highlight our understanding of the following aspects of the current proposal. Due to the nature of the changes in the updated proposal, it is only this first section that differs from the previous impact analysis.   

This policy would allow LIRs to transfer IPv4 allocations to and from the RIPE NCC service region. When transferring allocations between service regions, the Destination RIR will be responsible for evaluating the justification for the transfer. The minimum block size that can be transferred is the minimum allocation size at the time of the transfer. Currently this is a /22 in the RIPE NCC Service Region. If the other RIR's policies define a different minimum size, the larger of the two will prevail.

This new version of the proposal contains an amendment in section 5.5 that adds another requirement for transfers where the RIPE NCC is the Originating RIR. In addition to the Destination RIR having an inter-RIR transfer policy in place, this policy must also be compatible with the RIPE NCC’s. This requirement has not been introduced for transfers where the RIPE NCC is the Destination RIR.

B. Impact of Policy on Registry and Addressing System

Address/Internet Number Resource Consumption:

After analysing the data that is currently available, the RIPE NCC does not anticipate that any significant impact will be caused if this proposal is implemented.

Fragmentation/Aggregation:

After analysing the data that is currently available, the RIPE NCC does not anticipate that any significant impact will be caused if this proposal is implemented.

C. Impact of Policy on RIPE NCC Operations/Services

Registration Services:

It is very relevant to note that the implementation of this policy proposal will require a significant effort of co-ordination between the RIPE NCC and the other RIRs. It is unclear at the moment how much time and resources will be needed to fully implement the proposal.

Billing/Finance Department:

After analysing the data that is currently available, the RIPE NCC does not anticipate that any significant impact will be caused if this proposal is implemented.

RIPE Database:

After analysing the data that is currently available, the RIPE NCC does not anticipate that any significant impact will be caused if this proposal is implemented.

D. Legal Impact of Policy

If this policy proposal will be accepted, the RIPE NCC will need to create appropriate legal procedures and template agreements in order for all parties to understand and agree on the preconditions and the consequences of the transfer in accordance with the provisions of this policy.