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.

Policy text:

New Policy Text

[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.

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.

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

The RIPE NCC deems it important to highlight our understanding of the following aspects of the proposal.

In the policy proposals there are references to current policy compliance “at the time of transfer” (sections 1.2.3, 1.2.6, 2.0.4,3.0.4). The RIPE NCC interprets "the time of transfer" as the moment the update of the transferred resources is completed in the RIPE registry and in the RIPE Database. It is worth noting that future policy changes may occur during the processing of an ongoing transfer request process: i.e., at the end of the evaluation and before the transfer finalisation. The RIPE NCC emphasises that this will require a new evaluation of the same transfer according to the new policies.

In the case of transfers to the RIPE NCC service region, the RIPE NCC will be the Destination RIR. The Originating RIR will be responsible for evaluating that the Originating LIR complies with all of the relevant policies from their service region.

This policy proposal requires the RIPE NCC LIRs to be in compliance with the RIPE NCC's policies. The RIPE NCC will conduct an audit to ensure that this is the case prior to completing a transfer.

The RIPE NCC would like to note an editorial aspect of this policy proposal: sections 2.3 and 3.3 refer to section 5.5 of “IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region”. References to the broader IPv4 policy framework are also made in sections 2.2 and 3.1 of this policy proposal.

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.