RIPE NCC Services to Legacy Internet Resource Holders

Summary of Proposal

A framework is proposed as the basis for rigorous maintenance of registration data and for delivery of registry services to legacy  Internet resource holders in the RIPE NCC service region.
In addition, amendment to existing policy is proposed where this is not consistent with the framework just mentioned.

Policy Text

a. New policy

Abstract

This proposed framework establishes the principles to be applied by the RIPE community in offering and implementing registry services for legacy Internet resource holders. The importance of maintaining accurate records in the RIPE database is recognised as the NCC's principal task.  The community of legacy Internet resource holders is defined. Some rights of members of this community are described, as are the principles governing the manner in which the RIPE NCC should engage with and provide services to this community.

1.0 Introduction

Internet resources obtained prior to or otherwise outside the current hierarchical Internet Registry System (involving the RIPE NCC or any of the other Regional Internet Registries) are considered legacy resources.

The RIPE NCC maintains and publishes registry data for resources held by its members and by legacy resource holders located in the RIPE NCC service area. It strives to maintain the accuracy of these data.  The RIPE NCC also provides reverse DNS delegation and a routing registry for IP address and Autonomous System Numbers, both of which include legacy resources.

Historically, legacy resource holdings have been kept outside any formal relationship between their holders and the RIPE NCC, even in cases where such a relationship covers other resources held by the same holder. To improve the accuracy and trustworthiness of the registry data the RIPE NCC and a number of legacy resource holders have indicated that a formal relationship is desirable.

Some of the legacy holders are also interested in a more formal relationship which would give clarity regarding services and allow them to participate in the RIPE NCC's cost-sharing model.
This framework defines the basis for rigorous maintenance of registration data and for delivery of registry services to legacy Internet resource holders in the RIPE NCC service region.

1.1 Definitions

The following definitions apply in this policy and are of particular importance to the understanding of the goals described in this document.

Internet Resource
An IP address block or Autonomous System number.

Legacy Internet Resource
Any Internet Resource obtained prior to or otherwise outside the current system of hierarchical distribution (by allocation or assignment) through the Regional Internet Registries.

Legacy Internet Resource Holder
The holder of a Legacy Internet Resource. Either by receiving these resources directly or by receiving (part of) Legacy Internet Resources from a Legacy Internet Resource Holder.

Registry Services
Services provided by the RIPE NCC in its capacity as a Regional Internet Registry, including the following and such additional services as may be identified from time to time as registry services:

• Maintenance of data relating to Internet Resources  by the NCC in their Internet Resource registry;
• Access to these data for update by or on behalf of the respective holder;
• Public availability of registration data;
• Certification of these data; and
• Delegation of reverse DNS to the registered DNS servers.

Registry Service Element
In practice, any Legacy Resource Holder actually avails of a subset of the Registry Services mentioned above.  Where it is necessary to distinguish between the entire class of Registry Services and the specific Registry Services actually provided in a particular case, the latter are described as Registry Service Elements.

1.2 Scope

The framework described in this document applies to the provision of Registry Services by the RIPE NCC in respect of Legacy Internet Resources. Any other services offered by the RIPE NCC (whether different in nature, or relating to other kinds of resources) are out of scope for this policy.

Any existing or future RIPE policy referring to resources shall not apply to legacy resources unless the policy explicitly includes legacy resources in its scope.

Rights of the holder to hold, use, or transfer any Legacy Internet Resource are not addressed or restricted by this policy.

The holder of a Legacy Internet Resource who so wishes may, separately in respect of each such resource held, choose either to return the resource to the appropriate free pool or to have the resource registered without legacy status as if it had been distributed by the RIPE NCC.  In either such case, the resource involved will no longer be subject to this policy or to any other provisions of a RIPE policy which relates exclusively to Legacy Internet Resources, and will no longer be eligible to have its legacy status re-instated as provided for below.

In case the current holder, or a previous holder, of a resource which was originally a legacy resource (or part of a legacy resource) has, before the coming into effect of this policy, registered the resource as if it had been distributed by the RIPE NCC, whether in connection with a transfer of resource or otherwise, the current holder shall be given the opportunity to have the legacy status of the resource re-instated and to choose to have it registered under one of the options available for registering a legacy resource, as set out in this or any subsequent policy relating specifically to Legacy Internet Resources.

In the case just mentioned, if the resource holder, having been alerted to the other options available, confirms the intent to have a particular resource registered as if it had been distributed by the RIPE NCC, the NCC shall apply the RIPE policies about resources it has distributed to these particular resources too, rather than reverting to the legacy status and beginning a fresh engagement with the resource holder from that position.

The scope of this policy does not include the resolution of any dispute arising as to the right to use a particular Legacy Internet Resource.

Although specification of charges made by the RIPE NCC is also out of scope here, the appropriate kind of charge corresponding to a specific set of circumstances is identified where this seems useful for clarity.

2.0 Relationship between Legacy Internet Resource Holder and RIPE NCC

A direct or indirect contractual relationship between a Legacy Internet Resource Holder and the RIPE NCC provides contractual certainty to both parties regarding services, rights, and responsibilities.  Such a relationship also provides for payment of appropriate fees for services provided by the RIPE NCC. Different methods for establishing such a relationship are described below in sections 2.1, 2.2, 2.3, and 2.4.

In exceptional cases where the Legacy Resource Holder wishes to engage with the RIPE NCC but none of the methods just mentioned is feasible, section 2.5 will apply.

Section 2.6 will apply in case such a relationship or agreement as described below in sections 2.1, 2.2, 2.3, 2.4, or 2.5 has not been established.

Section 2.7 will apply in case such a relationship or agreement has been established, but has lapsed.

2.1 Legacy Internet Resource Holder is already a RIPE NCC member

If the Legacy Internet Resource Holder is already a RIPE NCC member then there is already a contractual relationship between the RIPE NCC and the Resource Holder, who may extend the existing contract by registering the Legacy Internet Resources involved subject to the conditions defined in section 3 below.

In this case, the RIPE NCC may require the payment of charges for membership and services according to the RIPE NCC charging plan for the time being in force.

2.2 Option to become a RIPE NCC member

A Legacy Internet Resource Holder who is not already a RIPE NCC member may opt to become a member by establishing a membership contract under which the Legacy Internet Resources involved will then be registered subject to the conditions defined in section 3 below.

In this case, the RIPE NCC may require the payment of charges for membership and services according to the RIPE NCC charging plan for the time being in force.

2.3 Option to engage via sponsoring LIR

A Legacy Internet Resource Holder who either is not already a RIPE NCC member or, being a member, does not wish to extend the membership contract as provided in section 2.1 above may opt to enter into a contract with a RIPE NCC member who is willing to act as a Sponsoring LIR for the purposes of registering the Legacy Resources involved, subject to the conditions defined in section 3 below, and subject to approval by the RIPE NCC of the form of contract between the Resource Holder and the Sponsoring LIR.

In this case, the Sponsoring LIR may require the payment of charges according to the terms of the contract agreed with the Legacy Resource Holder.

2.4 Option to engage directly with the RIPE NCC

A Legacy Internet Resource Holder whose circumstances match those described in section 2.3 above, but cannot find a Sponsoring LIR with which a mutually satisfactory contract of the kind mentioned in that section, may opt to enter a non-member service contract with the RIPE NCC for the purposes of registering the Legacy Resources involved, subject to the conditions defined in Section 3 below.

In this case, the RIPE NCC may require the payment of reasonable charges according to the terms of the non-member service contract.

2.5 When there are obstacles for 2.1/2.2/2.3/2.4

Due to specific enduring or temporary circumstances which are recognized by the RIPE NCC as being outside the resource holder's control, a legacy resource holder may be unable to enter into a relationship of any of the kinds described above (2.1 .. 2.4).  In such a case, the RIPE NCC will offer and provide registry services as if a contractual relationship of one of the kinds described above had been established, and shall do so for as long as the circumstances continue which constitute an obstruction to the establishment of a contract.

However, notwithstanding the preceding paragraph, the RIPE NCC may refuse to provide any specific registry service for which particular technical requirements apply, which the Resource Holder is unable to meet.

2.6 No relationship

In case no formal relationship has been established in support of a particular legacy resource, the RIPE NCC

• will continue to provide any registry service element already provided in support of each Legacy Internet Resource involved;
• will have no obligation to begin to provide any registry service element not already provided in support of a particular Legacy Internet Resource, even in case the service element is provided in support of any other Legacy Internet Resource held by the same or another Resource Holder;
• and may update the related entries in the RIPE Database from time to time to correspond to the current actual situation.

2.7 Lapse of relationship or agreement

In case a relationship or agreement as described above in sections 2.1, 2.2, 2.3, 2.4, or 2.5 has lapsed, the RIPE NCC may refuse to continue to provide, in support of each legacy resource involved, any service element which was not being provided immediately before the establishment of the relationship or agreement which has lapsed.

3.0 Contractual requirements

The service agreement covering registration of a legacy Internet resource between the corresponding Resource Holder and either the Sponsoring LIR or the RIPE NCC must include

• identification of each resource covered by the service agreement;
• specification of the service or services offered in respect of each resource identified;
• the obligation for both parties to comply with this policy and with other RIPE policies which relate to Legacy Internet Resources;
• a statement of the responsibility of the resource holder to maintain accurate data in the registry in respect of each resource identified;
• a statement of the responsibility of the resource holder to assist the RIPE NCC with data-accuracy checks;
• a statement that the RIPE NCC is not entitled to deregister the resources for whatever purpose unless so instructed by the resource holder;
• a statement of the measures which the RIPE NCC is entitled to take in case the resource holder does not meet their contractual responsibilities.

4.0 Services to be offered and provided

The RIPE NCC will offer and provide services in respect of a given Legacy Internet Resource corresponding to the relationship established with the holder of that resource.

In the case of any of the forms of relationship described in sections 2.1, 2.2, or 2.3 above, this policy shall not exclude any service from being offered and/or provided in respect of a Legacy Internet Resource registered under the terms of the corresponding direct or indirect contractual agreement relationship with the RIPE NCC.

In the case of any of the forms of relationship described in sections 2.1, 2.2, 2.3, or 2.4 above, the RIPE NCC shall offer Registry Services as defined in section 1.1 above in respect of each Legacy Internet Resource involved and as requested by the corresponding Resource Holder.
 In case the situation corresponds to section 2.6 above, the RIPE NCC shall maintain each Registry Service element already provided in respect of any corresponding Legacy Internet Resource.

5.0 Arbitration in case of conflict

In case of conflict between a Legacy Internet Resource Holder and the RIPE NCC about any matter within the scope of this policy, the RIPE NCC Conflict Arbitration Procedure is to be applied.

b. Amendment to existing policy document RIPE-592

It is proposed to replace section 5.5 of RIPE-592, currently

"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. "

with

"Any LIR is allowed to re-allocate complete or partial blocks of IPv4 address space that were previously allocated to them by the RIPE NCC or otherwise through the Regional Internet Registry System."

Rationale

• Arguments supporting the proposal

  New policy covering provision of services to legacy resource holders is needed because the scope of existing RIPE policies extends only to Internet resources distributed through the RIPE NCC.  Such new policy will support the RIPE NCC in addressing what RFC 2050 describes as the "primary function" of a Regional Internet Registry and will give legacy Internet resource holders clarity as to the services they may expect.

  Extensions to the RIPE NCC service model are proposed because of the need for a "public registry" (rather than a members-only registry) identified in RFC 2050.
  [and as may be received during the discussion phase]

• Arguments opposing the proposal

  Extensions to the RIPE NCC service model are proposed.
  [and as may be received during discussion phase]

Legacy Internet Resources Proposal October 2013

The RIPE NCC is hereby publishing an initial impact analysis based on its interpretation of the policy proposal text. This analysis is also intended to highlight the need for more guidance and information from the community in defining a number of fundamental pre-requisites in order to determine the nature of the various implementations, and the impact of the policy proposal itself.

Executive Summary

Given the length of this analysis, the following Executive Summary presents some of the interpretations and issues the RIPE NCC outlines in a more concise format. For further detail and the reasoning behind these points, please refer to the relevant section in the impact analysis below.

1. Due diligence checks will be required to verify the legitimacy of Legacy Resource Holders. If the correct documentation cannot be provided, the RIPE NCC will be unable to enter into a contractual relationship with the Legacy Resource Holder.
2. Section 2.1 of the proposal allows Legacy Internet Resources to be covered by the RIPE NCC Standard Service Agreement (SSA). Modifications to the SSA will require approval by the General Meeting (GM).
3. Section 2.4 of the proposal allows the Legacy Resource Holder to engage directly with the RIPE NCC through a special contract if they cannot find a sponsoring LIR. While the RIPE NCC cannot think of any circumstances where this might be the case, it concedes that this could be possible. The creation of such a special class of contract would require approval by the GM.
4. Section 2.5 allows the Legacy Resource Holder to conclude no contract due to special enduring circumstances. The RIPE NCC will only provide the registration services it currently offers for Legacy Internet Resources without a contract. The RIPE NCC will be unable to force these resource holders to maintain accurate data in the registry. The RIPE NCC will add a remark to the RIPE Database object: no contract.
5. In cases where the Legacy Resource Holder has no formal relationship with regards to particular Legacy Internet Resources, the proposal allows for the RIPE NCC to update entries in the RIPE Database. The RIPE NCC will add a remark to the RIPE Database object: no contract.
6. If a Legacy Resource Holder that has signed an agreement does not comply with their contractual responsibilities, the RIPE NCC will apply a similar procedure as it does for other resources. If Legacy Resource Holders continue to not comply, their contract may be terminated.
7. Currently, The RIPE NCC Arbitration Procedure does not apply to Legacy Internet Resources. Amendments to the arbitration procedure are subject to approval by the GM.
8. If the proposal is accepted, the RIPE NCC considers it fair to contact Legacy Resource Holders that have their resources registered under the umbrella of an LIR and offer them the contractual options of the accepted proposal.
9. Legacy Internet number resource blocks may contain several layers of hierarchy. It is therefore not clear which of the organisations involved has the right to enter into a contractual agreement. It is the responsibility of the parties involved to find an agreement on which party is the legitimate holder of the Internet Legacy Resources. Only when the parties involved have agreed on a decision will the RIPE NCC evaluate a contractual relationship request.
10. If the community decides that this proposal should allow for the certification of Legacy Internet Resources, the RIPE NCC will need to create a certification system specific to these resources.
11. The RIPE NCC will contact all Legacy Resource Holders and offer them the options listed in the accepted policy. The total number of legacy Internet Resources in the RIPE Registry is approximately 4,200 IP blocks and 740 AS numbers, held by approximately 2,500 organisations.
12. RIPE Database objects referring to Legacy Internet Resources currently have several different "status:" attribute values. The RIPE NCC proposes changing these to ‘LEGACY’.
13. The RIPE NCC also proposes introducing a mandatory "status:" attribute for all AUT-NUM objects, which would take the value 'LEGACY' for all legacy AS Numbers. For all other AS Numbers the values would be set either to 'ASSIGNED' (assigned by the RIPE NCC) or 'OTHER' (assigned by other RIRs).
14. The introduction of the new type of direct engagement of the Legacy Internet Resource Holder with the RIPE NCC will have to be mapped out on the RIPE NCC systems that support business processes for this type of contract.

A. Understanding of the Policy Proposal

This policy proposal is meant to be applied by the RIPE NCC to Registration Services, as regards Legacy Internet Resources.

Legacy Internet Resources, as defined in this proposal, are any Internet resources obtained prior to (or otherwise outside of) the current system of hierarchical distribution (by allocation or assignment) through the Regional Internet Registries (RIRs). While this definition is not limited to resources in the RIPE Registry, the RIPE NCC does not have authority over Legacy Internet Resources in other registries. If this proposal is accepted, the RIPE NCC will implement it only for Legacy Internet Resources that are currently registered in the RIPE Registry.

This definition also refers to resources that have been distributed by IANA or InterNIC (or according to the appropriate manner at the time of distribution). This includes Legacy Internet Resources that have been transferred to the RIPE Registry since 1992.

This definition does not include:

• Resources that have been distributed or “obtained” in an inappropriate manner (e.g. hijacked resources).
• Resources transferred from other RIRs that have lost their “legacy” status due to the relevant RIR policies or processes (provided the RIPE NCC has an inter-RIR transfer policy).
• Resources that no longer have their legacy status after a relevant request by the Legacy Resource Holders (if the Legacy Resource Holders have requested for their resources to be registered and maintained as if they had been distributed by the RIPE NCC).

Registration Services, as defined in this proposal, are those services provided by the RIPE NCC in its capacity as an RIR. The proposal specifies them as services “including the following and such additional services as may be identified from time to time as registry services (section 1.1). These services include:

• Maintenance of data relating to Internet Resources by the NCC in their Internet Resource registry. The RIPE NCC understands this as the service to maintain a comprehensive record of the Internet number resources registered within its service region.
• Access to these data for update by or on behalf of the respective holder. The RIPE NCC understands this as the service of enabling the legitimate holder to update records in the RIPE Registry. The RIPE NCC must ensure that updates are legitimate. For this reason, updates are accepted solely by individuals and organisations authorised by the legitimate holder of the Internet number resource. Access to and updates of this data can be made by anyone using public tools (such as RIPE Database updates). Additionally, organisations that have entered into a contractual relationship with the RIPE NCC can update these data using member-only tools such as the LIR Portal.  
• Public availability of registration data. The RIPE NCC understands this as the service of making registration data available through the RIPE Database.
• Certification of these data. The RIPE NCC understands this as the service of making Legacy Internet Resources in the RIPE Registry eligible for Resource Certification (RPKI).
• Delegation of Reverse DNS to the registered DNS servers. The RIPE NCC understands this as the service of providing reverse DNS services to Legacy Internet Resources registered in the RIPE Registry.

This definition gives a non-exclusive list of services. Other services, both current and future, may also be considered Registration Services. This proposal does not specify the process according to which a service (other than those listed) is identified as Registration Services. Therefore, the RIPE NCC will make this decision after consultation with the membership and RIPE Community.

Registration Services Element – the term Registration Services Element is solely used in this document when referring to services that the RIPE NCC already provides with regards to Legacy Internet Resources (section 2.6). Therefore, the RIPE NCC understands that this term contains any of the following services:

• Maintenance of data relating to the Internet number resources registered by the RIPE NCC in its Internet resource registry, as defined above
• Access to these data for update by or on behalf of the respective holder
• Public availability of registration data
• Reverse DNS delegation

The proposal outlines a number of options for Legacy Resource Holders to enter into a contractual relationship for their resources, so that they can be provided with Registration Services. These options are analysed in detail below.

Transfers

The policy proposal provides that the rights of the holder to transfer any Legacy Internet Resources are not addressed or restricted by this policy. If the proposal becomes policy, the RIPE NCC may facilitate:

• Intra-RIR transfers. The new holder will have to adhere to this policy (i.e. have to sign a new contract so that they receive all registration services).
• Inter-RIR transfer of Legacy Internet Resources, provided:
  • There is a RIPE inter-RIR transfer policy that does not prohibit such transfers taking place
  • The other RIR facilitates such transfers in accordance with their policies and practices

B. Legal Impact

Contractual Relationship Between Legacy Resource Holder and the RIPE NCC

Legacy Resource Holder

If this proposal becomes policy, the RIPE NCC should enter into a contractual relationship with the Legacy Resource Holder or approve a contractual relationship between the holder and a sponsoring LIR.

This proposal defines the holder of Legacy Internet Resources as one who has received these resources either directly or from another Legacy Resource Holder. This definition does not include holders of resources that are not covered by the RIPE NCC’s understanding of the definition of Legacy Internet Resources (see above under Legacy Internet Resources).

The RIPE NCC is entitled to perform due diligence checks in order to enter into a contract with someone that claims to be a Legacy Resource Holder. These due diligence checks will consist of:

• Verification that the contractual party exists (and is valid) and that it is properly represented in the signing of the agreement in accordance with the RIPE NCC procedural document “Due Diligence for the Quality of the RIPE NCC Registration Data”.
• Verification that the party claiming to be the Legacy Resource Holder is indeed the legitimate holder of the resources. The holder will need to submit the relevant proof and documentation. The RIPE NCC will need to update the above-mentioned due diligence procedural document to clarify the details of this verification process.

If a party claiming to be a Legacy Resource Holder is unable to comply with these due diligence checks by providing satisfactory documentation as required, the RIPE NCC will not accept a contractual relationship as described in this proposal. In cases where there is uncertainty about the resource holder, the RIPE NCC will handle these resources as outlined in section 2.6 of the proposal (see Option 6 below).

Different Types of Contractual Relationship

Option 1 (section 2.1) - The Holder is a RIPE NCC Member and Extends the Existing Contract to the Legacy Internet Resources

If the Legacy Resource Holder has already signed the RIPE NCC SSA, the proposal provides that the SSA may be extended to cover their Legacy Internet Resources as well. However, the SSA must include certain conditions as defined in section 3.0 of the proposal.

The RIPE NCC offers the same SSA to all of its members. If the proposal becomes policy, the RIPE NCC will have to consider ways to include the extension of the SSA to Legacy Internet Resources in its legal framework. The outlined conditions may require amendments to the SSA, which will require approval by the General Meeting (GM).

Option 2 (section 2.2) - The Legacy Resource Holder Becomes a RIPE NCC Member

The same applies as in Option 1.

Option 3 (section 2.3) – The Legacy Resource Holder Enters into a Contract With a Sponsoring LIR

According to the proposal, this option should be available for non-LIRs as well as for LIRs that do not wish to include their Legacy Internet Resources under their SSA. In the latter case, however, it should be made clear that the RIPE NCC will not allow the Legacy Resource Holder to become the sponsoring LIR for its own Legacy Internet Resources.

Option 4 (section 2.4) – The Legacy Resource Holder Engages Directly with the RIPE NCC with Another Agreement (Not the SSA)

This option is available for those Legacy Resource Holders that cannot find a sponsoring LIR with which a mutually satisfactory contract can be signed. While the RIPE NCC cannot think of any circumstances where this might be the case, it concedes that this could be possible.

The creation of a special agreement for RIPE NCC services to non-members would need approval by the GM.

Option 5 (section 2.5) – The Legacy Resource Holder Concludes No Agreement

According to the proposal, the Legacy Resource Holder may not be required to have an agreement due to specific enduring or temporary circumstances which the RIPE NCC recognises as being beyond the holder’s control.

According to the proposal, the RIPE NCC will have to keep providing the services it currently provides to Legacy Resource Holders as if there was a contract in place and should do so for as long as the special circumstances still exist. In these cases, the RIPE NCC would be unable to provide services beyond the ones already provided to any Legacy Resource Holder (i.e. those identified above as Registration Services Elements) without a contract.

The RIPE NCC would like to point out that, currently, in order to provide minimum services for Legacy Internet Resources registered in the RIPE Database (not covered by a contract), it applies a due diligence process to verify that the person requesting the service is (or is acting on behalf of) the one registered in the RIPE Database as the Legacy Resource Holder. If this proposal becomes policy, the RIPE NCC will keep applying this due diligence process. Also, the RIPE NCC has no means of compelling the resource holder to maintain accurate data in the registry.

The fact that the RIPE NCC has no means of compelling the resource holder, without an agreement, to maintain accurate data in the RIPE Registry is considered a technical limitation related to Resource Certification (RPKI). The resources listed on a certificate are derived from information in the RIPE Registry. In case of Legacy Resource Holders (without an agreement), in practice there is only an entry in the RIPE Database that attests to the holdership. It is currently not technically possible to issue a resource certificate based on this information alone.

The RIPE NCC will add the remark "No-contract" in the INETNUM object.

Option 6 (section 2.6) – No Relationship

The proposal describes cases where the Legacy Resource Holder has no formal relationship with regards to particular Legacy Internet Resources. In this case, the RIPE NCC will have to continue providing any Registration Services Elements that are already provided to this specific Legacy Resource Holder. The RIPE NCC has defined what it considers to be Registration Services Elements above.

This option applies if a relationship or agreement as described in sections 2.1-2.5 has not been established (see section 2.0 of the proposal).

The situation applying under Option 5 above, regarding the due diligence process applied to Legacy Internet Resources registered in the RIPE Database but not covered by a contract, also applies to this option. In addition, the RIPE NCC has no means of compelling the resource holder to maintain accurate data in the registry.

The proposal also allows for the RIPE NCC to “update the related entries in the RIPE Database in accordance with the actual situation”. The RIPE NCC will add the remark "No-contract" in the RIPE Database resource object.

Non-compliance with the Contractual Responsibilities

If a Legacy Resource Holder that has signed an agreement as described in options 2.1-.2.4 does not comply with their contractual responsibilities, the RIPE NCC will apply a similar procedure as it does for other resources (see also http://www.ripe.net/ripe/docs/ripe-578#b2).

In particular, in case of non-compliance:

• The RIPE NCC will add the remark "under review" in the RIPE Database resource object.
• A warning statement is added to the relevant records of the RIPE Database mentioning that the Legacy Internet Resources are not in compliance with data accuracy obligations
• The RIPE NCC will revoke any certificates generated by the RIPE NCC Certification Service

If legacy holders continue to not comply, their contract may be terminated.

In this case:

• The RIPE NCC will add the remark “No-contract” in the RIPE Database resource object; and
• A warning statement will be added to the relevant records in the RIPE Database mentioning that the Legacy Internet Resources are not covered by a contractual relationship; and
• The RIPE NCC will withdraw the reverse delegation

Consequences of the termination of the contract

In accordance with section 2.7 of the proposal, if the holder’s agreement based on any of the options 2.1-2.4 is terminated for any reason, the RIPE NCC will not be obliged to keep providing the holder with services other than those identified above as Registration Services Elements.

Arbitration

Currently, arbitration does not apply to Legacy Internet Resources. If this proposal is accepted, the RIPE NCC arbitration procedure will have to be updated. Amendments to the arbitration procedure are subject to approval by the GM.

C. Impact on Registration Services

Legacy Internet Resources Currently Registered Under an LIR Umbrella

As mentioned above (Understanding of the Proposal–Legacy Internet Resources), the proposal includes Legacy Internet Resources that have been transferred to the RIPE Registry since 1992 and subsequently registered under the umbrella of a RIPE NCC member.

Between 1992 and 2011, the RIPE NCC has, at the request of holders, registered Legacy Internet Resources under the umbrella of an LIR on an ad hoc basis, without entering into a contractual relationship for these resources.

Between January 2012 and August 2012, the RIPE NCC accepted statements by Legacy Resource Holders agreeing that their resources are to be considered as having been distributed by the RIPE NCC, therefore losing their legacy status. These resources have been registered under the umbrella of an LIR at the holders’ requests.

If this proposal becomes policy, the RIPE NCC understands that it will contact the Legacy Resource Holders that have had their Legacy Internet Resources registered under the umbrella of an LIR, either with or without a signed statement, to offer them the contractual options of the accepted proposal.

Identifying the Legitimate Holder of a Legacy Internet Resource

Some Legacy Internet Resources were distributed by InterNIC to registries such as academic institutions and National Research and Education Networks (NRENs) with the intention that they would be further distributed to other organisations. Consequently, these Legacy Internet number resource blocks may contain several layers of hierarchy.

It is often not clear if the legitimate holder of these resources is the organisation that received the resources from InterNIC for redistribution, or the subsequent organisation that received the resources. It is therefore not clear which of the organisations involved has the right to enter into a contractual agreement.

When the situation presents itself where there are multiple layers of legacy resources distribution, it is the responsibility of the parties involved to find an agreement on which party is the legitimate holder of the legacy resource. Only when the parties involved have agreed on a decision, the RIPE NCC will evaluate a contractual relation request.

Resource Certification (RPKI)

The RIPE NCC would like to highlight that if the community decides that this proposal should allow for the certification of Legacy Internet Resources, the RIPE NCC will have to create a certification system specific to these resources. This is because of a previous decision by the RIPE NCC Executive Board to limit certification to RIPE NCC members-only address space.

Registration Services Operational Impact

• The RIPE NCC will contact all Legacy Resource Holders that have registered their resources as described in the section “Legacy Internet Resources Currently Registered Under an LIR Umbrella” and offer them the options listed in the accepted policy.

  The impact on the RIPE NCC to implement the above point is considered as low impact.

• The RIPE NCC will, via email, inform all other Legacy Resource Holders (contact details registered in the RIPE Database) about the options listed in the accepted policy. A remark “no contract” will be added to RIPE Database objects for Legacy Internet Resources not covered by a contractual agreement.

  The impact on the RIPE NCC to implement the above point is considered as low impact.

• The total number of Legacy Internet Resources in the RIPE Registry is approximately 4,200 IP blocks and 740 AS numbers, held by approximately 2,500 organisations.

  Assuming that all Legacy Resource Holders would want to enter into a contractual relation either with a Sponsoring LIR or with the RIPE NCC, we estimate the effort required to verify the documentation to be between 700 and 900 FTE working days. This estimate is based on experience accumulated through the ERX project, the legacy resource registration project and the implementation of RIPE Policy Proposal 2007-01.

• The creation of both internal and external documentation will be a one-time effort.

D. Impact on other departments

RIPE Database:

Currently, most legacy Internet number resource objects in the RIPE Database have the "status:" attribute value EARLY-REGISTRATION. But there are some that have other values.

This situation does not allow for a transparent and consistent overview, clearly indicating which resources are Legacy Internet Resources. The RIPE NCC receives many inquiries from organisations requesting clarification.

In order to solve this issue, and to increase the level of transparency, consistency and clarity, if this proposal is accepted, the RIPE NCC proposes to change the "status:" attribute value of all INETNUM objects for legacy space to the status LEGACY. This includes all more specific objects. Since the way this address space is used may not match the same structure used for RIPE allocated address space, it is considered more important to reflect its legacy status rather than where it fits within any hierarchy. The RIPE NCC can make this change in a single update to all legacy objects and their more specific objects.

AUT-NUM objects do not currently have a "status:" attribute. For the same reasons described above, if this policy proposal reaches consensus, the RIPE NCC proposes to introduce a mandatory "status:" attribute to the AUT-NUM object. This new attribute would take the value 'LEGACY' for all legacy AS Numbers. For all other AS Numbers, this value would either be set to 'ASSIGNED' or 'OTHER'. The value 'ASSIGNED' would be for all AS Number resources assigned by the RIPE NCC. The value 'OTHER' would be for copies of AS Number resources assigned by other RIRs that have been added to the RIPE Database for routing purposes.

The impact on the RIPE NCC to implement the above points is considered low impact. However, adding a mandatory attribute for the AUT-NUM object could have a high impact on the community because these objects are updated frequently by automated processes. Every AS Number resource holder would need to be well informed of such a change with plenty of time to adjust their scripts.

The RIPE NCC would like the community to consider this as one possible solution, along with any other options, and advise the RIPE NCC on the best way forward.

If this proposal is accepted then the required RIPE Database changes will be provided separately to the RIPE Database Working Group to discuss implementation using the appropriate and agreed procedures.

Business Applications:

If approved by the GM, the introduction of the new type of direct engagement of the Legacy Resource Holder with the RIPE NCC (Section 2.4) will have to be mapped out on the RIPE NCC systems supporting business processes for this type of contract.

Among the processes that will have to be mapped out are:

• Sign-up process for Legacy Resource Holders
• Billing process for Legacy Resource Holders
• Delivery of certain RIPE NCC Services to Legacy Resource Holders

The requirements are not known at the moment, so it is not currently possible to accurately estimate the impact of the proposal on the RIPE NCC software systems.

The introduction of the new status for INETNUM objects and the addition of a new mandatory attribute to AUT-NUM objects will have little impact on the RIPE NCC software systems.

Other:

Several other departments, such as Customer Services, Finance and Communications, will be affected but this will be low impact and on the department level.