[address-policy-wg] 2012-02 New Draft Document Published (Policy forInter-RIR Transfers of IPv4 Address Space) (Tore Anderson)

3. Re: 2012-02 New Draft Document Published (Policy for
Inter-RIR Transfers of IPv4 Address Space) (Tore Anderson)
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Message: 3
Date: Sat, 01 Dec 2012 12:57:07 +0100
From: Tore Anderson <tore.anderson at redpill-linpro.com>
Subject: Re: [address-policy-wg] 2012-02 New Draft Document Published
(Policy for Inter-RIR Transfers of IPv4 Address Space)
To: address-policy-wg at ripe.net
Message-ID: <50B9F093.9040700 at redpill-linpro.com>
Content-Type: text/plain; charset=ISO-8859-1

>From the Impact Analysis:

> 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.

I think that this is an excessively strict interpretation of the policy,
one which I suspect isn't the intention of the proposer. In my opinion,
an LIR should be assumed to be in compliance with the RIPE NCC's [sic]
policies; the mere act of participating in an inter-RIR transfer should
not cause an automatic LIR Audit.

Mandatory LIR Audits would only serve to increase the amount of hassle
and bureaucracy involved in completing such transfers, and might well
discourage LIRs from participating in them at all.

Given that this is the NCC's interpretation of 2012-02, I don't support
the proposal as it is currently worded, and hope it could be modified so
that it will not cause mandatory or automatic LIR Audits.

-- 
Tore Anderson
Redpill Linpro AS - http://www.redpill-linpro.com/


Can someone explain more about what is involved in the audit? I was
picturing more
of a needs justification process where the applicant would illustrate
that current IP's were 80%
utilized.  Is that the same as an audit?

Also, Tore's last point on 2012-03 should be applied to the passing of
2012-02.  In the event that 
2012-03 is agreed to, and needs justification is extended from 3 months
to 24 months, then 5.5 will have
new wording to accommodate the change.  Further, if 2012-02 is passed to
allow for inter-RIR transfers 
to-from RIR's with like-policies, then Chapter 5.5 “Transfers of
Allocations” of “IPv4 Address Allocation
 and Assignment Policies for the RIPE NCC Service Region”; will
require an additional wording change.  

Specifically, the second paragraph of 5.5 says: "...address space may
only be re-allocated to another LIR that is also a
 member of the RIPE NCC. " and if Inter-RIR transfers are approved this
will change to LIR's of another RIR.



Sandra Brown
President
IPv4 Market Group
sandrabrown at ipv4marketgroup.com
716-348-6768
www.ipv4marketgroup.com