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

Dear Tore,

>> 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.

The "audit" that is referred to here is the small audit that we have always
done when evaluating an additional allocation request. It is not the
full LIR audit that we conduct as part of our Audit Activity, nor is it
something new.

It mostly concerns cleaning up exsting records such as:

- LIR contact details that are out of date
- PA approvals that are no longer in use
- Direct assignment customers for whom the LIR is no longer the sponsoring LIR
- Invalid assignments in the RIPE DB

Experience shows that in the vast majority of such evaluations, there are
at least a few records and registrations that are out of date and have to be
corrected and that this is rarely a lot of work.

The RIPE NCC has always considered this to be part of the basic due-dilligence
required to keep records correct and up to date.

Best regards,

Alex Le Heux
Policy Implementation and Co-ordination
RIPE NCC