[address-policy-wg] 2012-05 New Draft Document and Impact Analysis Published (Transparency in Address Block Transfers)

> -----Original Message-----
> From: address-policy-wg-bounces at ripe.net [mailto:address-policy-wg-
> bounces at ripe.net] On Behalf Of Tore Anderson
> Sent: Wednesday, September 05, 2012 3:06 AM

> > So... Again your feedback please! Is there anyone who thinks that
> > anonymising details of rejected transfers is a bad idea? (and if so:
> > please explain why)
> 
> I object to publishing information of rejected transfers (and, by
> extension, rejected pre-approvals). The NCC does not publish any
> information about rejected PA allocation requests either, and I don't
> see why transfers should be any different.

[Milton L Mueller] You have not given us any reason not to provide this information, other than "we haven't done it before" - which I do not accept as a good reason. 

I will tell you why we need to do this. There are serious concerns in the existing transfer market about potential discrimination in the application of needs assessments, at least in the ARIN region. Needs assessment is not an entirely scientific or objective exercise. Providing basic statistical information about how many applications are rejected avoids undermining confidentiality but also provides some knowledge as to how many attempted transfers are coming in and how many are rejected. If there are complaints about the application of needs assessment criteria - and there already are in other regions - at least the community has some information about  

> That said, I am not quite sure it is really necessary, as all
> the requested information (except rejections) is already available: All
> allocations are listed in alloclist.txt along with their date and
> holding LIR (reg-id and name). It will be trivial to check for transfers
> - allocations made after the last /8 policy comes into effect outside of

[Milton L Mueller] Trivial to whom? To someone who has a system set up to constantly track this or who has bulk access to the entire database and can write scripts to check for it on a regular basis? This is not reasonable. RIRs need to recognize the significance of the emergence of a transfer market. The attitudes here in RIPE that I detect are incredibly complacent. A market for addresses will profoundly transform the nature of IP number allocation. All RIRs are obligated to do everything they can to make this market easily understood, transparent and efficient. Why shouldn't they? Can you provide a positive reason why not?

> The only information I know of that isn't easily accessible is which LIR
> originally held the transferred resource, since historic copies of
> alloclist.txt isn't available on the FTP. You would have had to build up
> your own archive by mirroring the file daily. I do expect that people
> who are interested in monitoring transfers would do just that, instead
> of waiting for the monthly digest called for by this proposal.

[Milton L Mueller] I think the description you provide of what would be necessary to track this information without the policy proposed in 2012-5 self-evidently proves that this policy is needed. Your approach is complex, expensive and would limit this information to a few specialists who would keep the data proprietary in order to protect their investment in collecting it. My proposal would make it accessible to anyone. You have not provided any good reason to limit it in that way. You have not provided any costs or harms that would occur if the information is made accessible. Perhaps you can do so? 

> I think that a simpler and probably much faster way (no PDP!) to
> accomplish the desired <transparency in address block transfers> would
> be to simply ask the NCC to publish historic versions of alloclist.txt,
> and/or to include a regid/LIR column for resources in delegated-ripencc-
> extended-latest (for which historic archives are available). This has
> been recently suggested in the services wg, but it was objected to,
> because of privacy issues for assignment holders (so irrelevant relevant
> to this proposal). I think I'll go and revive that thread now...

[Milton L Mueller] No, that is not "simpler". Not by any reasonable definition of "simple." RIPE could easily make this accessible to all with a few keystrokes and procedural change at the source. Can you explain why it should not? 

> Oh, and by the way: why specify exactly monthly? As noted above, the NCC
> has no problems publishing most of this information on a daily basis. If
> they are able to automatically publish the transfer list daily too, why
> not let them?

 [Milton L Mueller] This is a valid modification. I would be happy with "daily"