[address-policy-wg] 2013-03 New Draft Document and Impact Analysis Published (No Need - Post-Depletion Reality Adjustment and Clean up)

Hello Tore,

While I am curious for Michele's response to your mail too, here is my bit, as I feel I agree with him in terms of principles.

First of all, I am not totally against your proposal; it cleans up the policy text reflecting today's circumstances to some extent and it makes a long document way more readable. 
This is also why I am writing back because I've read the draft policy document from the beginning to the end.  

My observation is that the new document proposed is not exactly a "registration" policy document.
It more looked to me like a description of how address space management is done within RIPE NCC region "by the RIPE NCC". 

If I am not missing anything crucial, the main points described are:
 
- The language is English, 
- How big an allocation can be, 
- That there is no PI anymore to be assigned directly from the NCC pools to End users (except for the IXPs) so all resources will only goto LIRs 
- And these blocks can be transferred between LIRs.

The only bit about registration I see in the new text is section 4.0 Registration Requirements and it does not go more than saying details should be recorded in the database. 

So it does not contain any substantial information for registration or address management on the LIR's side. 

This is interesting as now with this proposed policy any End user's chance to get any IPv4 address space will be through an LIR and hope that these LIRs are responsible and know what they are doing. I would like to see some guidelines or at least principles mentioned in this document so the LIRs know their responsibility in terms of fair address management as well as the End Users so they know what to expect from these LIRs. This is what I would be expecting from a transparent documentation of a set of policies and principles that are still in place. 

We may not have too many specific policies to set for the few left-over resources but I would like to believe we still have "principles" towards the responsible management of these resources. 

In that sense Michele has a point and I argue that LIRs need to be guided for "good address management" even without the "conservation" principle as the top priority in the new IP world. This is missing in the proposed policy text for it to be considered as a helpful "registration" policy in my opinion.  

In practice, I can set up a new LIR now and ask for a new allocation and I may be someone who does not have any previous RIPE or RIPE NCC experience. 
If all I have is this document, I am not sure if it tells me enough about my responsibilities, while I will be a critical token in the EU address management and registration system by just becoming an LIR. 


My other concern is in regards to the transfers. As neatly put by the NCC Board in the Impact Analysis:

---
As mentioned in previous sections, the policy proposal would negatively affect the ability of LIRs to engage in inter-RIR transfers, as the RIPE NCC’s service region would be the only one without a needs-based requirement for transfers.
Implementation of the policy could expose LIRs to legal challenges under EU competition law.
---


I think singling out the RIPE NCC region in the world of transfers may not be the best idea at this stage.

Kind regards
Filiz Yilmaz




On 24 Jul 2013, at 10:52, Tore Anderson <tore at fud.no> wrote:

> * Michele Neylon - Blacknight
> 
>> As previously stated, I do NOT support the "no need" policy and
>> cannot support this document.
>> 
>> IP addresses are a finite resource, as we all know, and obliging
>> people to provide some level of justification makes sense.
>> 
>> The argument for "conservation" may no longer be valid, but there
>> will always be a compelling argument in favour of good resource
>> management, which I believe the policy covers.
>> 
>> RIPE should not remove the requirement to provide justification.
> 
> Hi Michele,
> 
> I doubt you'll find anyone in the working group who is against good
> resource management. I am convinced that the proposed policy is not in
> conflict with good resource management, otherwise I would never have
> proposed it. While I can obviously only speak with certainty for myself,
> I assume that the people who support the proposal feel the same way.
> 
> While it appears you believe that the proposal will bring about poor
> resource management, your message neglected to explain why or how. This
> makes it rather difficult for me to try to alleviate your concerns.
> 
> As Gert also pointed out recently, the main reason I believe that IPv4
> would continue to be consumed responsibly under the proposed policy, is
> that the LIRs in the region are painfully aware that there is no more
> IPv4 to be had from the RIPE NCC. Should an LIR anyway decide to go on a
> "spending spree" with its remaining inventory, it would only end up
> hurting itself by expediting its own depletion date. The community will
> not be impacted - without a Common, there can be no Tragedy.
> 
> Best regards,
> Tore Anderson
> 

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