[address-policy-wg] 2014-05 New Draft Document and Impact Analysis Published (Policy for Inter-RIR Transfers of Internet Resources)

* Marco Schmidt
> The draft document for version 2.0 of the policy proposal 2014-05, 
> "Policy for Inter-RIR Transfers of Internet Resources" has now been 
> published, along with an impact analysis conducted by the RIPE NCC.

Supported. I think it's fairly obvious that some resource holders will
engage in inter-regional transfers, and for the sake of registry
accuracy we should ensure that our policies do not stand in the way of
this. I have no objections to Nick's proposed amendments.

I'd like to point out that the proposal does not modify ripe-623 section
6.4 (PI transfers) in the same way it does 5.3 (PA transfers). This is
understandable, as 6.4 was very recently added, but it does contain
language that could conceivably be interpreted as a barrier to
inter-regional transfers, e.g., «any holder of Provider Independent (PI)
address space is allowed to re-assign complete or partial blocks of IPv4
address space that were previously assigned to them *by the RIPE NCC*»
(emphasis mine). That said, the Impact Analysis makes it clear that PI
transfers will be permitted, so this doesn't alone justify a version 3.0
of the proposal.

I note that the ARIN staff does not consider the policy to be
sufficiently compatible with theirs. That comes as no surprise to me,
but at least 2014-05 opens the door for the ARIN community to adjust
their policy in a way that would allow inter-regional transfers between
our regions, while at the same time allowing them to insist on need
evaluation being performed. We'll just have to wait and see whether they
accept our invitation or not; at least we're trying to be flexible and
accommodating here, we can't do much more than that.

That the APNIC staff are unsure whether or not their policy would be
compatible (due to different need evaluation requirements) surprises me
greatly. From http://www.apnic.net/policy/transfer-policy#rir-transfer:

> 4.3    Conditions on the recipient of the transfer
>
> The conditions on the recipient of the transfer will be defined by
> the RIR where the recipient organization holds an account. This means:
>
>   * For transfers to an APNIC recipient, the conditions defined in
>     Section 3.3 will apply.
>   * Where the recipient is in another region, the conditions on the
>     recipient as defined in the counterpart RIR's transfer policy at
>     the time of the transfer will apply.

Section 3.3 is where the need evaluation requirement is. It therefore
seems quite clear that for a transfer from the RIPE region to the APNIC
region, the receiver would be required to undergo a need evaluation per
section 3.3. This does not seem to be in conflict with 2014-05, rather
quite the opposite due to the statement that «the RIPE NCC will also
comply with the commitments imposed by the receiving RIR, in order to
facilitate the transfer».

For transfers from the APNIC region to the RIPE region, APNIC's section
3.3 (and thereby any APNIC need evaluation requirement) is not invoked;
rather, the «counterpart RIR's transfer policy» is. In other words,
2014-05 + ripe-623 sections 5.5 and 6.4. Since the APNIC policy
explicitly delegates all conditions on the RIPE region recipient to RIPE
region policies, I cannot see any potential conflict for transfers in
the APNIC->RIPE direction either.

I'm perplexed that the APNIC staff is uncertain whether or not 2014-05
is compatible with their policy. The way I read them, they unequivocally
are. Perhaps there are some APNIC folks lurking here who could elaborate?

Tore