[address-policy-wg] [policy-announce]2014-05 New Draft Document and ImpactAnalysis Published (Policy for Inter-RIR Transfers of InternetResources) (Erik Bais)

* steve.r.wright at bt.com

> Hi all, I support the goals of 2014-15, the suggestion below seems to be a practical solution, if acceptable to all parties.

Agreed.

I would have ideally preferred to see language that was sufficiently
generic to accommodate for any condition (i.e., not just limited to
ARIN's "needs-based" requirement) imposed by another RIR region on the
RIPE region entities engaging in inter-region transfers with that RIR
region. However, I see that accomplishing this might be more trouble
than it's worth, especially when taking into account that ARIN doesn't
consider the attempt currently in 2014-05 adequate.

So it would seem that a "KISS" approach would be better, explicitly
putting in a "needs-based" requirement as mandated by ARIN. John, thank
you for suggesting text, it's very helpful to have a starting point that
we know that ARIN will consider compatible.

I have some comments on your suggested text, though:

* John Curran

>  "For transfers from RIR regions which require needs-based policies,
>   recipients must provide a plan to the RIPE NCC for use of the
>   transferred resource within 24 months."  (for example)

1) «RIR regions which require needs-based policies» might be too broad.
APNIC requires needs-based for intra-region transfers but not for
inter-region transfers. As they already have (IMHO) misinterpreted the
current "interop clauses" in 2014-05 to apply to them even though there
is no need for that, we need to make it clearer that it only applies for
regions which require *the RIPE region* to have needs-based policies.

2) Hard-coding 24 months is a risk. If for example the ARIN community
changes their transfer policy to have different need period, then we
would find ourselves with incompatible policies again. So I think that
we should instead just refer to whatever need period the other RIR has.

3) I think it would be more flexible to not require the usage plan to be
presented to the NCC, but that it could be presented to the other RIR
instead. My reasoning is that the other RIR might already have the forms
and criteria ready for performing need evaluation in a way that's
(obviously) "compatible" with that RIR's own policies, while the NCC
might not. Therefore it could potentially be easier for all involved
parties if the other RIR performs the required need evaluation (if that
RIR and the NCC agrees on such a transfer procedure, that is). It might
also help prevent possibly complaints from the other region that the NCC
doesn't perform stringent enough evaluation, and so on.

Suggested new text that takes the above into account below. It would
replace the second paragraph in section 2.0 of 2014-05. (Also, the last
sentence of section 3.0 should be removed.)

«For transfers from RIR regions which require the RIPE region to have
needs-based policies, recipients must provide a plan to the RIPE NCC or
the other RIR for the use of the transferred resource within the time
period defined by the transfer policy of the other RIR».

It would be good if you could confirm that this variant would also be
regarded as "compatible" by ARIN, John.

Tore (who feels somewhat guilty for this stuff being tricky in the first
place...)