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

On Oct 21, 2014, at 10:28 AM, Tore Anderson <tore at fud.no> wrote:
> 
> * 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 wanted to make that this community understood the reason for the 
incompatibility, since it did not appear to be a mismatch in actual 
policy intent.  Glad it was helpful.

> I have some comments on your suggested text, though:
> ...
> 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.

To be clear, ARIN policy for inter-RIR transfers does not require any 
specific need period - my text was solely to be an example.  There must 
be policy text that refers to needs-based (i.e. some operational need 
for the address space), but any change in ARIN's policy for transfers
within the ARIN region should not require a change to RIPE policy for 
needs-based compatibility in any circumstance.

> 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.

Once the RIPE Inter-RIR transfer policy is determined to be needs-based and 
compatible, then processing of individual requests can easily be handled by 
RIPE NCC without any need for sharing of requesters information with other 
parties. This works quite well quite Inter-RIR transfers between APNIC and 
the ARIN region today, whereas there are likely to be potential implementation 
issues with your proposed approach that would need to be carefully explored; 
for example, ARIN has no relationship to a requestor in the RIPE region, no
non-disclosure agreement, etc.

> 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.

I believe that all of the RIRs must rely on each other for faithful 
implementation of policy, but again, this has not been a problem for
other Inter-RIR transfers to/from the ARIN region.

FYI,
/John

John Curran
President and CEO
ARIN