[address-policy-wg] 2017-01 New Policy Proposal (Publish statistics on Intra-RIR Legacy updates)

All,

On Tue, Apr 25, 2017 at 02:39:43PM +0200, Marco Schmidt wrote:
>
>A new RIPE Policy proposal, 2017-01, "Publish statistics on Intra-RIR Legacy updates" is now available for discussion.
>
>The goal of this proposal is to require the RIPE NCC to publish all changes to the holdership of legacy resources in the existing transfer statistics.
>
>You can find the full proposal at:
>https://www.ripe.net/participate/policies/proposals/2017-01

It would be nice if the initial email for a new proposal could
contain the textual changes to policy documents. It would make it
infintely easier to comment inline on the changed sections.

> 4.0 Transfer Statistics
[...]
> This list will contain information about approved changes. The
> following information will be published:
[...]
> Whether it was a transfer according to this policy, a transfer
> due to changes to an organisation's business structure (such as a
> merger or acquisition) or a change in the RIPE Database to the
> organisation holding a Legacy Internet Resource.

Since when has the RIPE NCC a mandate to "approve" changes in
legacy objects? (Except perhaps where a contractual relationship
exists)

> RIPE NCC Services to Legacy Internet Resource Holders
[...]
> 1.1 Definitions
[...]
> Registry services
[...]
> Transfer services as per RIPE Resource Transfer Policies. Any
> change in the RIPE Database updating the organisation holding the
> Legacy Internet Resource can only be finalised once the RIPE NCC
> has received and verified a written request signed by authorised
> representatives of both the current holder and the new holder.

Since when does the RIPE NCC have the mandate to impose such a
process on legacy resource holders? 

> Rationale

> a. Arguments supporting the proposal

> Providing complete statistics about IPv4 transfers and updates to
> the holdership of legacy resources would clearly show the whole
> picture of a young, unpredictable and volatile transfer market.
> We currently see only partial information and it is difficult to
> understand the real dimensions of the size and number of IPv4
> transfers.

> Over the past few years, this update has been requested by
> everyone analysing the IPv4 marketplace and presenting at RIPE,
> ARIN or APNIC conferences. The RIPE NCC already publishes
> statistics on inter-RIR transfers and adding this last bit
> (updates on who holds legacy resources) would be consistent with
> the community's requests around transparency and consistency.

Read this as:
"This is the latest attempt to instrumentalise the
(membership-funded) RIPE NCC as a free business intelligence
resource for IPv4 address brokers."  

> In order to identify all legacy changes, a confirmation will be
> sent to the RIPE NCC to finalise the process (currently this is
> only checked for legacy resources that have a contractual
> relationship with the RIPE NCC or sponsoring LIR). This
> verification requirement does not impact the transfer of legacy
> resources or the updates in the RIPE Database. It only adds an
> additional step to increase the registration quality.

What makes you think imposing a bureaucratic requirement on
legacy holders out of the blue will not be resisted? I remember
the discussions around formalising the legacy resource
relationship with the NCC and how the voluntary nature of any
such relationship was emphasized in order to get any sort of
consensus. 

In short, this proposal has the potential to:

- benefit the few at a cost to all members,
- sour relations with legacy resource holders,
- have a deletorious effect on registry quality where resource
  holders do not wish to submit to a "verification" process,

and therefore I, strenuously, object to this proposal (for
whatever that may be worth)

rgds,
Sascha Luck