[address-policy-wg] @EXT: Inputs/observations from EUROPOLon proposal 2023-04

Hi Denis,

On Fri, 2023-12-15 at 11:45 +0100, denis walker wrote:

> On Thu, 14 Dec 2023 at 16:34, Tore Anderson <tore at fud.no> wrote:
> > 
> > Did this consultation take the information in the Impact Analysis into
> > account – in particular the clarification made by the RIPE NCC that
> > 2023-04 does *not* change the current policies and procedures when it
> > comes to the registration requirements for End User contact
> > information?
> 
> This is NOT clarified at all in the Impact Analysis. Why are you still
> saying this when I know, you know and by now probably every one knows,
> it is simply NOT true.

(…)

> > As clarified by the RIPE NCC in the Impact Analysis, the current
> > policies and procedures are already allowing assignments to be
> > “somewhat anonymised”. This is not a change that 2023-04 will bring
> > about.
> 
> Again this is simply not true. That line you propose to remove does
> not currently permit anonymised assignments as they MUST include
> contact details of the End User. So this IS a change that 2023-04 WILL
> bring about.
> 
> Will you please finally acknowledge that 2023-04 will allow totally
> anonymised, individual assignment objects that the current policy does
> not allow? (This is without even using the aggregated feature you are
> proposing to introduce.)

As we mentioned in our message on Wednesday, Jeroen and I simply defer
to the RIPE NCC’s interpretation of what current policy allows and does
not allow. We will be happy to acknowledge that 2023-04 changes
something the moment the RIPE NCC acknowledges the same.

Let me remind you of the example assignment made by «SuperLIR GmbH» to
«CarFactory GmbH», registered in the RIPE database as follows:

   inetnum:  192.0.2.0 - 192.0.2.128
   netname:  ABCDEFGHIJKLMNOPQRSTUVWXYZ
   country:  DE
   admin-c:  SUPERLIR-NOC-RIPE
   tech-c:   SUPERLIR-NOC-RIPE
   status:   ASSIGNED PA
   mnt-by:   SUPERLIR-MNT
   source:   RIPE
  
We assume that you agree that the above is a «totally anonymised,
individual assignment object»?

We asked the RIPE NCC whether or not the above object was compliant
with *current* IPv4 address policy or not. The RIPE NCC Policy Officer
answered as follows:

«The above registration compliant with current IPv4 address policy. …»

(For the full answer, see
https://www.ripe.net/ripe/mail/archives/address-policy-wg/2023-September/013856.html
).

This sentiment is echoed in the 2023-04 Impact Analysis (section A,
paragraph 3).

In light of this, we remain convinced that we accurately and truthfully
represent the RIPE NCC’s interpretation of the current policy in our
messages to the working group, and also that we accurately and
truthfully represent the RIPE NCC’s view that 2023-04 will not change
the contact registration requirements. (While admin-c and tech-c will
remain mandatory, they can be delegated as in the example object
above.)

We are well aware that you strongly disagree with the RIPE NCC – and by
extension, Jeroen and I – in this interpretation. That is of course
totally fine. However, if you would like to see the actual
implementation of the policy brought in line with your interpretation
of it, you would need to persuade the RIPE NCC to change their mind –
not Jeroen or I. Jeroen or I cannot change the RIPE NCC’s procedures.

To that end, you might want to submit a policy proposal that would
clarify for the RIPE NCC what the correct implementation should be, so
that their procedures are brought in line with your expectations. If
you do that, we can put 2023-04 on hold pending the outcome of your
proposal.

Best regards,
Tore and Jeroen