[members-discuss] [comms] [ncc-announce] [news] RIPE NCC Members and Multiple

Dear RIPE NCC Board,

Thank you for opening this discussion/consultation.

> 1. Is the activity of members opening additional LIR accounts a 
> problem that must be prevented?

It is. The RIPE NCC policies should be written in a way which is
beneficial to its community.
Having a number of organisations using them to profit (financially or by
gaining more IP addresses) is not in our community’s interest.

However, any response to a problem should be proportional to the issue
and therefore the RIPE NCC’s answer to this problem should take
in consideration the number of member abusing the system and the harm
being done to the community.

The last /8 policy was mostly written to make sure new entrants are not
priced out of market and from the data there is no evidence this is yet
the case. Therefore any solution should be careful to keep this goal.

2. If this activity is a problem that must be prevented, what action
should the RIPE NCC take to attempt its prevention?

This is a very broad topic, and a decision by consensus without some
more research and a/some paper(s) to guide the discussion seems unwise
here. That said …

Like others, I can see two scenarios why an organisation may register
several LIR:
  (0) it is practical for their organisation - nothing to see
  (1) to secure for itself several /22 when the last /8 policy comes in
play
  (2) to secure a number of /22 to resell
  … If the board is aware of other case, I would welcome some
enlightemement

For case (1) The RIPE NCC could restrict the number of LIR an
organisation wish to have (to a suitable low but practical number) as
long as this does not impact genuine use of the RIPE NCC.

For case (2), The most likely impact of forbidding this practice may be
to increase the price of IPv4 at sales (passing on the cost of the
business creation), which would affect people needing IP space - and
required to purchase some - more than the people selling it and making
the profit.

Price changes should only be brought forward if the RIPE NCC is sure it
can price ‘bad’ business models out. As this is something we have no
data to make our mind on and and which may also have other side effects
- I am unsure it would be wise.

Also the membership should keep in mind that any new ‘policy’ will 
be
immediately ‘played’ by people actively trying to game the system.
Therefore careful thoughts should be placed on any new rule placed
which will therefore inevitably have unintended consequences.

Regarding enforcing some rules for the transfer of resources, I am
concerned it could place the organisation in a position where it could
be on the receiving hand of legal challenges. Therefore I would favour
any solution which would not require any ‘human judgement’ by the
RIPE NCC at transfer time.

> The Board will monitor the discussion and will review it at the next
> Executive Board Meeting on 31 March 2016. Depending on the outcome of
> that meeting, the Board may propose a resolution for members to vote 
> on at the RIPE NCC General Meeting in May 2016.

I would hope the RIPE NCC does put forwad some proposals for vote. As
the board may not be in a position to ‘guess’ the option(s) most 
likely
to gain consensus, a number of proposals could be presented to the
membership so should a proposal succeed (or fail) others can be
presented to complete / replace it. (This assumes the extra new LIRs are
not already in a veto position with our usual voting engagement)

Also the RIPE NCC may consider to add this information to the list of
RIPE NCC’s LIR as:
  - it would allow to spot who may oppose changes to the RIPE NCC
policies due to personal gain
  - it would the community to use other form of self-regulation to act
on this matter should the RIPE NCC fail to reach consensus.

Some of the options to remove the benefit of registering several LIR are
(more than one could be considered for a solution):
  - creating some more aggresive rules regarding the transfer of
resources
  - not allowing resources transfer for ‘young’ LIR
  - changing the rules for the last /8
     * having a concept of related LIR
     * providing some space in relation to the existing allocation (at
the cost of increasing the fragmentation of the /8).
  - revoking the last /8 policy - treating it as normal
  - revoking the last /8 policy - keeping the space until more
visibility on how best use it can be gathered.
  - .. surely some more ..

Sincerely,

Thomas Mangin
Exa Networks Limited
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