[members-discuss] Administrative procedures within RIPE NCC: Any way to soften it ?

Hello,

On 7/22/20 3:15 PM, Hans Petter Holen wrote:
>> The Board has decided on a measure to be taken immediately to deter the acquiring of /22s of address space with the sole purpose of transferring it to another legal entity. The RIPE NCC will therefore broaden the definition of policy transfers by including network acquisitions in the scope of the transfer policy.

This is completly *unrelated* to this topic (organisational changes in
well-established LIRs, which exists for many years). Board measurement
was targetted against *new* LIRs, which were created just to grab
declining IPv4 addresses (and I know this was huge problem).

But this is like throwing the baby out with the bathwater. Why apply
such requirement for changes requiring new payment to parties, where
their organisational are well-documented and officially confirmed (by
courts, company registries etc)? If company-spinoff is performed legally
according to all laws and legal successor is clearly vissible even in
formal public documentation (public company registry), I don't see
logical reason to apply that "protective" measurements... that was not
their purpose.

It's simply extensive interpretation of the law and rules in my eyes
just to simplify work at NCC. It's not a service for members, it's stick
in the way making life much harder. And more expensive.

> I am sure the board would like to hear from the broader membership if
> this should be changed.

It's quite complicated I think wait here from wider audience (with
respect to recent topic-hijacks to unrelatted discussions in the past).
And non-affected LIRs have no reason to raise their concerns. Until
they'll face similar problems... that's normal behavior.

> My recommendation would be an holistic approach to the fee structure
> rather than exceptions from the main rule that may require interpretation.

There's already such exception, which is widely in use. If I sign new
SSA according to section 4.0 of RIPE-709, there's no signup payment
(even SSA mentions signup payment requirement).

Major question is still unanswered. If there's legal sucessor after
documented organisational change, why isn't possible to sign new SSA and
terminate existing one (action like during company name change). If
needed, also transfer agreement can be signed in one batch to confirm
change. Involved member did not asked for new addresses, he just wanted
to move it's membership from one company to another, from mother to
child... just because not only name, but also registration *number*
changed (because legal spin-off procedure according to law forces this
in some cases).

And finally - we're even not talking about documented policies. As we
see, this is simple board decision hidden deeply in mailing-lists
archives, but NCC staff hides itself behind policies. And Dutch law is
just another excuse, which doesn't have real justification. Finally, NCC
staff (both registration services & legal department) aren't able to
point to these decisions, that's real experience...

I think these "board decisions" (which have long-term impact) should be
also clearly documented on NCC website in parts, which are focused for
particular task (organisational changes in this cases).

- Daniel