<div class="markdown"> Dear RIPE NCC Board, Thank you for opening this discussion/consultation. <blockquote> <ol> <li value=1>Is the activity of members opening additional LIR accounts a problem that must be prevented?</li> </ol> </blockquote> 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. <ol> <li value=2>If this activity is a problem that must be prevented, what action should the RIPE NCC take to attempt its prevention?</li> </ol> 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. <blockquote> 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. </blockquote> 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 </div>