[ncc-services-wg] 2012-07 Discussion Period extended until 21 February 2013 (RIPE NCC Service to Legacy Internet Resource Holders)

On 24/01/2013 13:33, Emilio Madaio wrote:
> The text of the policy proposal 2012-07, "RIPE NCC Services to Legacy
> Internet Resource Holders", has been revised based on the community
> feedback received on the mailing list.  We have published the new
> version (version 2.0) today. As a result a new Discussion Phase is set
> for the proposal.

ok, I'll bite.

in general, this is a vast improvement on v1.0 and I think it could
feasibly form the basis of a working policy, but there are still some
shortcomings and omissions which need to be dealt with.

LRH == legacy resource holder

minor nits:

- 1.0 introduction: some legacy resources were assigned by the InterNIC
after the creation of the RIPE NCC, so it is incorrect to define LRHs as
those who "were granted internet resources before the creation of the RIPE
NCC".  A similar comment applies to the definition given in 1.1.

- section 3.0: contractual requirements: I don't understand why there is a
suggested contractual requirement to acknowledge that the terms and
conditions of the original assignment are outside the scope of the new
contractual arrangement, unless (straw man) someone can provide a copy of
those T&Cs.  I.e. this is probably unenforceable.  I dunno.  Looks odd to me.

- 4.0: "in cast the situation corresponds to section 2.5 above" - perhaps
the authors may have omitted section 2.6?

larger grievances:

- I don't believe that there is a requirement for section 2.4.
Disregarding that the RIPE NCC has ended the possibility of directly
assigned resources for general PI holders (which I think has direct
relevance to this), I don't accept that a legacy resource holder couldn't
find one out of the current 8800 RIPE NCC members that wouldn't be
appropriate for a sponsorship contract.

- section 2.5: you can't be serious?  "due to specific enduring or
temporary circumstances"??  This is a carte-blanche for any LRH to ignore
this policy until the heat death of the universe.

- there is probably a requirement for the LRHs to provide some form of
formal identification about who they are and why they have a claim on the
resources they claim to hold.  For sure, the RIPE NCC cannot certify
resources without a reasonable level of due diligence.

- the proposed policy does not touch on the subject of transfer of
resources to third parties.  I think this should be dealt with, and that
the RIPE NCC should be required to accept any transfer of resources to
third parties.

- I'd like to see a requirement for publication of sponsorship details.

- the proposed policy does not touch on the subject of deregistration.  I
believe that it is important to deal with this, as otherwise the RIPE
community has no mechanism for garbage collection of resources.  The
alternative is for the RIPE community to believe that the current set of
LHRs will continue to exist until the fall of civilisation and that in this
period, they will continue to be the canonical holders of the relevant
resources.  Not credible.

As a subset of this issue, the following sub-issues arise:

	- there are no terms to deal with what the RIPE NCC should do with the
resources in the situation where they are deregistered via whatever
mechanism.  I would suggest the IANA free pool.

	- there are no terms to deal with the eventuality that a LRH might want to
voluntarily deregister the resources.

	- there are no terms to deal with the eventuality that all LRHs will
eventually cease to exist, whether through bankruptcy, being forgotten,
death, winding up, petition, etc.

- the root contention with this policy still remains:  what happens to
those organisations who decline to pay a registration payment and who
decline to sign any contract?  This policy proposal fails to establish a
quid pro quo in this situation.  The RIPE NCC does not operate on a zero
cost basis, and it is only fair that those who depend on its registration
services be required to pay for this.  I can understand that many LRHs will
have an idealogical objection to this but as King Lear said, "nothing will
come of nothing".

suggestions:

- the RIPE NCC understands PA & PI address blocks. Would it be sensible
from a service atomicity/equivalence point of view to suggest that LRHs who
are RIPE NCC members receive exactly the same services as PA address
holders (after due diligence on identity performed), and that LRH resources
handled by sponsoring LIR be provided with the same services as PI address
space?

- ASNs are the same for everyone, so it would probably be useful to declare
that any LRH ASN will receive the same service level as any RIPE
NCC-assigned ASN (obviously given suitable contractual link between
resource holder and the RIPE NCC).

Nick