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

Daniel Stolpe wrote:

> 
> On Sun, 3 Feb 2013, Nick Hilliard wrote:
> 
>> 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.
> 
> 
> In general yes. Well done so far.
> 
>> 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.
> 
> 
> Might seem minor but the definition certainly has to be correct.

True. I propose to turn the logic around, i.e. resources not obtained by
way of an RIR, because the initial set of 3 RIRs were not born on the same
date :-) Incidentally, the RIPE NCC was the first one to exist.

>> - 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.

Well, the LRHs are a mixed crowd out there, and some will indeed have
(legal and logistical) problems to sign a contract with an LIR (or the NCC)

> It does sound odd that when we are going away from the direct relation
> between the RIPE NCC and end users we are suggesting new relationships
> of the same kind.
> 
> Find an LIR or become one. That should be enough.

Yes, in the vast majority of cases, but we may be faced with a few deadlock
cases. Thus I do support the escape path.

>> - 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.

Yes, in this version.
But let us take the initial steps into the right direction asap and then
have a look at where we got, and how quickly.

> I feel a bit lost here. What circumstances are we talking about?
> 
>> - 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.

Yes, although in reality, the -technically- most credible proof of existence
and identity is to look at the connectivity and use for those resources.

We are trying to roll back transactions that happened 20+ years ago. Back
then, the "documentation" and/or "proof of existence" were a phone call,
an email over a set of protocols that didn't even use IP(v4) yet,... :-)

> This is usually the biggest obstacle in my experience. We regularly help
> LRH:s with these matters and I think there should be clearer definitions
> of the paper work needed for identification. We are often talking about
> events 15-20 years back and since many LRH:s are large corporate groups
> they have often changed names and structure a few times since and now
> they have no idea what documentation to provide to prove they are
> acually the same entity.

The NCC will need a good deal of flexibility and accept different types
of "indications", rather than a complete trail of legal paperwork. In some
cases it simply will not exist.

>> - 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.

This seems like a good idea, and iirc is dicussed already  under a different
headline.

>> - 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
> 
> 
> 
> On the whole, very well put Nick.
> 
> 
> Best Regards,
> 
> Daniel Stolpe

[ Wearing my hats as LIR manager and employeein the IT department of a
  University which is itself an LHR ]:

While there are still minor improvements to make, I support the proposal.

I'd also like to suggest to deal with the management of deregistered or
voluntarily returned resources form a higher vantage point, rather than
within the framework of a/this special purpose policy.

Best regards,
Wilfried.