[ncc-services-wg] UA IP transfers situation

Hi All !


> Hi All!
>
> Let me point out what is happening with Ukrainian resources
> transfers.
>
> We are now facing with the hugest government based attack
> against our basic principles of government free self
> regulation.
>
> I think the real target of the attacker is to obtain
> a financial gain from IPv4 market.
>
> First, the deputy of Ukrainian Parliament Olexandr Fedienko
> wrote a letter to RIPE NCC with the initiative of hand-checking
> transfer requests with Ukrainian government agency. This idea
> was not accepted neither by Ukrainian, nor by European
> community. People understand this is a step out from RIPE
> community self-governance and the source of corrupted money for
> this agency as it should decide either pass the transfer or
> not.
>
> After that initiative was rejected, Fedienko with the help of
> his representatives at the RIPE 85 meeting in Belgade tried to
> ban all the transfers outside Ukraine. His representatives
> promoted a set of very expressive and emotional speeches about
> possible forced transfers. He also used his power and pushed
> a set of Ukrainian companies to register online to RIPE 85 (and
> for some reason - for GM, I think he just don't understand the
> difference) and to send a copy-pasted message about support of
> the ban.
>
> The idea is to close the market, limiting the transfers only to
> Ukrainian companies.


The proposal is to temporarily deny ALL transfers, inside and outside of
Ukraine, so that all resource holders will remain with what they have, and
nobody could possibly get hold of their resources.


> And to buy resources almost for free, as the war pushes people
> to sell it, while the buy offers are very limited. It looks
> logical. But their arguments for the ban are not.


This is very hypothetical scenario, based on wrong assumption, described
one paragraph above.

And even if that assumption would not be wrong, it is quite unrealistic
that Ukrainian companies that maintain infrastructure and struggle to
rebuild networks on destroyed or de-occupied territories are going to sell
their IP addresses to get some profit - they do not have enough of them
already, how are they going to get more?

On the other hand, there is quite real scenario for companies whose
business is based on re-selling IP addresses or providing "services" of
moving resources out of Ukraine, including the one that Max Tulyev
announced just several days ago (
https://www.facebook.com/mt6561/posts/pfbid0273c1ndwbZXBLc9ST7sFwisCC9o8Bw9Yhs8vAUfX1e9HP5UmQexvUCbnGp8RtQVvFl
).

Such businesses will not thrive if the transfers will be frozen.

Of course, these companies are also part of the RIPE community. But the
community could choose what values it supports.


> They said they need the whole-Ukrainian ban to protect
> resources at the distressed areas against the forced transfer.
>
> First, while RIPE NCC accepts "documents" issued on the
> occupied territories based on LPR/DPR/Russian jurisdiction,
> this ban of Ukrainian resources transfer can be easily avoided
> just using these "documents". Including for the real forced
> transfers.


It isn't clear what is the problem you describe here.
However, it is a problem that many companies from those territories are
registered by RIPE NCC based on registration papers issued either by russia
or dnr/lnr, and therefore might not be seen as Ukrainian.
Ideally RIPE NCC should block transfers of companies registered on the
whole internationally recognized territory of Ukraine, including all
occupied territories.


> Second, it is nothing to do with Ukrainian companies based on
> the territories not in the distress area. From the war front
> line to for example Uzhgorod city there are ~800km and 2000m
> high mountains. Why should we complicate the life for these
> companies?


For someone who fled the country it might seem that there are distressed
areas and areas "behind high mountains". But the reality in Ukraine is that
the whole country is distressed. There are companies registered in what you
describe as "safe areas", but they have representatives on all territory of
the country, including occupied areas. Or the head of a company in the
"safe" territory could have relatives who are under occupation. In all such
cases they could be threatened and forced to sign transfer documents.


> Third, it is unclear why transfers inside Ukraine should not be
> banned for the time the policy is being updated. If we really
> have the problem, it is logical to ban all transfers.


Again, the proposal is to temporarily hold all transfers of Ukrainian
holders.


> Forth, I asked many times to show any example of the forced
> transfer in the distress area. They can't. I did not hear any
> of these situations myself. So for me the problem they are
> trying to solve did not even exist.
>
> This situation with the possible country-wide transfer ban rose
> a big discussion in Telecom Ukraine telegram channel, which is
> a discussion point for a lot of (but not all) Ukrainian
> Internet and telecom companies.
>
> Instead of explaining things for my requests, Olexandr Fedienko
> call me there a hidden Russian FSB agent, and Olena Kushnir
> said I do not understand that "we should keep a valuable
> resource inside our country during the war". But sorry, these
> are definitely not their resources! So they should not tell
> holders what to do with it, until we are not live in
> a Communist country where all things belongs to the government.
>
> This situation makes deeply concern Ukrainian community and
> resources holders. We are really afraid some of this proposals
> will be implemented without consensus inside Ukrainian
> community, just because of government letters, emotional
> speeches. And definitely without any "closed meetings" (C)
> Olena Kushnir with NCC staff inaccessible for people with
> another opinion.
>
> It will be so kind if RIPE NCC officials release a statement
> where they clearly state they will not implement any bans for
> resource holders not in the distress area. And any changes on
> the policy will be implemented with the current policy
> development process, consensus, and in the co-operation with
> all community. This will calm down the situation and will
> convince people that NCC really respects and protects the
> interests of the community members.
>
> Thank you very much for the long reading!
>

And in the end it will be better if we focus our efforts on solving the
problem, and not on writing a hypothetical stories. The discussion should
be constructive and effective.
Thanks.

Viktoriia Opanasiuk
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