No Restrictions on End User Assignments in Intra-RIR Transfers

Summary of Proposal

This policy proposal intends to update the intra-RIR IPv4 transfer policy with the removal of the restriction on End User assignments.  Currently, in the “IPv4 Address the Allocation and Assignment Policies for the RIPE NCC Service Region” the section 5.5 “Transfer of Allocations" requires address space to be free from End User assignments before a transfer is possible. This was discussed at the RIPE 66 meeting and the Address Policy Working Group concluded that it was worth submitting a policy change to the PDP.

Policy Text

a. Current policy text

[Following text is to be modified from the RIPE Policy Document “IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region”, if the proposal reaches consensus. This will result in a new policy section.]

5.5 Transfers of Allocations

Any LIR is allowed to re-allocate complete or partial blocks of IPv4 address space that were previously allocated to them by either the RIPE NCC or the IANA. Such address space must not contain any block that is assigned to an End User.

[…]

b. New policy text

[Following text will replace section 5.5 in the RIPE Policy Document “IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region”, if the proposal reaches consensus. This will result in a new policy section. NOTE:  removed the last sentence of the first paragraph.]

5.5 Transfers of Allocations

Any LIR is allowed to re-allocate complete or partial blocks of IPv4 address space that were previously allocated to them by either the RIPE NCC or the IANA.

[…]

Rationale

1. Arguments supporting the proposal
   1. End Users that run their services on an address block assigned to them by an LIR may reach a point where they wish to establish themselves as an LIR. This proposal would allow such operators to continue using those same addresses, without the need to re-number their network – upon reaching an agreement with their original upstream LIR, an allocation block containing the assignment in use may be transferred to the newly created LIR. While such a process would seem to be straightforward, the current policy does not permit such a transfer since the allocation is not free of End User assignments (and as it is not a merger or acquisition).
   2. Internet service providers will more easily be able to transfer their complete business, including LIR account, End Users, used and unused address space to another entity. The current policy requires LIRs to follow two different procedures to transfer used and unused address space.
      The current policy situation may also create an incentive for LIRs to cancel their service relationships with End Users to allow them to transfer an empty (unused) allocation.
   
   
   
2. Arguments opposing the proposal

   The LIR receiving the transferred allocation may decide to cancel the service relationship with End Users using assignments from that allocation.

   Counter-argument:

   Every LIR can decide to cancel the service relationship with their End Users, in line with the contractual terms and conditions established between LIR and End User.

In order to provide additional information related to the proposal, details of an impact analysis carried out by the RIPE NCC are documented below. The projections presented in this analysis are based on existing data and should be viewed only as an indication of the possible impact that the proposal might have if it is accepted and implemented.

A. The RIPE NCC's Understanding of the Proposed Policy

The RIPE NCC understands that this proposal would remove the requirement for an allocation to be free of any block assigned to an End User before it can be transferred. Accordingly, if the proposal is accepted, it would become possible to transfer an allocation regardless of whether parts of it are assigned or not.

From a RIPE NCC perspective, this policy would also allow a more straightforward administrative process for the handover of LIR accounts between organisations.

The proposal says nothing about what should happen to the assigned address blocks during/after the transfer. This is left undefined and open to interpretation. The RIPE NCC understands that it will be the responsibility of the LIRs involved to update any contractual relationships between the resource-holding LIR and relevant End Users.

B. Impact of Policy on Registry and Addressing System

Removing the requirement that an allocation must be free of end user assignments would facilitate the transfer of allocations and the handover of LIR accounts. This may have a positive effect on the quality of registry data, as it will remove the incentive for organisations not to inform the RIPE NCC when such changes takes place.

Address/Internet Number Resource Consumption:

After analysing the data that is currently available, the RIPE NCC does not anticipate any significant impact if this proposal is implemented.

Fragmentation/Aggregation:

After analysing the data that is currently available, the RIPE NCC does not anticipate any significant changes to the amount of fragmentation compared to the situation under the current intra-RIR transfer policy.

C. Impact of Policy on RIPE NCC Operations/Services

Registration Services:

If the proposal is accepted, after receiving an allocation transfer request the RIPE NCC will check to see if any End User assignments or sub-allocations are registered within the allocation. The RIPE NCC will then inform the LIRs involved to ensure that they are aware of these End Users. The LIRs should then acknowledge that the allocations are not empty and that the receiving LIR is responsible for these End Users. The additional workload involved is not expected to be significant.

Billing/Finance Department:

After analysing the data that is currently available, the RIPE NCC does not anticipate that any significant impact will be caused if this proposal is implemented.

RIPE Database:

After analysing the data that is currently available, the RIPE NCC does not anticipate that any significant impact will be caused if this proposal is implemented.

D. Legal Impact of Policy

If this proposal is accepted, the RIPE NCC will approve transfers of allocations that contain assignments, provided both parties agree to the transfer and the relevant conditions are met. The LIRs involved will be responsible for ensuring that the End User is informed and that any contractual relationship is updated to reflect the transfer. When evaluating the transfer request, the RIPE NCC will assume that the End User of the assignment is informed of the transfer and that all of the relevant paperwork has been completed.