Policy for Inter-RIR Transfers of Internet Resources

Summary of Proposal

This RIPE Policy Proposal describes how the transfer of Internet number resources will occur between resource holders in the RIPE NCC service region and those in other Regional Internet Registry (RIR) service regions.

The policy should be as similar as possible for transfers both within and outside the RIPE NCC service region. For transfers from regions where the RIR requires the receiving region to have needs-based policies, recipients must provide a plan to the RIPE NCC for the use of at least 50% of the transferred resources within five years.  In all cases, the registries of the different RIRs must be consistent.

With this policy, legacy resources can be transferred to or from the RIPE NCC service region, in spite of the fact that there is no specific transfer policy for them.

Amendments to the existing policy, “IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region”, are also proposed to bring the policy in line with the new policy.

Policy Text

a. New Policy

Abstract:

This policy describes the transfer of Internet number resources between a resource holder within the RIPE NCC service region and a resource holder within the region of another another Regional Internet Registry (RIR).

1.0 Introduction

This policy outlines the rules for Internet number resource transfers between the RIPE NCC and other RIR service regions.

1.1 Scope

The policy for transferring Internet number resources to or from the RIPE NCC service region will apply to any type of Internet number resources for which there is a transfer policy within the RIPE NCC service region.With this policy, legacy resources can be transferred to or from the RIPE NCC service region, in spite of the fact there is no specific transfer policy for them.

While the transfer is in process, during the time the internet number resources are registered in the RIPE NCC service region, then RIPE policies will apply. 

2.0 Transferring Internet Resources to the RIPE NCC Service Region

The RIPE NCC shall accept all transfers of Internet number resources to its service region, provided that they comply with the policies relating to transfers within its service region.

For transfers from RIR regions that require the receiving region to have needs-based policies, recipients must provide a plan to the RIPE NCC for the use of at least 50% of the transferred resources within 5 years.

3.0 Transferring Internet Resources from the RIPE NCC Service Region

When transferring Internet number resources to another RIR, the RIPE NCC will follow the transfer policies that apply within its own service region. The RIPE NCC will also comply with the commitments imposed by the receiving RIR in order to facilitate the transfer. 

b. Modification to Existing Policy Document ripe-623

[The following text will update section 5.5 in the RIPE Document ripe-623, “IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region”, if the proposal reaches consensus.]

Current Policy Text

5.5 Transfers of Allocations

Any Local Internet Registry (LIR) is allowed to re-allocate complete or partial blocks of IPv4 address space that were previously allocated to them either by the RIPE NCC or otherwise through the Regional Internet Registry system.

Address space may only be re-allocated to another LIR that is also a member of the RIPE NCC.

Re-allocation must be reflected in the RIPE Database. This re-allocation may be on either a permanent or non-permanent basis.

LIRs that receive a re-allocation from another LIR cannot re-allocate complete or partial blocks of the same address space to another LIR within 24 months of receiving the re-allocation.

[…]

New Policy Text

5.5 Transfers of Allocations

Any resource holder is allowed to re-allocate complete or partial blocks of IPv4 address space that were previously allocated to them by the RIPE NCC or otherwise through the Regional Internet Registry (RIR) system.

Address space may only be re-allocated to another resource holder who is a member of an RIR that allows transfers.

Re-allocation must be reflected in the RIPE Database. This re-allocation may be on either a permanent or non-permanent basis.

For transfers from RIR regions that require the receiving region to have needs-based policies, recipients must provide a plan to the RIPE NCC for the use of at least 50% of the transferred resources within five years.

While the transfer is in process, during the time the internet number resources are registered in the RIPE NCC service region, then RIPE policies will apply.

Resource holders that receive a re-allocation from another resource holder cannot re-allocate complete or partial blocks of the same address space to another resource holder within 24 months of receiving the re-allocation.

[…]

Rationale

a. Arguments Supporting the Proposal

• Provides a minimal framework for inter-RIR Internet number resource transfers that doesn’t set any new rules on either party or the resources involved
• Can be applied to multiple resources
• Increases the supply of IPv4 addresses available to RIPE NCC resource holders
• Maintains the integrity of the RIPE Database and ensures that the RIPE NCC is part of the approval and transfer process
• Allows resource holders in the RIPE NCC service region to participate in a market already available to ARIN and APNIC resource holders
• Allows RIPE NCC members with excess resources to transfer these to networks in other RIR regions

b. Arguments Opposing the Proposal

• Resource holders with excess IPv4 addresses in the RIPE NCC service region may not wish to expand IPv4 inventories in the region
• It may reintroduce needs justification to the RIPE region for resources transferred from other RIRs that require needs-based, explicitly stated, policy principles.

In order to provide additional information related to the proposal, details of an impact analysis carried out by the RIPE NCC are documented below. This analysis is based on existing data and should be viewed as an indication only.

Executive Summary

1. The proposed policy sets a general framework for inter-RIR resource transfers

1. Executing inter-RIR transfers successfully depends on the other RIRs having compatible policies: ARIN and APNIC both see the proposal as compliant with their current policies
2. Currently, the proposed inter-RIR transfer policy would apply to IPv4 PA allocations, IPv4 PI assignments and legacy resources
3. Resources being transferred would remain subject to the policies of the sending RIR until the transfer is completed
4. The RIPE NCC Registration Services Department expects a considerable increase in administrative work if the proposal is accepted

1. If required by the other RIR, a receiving organisation must justify its need for the resource transfer

Note: Compatibility with other RIRs

The proposed policy sets a general framework for transferring Internet number resources between the RIPE NCC service region and other Regional Internet Registry (RIR) service regions. The effectiveness and execution of the proposed policy depends not only on its implementation by the RIPE NCC, but also on its acceptance by the other RIRs. The RIPE NCC has therefore requested feedback from the other RIRs with inter-RIR transfer policies in place (APNIC and ARIN).

Both RIRs have since confirmed that the proposed policy is compatible with their Inter-RIR transfer policies. The modified proposal meets the “needs based” requirement that is explicitly stated in ARIN's policy. APNIC will hold a public consultation at the APNIC 39 Policy SIG, after which it will advise if there are any remaining areas of concern.

The following impact analysis focuses on the interpretation and implementation details only as they relate to the RIPE NCC. It only considers situations in which the other RIR allows transfers to or from the RIPE NCC service region. Ultimately, this depends on policy development in other regions, which is an ongoing process that is difficult to predict.

A. RIPE NCC's Understanding of the Proposed Policy

General

The proposed policy sets a general framework for transferring Internet number resources between RIPE NCC members and resource holders in other RIR service regions.

Resources may be transferred to and from the RIPE NCC service region if:

• There is a policy allowing these resources to be transferred within the RIPE NCC service region (legacy resources can be transferred although there is no relevant transfer policy)
• The transfer is in accordance with the existing RIPE Policy on transfers within the RIPE NCC service region
• The transfer is compatible with the other RIR’s policy on inter-RIR transfers. For transfers from RIR regions that require a needs-based policy, the recipient must provide the RIPE NCC with a plan for the use of at least 50% of the transferred resources within five years.

Applicable Types of Internet Resources

Currently, the RIPE NCC service region has a transfer policy for IPv4 Provider Aggregatable (PA) allocations and IPv4 Provider Independent (PI) assignments. If this proposal is accepted, it will be possible to transfer these resources to and from the RIPE NCC service region. IPv4 PA allocations and IPv4 PI assignments transferred to the RIPE NCC service region will be considered as registrations made directly by the RIPE NCC and existing RIPE Policies will be applied.

Other internet resources such as IPv6 and ASNs will become available for inter-RIR transfers if the relevant transfer policies are accepted by the RIPE community.

The RIPE NCC will only register resources if the network that will be using them has at least one active element located in the RIPE NCC service region. This is in line with the current practice of only allocating or assigning resources for use in our service region.

Legacy resources that are transferred to the RIPE NCC service region, and have not had their legacy status revoked by the transferring RIR, will be treated as legacy according to RIPE Policy. If they have lost their legacy status, they will be handled in accordance with their new status.

IPv4 PA allocations, IPv4 PI assignments and legacy resources transferred from the RIPE NCC service region to another RIR will receive the status defined by the policies and contracts of the receiving RIR.

Applicable Policy

The proposed policy states that "while the transfer is in process, during the time the internet number resources are registered in the RIPE NCC service region, then RIPE policies will apply." For transfers to other regions, the resources will remain registered in the RIPE Registry until the transfer is completed. For transfers to the RIPE NCC service region, the resources will only be registered in the RIPE Registry when the transfer is completed.

It is the RIPE NCC’s understanding that resources being transferred are subject to the policies of an RIR as long their are registered in its registry. 

For transfers from the RIPE NCC service region to another RIR, “The RIPE NCC will also comply with the commitments imposed by the receiving RIR in order to facilitate the transfer.” It is the RIPE NCC’s understanding that the other RIR might need the RIPE NCC’s support to ensure their policies can be followed to complete the transfer. For example, the other RIR might request documentation from the resource holder in the RIPE NCC service region. 

In addition, for transfers to the RIPE NCC service region from RIRs that require needs-based policies, recipients must provide the RIPE NCC with a plan for the use of at least 50% of the transferred resources within five years.

The proposed policy can only apply to RIRs with compatible inter-RIR transfer policies.

The RIPE NCC cannot guarantee that the other RIR will agree to a resource transfer, even if it is approved by the RIPE NCC. The requirement to ensure consistency between RIRs means that both registries have to be in agreement to execute a transfer. The RIPE NCC can not, on its own, ensure that the policy requirements of the other RIR are met. Failure to comply with any RIR policy in such cases could lead to a difference of opinion on whether a transfer is acceptable between the transferring and receiving RIRs.

Transfer Period

It is the RIPE NCC’s understanding that a resource transfer can be on a permanent or non-permanent basis. Temporary transfers will be moved back from the RIPE Registry to the transferring RIR once the transfer period has ended or vice versa.

Deregistration

Resources that are permanently transferred to the RIPE NCC service region, and are later deregistered (for any reason), will be added to the RIPE NCC’s pool of available resources.

Documentation and Holding Period

The RIPE NCC will publish a list of transferred resources between RIRs if this is required in the applicable transfer policy for the RIPE NCC service region. Similarly, if the applicable transfer policy contains a holding period for received resources, then this will also apply to resources received from other RIR service regions.

Arbitration

The potential for disagreement between RIRs on policy compliance could require cross-registry arbitration to resolve such conflicts (for example, if a member of the RIPE NCC disagrees with the decision of another RIR). The RIPE NCC Conflict Arbitration procedure does not include appeals of this nature and can only settle disputes between members and the RIPE NCC, between members, and between legacy Internet resource holders and the RIPE NCC.

B. Impact of Policy on Registry and Addressing System

Address/Internet Number Resource Consumption:

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.

Fragmentation/Aggregation:

If it is accepted, the proposal would likely result in increased deaggregation, as existing IP ranges could be split and transferred in parts. The RIPE NCC has no historical data to estimate the likely amount of deaggregation. 

C. Impact of Policy on RIPE NCC Operations/Services

Registration Services: 

Amount of Requests

In the RIPE NCC service region, there are more than 23,000 PA allocations, more than 22,000 PI assignments, and more than 5,000 legacy resources that can potentially be transferred (either in their entirety, or further broken up into smaller blocks). This is in addition to all of the eligible prefixes registered in other RIR service regions that could be transferred.

The RIPE NCC has seen a considerable increase in transfer activity since 2012. In 2014, more than 900 PA allocation transfers were completed within the RIPE NCC service region. A similar number of inter-RIR transfers will likely result if the proposal is accepted, though the RIPE NCC is unable to provide an actual estimate.

Inter-RIR Coordination and Evaluation of Requests 

If this proposal reaches consensus and is deemed compatible by other RIRs, the RIPE NCC will process requests to transfer resources to or from its service region:  

• For transfers from RIR service regions that require needs-based policies, recipients must provide a plan to the RIPE NCC for the use of at least 50% of the transferred resources within five years. The RIPE NCC will evaluate the provided addressing plan and will only approve the transfer if this requirement is met.
• For transfers to other RIR service regions, the RIPE NCC will apply the transfer policies of its region along with “the commitments imposed by the receiving RIR”. This means that the RIPE NCC might need to support the other RIR to ensure that the transfer is compliant with their policies. For example, if the other RIR requires documentation from a resource holder in the RIPE NCC service region, the RIPE NCC would support this process.

In this context, it is important to highlight that maintaining the inter-RIR transfer framework is expected to require considerably more work than transfers within the RIPE NCC service region. Inter-RIR coordination is necessary to ensure that the transfer is in accordance with the related policies in both regions. The update in the RIR registries must be synchronised to ensure correct registration. As RIRs operate in different time zones the processing of inter-RIR transfers is expected to take longer than intra-RIR transfers.

Billing/Finance Department:

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

RIPE Database and DNS:

The RIPE Database will reflect inter-RIR transfers.
For prefixes transferred to the RIPE NCC service region, resource holders will be able to set up reverse DNS in the RIPE Database based on the existing inter-RIR DNS information exchange.

Software Engineering:

Software development will be needed to process inter-RIR transfers. Given the information that is currently available, a medium impact is expected, with between two and three months needed to develop the necessary software tools.

D. Legal Impact of Policy

Contractual Relationship

The RIPE NCC can only evaluate a transfer request for resources that are subject to a contract, except in the case of legacy resources. However, while the RIPE NCC can evaluate legacy transfer requests without a contract, the other RIR may have concrete contractual requirements that cannot be avoided. The RIPE NCC will also perform due diligence checks to ensure that the offering part is the legitimate holder of any resources being transferred.

Transfer Procedure and Due Diligence

A procedural document will need to be drafted that outlines the transfer procedure and due diligence checks of all the RIRs involved in inter-RIR transfers.

Shift of Responsibility – Updates on Contracts

Until the transfer is completed, the transferring party is responsible for complying with the transferring RIR’s policies and any relevant contractual and legal obligations with regards to the resources to be transferred.
After the transfer is completed, the transferring party may need to update its contract so that the transferred resources are no longer subject to it anymore. The receiving party is responsible for complying with the receiving RIR’s policies. The existing contractual obligations of the receiving party will have to extend to the transferred resources. A new contract may therefore need to be signed or the existing contract may need to be updated in order to include the transferred resources (e.g. if legacy resources are transferred to or from the RIPE NCC service region, the existing contract with the RIPE NCC or a RIPE NCC member will need to be updated accordingly). The receiving party will also be responsible for any other legal obligations regarding the transferred resources.

Responsibility for the Evaluation

The requirements for a transfer to be approved by the RIPE NCC may be different from those of other RIRs. According to the proposal:

• For transfers to the RIPE NCC service region, the RIPE NCC will evaluate requests in the same manner it would evaluate a request for a transfer within its service region. If the request comes from an RIR service region that requires a needs-based policy, the RIPE NCC will evaluate “a plan for the use of at least 50% of the transferred resources within 5 years” that is provided by the recipient.
• For transfers from the RIPE NCC service region, the RIPE NCC will evaluate the request in the same manner it would evaluate a request for transfer within its service region and “will comply with the commitments imposed by the receiving RIR” in order to facilitate the transfer.

When the other RIR has additional requirements, the RIPE NCC will work with the resource holder to comply with these. This will require the RIPE NCC to share confidential information about the resource holder with the other RIR, though it will only do so if it has the resource holder’s approval. The RIPE NCC will also need to draft and sign an NDA with the other RIR regarding the third party information shared.  

E. Implementation

With the information currently available, it is expected that implementation of the proposal would have a medium impact in terms of the software development needed to facilitate inter-RIR transfers in internal RIPE NCC systems. The RIPE Registry will document transfers and received resources. New processes and documentation will also need to be created in coordination with other RIRs.

It is important to note that the implementation will only establish the framework for the RIPE NCC to process inter-RIR transfers. The actual execution will be dependent on matching policies and procedures between the RIRs involved.