May 2016 - address-policy-wg - mailman.ripe.net

2016-03 New Policy Proposal (Locking Down the Final /8 Policy)
by Marco Schmidt 13 Jun '16

13 Jun '16

Dear colleagues, A new RIPE Policy proposal 2016-03, "Locking Down the Final /8 Policy" is now available for discussion. The goal of this proposal is to limit IPv4 from the remaining address pool to one /22 per LIR (regardless of how it was received). These “final /22” allocations will receive a separate status with several restrictions: - These allocation are not transferrable - LIRs may only retain one final /22 following a merger or acquisition - Sub-allocations are not possible - Reverse delegation authority can not delegated to another party You can find the full proposal at: https://www.ripe.net/participate/policies/proposals/2016-03 We encourage you to review this proposal and send your comments to <address-policy-wg(a)ripe.net> before 15 June 2016. Regards Marco Schmidt Policy Development Officer RIPE NCC

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opposition to 2015-04
by Remco van Mook 30 May '16

30 May '16

Dear all, as just mentioned during the address policy session, I'm withdrawing my objection to 2015-04. While I do think a discussion about policy structure still needs to be held, I don't think it should hold up this proposal any longer. This can be fixed after adoption - as long as we're aware. I do maintain my suggestion to put references in place where chapters about transfers are removed from other sections of policy. Kind regards, Remco

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ALLOCATED FINAL and M&As
by William Waites 26 May '16

26 May '16

This suggestion is intended to address the problem of abusively opening many LIRs or many companies to make new members to stockpile addresses from the last /8. First, if there are intended to be special rules applying to these addresses, they should have a special status to make it clear. For the sake of argument ALLOCATED FINAL. This doesn't change anything, it just makes things a bit more explicit. Any organisation should be entitled to at most one such FINAL allocation from RIPE (if we go back to multiple LIR accounts, only one of them may get a FINAL block). FINAL allocations are only for use on the Internet, not for internal, non-announced uses: that is a legitimate use case, but don't squander the last of the pool for that. Transfers of FINAL blocks are only allowed if they are demonstrably in use. "In use" means (1) announced in the global BGP tables and (2) with documentation of deployment in a non-trivial topology, i.e. assigning everything in the /22 to a single host so that it answers ICMP packets doesn't fly. Yes, there are still ways to game this, but the bar is much higher. Yes, it means that the NCC has to do more work to check that transfers are legitimate, but that is a necessary cost for dealing with the problem of the bad actors. --- Motivation/disclosure. HUBS is made up of a dozen or so small rural providers mostly in the south of Scotland. We are an LIR and allocate addresses to them on pretty much the same basis as we get them from RIPE. We encourage them to do IPv6 but made an explicit choice not to dictate or interfere in their internal operations. They may use their IPv4 allocations for "CG"-NAT, or assign them to customers, and we offer advice but not more. Another organisation, WHAN, was set up to do this along similar lines on the west coast (and actually to extend the model by making a distributed IXP for their networks to connect to rather than looking like a transit provider). There is some overlap of people (exactly two) but they operate in a different geographical area and the set of member networks is completely disjoint. At some point it is quite possible that these two organistions will merge. That would be extremely and unnecessarily painful if that meant that networks already assigned and in use had to be returned. These organisations are already operating in areas characterised by market failure, on extremely tight budgets largely reliant on volunteers to provide the only option for decent Internet access. The policy that has been mooted of a rigid rule of exactly one final allocation per organisation would be hugely damaging. Best wishes, William Waites Network Engineer HUBS AS60241

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Join the Address Policy WG Discussions Tomorrow
by Marco Schmidt 24 May '16

24 May '16

Dear colleagues, Tomorrow at RIPE 72, the Address Policy Working Group will be discussing the following policy proposals: - 2015-04, "RIPE Resource Transfer Policies" - 2015-05, "Revision of Last /8 Allocation Criteria" - 2016-03, "Locking Down the Final /8 Policy" While no decisions are made during this session, it’s a good opportunity to discuss the proposals and give feedback directly to the proposers. If you can't attend tomorrow’s session in person, you can participate remotely. The following link will provide you with a live webstream and a chat client. https://ripe72.ripe.net/live/main/ The session begins at 07:00 UTC on 25 May 2016. We encourage you to join the discussion if you have an opinion about one of these proposals. The second Address Policy Working Group session begins at 9:00 UTC on the same day and includes a presentation on "Market Concentration in the Transfer of IPv4 Space”, as well as feedback from the RIPE NCC's Registration Services Department. We invite you to tune in to see these presentations as well. Kind regards, Marco Schmidt Policy Development Officer RIPE NCC

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New on RIPE Labs: Developments in IPv4 Transfers
by Mirjam Kuehne 24 May '16

24 May '16

Dear colleagues, In May 2015, we looked at IPv4 transfers in the RIPE NCC service region and found signs of an emerging market. Both the number and size of transfers conducted under RIPE Policy showed an upward trend in the years 2013-2014. One year later, we take another look. Did this trend continue? What have been the effects of the inter-RIR transfer policy? Please read on RIPE Labs: https://labs.ripe.net/Members/wilhelm/developments-in-ipv4-transfers?pk_cam… Kind regards, Mirjam Kuehne RIPE NCC

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2015-05 Discussion Period extended until 13 June 2016 (Last /8 Allocation Criteria Revision)
by Marco Schmidt 24 May '16

24 May '16

Dear colleagues, The Discussion Period for the proposal 2015-05, "Last /8 Allocation Criteria Revision" has been extended until 13 June 2016. You can find the full proposal at: https://www.ripe.net/participate/policies/proposals/2015-05 We encourage you to review this policy proposal and send your comments to <address-policy-wg(a)ripe.net>. Regards, Marco Schmidt Policy Development Officer RIPE NCC

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“RIPE 72” has been canceled.
by mostafa shahdadi 23 May '16

23 May '16

“RIPE 72” has been canceled. starts: All-Day, Monday, May 23, 2016 ends: All-Day, Friday, May 27, 2016 location: Copenhagen, Denmark note: now deleted by: mostafa shahdadi --- iCloud is a service provided by Apple. Apple ID: https://appleid.apple.com/choose-your-country/ Support: https://www.apple.com/support/icloud/ww Terms and Conditions: https://www.apple.com/legal/internet-services/icloud/ww/ Privacy Policy: https://www.apple.com/legal/internet-services/privacy/ Copyright 2016 Apple Inc. 1 Infinite Loop, Cupertino, CA 95014, United States. All rights reserved.

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Re: [address-policy-wg] [policy-announce] 2015-05 Discussion Period extended until 13 June 2016 (Last /8 Allocation Criteria Revision)
by alain.bidron＠orange.com 20 May '16

20 May '16

Envoyé depuis mon mobile Orange ----- Reply message ----- De : "Marco Schmidt" <mschmidt(a)ripe.net> Pour : "policy-announce(a)ripe.net" <policy-announce(a)ripe.net> Objet : [policy-announce] 2015-05 Discussion Period extended until 13 June 2016 (Last /8 Allocation Criteria Revision) Date : ven., mai 20, 2016 15:03 Dear colleagues, The Discussion Period for the proposal 2015-05, "Last /8 Allocation Criteria Revision" has been extended until 13 June 2016. You can find the full proposal at: https://www.ripe.net/participate/policies/proposals/2015-05 We encourage you to review this policy proposal and send your comments to <address-policy-wg(a)ripe.net>. Regards, Marco Schmidt Policy Development Officer RIPE NCC _________________________________________________________________________________________________________________________ Ce message et ses pieces jointes peuvent contenir des informations confidentielles ou privilegiees et ne doivent donc pas etre diffuses, exploites ou copies sans autorisation. Si vous avez recu ce message par erreur, veuillez le signaler a l'expediteur et le detruire ainsi que les pieces jointes. Les messages electroniques etant susceptibles d'alteration, Orange decline toute responsabilite si ce message a ete altere, deforme ou falsifie. Merci. This message and its attachments may contain confidential or privileged information that may be protected by law; they should not be distributed, used or copied without authorisation. If you have received this email in error, please notify the sender and delete this message and its attachments. As emails may be altered, Orange is not liable for messages that have been modified, changed or falsified. Thank you.

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comment on "Revision of Last /8 Allocation Criteria"
by Kai Rottleb 20 May '16

20 May '16

Dear Mr. Schmidt, I want to make a comment on your proposal "Revision of Last /8 Allocation Criteria“. https://www.ripe.net/participate/policies/proposals/2015-05 <https://www.ripe.net/participate/policies/proposals/2015-05> We became RIPE member about 1,5 years ago. We have received one single /22 subnet. Due to groth requirement, we have purchased an additional /23 subnet a few weeks ago in an auction. In you proposal it is stated that for an additional /22 allocation the member „must not have transferred any IPv4 address space before“. I hope this requirement only concernes transfers away from us, not to us. Otherwise I find it very unfair that we are punished for organizing additional subnets in a legal way for our regular business. We don’t intend to trade with those IPs. Best regards, Kai Rottleb -- KNT Internet, Inh. Kai Rottleb Riethnordhaeuser Str. 71 99189 Hassleben, Germany Mail: kai.rottleb(a)knt.io <mailto:kai.rottleb@knt.io> Tel: 036201 61055 Mobil: 01723971017

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Re: [address-policy-wg] 2016-03 New Policy Proposal (Locking Down the Final /8 Policy)
by Athina Fragkouli 19 May '16

19 May '16

Dear Sasha, all, The concern you raise was addressed back in 2009, when the RIPE community was discussing three different last /8 policy proposals (the proposals 2008-06, 2009-3 and 2009-04). All three policy proposals allowed one single /22 allocation per LIR. Back then the RIPE NCC received legal advice from external legal advisers with an expertise in EU Competition Law. The advise was based on the assumption that each new LIR would receive no more than a single /22. The RIPE NCC had shared this legal advise with the RIPE community and has presented on it at RIPE 59 in Lisbon: https://www.ripe.net/ripe/mail/archives/address-policy-wg/2009-October/0047… https://www.ripe.net/ripe/mail/archives/address-policy-wg/attachments/20091… http://ripe59.ripe.net/presentations/pawlik-final-shalsh-8.pdf The outcome of the advise was the following: "The proposed final /8 policies are likely to comply with the conditions of article 81(3) EC: they contribute to optimising distribution and/or to promoting technical progress; in so doing, they benefit consumers; they do not appear to impose restrictions which are not indispensable to the attainment of their objective of optimising the usage of the IPv4 unallocated pool; and they do not eliminate competition in respect of the IPv4 unallocated pool. [...] For future reference, [...] any final /8 policy adopted by the RIPE Community and implemented by RIPE NCC should: (i) continue to be adopted by means of the bottom-up, consensus driven open policy development process of the RIPE Community; (ii) be as open as possible (i.e., involve as many LIRs as possible, which is the case for the currently proposed policies); and (iii) be applied in a clear non-discriminatory manner, and third parties (new LIRs) should have fair, reasonable and non-discriminatory access." I would like to highlight that since 2009 article 81(3) has been renumbered to 101(3) of the Treaty of the Functioning of the European Union, but the content remains the same: http://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:12008E101 I hope this helps. Kind regards, Athina Fragkouli Head of Legal RIPE NCC > Subject: Re: [address-policy-wg] 2016-03 New Policy Proposal (Locking > Down the Final /8 Policy) > Date: Tue, 17 May 2016 14:44:14 +0100 > From: Sascha Luck [ml] <apwg(a)c4inet.net> > To: address-policy-wg(a)ripe.net > > > > On Tue, May 17, 2016 at 02:05:26PM +0200, Marco Schmidt wrote: >>A new RIPE Policy proposal 2016-03, "Locking Down the Final /8 Policy" >>is now available for discussion. >> >>The goal of this proposal is to limit IPv4 from the remaining address pool >>to one /22 per LIR (regardless of how it was received). >>These âfinal /22â allocations will receive a separate status with >>several restrictions: >> >>- These allocation are not transferrable >>- LIRs may only retain one final /22 following a merger or acquisition >>- Sub-allocations are not possible >>- Reverse delegation authority can not delegated to another party > > I would like to see a statement from NCC Legal on the legality of > any of these proposals with particular emphasis on EU "barrier to > entry" legislation. > > rgds, > Sascha Luck > > > >

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