December 2023 - address-policy-wg

2023-04 Review Phase (Add AGGREGATED-BY-LIR status for IPv4 PA assignments)
by Angela Dall'Ara 13 Feb '24

13 Feb '24

Dear colleagues, Policy proposal 2023-04, “Add AGGREGATED-BY-LIR status for IPv4 PA assignments”, is now in the Review Phase. The goal of this proposal is to introduce the AGGREGATED-BY-LIR status for IPv4 PA assignments to reduce LIR efforts in registration and maintenance. This proposal has been updated and it is now at version 2.0. The proposed policy text did not change, the only difference is that the section "Arguments opposing the proposal" includes a reference to the last round of discussion. The RIPE NCC has prepared an impact analysis on this proposal to support the community’s discussion. You can find the proposal and impact analysis at: https://www.ripe.net/participate/policies/proposals/2023-04 https://www.ripe.net/participate/policies/proposals/2023-04#impact-analysis And the draft document at: https://www.ripe.net/participate/policies/proposals/2023-04/draft As per the RIPE Policy Development Process (PDP), the purpose of this four-week Review Phase is to continue the discussion of the proposal taking the impact analysis into consideration, and to review the full draft RIPE Policy Document. At the end of the Review Phase, the Working Group (WG) Chairs will determine whether the WG has reached rough consensus. It is therefore important to provide your opinion, even if it is simply a restatement of your input from the previous phase. We encourage you to read the proposal, impact analysis and draft document and to send any comments to address-policy-wg(a)ripe.net before 20 December 2023. Kind regards, Angela Dall'Ara Policy Officer RIPE NCC

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Update on AS Number Assignments - Transitioning to Policy Compliance
by Marco Schmidt 26 Jan '24

26 Jan '24

Dear colleagues, During the RIPE 87 Address Policy working group session yesterday, I presented the topic of AS Number assignments, specifically addressing a policy in place since 2010. According to this policy, assignments should be made from an undifferentiated 32-bit AS Number allocation pool. https://www.ripe.net/publications/docs/ripe-679#ASnumbers Before this policy became active in 2010, the Address Policy WG recognized that many providers were not ready to exclusively work with 32-bit ASNs, mostly due to technical constraints. A verbal consensus in 2009 suggested that the RIPE NCC would temporarily continue using two pools of 16-bit and 32-bit AS Numbers. The plan was to attempt to extend the global policy by 12 months, but this effort was never undertaken. To date, the RIPE NCC remains the only Regional Internet Registry (RIR) employing this temporary approach. Observing that other RIRs have successfully issued AS Numbers from an undifferentiated pool for many years without technical challenges for operators, the RIPE NCC plans to phase out the current temporary approach. The intention is to align with the policy and issue AS Numbers accordingly. No objections were raised during the working group session. However, for transparency, we want to inform working group members who couldn't attend the RIPE meeting. The presentation can be viewed here: https://youtu.be/Zoq4PpqlaK4?t=1797 Kind regards, Marco Schmidt Manager Registration Services RIPE NCC

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Reducing IXP IPv4 assignment default size to a /26
by Viacheslav Adamanov 11 Jan '24

11 Jan '24

Dear community, The problem with ipv4 network speculation for IXP is exaggerated. RIPE NCC forbids transferring this networks to another company. Have there been cases of transmission of such networks? Kind regards, Viacheslav Adamanov. IXP Mesh Ukraine, Mariupol

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Extend Review Phase for 2023-04 - "Add AGGREGATED-BY-LIR status for IPv4 PA assignments"
by Leo Vegoda 10 Jan '24

10 Jan '24

Dear colleagues, There's still an active discussion on 2023-04 - "Add AGGREGATED-BY-LIR status for IPv4 PA assignments". We'll extend the Review Phase until 18 January 2024. You can find the policy proposal, the draft RIPE document, and the RIPE NCC's Impact Analysis here: https://www.ripe.net/participate/policies/proposals/2023-04 The RIPE NCC will update the proposal web page with the new dates soon. Kind regards, Leo Vegoda, for the Address Policy WG co-chairs

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2023-04 Extended Review Phase (Add AGGREGATED-BY-LIR status for IPv4 PA assignments)
by Karen Hung 22 Dec '23

22 Dec '23

Dear colleagues, The policy proposal 2023-04, “Add AGGREGATED-BY-LIR status for IPv4 PA assignments” is now in the extended Review Phase. As per the RIPE Policy Development Process (PDP), the purpose of this Review Phase extension is to continue discussing the proposal taking the impact analysis into consideration, and to review the full draft RIPE Policy Document. At the end of the Review Phase, the Working Group (WG) Chairs will determine whether the WG has reached rough consensus. It is therefore important to provide your opinion, even if it is simply a restatement of your input from the previous phase. If you support the proposal, please indicate that support with a simple message to the mailing list. If you have objections or would like a change, please provide that feedback to the mailing list. You can find the proposal and impact analysis at: https://www.ripe.net/participate/policies/proposals/2023-04 https://www.ripe.net/participate/policies/proposals/2023-04#impact-analysis And the draft document at: https://www.ripe.net/participate/policies/proposals/2023-04/draft We encourage you to read the proposal, impact analysis and draft document and to send any comments to address-policy-wg(a)ripe.net <mailto:address-policy-wg@ripe.net> before 18 January 2024. Kind regards, Karen Hung On behalf of Policy Officer RIPE NCC

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@EXT: FW: 2023-04 Review Phase (Add AGGREGATED-BY-LIR status for IPv4 PA assignments)
by Kessler, Emmanuel 21 Dec '23

21 Dec '23

Dear all, Thanks for the various points provided after my last message of the 13th December. we are assessing them with our colleagues of the police forces and we have shared with cybersecurity actors the EU. >From Law enforcement perspective, we would consider highly reasonable that RIPE organises a full consultation with relevant stakeholder groups that use RIPE data basis, to fully assess the impact and their needs. Such consultation would be necessary and legitimate as considering the official agreement signed on 2016 between RIPE NCC and EUROPOL that states that both parties, in accordance with their respective mandates, inform each other about the implementation of their respective mandates in the area of cybercrime, inform each other of programmes of potential interest in order to identify possibilities for joint activities and mutual contributions. As already mentioned, we were informed only recently about the proposal that would need full assessment that takes time. Any new loss of information linked with aggregation of IPV4, would mean less criminals identified and more victims targeted or in life danger. Such losses of information would also conflict with current EU regulatory activities against the "going dark matter" (loss of access to information for LE authorities for judicial purposes). This problem is highly identify at EU level, and I would also prefer to prevent any future misunderstanding between actors in RIPE and EU actors, would the measure be adopted in an hasty way... >From reading your points, I observe that beyond text, is the matter of the real implementation by LIRs and others...we need to clarify and ensure that. Thanks for your understanding and constructive spirit. Regards Emmanuel KESSLER Emmanuel KESSLER Head of Team - Prevention/Outreach Europol - O3 European Cyber Crime Centre (EC3) Eisenhowerlaan 73, 2517 KK The Hague, The Netherlands Phone: [Moderated] / mobile [Moderated] www.europol.europa.eu<http://www.europol.europa.eu/> [cid:image001.png@01D8169D.5B765D70] -----Original Message----- From: denis walker <ripedenis(a)gmail.com> Sent: 15 December 2023 15:05 To: Jeroen Lauwers <jlauwers(a)a2b-internet.com> Cc: RIPE Address Policy Working Group <address-policy-wg(a)ripe.net>; Gert Doering <gert(a)space.net>; Kessler, Emmanuel <Emmanuel.Kessler(a)europol.europa.eu> Subject: Re: [address-policy-wg] 2023-04 Review Phase (Add AGGREGATED-BY-LIR status for IPv4 PA assignments) This email originated from outside Europol. Do not click links or open attachments unless you recognize the sender and know the content is safe. The external address that sent the message is: denis1(a)gmail.com Hi Jeroen Looking back over this email, there are two things that really stand out to me. "Do you already use AGGREGATED-BY-LIR when registering IPv6 assignments? Would you find it convenient and useful to be able to register IPv4 assignments in the same way?" "the statement <When an End User has a network using public address space this must be registered separately with the contact details of the End User> found in the current policy (and removed by 2023-04 in order to bring the wording in line with that of the IPv6 policy)" These two statements that you made basically sum up this policy proposal. You are suggesting we fundamentally change IPv4 address policy for the 'convenience' of operators and to 'align' some words between two different policies regardless of the consequences. When you add to this a comment Gert made at RIPE 87 when he said that after 30 years we have no clue as to what the "admic-c:" attribute means or why anyone would want to contact them or what they would expect to get from such contact. We have maybe 5 or 6 million inetnum objects in the RIPE Database, a few million inet6num objects and probably tens of thousands of aut-num objects. They all have a mandatory admin-c and we don't know why it is there. All we have is a 30 year old definition that says it must be an on-site contact for the End User in the case of assignment and ASNs. This is a dreadful situation to be in. I suggest that 2023-04 is withdrawn. Then we have a wide reaching consultation with many stakeholder groups who use the RIPE Database. Determine what their needs are for a public registry. What information they need and would like to have in the RIPE Database. Basically do what I expected the last database task force to do, produce a business requirements document for the RIPE Database as a public registry. Then see where we go from there. cheers denis On Wed, 13 Dec 2023 at 19:14, Jeroen Lauwers <jlauwers(a)a2b-internet.com> wrote: > > Dear colleagues, > > Though we recognise that most of you are probably busy preparing for the upcoming holidays, we would like to ask you to share your opinion on proposal 2023-04. Remember that Policy Development Process requires any comments made during the Discussion phase must be repeated during the Review phase in order to count towards or against rough consensus, as your views can now take the RIPE NCC's Impact Analysis into account. > > Here are some questions for the WG to get the discussion started: Do you already use AGGREGATED-BY-LIR when registering IPv6 assignments? Would you find it convenient and useful to be able to register IPv4 assignments in the same way? Does 2023-04 address this use case well in its current form, or could you think of any potential improvements? > > We hope you will find the time to let your voice be heard! > > The Policy Development Process requires the proposers to adequately address any suggestions for changes or objections to the proposal in each phase, which we will do below. > > 1. Does 2023-04 change the contact registration requirements for assignments? > > > The argument made is that the statement <When an End User has a network using public address space this must be registered separately with the contact details of the End User> found in the current policy (and removed by 2023-04 in order to bring the wording in line with that of the IPv6 policy), implicitly requires LIRs to register non-delegated/outsourced contact information for the End User in the RIPE database, not necessarily in the mandatory <admin-c> or <tech-c> attributes, but possibly in an optional attribute like <descr>, <org> or <remarks>. > > Proposers' response: > > We do not believe so, for the following reasons, and keeping the current practice and policies in consideration: > > The RIPE NCC does not consider that 2023-04 changes the contact registration requirements in any way[1][2][3]. Absent any (rough) consensus in the Working Group to the contrary, we defer to the RIPE NCC's judgement on this point. > The practice of creating assignments with all contact information delegated is already widespread. If this was a policy violation made possible due to the RIPE NCC implementing RIPE policy incorrectly, we would have expected the community to take action to correct this situation. However, no such policy proposal has been put forward by the community. > Outsourcing and delegation of contact information is a common practice across many industries, including in networking and information technology. There is no policy language that explicitly prohibits this for IPv4 assignments. Absent that, we believe any implicit prohibition found "between the lines" is essentially <void for vagueness>[4]. > An obligation to publish the End User's contact information in the RIPE database will constitute a violation of Article 6(3) of the RIPE Database Terms and Conditions[5] and Article 6(1)(a) of the GDPR[6], if the End User's contact person has not given explicit consent to such publication. We believe that the RIPE policy cannot reasonably be interpreted to require LIRs to break EU law (and even if it explicitly did require that, EU law would still take precedence). > The policy's stated goal of registering assignments is <to ensure uniqueness and to provide information for Internet troubleshooting at all levels>[7]. Requiring LIRs to publish the contact information of End Users who often will not have any knowledge or capability to aid with troubleshooting does work towards this attaining goal. On the contrary, delegating the contact information to the LIR/ISP may well be the only way to attain this goal. > > > [1] > https://www.ripe.net/ripe/mail/archives/address-policy-wg/2023-Septemb > er/013856.html [2] > https://www.ripe.net/participate/policies/proposals/2023-04#impact-ana > lysis [3] > https://www.ripe.net/ripe/mail/archives/address-policy-wg/2023-Novembe > r/013892.html [4] https://www.law.cornell.edu/wex/void_for_vagueness > [5] > https://www.ripe.net/manage-ips-and-asns/db/support/documentation/term > s [6] > https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0 > 679#d1e1888-1-1 [7] https://www.ripe.net/publications/docs/ripe-804#3 > > 2. The <assignment-size> attribute should be a CIDR prefix length > > Leaving it undefined could result in some LIRs using it to represent an IPv4 address count, while others would use it to represent a CIDR prefix length. > > Proposers' response: > > We agree <assignment-size> should be a CIDR prefix length. We understand that, if proposal 2023-04 would be accepted, the RIPE NCC could implement the <assignment-size> attribute for IPv4 inetnum objects to be a CIDR prefix length, and document it as such. Therefore we do not believe it is necessary to spell this out explicitly in the policy document (it is not spelled out in the IPv6 policy document either). > > > Thank you for your attention and enjoy your holidays! > > Best regards, > Jeroen and Tore > > > Op 21 nov. 2023, om 11:13 heeft Angela Dall'Ara <adallara(a)ripe.net> het volgende geschreven: > > > Dear colleagues, > > Policy proposal 2023-04, "Add AGGREGATED-BY-LIR status for IPv4 PA assignments", is now in the Review Phase. > > The goal of this proposal is to introduce the AGGREGATED-BY-LIR status for IPv4 PA assignments to reduce LIR efforts in registration and maintenance. > > This proposal has been updated and it is now at version 2.0. The proposed policy text did not change, the only difference is that the section "Arguments opposing the proposal" includes a reference to the last round of discussion. > > The RIPE NCC has prepared an impact analysis on this proposal to support the community's discussion. > > You can find the proposal and impact analysis at: > https://www.ripe.net/participate/policies/proposals/2023-04 > https://www.ripe.net/participate/policies/proposals/2023-04#impact-ana > lysis > And the draft document at: > https://www.ripe.net/participate/policies/proposals/2023-04/draft > > As per the RIPE Policy Development Process (PDP), the purpose of this four-week Review Phase is to continue the discussion of the proposal taking the impact analysis into consideration, and to review the full draft RIPE Policy Document. > > At the end of the Review Phase, the Working Group (WG) Chairs will determine whether the WG has reached rough consensus. > It is therefore important to provide your opinion, even if it is simply a restatement of your input from the previous phase. > > We encourage you to read the proposal, impact analysis and draft document and to send any comments to address-policy-wg(a)ripe.net before 20 December 2023. > > Kind regards, > Angela Dall'Ara > Policy Officer > RIPE NCC > > -- > > To unsubscribe from this mailing list, get a password reminder, or > change your subscription options, please visit: > https://lists.ripe.net/mailman/listinfo/address-policy-wg > > > -- > > To unsubscribe from this mailing list, get a password reminder, or > change your subscription options, please visit: > https://lists.ripe.net/mailman/listinfo/address-policy-wg

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@EXT: Inputs/observations from EUROPOLon proposal 2023-04
by Kessler, Emmanuel 20 Dec '23

20 Dec '23

Dear partners, companies and RIPE, on the last RIPE meeting, my inputs have unfortunately been hampered by some technical problems of online connection. With this message, I would like to express from Europol perspective, our questions and some clear concerns about the measure 2023-04 as proposed. We have been very recently informed about the project of measure that would indeed remove User assignment data from the RIPE Database public registry. We have started a consultation of EU law enforcement services (that however takes time), and informed the EU Commission. >From the first feedback we have gathered, the measure will have some clear negative impacts on the capacity of law enforcement authorities to lead investigation, considering the current situation and practices. Various law enforcement actors (LEA) do appreciate to have the information in the RIPE databases. This direct access helps many investigators to work swiftly in their daily activity against cybercriminals, fraudsters, pedophiles, terrorists...as we all know. The first negative impact will concern the swift availability of data : with the new measure, LEA will systematically have to request information to the LIRs, with a court order. Beyond the sole matter of lawfulness requirement, it will not ease as such the daily work, but instead it will be another barrier to the facilitated access to the data : easing the access means easing an efficient and swift investigation. The proposed measure does not prioritize it. Maintaining access to the data of end users at RIPE level is also a way to ensure access to all data, in spite of the uncertainty of answers from some LIRs. Registration practices are far to be uniform across the various LIRs. Please kindly consider that capacity of Law Enforcement is asymmetric towards large volumes of ransomware attacks, online scam types and massive sharing of Child Sexual Abuses Material,...all support from our partners is the most precious to counter these realities. The other main impact will be on the quality of collected data. In practice, the proposed policy could indeed allow assignments to be somewhat anonymised. The measure would have here an impact on data granularity : The shift to aggregated assignments would result in less granular data available to law enforcement. While individual assignments offer specific and detailed information about each IP address's usage, aggregated data may obscure such details, potentially complicating investigations that rely on precise IP address information.. We do understand that the aggregated registration of IPv4 addresses would streamline administrative processes for LIRs but, it is important to acknowledge that it would also have a negative impact on the efficiency and effectiveness of law enforcement investigations. The less detailed information will require additional steps or inquiries to ascertain the specifics of an IP address's usage, potentially delaying investigative processes. Identifying IPV4, remains highly challenging in many cases, as all know, and IPV6 will not replace it at short term. All delays hamper the general (complex) process of investigation and may have an strong impact on the final result (bad guys arrested and new victims prevented or saved) EU has recently adopted the NIS2 directive with its article 28 for a better access to DNS information for the legitimate actors. we observe that the planned measure 2023-04 would open an opposite (negative) trend on the access to IP information. We express our serious concern with the impact that such a measure would have on various investigations carried out by EU competent authorities, and the protection of victims, should it be adopted. Thank you for your attention and consideration. Regards Emmanuel KESSLER Head of Team - Prevention/Outreach Europol - O3 European Cyber Crime Centre (EC3) Eisenhowerlaan 73, 2517 KK The Hague, The Netherlands Phone: [Moderated] / mobile [Moderated] www.europol.europa.eu<http://www.europol.europa.eu/>

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