Hello everyone,
Following the suggestion of the RIPE NCC, we are seeking early feedback on an upcoming policy proposal we currently have in draft status.
As mentioned last week after the Registration Services update from Marco at the AP-WG session - Peter Hessler and I, members of the now concluded Charging Scheme Task Force, are drafting a policy proposal to clarify the non-transferability of legacy status to address the issues of increasing overhead for the RIPE NCC, increasing market speculation around a scarce resource and its impact on the adoption of best practices like RPKI. Our proposal will modify these existing policies:
1. “RIPE Resource Transfer Policies” (RIPE-807) with additional clarifications in the Transfer Restrictions section and the Inter-RIR policy section. M&A/org restructuring transfers will be explicitly excluded.
2. “RIPE NCC Services to Legacy Internet Resource Holders” (RIPE-639) with modifications to remove the language implying new holders can keep legacy status after transfer.
For background, legacy status was meant to indicate when an Internet resource had been directly assigned to the holder by IANA, before the RIRs were established. As such, ARIN, LACNIC and AFRINIC policies dictate that IPv4 legacy resources will no longer be regarded as legacy resources after a policy transfer takes place (excluding M&A transfers). RIPE is the only RIR that currently allows the recipient of a legacy transfer the ability to inherit the legacy status that was assigned to the original holder by IANA. This is currently being used as a loophole by certain actors to opt out of having a contractual relationship with the RIPE NCC in order to circumvent:
1. RIPE registration services fees.
2. The 24-month transfer lock that was introduced by this working group to prevent flipping of scarce resources.
3. Needs-based inter-RIR transfer policy utilization requirements in the case of transfers from another RIR to a recipient of a legacy resource transfer in the RIPE region.
Following the publication of the Report of the RIPE NCC Charging Scheme Task Force, the membership learned that the RIPE NCC currently needs to dedicate a 0.5FTE to process legacy transfers. There are currently around 2,400 legacy resources held by 1,600 holders with no contractual relationship with the RIPE NCC (neither direct nor via a sponsor). That is around 40M IPs total or 5% of RIPE IPv4 space. In the last four years, NCC staff have processed between 370-280 legacy transfers per year, of which roughly a third do not involve a party with a contractual relationship with the NCC. Legacy transfers are more labor-intensive than other transfer types because the due diligence process requires the Registration Services team to manually source and verify pertaining documentation without the benefits of the automated processes for standard allocations. Legacy transfers take an average seven working hours to process when neither party has a contractual relationship with the NCC (around a third of legacy transfers), and six working hours to process when the parties have a contractual relationship with the NCC. If resources lost their legacy status after a transfer, these would then become standard allocations and staff could leverage enhanced compliance checks and automated processes to facilitate any future updates/transfers. These just take 1-3 working hours to process instead. Given that the task force was deemed out of scope for a policy change to address this gap, this is being brought to the attention of the Address Policy Working Group for action.
If there are any concerns, questions or considerations you would like to bring up before we submit this proposal for discussion in the next week or two, we would really appreciate hearing from you so we can address these and/or incorporate them.
Thanks in advance,
Clara Wade
