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

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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Agenda for APWG sessions at RIPE 72
by Sander Steffann 19 May '16

19 May '16

Hi APWG folks, below you can find a draft for the RIPE address policy WG meeting's agenda, which will take place in Copenhagen in the following time slots: Wednesday, May 25, 09:00 - 10:30 Wednesday, May 25, 11:00 - 12:30 If you have anything else you want to see on the agenda, or if we need to change anything, please let us know. The distribution of items to the two timeslot is somewhat subject to the time spent on discussion - but we'll try to stick to what's published. regards, Sander Steffann, Gert Döring APWG chairs ---------------------------------------------------------------------- Wednesday, 09:00-10:30 ---------------------------------------------------------------------- A. Administrative Matters 5 min (welcome, thanking the scribe, approving the minutes, etc.) B. WG Chair Selection 10 min - longest-serving chair (Sander Steffann) stepping down - willing to be re-appointed and serve another term C. Current Policy Topics - Marco Schmidt, NCC PDO 25 min - global policy overview "what's going on?" - common policy topics in all regions (end of IPv4, transfers, ...) - overview over concluded proposals in the RIPE region since RIPE 71 - brief overview over new proposals 2016-01 (AAWG) Include Legacy Internet Resource Holders in the Abuse-c Policy 2016-02 Resource Authentication Key ( RAK ) code for third party authentication 2016-03 Locking Down the Final /8 Policy F. Discussion of open policy proposals 50 min 2015-04 RIPE Resource Transfer Policies Erik Bais 2015-05 Revision of Last /8 Allocation Criteria Discussion phase not leading to consensus 2016-03 Locking Down the Final /8 Policy Remco van Mook - Discuss the direction of our IPv4 allocation policy in general: Is it good enough, do we want it to be more liberal, or do we want it to be stricter? ---------------------------------------------------------------------- Wednesday, 11:00-12:30 ---------------------------------------------------------------------- Welcome back G. Market concentration in the transfers of IPv4 space 30 min Alain Durand and Gabe Fried D. Feedback From NCC Registration Service - Andrea Cima 45 min (+ discussion with the group) - IPv6 /48 potential policy bug - Update on ALLOCATED PI/ALLOCATED Unspecified - Legacy transfers straight after Inter-RIR transfer - Why RIPE NCC asks for prefix to be announced during ASN request - IPv4 IXP assignments - LIRs collect multiple IPv6 allocations Y. Open Policy Hour 15 min The Open Policy Hour is a showcase for your policy ideas. If you have a policy proposal you'd like to debut, prior to formally submitting it, here is your opportunity. Z. AOB

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New on RIPE Labs: RIPE NCC Membership and Available IPv4 Statistics - an Update
by Mirjam Kuehne 18 May '16

18 May '16

Dear colleagues, Ahead of RIPE 72, we wanted to take another look at our membership statistics. Was membership growth affected by the Executive Board's resolution preventing multiple LIR accounts? And how will the growth in new LIRs affect the projected lifespan of the available IPv4 pool? Please read more on RIPE Labs: https://labs.ripe.net/Members/wilhelm/ripe-ncc-membership-and-available-ipv… Kind regards, Mirjam Kuehne RIPE NCC

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2016-03 New Policy Proposal (Locking Down the Final /8 Policy)
by Куприянов Роман 17 May '16

17 May '16

Dear colleagues, It's no secret that the remaining blocks IPV4 - is the object of sale and purchase some sort of business. And this is a problem. Respected community, we should think about and finally form an idea and a road map how to finally bury the IPV4 and motivation to develop the path to go to the Internet to IPV6 irrevocably. Otherwise we will be until the end of his life to stagnate and share of long-dead body IPV4. ---------- Best regards, Kupriyanov Roman (ru.enigma)

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Re: [address-policy-wg] 2016-03 New Policy Proposal (Locking Down the Final /8 Policy)
by remco.vanmook＠gmail.com 17 May '16

17 May '16

It means it's not allocated PI, in line with the other definitions in chapter 7. Remco Sent from my HTC ----- Reply message ----- From: "Aleksey Bulgakov" <aleksbulgakov(a)gmail.com> To: "Gert Doering" <gert(a)space.net> Cc: "Marco Schmidt" <mschmidt(a)ripe.net>, "address-policy-wg(a)ripe.net" <address-policy-wg(a)ripe.net> Subject: [address-policy-wg] 2016-03 New Policy Proposal (Locking Down the Final /8 Policy) Date: Tue, May 17, 2016 17:03 ALLOCATED FINAL: This address space has been allocated to an LIR and no assignments made from it are portable. What does it mean "are portable"? 2016-05-17 16:38 GMT+03:00 Gert Doering <gert(a)space.net>: > Hi, > > On Tue, May 17, 2016 at 02:01:17PM +0100, Nick Hilliard wrote: >> I'd politely like to ask the chairs to do two things: >> >> 1. declare their opinion on whether 2015-05 reached consensus > > Right now, we have no consensus to move forward. We're currently > discussing with the proposers what to do next - extend the discussion > phase (to formally include the RIPE72 AP WG meeting), or withdraw. > >> 2. use the bunfight which is inevitably going to happen in Copenhagen to >> allow them to exercise more restraint about what sort of proposals hit >> the mailing list in future so that we don't spend years wasting time >> squabbling about the dregs sitting at the bottom of the ipv4 allocation >> barrel. > > I'm hearing you, and we think this discussion is indeed necessary (to be > held on wednesday about 09:30-10:30) to see whether there is general WG > consensus to move towards a more liberal (2015-05-ish), strict (2016-03-ish), > or "leave it as it is!" last /8 policy. And then, decide what to do with > upcoming policy proposals. > > Gert Doering > -- APWG chair > -- > have you enabled IPv6 on something today...? > > SpaceNet AG Vorstand: Sebastian v. Bomhard > Joseph-Dollinger-Bogen 14 Aufsichtsratsvors.: A. Grundner-Culemann > D-80807 Muenchen HRB: 136055 (AG Muenchen) > Tel: +49 (0)89/32356-444 USt-IdNr.: DE813185279 -- ---------- Best regards, Aleksey Bulgakov Tel.: +7 (926)690-87-29

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2015-05 Discussion Period extended until 13 May 2016 (Last /8 Allocation Criteria Revision)
by Marco Schmidt 14 May '16

14 May '16

Dear colleagues, The Discussion Period for the policy proposal 2015-05, "Last /8 Allocation Criteria Revision" has been extended until 13 May 2016. The goal of this proposal is to allow LIRs to request an additional /22 IPv4 allocation from the RIPE NCC every 18 months. The text of the proposal has been revised based on mailing list feedback and we have published a new version (2.0) today. As a result, a new Discussion Phase has started for the proposal. Some of the differences from version 1.0 include: - Additional /22 IPv4 allocations can be only provided from address space outside 185/8 - Only LIRs with less than a /20 in total are eligible to receive additional allocations - LIRs must document their IPv6 deployment as part of the request 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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agreement
by Ehsan Behbahani 14 May '16

14 May '16

-----Original Message----- From: "Ehsan Behbahani" <behbahani(a)soshiant.net> To: apwg(a)ripe.net Date: Sun, 08 May 2016 17:39:44 +0430 Subject: agreement Hi we are agree about theLast /8 Allocation Criteria Revision proposal . https://www.ripe.net/participate/policies/proposals/2015-05 [https://www.ripe.net/participate/policies/proposals/2015-05] RegID: ir.shnt best regards. Ehsan behbahani

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Draft agenda for RIPE 72
by Sander Steffann 13 May '16

13 May '16

Hi APWG folks, Below you can find a draft for the RIPE address policy WG meeting's agenda, which will take place in Copenhagen in the following time slots: Wednesday, May 25, 09:00 - 10:30 Wednesday, May 25, 11:00 - 12:30 If you have anything else you want to see on the agenda, or if we need to change anything, please let us know. So far, the agenda is fairly light - if you have something you want to address, or that bothers you, let us know and we make room for you :-) The distribution of items to the two timeslot is somewhat subject to the time spent on discussion - but we'll try to stick to what's published. regards, Sander Steffann, Gert Döring, APWG chairs ---------------------------------------------------------------------- Wednesday, 09:00-10:30 ---------------------------------------------------------------------- A. Administrative Matters (welcome, thanking the scribe, approving the minutes, etc.) B. WG Chair Selection C. Current Policy Topics Marco Schmidt, NCC PDO F. Discussion of open policy proposals ---------------------------------------------------------------------- Wednesday, 11:00-12:30 ---------------------------------------------------------------------- Welcome back G. Market concentration in the transfers of IPv4 space Alain Durand and Gabe Fried D. Feedback From NCC Registration Service Andrea Cima Y. Open Policy Hour The Open Policy Hour is a showcase for your policy ideas. If you have a policy proposal you'd like to debut, prior to formally submitting it, here is your opportunity. Z. AOB

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Comment on IPv4 depletion rate for proposal 2015-05
by Martin Huněk 11 May '16

11 May '16

Hello, I would also like to add my point of view on proposal 2015-05. In my opinion, this might even slow down depletion rate of 185/8. But it does not cover all cases of cheating the system. You all probably know better then me that if you want to get larger address space, the easiest way (and probably the cheapest) is to make new LIR, pay for 2 years and then transfer all its resources to your main LIR and close the new one. The proposed policy would probably lower the need for such practice a little bit, but still some space for cheating remains. I would like to see minor change in policy, such like that LIR could not transfer IPv4 resources from pool 185/8 to another LIR (or its sponsored organizations) so that receiving LIR (and its sponsored organizations) would held more than /22 in 185/8 pool. That way, it would not matter how many LIR you open, when you close LIR you would not be able to transfer resources to any of your other LIRs (in RIR region), so it would had to be returned to RIPE for new comers. Other than that, I agree with proposed policy change (2015-05). It might reduce the need for cheating system by offering the official way to expand LIRs pools, with motivation to start using IPv6 as well as limiting LIRs to monetize their (in 4 and a half years) pools so they can reach /20. Sincerely Martin Hunek Freenet Liberec, z.s.

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Re: [address-policy-wg] 2015-05 Discussion Period extended until 13 May 2016 (Last /8 Allocation Criteria Revision)
by Randy Bush 11 May '16

11 May '16

you may find reading the actual last /8 policy informative. > Last /8 is not really get affected by this policy. > - Additional /22 IPv4 allocations can be only provided from address space > outside 185/8 this is misleading or just sadly misinformed last /8 is not an address range, it is a state reached once the ncc had only that address range and continues on irrespective of additions or subtractions of space to the ncc's pool. randy

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Re: [address-policy-wg] agreement
by Arash Naderpour 10 May '16

10 May '16

Hi Sebastian, I understand your point but please consider that setting up a new LIR does not mean you are immediately eligible to receive additional /22. - allow LIRs to request an additional /22 IPv4 allocation from the RIPE NCC every 18 months. - Additional /22 IPv4 allocations can be only provided from address space outside 185/8 - Only LIRs with less than a /20 in total are eligible to receive additional allocations - LIRs must document their IPv6 deployment as part of the request - Allow LIRs to request an additional /22 IPv4 allocation from the RIPE NCC every 18 months. And you cannot transfer out your /22 for 2years, So affection to the depletion rate looks less than setting up multi LIR to receive immediately an /22 from 185/8 or encouraging small businesses in need of small blocks to become LIR. Regards, Arash Naderpour -----Original Message----- From: Sebastian Benoit [mailto:benoit-lists@fb12.de] Sent: Tuesday, 10 May 2016 5:07 AM To: Arash Naderpour <arash_mpc(a)parsun.com> Cc: RIPE Address Policy WG <address-policy-wg(a)ripe.net> Subject: Re: [address-policy-wg] agreement Hi, Arash Naderpour(arash_mpc(a)parsun.com) on 2016.05.09 23:25:56 +1000: > Hi, > > This policy may actually reduce the depletion rate for last /8, but > without it the last /8 can be used more day by day. > In the real world, even when a customer needs for example an /24, they > need to become an LIR (and get the /22 from the last /8) as their old > LIR cannot provide them with additional blocks. That also speed up the > depletion of last / 8. have you considered these when you made your objection? > > This policy is not increasing the demand for IPv4, It creates a > possibility for small LIRs to receive additional blocks (not from last > /8) based on some conditions, so no change in depletion rate from my point of view. On the other hand, there is also the possibility that 2015-05 will increase the depletion rate, not only because more address space will be handed out, but because it will make it more attractive (from a financial point of view) to set up a new LIR when you get more than a /22 out of it. That is, it might make the secondary market less attractive.

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2015-05 proposal
by Fabio Zannicolò - Voix s.r.l. 09 May '16

09 May '16

Hi, I would like to share with you my opinion on Last /8 Allocation Criteria Revision proposal (2015-05). Today small companies have competitiveness problems due to lack of IPv4 resources. I consider unfair the current treatment, the big companies have stocks of IPv4 addresses. We need a balance between resource conservation and fair treatment, in addition to those already proposed my suggestions are: -allocations of a /22 every 18 months only from IPv4 Addresses Available Outside 185/8 to small LIRs (if LIR own < /20 of total allocations) -leave the current policy only for IPv4 Addresses Available in 185/8 to avoid the too fast depletion of resources -the addresses acquired with this system should not be able to be transferred for a long period of time to avoid profit Best regards, Fabio Zannicolò

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Disabuse
by Rayanravesh Sena 07 May '16

07 May '16

Hi, My name is Borhan Habibi and my company name is Rayanravesh Sena, I sent my first email without noticing it has wrong from address field, so thought it would be better to resend it with my own name. I'm just one person, Hope it is clear to you and any one else got confused, Borhan Habibi

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Support the 2015-05 Policy
by Rayanravesh Sena 06 May '16

06 May '16

I think this policy is fair, i support it. With luck, Borhan Habibi

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additional /22
by Rayanravesh Sena 06 May '16

06 May '16

+1 2015-05

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I support this policy
by info＠rivebit.com 05 May '16

05 May '16

I support this policy

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additional /22
by Mojtaba Abolhasani 05 May '16

05 May '16

+1 to 2015-05

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additional /22
by Mojtaba Abolhasani 05 May '16

05 May '16

+1 2015-05

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Fwd: [ncc-announce] [news] RIPE Policy Proposals - April Update
by Sergiu IANCIUC 02 May '16

02 May '16

hello, PLS, take in consideration the situation Company X has a /22 from its LIR. The LIR can not offer more IPv4 spaces and the Company X becomes a LIR to satisfy its needs. Now, it is logical that the LIR (if agreed between these 2 LIRs) transfers the space allocated to the Company X (now the new LIR) AND THIS have to not be the part from the policy - "requirements, such as the LIR has not transferred any IPv4 address space before." What are you thinking about? Best Regards, - Sergiu IANCIUC SC ITNS.NET SRL MD-2068, Moldova or. Chisinau, str. Miron Costin 3/1 tel.: +373 22 877 877 fax : +373 22 44 11 73 mobile: +373 690 22 111 url: http://www.itns.md Save a tree... Don't print this email unless you have to... This is a forwarded message From: Marco Schmidt <mschmidt(a)ripe.net> To: ncc-announce(a)ripe.net Date: Friday, April 29, 2016, 11:18:23 AM Subject: [ncc-announce] [news] RIPE Policy Proposals - April Update ===8<==============Original message text=============== Dear colleagues, Here is our monthly overview of open policy proposals and their stage in the RIPE Policy Development Process (PDP). If you wish to join the discussion about a particular proposal, please do so on the relevant working group mailing list. Proposals Open for Discussion: 2015-05, "Revision of Last /8 Allocation Criteria" Proposals Awaiting Input: 2015-04, "RIPE Resource Transfer Policies" 2016-01, "Include Legacy Internet Resource Holders in the Abuse-c Policy" Proposal Overviews: PROPOSAL: 2015-05, "Revision of Last /8 Allocation Criteria" OVERVIEW: Aims to allow LIRs to request an additional /22 IPv4 allocation from the RIPE NCC every 18 months. The latest version of the proposal suggests several requirements, such as the LIR cannot hold more than a /20 IPv4, must document their IPv6 deployment and has not transferred any IPv4 address space before. STATUS: Discussion Phase WHERE TO COMMENT: Address Policy Working Group: address-policy-wg(a)ripe.net DEADLINE: 13 May 2016 FULL PROPOSAL: https://www.ripe.net/participate/policies/proposals/2015-05 ===== The following proposals are awaiting input before they can go any further in the PDP. PROPOSAL: 2015-04, "RIPE Resource Transfer Policies" OVERVIEW: Aims to create a single transfer policy with all relevant information on the transfer of Internet number resources, replacing text in several RIPE Policies. The proposal also introduces a 24-month holding period for IPv4 addresses and 16-bit ASNs after any change of holdership. RIPE NCC IMPACT ANALYSIS: Includes the point how the 24-month holding period for scarce resources will be applied. STATUS: Review Phase – Awaiting decision from working group chair FULL PROPOSAL: https://www.ripe.net/participate/policies/proposals/2015-04 PROPOSAL: 2016-01, "Include Legacy Internet Resource Holders in the Abuse-c Policy" OVERVIEW: Aims for a mandatory abuse contact for Legacy Internet Resource holders in the RIPE Database. STATUS: Discussion Phase – Awaiting decision from proposer FULL PROPOSAL: https://www.ripe.net/participate/policies/proposals/2016-01 The RIPE NCC provides an overview of current RIPE Policy Proposals on www.ripe.net: https://www.ripe.net/participate/policies/current-proposals/current-policy-… We look forward to your involvement in the PDP. Kind regards, Marco Schmidt RIPE Policy Development Officer RIPE NCC ===8<===========End of original message text===========

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(no subject)
by mostafa shahdadi 30 Apr '16

30 Apr '16

-- Sent from Gmail Mobile

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samuel.iii.barfield@hotmail.com
by Samuel Barfield III 26 Apr '16

26 Apr '16

Samuel Samuel Business of Information

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RIPE 71 Address Policy WG Draft Minutes
by Marco Schmidt 25 Apr '16

25 Apr '16

Dear colleagues, The draft minutes from the Address Policy Working Group sessions at RIPE 71 have now been published: https://www.ripe.net/participate/ripe/wg/ap/minutes/ripe-71 Please let us know of any corrections or amendments. Kind regards, Marco Schmidt Policy Development Officer RIPE NCC

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Re: [address-policy-wg] 2015-05 Discussion Period extended until 13 May 2016 (Last /8 Allocation Criteria Revision)
by remco.vanmook＠gmail.com 22 Apr '16

22 Apr '16

This confusion has been haunting the final /8 policy from day one - it was never about what to do with specifically 185/8, but what to do with all future allocations from the moment we needed to start allocating out of it. The policy text itself was never limited to a single /8, nor was that limitation any part of the discussion. Remco Sent from my HTC ----- Reply message ----- From: "Radu-Adrian FEURDEAN" <ripe-wgs(a)radu-adrian.feurdean.net> To: "Randy Bush" <randy(a)psg.com>, "Marco Schmidt" <mschmidt(a)ripe.net> Cc: "RIPE address policy WG" <address-policy-wg(a)ripe.net> Subject: [address-policy-wg] 2015-05 Discussion Period extended until 13 May 2016 (Last /8 Allocation Criteria Revision) Date: Sat, Apr 16, 2016 11:53 On Thu, Apr 14, 2016, at 19:24, Randy Bush wrote: > the purpose of the single last /8 allocation was to allow NEW ENTRY. The *single* "last /8" (185.0.0.0/8) is still reserved to what most people consider new entry. Further allocations would be from recovered space, which can also serve "new entry". Did you actually read the new text ? > pigs coming back to the trough every 18 months is not new anything. No, it's not. It'a actually commonplace in the other RIRs. -- Radu-Adrian FEURDEAN fr.ccs

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trouble with email client repreated messages
by Riccardo Gori 20 Apr '16

20 Apr '16

Please list consider only my last message of repeated ones about "Re: [address-policy-wg] 2015-05 Discussion Period extended until 13 May 2016 (Last /8 Allocation Criteria Revision)" I am getting in trouble with my email client and seems to send sort of draft revision of messages wich I didn't even saved as draft on it. It's second time happens and I didn't realize how. I am just replying normally and leaving opened on my pc the the draft and while waiting it seems to send 5 minutes time revision to list. Sorry I am using Thunderbird 38.7.2 and I was not aware of this kind of problem. I will change/update it as soon as possible. Sorry, It's happing out of my control. regards Riccardo -- Ing. Riccardo Gori e-mail: rgori(a)wirem.net Mobile: +39 339 8925947 Mobile: +34 602 009 437 Profile: https://it.linkedin.com/in/riccardo-gori-74201943 WIREM Fiber Revolution Net-IT s.r.l. Via Cesare Montanari, 2 47521 Cesena (FC) Tel +39 0547 1955485 Fax +39 0547 1950285 -------------------------------------------------------------------- CONFIDENTIALITY NOTICE This message and its attachments are addressed solely to the persons above and may contain confidential information. If you have received the message in error, be informed that any use of the content hereof is prohibited. Please return it immediately to the sender and delete the message. Should you have any questions, please contact us by re- plying to info(a)wirem.net Thank you WIREM - Net-IT s.r.l.Via Cesare Montanari, 2 - 47521 Cesena (FC) --------------------------------------------------------------------

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2015-05: Revision of Last /8 Allocation Criteria
by Denis Fondras 29 Mar '16

29 Mar '16

Hello, A few comment about this draft : - "1. The size of the allocation made will be the equivalent of a /22." may be reworded as "1. The size of the initial allocation made will be the equivalent of a /22." - "1. The LIR has not transferred any IPv4 address space out of its registry." may be reworded as "1. The LIR has not transferred any IPv4 address space out of its registry in the last 18 months."

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