Hi Carsten,

not only that the loophole exists, but the RIPE NCC has even pointed it out in an RIPE Labs article (and several previous RIPE Meetings):
https://labs.ripe.net/Members/wilhelm/ripe-ncc-membership-statistics-2014

I think that the more we talk about it, the more this loophole will be (ab)used. The part that was just theoretical was estimating how long it will take a company to decide that instead of going to the market, they could actually go to the RIPE NCC and get a /16 or maybe a /12 at €2.3 - €3.4 per IP (depending in which quarter you decide to do it).
- this policy proposal will still not fix this issue, will just raise even more awareness.. this policy proposal is just trying to patch the transfer policy. we still need to discuss whether we want to touch the mergers and acquisitions process.

regards,
elvis


On 10/03/15 09:13, DOI (BIT I 5) wrote:

Hi Elvis,

I agree with your proposal. I’m interested in the fact: Are there such “loophole” cases right now or is it a theoretical problem, that could be happen if 2015-01 would not be accepted?

Regards,

Carsten

 

Von: address-policy-wg [mailto:address-policy-wg-bounces@ripe.net] Im Auftrag von Elvis Daniel Velea
Gesendet: Montag, 9. März 2015 17:32
An: address-policy-wg@ripe.net
Betreff: Re: [address-policy-wg] 2015-01 New Policy Proposal (Alignment ofTransfer Requirements for IPv4 Allocations)

 

Hi everyone,

I have thinking at what to answer regarding the comments on this proposal.

Firstly, the /22 from the last /8 policy proposal aimed to create a method for anyone to receive at least a few (1024) IPv4 addresses by becoming a member of the RIPE NCC.
Even then, the proposers had noted that anyone can open multiple LIRs and receive from the RIPE NCC more than 1024 IP addresses and asked the RIPE NCC to be vigilant. [1]

What happens now is not in the spirit of that policy proposal as the /22 from the RIPE NCC does not have the two years holding period so a few found a way to make a business using this loophole.
This policy proposal is just trying to add the same holding period for a transfer of the /22 as it is already for the rest of the allocations made by the RIPE NCC.


While I do agree that if the RIPE NCC free pool would be depleted, the market would takeover and normalize the price, the community has decided to have IPv4 addresses available for anyone that
 wants to become a member of the RIPE NCC and therefore request & receive a /22.
I think that a separate proposal could tackle this issue, there were some discussions last year (if I remember correctly) and some members of this community suggested the increasing the limit from /22 to /21. That may deplete the free pool faster, but it will still slowly bleed out in a few years.

If we do not agree that this policy proposal is fair and needed, I predict that we will see more and more companies opening LIRs just to make use of this loophole and make a profit from selling one or more /22s from the last /8.
Actually, this policy proposal may have already harmed the free pool because if it does not get approved, more people have found out of the loophole and nothing will stop them from using it, they will have the endorsement of the community to just go ahead and open multiple LIRs.
I would not be surprised to see a very large ISP or (content) hosting company setting up 1.000 LIRs to get 1million IP addresses.. and if they setup 1024 LIRs in the same 'day' they may even get a /12 as a contiguous block.
In that case, would you find it fair that if someone wants to use a loophole (1024 times) they can get a /12 from the RIPE NCC while others need to use the market?

Considering these, Martin (and whoever else does not like this policy proposal), please let me know if you oppose to to this proposal as it is written and if you have any suggestion on what would be acceptable.

regards,
Elvis

 
[1] https://www.ripe.net/ripe/policies/proposals/2010-02
"Some organisations may set up multiple LIR registrations in an effort to get more address space than proposed. The RIPE NCC must be vigilant regarding these, but the authors accept that it is hard to ensure complete compliance."

--

Elvis Daniel Velea

Chief Executive Officer

Email: elvis@V4Escrow.net
US Phone: +1 (702) 475 5914
EU Phone: +31 (0) 61458 1914

Recognised IPv4 Broker/Facilitator in:

This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received this email in error, please notify the sender immediately and delete the original.Any other use of this email is strictly prohibited.

 



--

Elvis Daniel Velea

Chief Executive Officer

Email: elvis@V4Escrow.net
US Phone: +1 (702) 475 5914
EU Phone: +31 (0) 61458 1914

Recognised IPv4 Broker/Facilitator in:

This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received this email in error, please notify the sender immediately and delete the original.Any other use of this email is strictly prohibited.