On 04.08.2016 09:39, Ingrid Wijte wrote:

Dear colleagues,

During RIPE 72, the RIPE NCC was asked to suggest a way forward with regards to the unclear situation arising from address blocks in the RIPE Database with the status ALLOCATED PI or ALLOCATED UNSPECIFIED. We want to give you an update on this work and ask for your input.

BACKGROUND

Although PI assignments made by LIRs have the same status in the RIPE Database, it is not clear if resource holders with assignments from LIRs have the same rights as resource holders with those issued by the RIPE NCC. The community, mainly End Users, has asked the RIPE NCC to clarify the situation.

In the early days of the RIPE NCC, a small number of LIRs received allocations with the status ALLOCATED PI or ALLOCATED UNSPECIFIED. From these address blocks, LIRs could assign ranges with the status ASSIGNED PI.
The RIPE community later decided that the RIPE NCC should be the only party assigning ranges with ASSIGNED PI to End Users. It was not clear what the status of the assignments that had already been made should be.

ACTION TAKEN

At RIPE 71, the Address Policy Working Group asked the RIPE NCC to check the actual assignment status with the holders of these allocations. We contacted all of the LIRs involved and around 50% said they had no contact with holders of assignments with the status ASSIGNED PI within their allocations. Several allocations containing only PA assignments were converted from ALLOCATED UNSPECIFIED to ALLOCATED PA following communication with LIRs.

The RIPE NCC presented these results to the Address Policy Working Group at RIPE 72. The WG stressed that data accuracy must have the highest priority. It was further suggested that the RIPE NCC should follow up with the LIRs on a case-by-case basis, following the principles outlined below.

The WG agreed that, where the LIR can document a mutual agreement that they administer the address space, a conversion from PI to PA should take place. In all other cases, assignments with the status ASSIGNED PI should be treated as being assigned by the RIPE NCC.

It was also stated that LIRs should not register any new assignments with the status ASSIGNED PI, as policy no longer allows for new IPv4 PI assignments (with the exception of IXP PI assignments from our reserved address pool).

APPROACH
 
The RIPE NCC  will contact the 38 LIRs holding allocations that contain address blocks with the status ASSIGNED PI (3,600 inetnum objects in total).

In the following months, these LIRs will check if their RIPE Database entries are still correct. Each LIR will check their records and with their customers to see under what conditions the assignments were originally provided.

After the LIRs have finished their research, the RIPE NCC will:

-    Convert assignments to ASSIGNED PA if it can be documented that the administrative responsibility lies with the LIR
-    Follow up directly with resource holders of ASSIGNED PI to apply the RIPE policy, “Contractual Requirements for Provider Independent Resource Holders in the RIPE NCC Service Region”. The PI assignments will become part of the address space managed by the RIPE NCC just like all other PI space. Once the resource holders have fulfilled the contractual requirements, they will have the same rights and obligations as any other End User of PI space.
-    Split the allocations to separate the PI assignments and convert the blocks that remain with an LIR to ALLOCATED PA.

We suggest giving these LIRs until the end of January 2017 to clarify the status of the assignments within their ALLOCATED PI/UNSPECIFIED allocations.

In situations where a dispute arises between the LIR and the assignment holder about the administrative responsibility, the RIPE NCC will do its best to support a fair solution.

We welcome your feedback on this suggested approach. Please provide your input before 12 September 2016.

Kind regards,

Ingrid Wijte
Assistant Manager Registration Services
RIPE NCC