Re: [address-policy-wg] 2014-05 New Draft Document and Impact Analysis Published (Policy for Inter-RIR Transfers of Internet Resources)
* Marco Schmidt
The draft document for version 2.0 of the policy proposal 2014-05, "Policy for Inter-RIR Transfers of Internet Resources" has now been published, along with an impact analysis conducted by the RIPE NCC.
Supported. I think it's fairly obvious that some resource holders will engage in inter-regional transfers, and for the sake of registry accuracy we should ensure that our policies do not stand in the way of this. I have no objections to Nick's proposed amendments. I'd like to point out that the proposal does not modify ripe-623 section 6.4 (PI transfers) in the same way it does 5.3 (PA transfers). This is understandable, as 6.4 was very recently added, but it does contain language that could conceivably be interpreted as a barrier to inter-regional transfers, e.g., «any holder of Provider Independent (PI) address space is allowed to re-assign complete or partial blocks of IPv4 address space that were previously assigned to them *by the RIPE NCC*» (emphasis mine). That said, the Impact Analysis makes it clear that PI transfers will be permitted, so this doesn't alone justify a version 3.0 of the proposal. I note that the ARIN staff does not consider the policy to be sufficiently compatible with theirs. That comes as no surprise to me, but at least 2014-05 opens the door for the ARIN community to adjust their policy in a way that would allow inter-regional transfers between our regions, while at the same time allowing them to insist on need evaluation being performed. We'll just have to wait and see whether they accept our invitation or not; at least we're trying to be flexible and accommodating here, we can't do much more than that. That the APNIC staff are unsure whether or not their policy would be compatible (due to different need evaluation requirements) surprises me greatly. From http://www.apnic.net/policy/transfer-policy#rir-transfer:
4.3 Conditions on the recipient of the transfer
The conditions on the recipient of the transfer will be defined by the RIR where the recipient organization holds an account. This means:
* For transfers to an APNIC recipient, the conditions defined in Section 3.3 will apply. * Where the recipient is in another region, the conditions on the recipient as defined in the counterpart RIR's transfer policy at the time of the transfer will apply.
Section 3.3 is where the need evaluation requirement is. It therefore seems quite clear that for a transfer from the RIPE region to the APNIC region, the receiver would be required to undergo a need evaluation per section 3.3. This does not seem to be in conflict with 2014-05, rather quite the opposite due to the statement that «the RIPE NCC will also comply with the commitments imposed by the receiving RIR, in order to facilitate the transfer». For transfers from the APNIC region to the RIPE region, APNIC's section 3.3 (and thereby any APNIC need evaluation requirement) is not invoked; rather, the «counterpart RIR's transfer policy» is. In other words, 2014-05 + ripe-623 sections 5.5 and 6.4. Since the APNIC policy explicitly delegates all conditions on the RIPE region recipient to RIPE region policies, I cannot see any potential conflict for transfers in the APNIC->RIPE direction either. I'm perplexed that the APNIC staff is uncertain whether or not 2014-05 is compatible with their policy. The way I read them, they unequivocally are. Perhaps there are some APNIC folks lurking here who could elaborate? Tore
* Tore Anderson
I'm perplexed that the APNIC staff is uncertain whether or not 2014-05 is compatible with their policy. The way I read them, they unequivocally are.
I was pointed this recording of APNIC's policy-sig meeting which sheds some more light on the matter (the relevant presentation starts at 1:33): https://www.youtube.com/watch?v=5cXk8BrMJJU It would appear there are two distinct problems: 1) APNIC feels that 2014-05 causes a circular policy loop for APNIC->RIPE transfers, cf. the slide that's up at 1:36:30. As I understand it, the problem is that APNIC's policy says any requirements on the receiver is «as defined in [RIPE's] tranfer policy», which in turn says the «the RIPE NCC will work with the resource holder to fulfil[sic] any requirements of [APNIC]». I personally believe this is a misinterpretation on APNIC's part, as my understanding on the latter language is that it is only to be applied when the sending RIR insists on particular requirements being imposed on the receiver, that which are not found in our own set of policies. The most obvious example of such a requirement would be ARIN's insistence on «reciprocal, compatible, needs-based policies» (cf. https://www.arin.net/policy/nrpm.html#eight4). For APNIC, on the other hand, there does not appear to be any policy requirement that would require this language to come into effect. (They could still use it for non-policy requirements though, such as demanding a transfer fee from the RIPE region recipient, but I digress.) Therefore, the receiver of a transfer from APNIC to RIPE would only be subject to any requirements in our own policies (i.e., ripe-623 section 5.5 or 6.4). In any case, 2014-05 probably needs to be amended so that it is clear that the statements «when Internet number resources are transferred from another RIR, the RIPE NCC will work with the resource holder to fulfil any requirements of the sending RIR» and «the RIPE NCC will also comply with the commitments imposed by the receiving RIR, in order to facilitate the transfer», is only to be used if and only if there other RIR has an absolute requirement that does not exist in our policies, and furthermore that they are used to allow compliance with that particular requirement alone. 2) Assuming the previous point is handled, there is an additional concern that if 2014-05 passes, it will cause ARIN to declare that APNIC's policy is no longer compatible. It wasn't entirely clear to me if they though this would happen instantaneously (by ARIN-the-RIR, not the community), or if they were worried that the ARIN community would react by changing their policies to make them incompatible. - The instantaneous alternative does strike me as somewhat far fetched, considering that ARIN has already deemed APNIC's policy to be «reciprocal, compatible, needs-based», and the fact that 2014-05 doesn't change a single word in neither ARIN's nor APNIC's policy documents. That said, obviously I can't know for certain if 2014-04 could possibly cause such an instantaneous change in how ARIN interprets APNIC's policy text. Maybe John could chime in? - The other alternative, where 2014-05's passing would prompt the ARIN community to change their policy document so that APNIC<->ARIN transfers are no longer possible, does seems more plausible, yet somewhat speculative as we have no idea whether the ARIN community cares about 2014-05 at all and if so what they think about it. Another possibility, which was suggested by one commentator, is that the APNIC community preempts such an ARIN policy change, by changing their own policy instead (if they feel it is necessary in order to keep the ARIN community happy that is). In any case, as other RIRs' policies are out of our hands, I don't think we can do much about it in 2014-05, unless there is some clear guidance from APNIC and/or ARIN on how 2014-05 could be amended to make them happy (assuming either of them are unhappy in the first place). While I'm a firm believer in letting the individual RIR communities write their own policies without other regions trying to influence the process, Inter-RIR policies are necessarily exceptions. Tore
On 15/10/14 09:10, Tore Anderson wrote: > * Tore Anderson > >> I'm perplexed that the APNIC staff is uncertain whether or not 2014-05 >> is compatible with their policy. The way I read them, they unequivocally >> are. > 2) Assuming the previous point is handled, there is an additional > concern that if 2014-05 passes, it will cause ARIN to declare that > APNIC's policy is no longer compatible. It wasn't entirely clear to me > if they though this would happen instantaneously (by ARIN-the-RIR, not > the community), or if they were worried that the ARIN community would > react by changing their policies to make them incompatible. > > - The instantaneous alternative does strike me as somewhat far fetched, > considering that ARIN has already deemed APNIC's policy to be > «reciprocal, compatible, needs-based», and the fact that 2014-05 doesn't > change a single word in neither ARIN's nor APNIC's policy documents. > That said, obviously I can't know for certain if 2014-04 could possibly > cause such an instantaneous change in how ARIN interprets APNIC's policy > text. Maybe John could chime in? > > - The other alternative, where 2014-05's passing would prompt the ARIN > community to change their policy document so that APNIC<->ARIN transfers > are no longer possible, does seems more plausible, yet somewhat > speculative as we have no idea whether the ARIN community cares about > 2014-05 at all and if so what they think about it. > > Another possibility, which was suggested by one commentator, is that the > APNIC community preempts such an ARIN policy change, by changing their > own policy instead (if they feel it is necessary in order to keep the > ARIN community happy that is). > Just for information, at the recent ARIN meeting last week, John Curran stated that the adoption of 2014-05 would *not* impair the ability of LIRs to transfer address space from ARIN to APNIC and thence to RIPE NCC. Nigel
On Oct 15, 2014, at 1:10 AM, Tore Anderson <tore@fud.no> wrote:
... 2) Assuming the previous point is handled, there is an additional concern that if 2014-05 passes, it will cause ARIN to declare that APNIC's policy is no longer compatible. It wasn't entirely clear to me if they though this would happen instantaneously (by ARIN-the-RIR, not the community), or if they were worried that the ARIN community would react by changing their policies to make them incompatible.
- The instantaneous alternative does strike me as somewhat far fetched, considering that ARIN has already deemed APNIC's policy to be «reciprocal, compatible, needs-based», and the fact that 2014-05 doesn't change a single word in neither ARIN's nor APNIC's policy documents. That said, obviously I can't know for certain if 2014-04 could possibly cause such an instantaneous change in how ARIN interprets APNIC's policy text. Maybe John could chime in?
Per <https://www.ripe.net/ripe/policies/proposals/2014-05>, section "Compatibility with other RIRs" -
... The following statement has been received from APNIC and ARIN:
“After consulting with both ARIN and APNIC, the two RIRs have confirmed how ARIN policy requires ‘needs based’, explicitly stated, policy principals to be in place to allow for inter-RIR resource transfers, and that APNIC’s has the same needs based principles explicitly stated in its policy document. RIPE policy document ripe-622 (paragraph 5.1, sub 3), addresses a needs base in an implicit manner. It is therefore not possible for the APNIC secretariat to interpret this and take a position. The APNIC secretariat indicates that it will consult their community in order to get guidance on how to proceed. ARIN staff notes that the lack of a specific needs-based requirement in the RIPE policy document will prevent the policy from being deemed compatible with ARIN's Inter-RIR transfer policy requirements to the RIPE region (although its adoption will have no effect on Inter-RIR transfers between ARIN and the APNIC region.)”
- The other alternative, where 2014-05's passing would prompt the ARIN community to change their policy document so that APNIC<->ARIN transfers are no longer possible, does seems more plausible, yet somewhat speculative as we have no idea whether the ARIN community cares about 2014-05 at all and if so what they think about it.
Indeterminate. The existence of RIPE 2014-05 was raised last week during the ARIN 34 meeting, and I noted the ARIN staff determination on this matter (that APNIC's inter-RIR transfer policy remains compatible with ARIN policy if RIPE 2014-05 is adopted by the RIPE community.) The ARIN community is aware that they would need to propose some change to ARIN's Inter-RIR transfer policy if another outcome is desired. FYI, /John John Curran President and CEO ARIN p.s. The RIPE and APNIC RIR policy development staff should be thanked for their foresight in researching this topic in advance, and arranging for the very coherent "Compatibility with other RIRs" section in the RIPE 2014-05 Impact Analysis... thanks! :-)
Hi John,
Per <https://www.ripe.net/ripe/policies/proposals/2014-05>e
[...] (although its adoption will have no effect on Inter-RIR transfers between ARIN and the APNIC region.)”
There it is indeed, black on white. Thank you for pointing out my poor short time memory. :-) I suppose that the reason why this was being brought up as a possible problem at the APNIC meeting was that this clarification had not yet been made at that point.
The existence of RIPE 2014-05 was raised last week during the ARIN 34 meeting, and I noted the ARIN staff determination on this matter (that APNIC's inter-RIR transfer policy remains compatible with ARIN policy if RIPE 2014-05 is adopted by the RIPE community.) The ARIN community is aware that they would need to propose some change to ARIN's Inter-RIR transfer policy if another outcome is desired.
Ack. This is reasonable and what I would expect. I would find it interesting to watch this discussion from the ARIN 34 meeting, hopefully recordings from it will be made available at some point.
p.s. The RIPE and APNIC RIR policy development staff should be thanked for their foresight in researching this topic in advance, and arranging for the very coherent "Compatibility with other RIRs" section in the RIPE 2014-05 Impact Analysis... thanks! :-)
Indeed, it is important to know if the new policy is going to work at all before adopting it. Not much point in doing it if not... I guess what remains to be done with 2014-05 in this regard, is to clarify it so that APNIC (or any other RIR for that matter) realises that its language isn't meant to cause a "policy loop", but rather to be accommodating to RIR communities that would like to explicitly insist that a out of region transfer source/destination entity must be invariably subjected to a certain set of conditions (which are not necessarily duplicated in the policies of the region of the aforementioned entity). Tore
participants (3)
-
John Curran -
Nigel Titley -
Tore Anderson