Re: [address-policy-wg] [policy-announce]2014-05 New Draft Document and ImpactAnalysis Published (Policy for Inter-RIR Transfers of InternetResources) (Erik Bais)
Hi Erik - -
The model proposed in the policy is intended to mimic the existing policy between APNIC and ARIN whereby the arbitration topic is not needed. When two RIR's have like needs assessment, this topic goes away.
I noticed that the existing policy proposal doesn't have the arbitration point and the fact is, that the policies between RIPE and APNIC >>and RIPE and ARIN aren't the same. That in combination with the remark in the current policy summary :
RIPE NCC should create an operational procedure that satisfies the requirements of both RIRs in order to allow transfers to and from its service region.
That is an issue in my view.
That in combination with what is stated in the Impact Assessment that the ARIN staff does not see the policy to be compatible with >>theirs .. are the points that I wanted to address.
By having the other RIR pre-approve the transfer (either receiving or sending transfers) based on their view and interpretation of their >>own policy, they can do the need justification. Adjustments in their policy won't affect compatibility of the inter-RIR policy.
And when the transfer is then submitted for processing to RIPE, it will always be compatible, the RIPE staff doesn't have to cram up on >>all policy changes, arbitration isn't an issue and you will have a policy that will work. If one of the other RIR's is going to change to a no needs justification policy, they can just pre-approve the transfer, and the RIPE NCC >>can still just process the transfer ...
Personally I think that having the other RIR (not RIPE NCC) do the local policy checking and need justification if they have it for the >>transfer, makes this a lot easier, without having the RIPE NCC to line up on both the ARIN and APNIC policies.
As an example: What if Registration Services (RS) from RIPE NCC would approve a certain justification according to their policy interpretation and ARIN >>or APNIC RS would not approve the same logic ? Policy interpretation and the justification checking, should be done at the RIR who has the most strict policy. It doesn't make sense to >>me, to have RIPE IPRA's try to do a justification check based on interpretation of the APNIC or ARIN policy ...
Erik, if I understand you correctly, you are saying that the RIR with the strictest rules will perform the justification checks. For example, If we had a transfer from ARIN region to RIPE NCC region, then you are proposing the RIPE region buyer would have the needs justification performed by ARIN. Do I understand you correctly? The wording of the current proposal simply says that RIPE NCC would create an operational procedure. Marco Schmidt guides me that this operational procedure will be created in detail between the RIRs once RIPE NCC implements the proposal. The proposal will open the door for the option that other RIRs ask for information from the buying resource holder in RIPE NCC, in other words, that the operational procedure could be what you suggest, that another RIR, such as ARIN in my example above, would perform the needs justification on the RIPE buyer. Another solution might be that the other RIR sends a list of questions based on its policies/requirements and RIPE NCC passes this information to the purchaser and communicates back its answers. This seems more practical than having RIPE NCC staff updated about any policy changes in other regions. However what procedure(s) will be established is to be decided between the RIRs and, as I said, I did not intend for the policy itself to define operational procedures. So far we only know that ARIN doesn't see compatibility between the policies - again, to add commentary, I find this very surprising, since I repeat again, that the policy allows for the enforcement of needs justification to ARIN's content, through operational control. APNIC is unsure. Erik, I think we are on the same page with respect to the meaning, and it is merely that Marco, Gert, Sander, et al, should guide us on what is policy versus operational procedure.
This is the nature of negotiation in the global community.
Perhaps, but a policy for the benefit of the global community, should have some kind of arbitration clauses in there or at least define >>where arbitration should be done. It is good stewardship to have a RIPE policy that wouldn't open up the doors for long international discussions without a clear view on >>who the 'problem-owner' is .. and for future customers it should be clear where they can take their complains if they are not happy >>with the outcome.
I asked Marco about this and so far there is no Inter-RIR arbitration. Currently if an LIR in our region disagrees with a RIPE NCC decision, they can start an arbitration. However, as you point out, if a resource holder in RIPE NCC region disagrees with a decision e.g. from ARIN, there will be no direct way that they can start arbitration against this decision. I suppose a solution would be a global arbitration procedure, and this would seem to need a global policy proposal (to be accepted by the different RIRs and beyond the scope of 2014-05). Another more light-weight solution would be that the transfer partner in the other region starts the arbitration. Here is another hypothetical example. Say, Company A in ARIN wants to transfer to company B in RIPE NCC region. ARIN rejects the transfer request, due to missing requirements by company B. They both disagree with ARIN's decision. Then Company A starts an appeal with ARIN (as the ARIN member). This use of existing mechanisms would at least allow 2014-05 to get off the ground without making it too large.
Regards, Erik Bais
Regards, and thanks for pointing out these potential issues, Sandra Brown
On Oct 17, 2014, at 8:29 AM, sandrabrown@ipv4marketgroup.com wrote:
So far we only know that ARIN doesn't see compatibility between the policies - again, to add commentary, I find this very surprising, since I repeat again, that the policy allows for the enforcement of needs justification to ARIN's content, through operational control.
Sandra - The assessment of RIPE 2014-05 for compatibility is based on the very first sentence of the section 8.4 (Inter-RIR Transfer) of the ARIN Number Resource Policy Manual - "Inter-regional transfers may take place only via RIRs who agree to the transfer and share reciprocal, compatible, needs-based policies." The requirement is quite specific, in that ARIN can only to transfers to RIRs which share _policies_ which are compatible and needs-based. I do understand that adoption and implementation of RIPE 2014-05 may result in some form of operational processes which meet this criteria, but the policy itself must be explicitly needs-based and would not be as presently proposed. The goal of RIPE 2014-05 is laudable, in that the proposed policy text seeks to meet the requirements of any other RIR with amazing level of brevity. Unfortunately, it is lacks any needs-based specific criteria and thus it is not explicitly compatible with respect to Inter-RIR transfers from the ARIN region per our community-developed policy. Given that the intention of the RIPE 2014-05 proposal is to be compatible with ARIN's Inter-RIR transfer policy (including needs-based requirement), and it is just the lack of specificity in the proposed policy text which is problematic, would it be worth considering changing your very streamlined policy text to make the needs-basis requirement explicit for transfers from region that requiring such? This could be as simple as adding a policy statement to the effect of: "For transfers from RIR regions which require needs-based policies, recipients must provide a plan to the RIPE NCC for use of the transferred resource within 24 months." (for example) I recognize that having to place such a statement in your proposed policy text detracts from its present elegance, but this may be a situation where a less refined approach is warranted so that maximum compatibility can be achieved to the benefit of all IP address users. If this suggestion is not of interest, please disregard. If you have any questions of the above, I'd be happy to answer them either on-list or privately as you prefer. Best wishes, /John John Curran President and CEO ARIN p.s. Regardless of outcome, I will also report back to the ARIN community about how the current NRPM 8.4 policy text places requirements on other RIR's policy text, and to consider the merits and concerns when compared to other approaches, e.g. putting any Inter-RIR recipient requirements (to extend deemed necessary at all) in ARIN's policy text instead. FYI,/John
Hi all, I support the goals of 2014-15, the suggestion below seems to be a practical solution, if acceptable to all parties. Best regards, Steve Wright BTnet This email contains BT information, which may be privileged or confidential. It's meant only for the individual(s) or entity named above. If you're not the intended recipient, note that disclosing, copying, distributing or using this information is prohibited. If you've received this email in error, please let me know immediately on the email address above. Thank you. We monitor our email system, and may record your emails. British Telecommunications plc Registered office: 81 Newgate Street London EC1A 7AJ Registered in England no: 1800000 -----Original Message----- From: address-policy-wg-bounces@ripe.net [mailto:address-policy-wg-bounces@ripe.net] On Behalf Of John Curran Sent: 18 October 2014 01:02 To: sandrabrown@ipv4marketgroup.com Cc: Tore Anderson; Erik Bais; address-policy-wg@ripe.net Subject: Re: [address-policy-wg] [policy-announce]2014-05 New Draft Document and ImpactAnalysis Published (Policy for Inter-RIR Transfers of InternetResources) (Erik Bais) On Oct 17, 2014, at 8:29 AM, sandrabrown@ipv4marketgroup.com wrote:
So far we only know that ARIN doesn't see compatibility between the policies - again, to add commentary, I find this very surprising, since I repeat again, that the policy allows for the enforcement of needs justification to ARIN's content, through operational control.
Sandra - The assessment of RIPE 2014-05 for compatibility is based on the very first sentence of the section 8.4 (Inter-RIR Transfer) of the ARIN Number Resource Policy Manual - "Inter-regional transfers may take place only via RIRs who agree to the transfer and share reciprocal, compatible, needs-based policies." The requirement is quite specific, in that ARIN can only to transfers to RIRs which share _policies_ which are compatible and needs-based. I do understand that adoption and implementation of RIPE 2014-05 may result in some form of operational processes which meet this criteria, but the policy itself must be explicitly needs-based and would not be as presently proposed. The goal of RIPE 2014-05 is laudable, in that the proposed policy text seeks to meet the requirements of any other RIR with amazing level of brevity. Unfortunately, it is lacks any needs-based specific criteria and thus it is not explicitly compatible with respect to Inter-RIR transfers from the ARIN region per our community-developed policy. Given that the intention of the RIPE 2014-05 proposal is to be compatible with ARIN's Inter-RIR transfer policy (including needs-based requirement), and it is just the lack of specificity in the proposed policy text which is problematic, would it be worth considering changing your very streamlined policy text to make the needs-basis requirement explicit for transfers from region that requiring such? This could be as simple as adding a policy statement to the effect of: "For transfers from RIR regions which require needs-based policies, recipients must provide a plan to the RIPE NCC for use of the transferred resource within 24 months." (for example) I recognize that having to place such a statement in your proposed policy text detracts from its present elegance, but this may be a situation where a less refined approach is warranted so that maximum compatibility can be achieved to the benefit of all IP address users. If this suggestion is not of interest, please disregard. If you have any questions of the above, I'd be happy to answer them either on-list or privately as you prefer. Best wishes, /John John Curran President and CEO ARIN p.s. Regardless of outcome, I will also report back to the ARIN community about how the current NRPM 8.4 policy text places requirements on other RIR's policy text, and to consider the merits and concerns when compared to other approaches, e.g. putting any Inter-RIR recipient requirements (to extend deemed necessary at all) in ARIN's policy text instead. FYI,/John
participants (3)
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ipaddman＠bt.com -
John Curran -
sandrabrown＠ipv4marketgroup.com