Re: [members-discuss] [comms] [ncc-announce] [news] RIPE NCC Members and Multiple
Dear RIPE NCC Board, Thank you for opening this discussion/consultation.
1. Is the activity of members opening additional LIR accounts a problem that must be prevented?
It is. The RIPE NCC policies should be written in a way which is beneficial to its community. Having a number of organisations using them to profit (financially or by gaining more IP addresses) is not in our community’s interest. However, any response to a problem should be proportional to the issue and therefore the RIPE NCC’s answer to this problem should take in consideration the number of member abusing the system and the harm being done to the community. The last /8 policy was mostly written to make sure new entrants are not priced out of market and from the data there is no evidence this is yet the case. Therefore any solution should be careful to keep this goal. 2. If this activity is a problem that must be prevented, what action should the RIPE NCC take to attempt its prevention? This is a very broad topic, and a decision by consensus without some more research and a/some paper(s) to guide the discussion seems unwise here. That said … Like others, I can see two scenarios why an organisation may register several LIR: (0) it is practical for their organisation - nothing to see (1) to secure for itself several /22 when the last /8 policy comes in play (2) to secure a number of /22 to resell … If the board is aware of other case, I would welcome some enlightemement For case (1) The RIPE NCC could restrict the number of LIR an organisation wish to have (to a suitable low but practical number) as long as this does not impact genuine use of the RIPE NCC. For case (2), The most likely impact of forbidding this practice may be to increase the price of IPv4 at sales (passing on the cost of the business creation), which would affect people needing IP space - and required to purchase some - more than the people selling it and making the profit. Price changes should only be brought forward if the RIPE NCC is sure it can price ‘bad’ business models out. As this is something we have no data to make our mind on and and which may also have other side effects - I am unsure it would be wise. Also the membership should keep in mind that any new ‘policy’ will be immediately ‘played’ by people actively trying to game the system. Therefore careful thoughts should be placed on any new rule placed which will therefore inevitably have unintended consequences. Regarding enforcing some rules for the transfer of resources, I am concerned it could place the organisation in a position where it could be on the receiving hand of legal challenges. Therefore I would favour any solution which would not require any ‘human judgement’ by the RIPE NCC at transfer time.
The Board will monitor the discussion and will review it at the next Executive Board Meeting on 31 March 2016. Depending on the outcome of that meeting, the Board may propose a resolution for members to vote on at the RIPE NCC General Meeting in May 2016.
I would hope the RIPE NCC does put forwad some proposals for vote. As the board may not be in a position to ‘guess’ the option(s) most likely to gain consensus, a number of proposals could be presented to the membership so should a proposal succeed (or fail) others can be presented to complete / replace it. (This assumes the extra new LIRs are not already in a veto position with our usual voting engagement) Also the RIPE NCC may consider to add this information to the list of RIPE NCC’s LIR as: - it would allow to spot who may oppose changes to the RIPE NCC policies due to personal gain - it would the community to use other form of self-regulation to act on this matter should the RIPE NCC fail to reach consensus. Some of the options to remove the benefit of registering several LIR are (more than one could be considered for a solution): - creating some more aggresive rules regarding the transfer of resources - not allowing resources transfer for ‘young’ LIR - changing the rules for the last /8 * having a concept of related LIR * providing some space in relation to the existing allocation (at the cost of increasing the fragmentation of the /8). - revoking the last /8 policy - treating it as normal - revoking the last /8 policy - keeping the space until more visibility on how best use it can be gathered. - .. surely some more .. Sincerely, Thomas Mangin Exa Networks Limited
Hello! Perfect contribution Thomas! I could put my sign under each word here. Thanks for your work! On Tue, Feb 16, 2016 at 3:46 PM, Thomas Mangin < thomas.mangin@exa-networks.co.uk> wrote:
Dear RIPE NCC Board,
Thank you for opening this discussion/consultation.
1. Is the activity of members opening additional LIR accounts a problem that must be prevented?
It is. The RIPE NCC policies should be written in a way which is beneficial to its community. Having a number of organisations using them to profit (financially or by gaining more IP addresses) is not in our community’s interest.
However, any response to a problem should be proportional to the issue and therefore the RIPE NCC’s answer to this problem should take in consideration the number of member abusing the system and the harm being done to the community.
The last /8 policy was mostly written to make sure new entrants are not priced out of market and from the data there is no evidence this is yet the case. Therefore any solution should be careful to keep this goal.
1. If this activity is a problem that must be prevented, what action should the RIPE NCC take to attempt its prevention?
This is a very broad topic, and a decision by consensus without some more research and a/some paper(s) to guide the discussion seems unwise here. That said …
Like others, I can see two scenarios why an organisation may register several LIR: (0) it is practical for their organisation - nothing to see (1) to secure for itself several /22 when the last /8 policy comes in play (2) to secure a number of /22 to resell … If the board is aware of other case, I would welcome some enlightemement
For case (1) The RIPE NCC could restrict the number of LIR an organisation wish to have (to a suitable low but practical number) as long as this does not impact genuine use of the RIPE NCC.
For case (2), The most likely impact of forbidding this practice may be to increase the price of IPv4 at sales (passing on the cost of the business creation), which would affect people needing IP space - and required to purchase some - more than the people selling it and making the profit.
Price changes should only be brought forward if the RIPE NCC is sure it can price ‘bad’ business models out. As this is something we have no data to make our mind on and and which may also have other side effects - I am unsure it would be wise.
Also the membership should keep in mind that any new ‘policy’ will be immediately ‘played’ by people actively trying to game the system. Therefore careful thoughts should be placed on any new rule placed which will therefore inevitably have unintended consequences.
Regarding enforcing some rules for the transfer of resources, I am concerned it could place the organisation in a position where it could be on the receiving hand of legal challenges. Therefore I would favour any solution which would not require any ‘human judgement’ by the RIPE NCC at transfer time.
The Board will monitor the discussion and will review it at the next Executive Board Meeting on 31 March 2016. Depending on the outcome of that meeting, the Board may propose a resolution for members to vote on at the RIPE NCC General Meeting in May 2016.
I would hope the RIPE NCC does put forwad some proposals for vote. As the board may not be in a position to ‘guess’ the option(s) most likely to gain consensus, a number of proposals could be presented to the membership so should a proposal succeed (or fail) others can be presented to complete / replace it. (This assumes the extra new LIRs are not already in a veto position with our usual voting engagement)
Also the RIPE NCC may consider to add this information to the list of RIPE NCC’s LIR as: - it would allow to spot who may oppose changes to the RIPE NCC policies due to personal gain - it would the community to use other form of self-regulation to act on this matter should the RIPE NCC fail to reach consensus.
Some of the options to remove the benefit of registering several LIR are (more than one could be considered for a solution): - creating some more aggresive rules regarding the transfer of resources - not allowing resources transfer for ‘young’ LIR - changing the rules for the last /8 * having a concept of related LIR * providing some space in relation to the existing allocation (at the cost of increasing the fragmentation of the /8). - revoking the last /8 policy - treating it as normal - revoking the last /8 policy - keeping the space until more visibility on how best use it can be gathered. - .. surely some more ..
Sincerely,
Thomas Mangin Exa Networks Limited
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On 16.02.16 14:46, Thomas Mangin wrote:
1. Is the activity of members opening additional LIR accounts a problem that must be prevented?
It is. The RIPE NCC policies should be written in a way which is beneficial to its community.
It is NOT. The problem is not a secondary LIR account itself, but an additional /22 allocated to same company. So quick way is to change policy and say every *COMPANY* should receive one /22, not every *LIR*. P.S. By the way, if there are several LIR accounts binded to one company, how many votes do that company have at General Meeting?
Hello, Why not to have a some rule to forbid IPv4 transfer from last /8 RIPE block for 3 or even 5 years? This will prevent companies to register LIR just for selling addresses. This of course is very strict, but some restriction like this can help. Best regards, Misak Khachatryan, Network Administration and Monitoring Department Manager, GNC- ALFA CJSC 1 Khaghaghutyan str., Abovyan, 2201 Armenia Tel: +374 60 46 99 70 (9670), Mob.: +374 55 19 98 40 URL: www.rtarmenia.am On Tue, Feb 16, 2016 at 7:02 PM, Max Tulyev <maxtul@netassist.ua> wrote:
On 16.02.16 14:46, Thomas Mangin wrote:
1. Is the activity of members opening additional LIR accounts a problem that must be prevented?
It is. The RIPE NCC policies should be written in a way which is beneficial to its community.
It is NOT. The problem is not a secondary LIR account itself, but an additional /22 allocated to same company.
So quick way is to change policy and say every *COMPANY* should receive one /22, not every *LIR*.
P.S. By the way, if there are several LIR accounts binded to one company, how many votes do that company have at General Meeting?
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Misak Khachatryan wrote:
Why not to have a some rule to forbid IPv4 transfer from last /8 RIPE block for 3 or even 5 years? This will prevent companies to register LIR just for selling addresses.
This of course is very strict, but some restriction like this can help.
this sort of thing won't help. Transfers will happen anyway. The only thing that will happen as a result of attempting to ban transfers is that the transfer will not be documented, which will drive the address market underground. This benefits no-one. Bear in mind that the purpose of the RIPE NCC registry is to ensure accurate registration of address resources, not to beat people with sticks and tell them what they can or cannot do. Nick
Another thought: how many LIR was opened in 2015 ? On 16/02/2016 16:21, Nick Hilliard wrote:
Misak Khachatryan wrote:
Why not to have a some rule to forbid IPv4 transfer from last /8 RIPE block for 3 or even 5 years? This will prevent companies to register LIR just for selling addresses.
This of course is very strict, but some restriction like this can help.
this sort of thing won't help. Transfers will happen anyway. The only thing that will happen as a result of attempting to ban transfers is that the transfer will not be documented, which will drive the address market underground. This benefits no-one.
Bear in mind that the purpose of the RIPE NCC registry is to ensure accurate registration of address resources, not to beat people with sticks and tell them what they can or cannot do.
Nick
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On 16.02.2016, at 16:21, Nick Hilliard <nick@netability.ie> wrote:
Misak Khachatryan wrote:
Why not to have a some rule to forbid IPv4 transfer from last /8 RIPE block for 3 or even 5 years? This will prevent companies to register LIR just for selling addresses.
This of course is very strict, but some restriction like this can help.
this sort of thing won't help. Transfers will happen anyway. The only thing that will happen as a result of attempting to ban transfers is that the transfer will not be documented, which will drive the address market underground. This benefits no-one.
When you look at my idea posted earlier, like you I won’t interfere with the usage, just the bill is higher from a business perspective. Matthias
Dear Max, On 16/02/16 16:02, Max Tulyev wrote:
On 16.02.16 14:46, Thomas Mangin wrote:
1. Is the activity of members opening additional LIR accounts a problem that must be prevented?
It is. The RIPE NCC policies should be written in a way which is beneficial to its community.
It is NOT. The problem is not a secondary LIR account itself, but an additional /22 allocated to same company.
So quick way is to change policy and say every *COMPANY* should receive one /22, not every *LIR*.
P.S. By the way, if there are several LIR accounts binded to one company, how many votes do that company have at General Meeting?
Votes at the General Meeting are assigned to members rather than LIRs. So a company with several LIRs will only have one vote at the GM. Fergal Cunningham Membership Communications Officer RIPE NCC
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On 16 Feb 2016, at 15:02, Max Tulyev wrote:
So quick way is to change policy and say every *COMPANY* should receive one /22, not every *LIR*.
It cost $100 euro (bulk figure) to setup a new business in the UK .. And now the RIPE NCC has no idea of who is related to who and who is abusing what. $100 is a trivial among to recover. Thomas
On Tue, Feb 16, 2016, at 16:02, Max Tulyev wrote:
So quick way is to change policy and say every *COMPANY* should receive one /22, not every *LIR*.
No, that is the SLOW way. Policy change takes 3-4 months in a best-case scenario (everybody agrees - it is not the case here). And there is a difference between *HAVING* multiple LIR accounts for a company (i.e. after a purchase or merger) and *OPENING* a new LIR account for a company that does already have an account. the first case may be legitimate and is less subject to abuse. The second one is much more subject to abuse, as it has been seen during 2015. ... and then there is the "related LIR" issue (or non-issue), which is much more complex and difficult to solve properly. -- Radu-Adrian FEURDEAN fr.ccs
Hi Guys: I think we all agree to following: IF you really want to open multiple LIR account, you always can,and in case your guys not notice, you do not even need to have company in this region--RIPE accept membership worldwide as long as you promise use 1 IP in the region, so you can go wild and going some island to open 1000 company to get 1000 LIR, it is possible. So the discussion bolt down to, should we make it hander for people to open multiple LIRs to get IPs. It always come down to economic incentives, as long as Address are cheaper at RIPE, economically people will always find way to "buy" more address from RIPE. But opening shell companies, getting more entities, isn't free, cost may varies quite a lot depends how you do it, but let's say each shell company cost 600USD a year, effectively by forbidding same company open multiple LIR, we are simply increase cost of RIPE membership for the people abuse the system by 600USD/year, or 0.6USD/IP/year. That's all the discussion come down to really, I personally has no objection to increase the cost for abusers, as the address was intentionally reserved for transition purpose but not really for daily business operation(in which this need nowadays you should go to market and buy). It's like university provide cheap food for student, but does not mean when you need food you should go to university to buy, as the intention of cheap food supply there are for student who didn't have job yet, while if you already graduated, there is a market for your food supply. The very reason I object such decision in the last GM was simply because I feel there is no way really prevent people opening multiple LIRs, such action will only increase amount of shell company in existence, but ok,since it does increase the cost for abuser,why not, doesn't hurt anything anyway. On Wed, Feb 17, 2016 at 12:35 AM, Radu-Adrian Feurdean <ripe-ncc@radu-adrian.feurdean.net> wrote:
On Tue, Feb 16, 2016, at 16:02, Max Tulyev wrote:
So quick way is to change policy and say every *COMPANY* should receive one /22, not every *LIR*.
No, that is the SLOW way. Policy change takes 3-4 months in a best-case scenario (everybody agrees - it is not the case here).
And there is a difference between *HAVING* multiple LIR accounts for a company (i.e. after a purchase or merger) and *OPENING* a new LIR account for a company that does already have an account. the first case may be legitimate and is less subject to abuse. The second one is much more subject to abuse, as it has been seen during 2015.
... and then there is the "related LIR" issue (or non-issue), which is much more complex and difficult to solve properly.
-- Radu-Adrian FEURDEAN fr.ccs
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Hello, a little example for (little) additional regulation. Other kinds of solutions work similar, this tries to boil down on motive and solution.
On 16.02.2016, at 13:46, Thomas Mangin <thomas.mangin@exa-networks.co.uk> wrote:
Dear RIPE NCC Board,
Thank you for opening this discussion/consultation. ... The last /8 policy was mostly written to make sure new entrants are not priced out of market and from the data there is no evidence this is yet the case. Therefore any solution should be careful to keep this goal.
New entrants have the interest to stay in the market, so any attempt to transfer a /22 given under last /8 policy can be denied. If any other LIR is e.g. buying this new LIR, they can migrate central services, or keep the LIR open, and pay membership twice for the time being. This would make it not only an one time investment to open/close additional LIRs, but increase the running cost of new IPv4 networks. This is essential what we want: make *new* IPv4 deployment more expensive, to all migrate to a hopeful brighter IPv6 future. Old players also have incentive to sell address space, instead of hoarding it, as a possible IPv6 world devalues the asset. Matthias
On 16 Feb 2016, at 15:13, Matthias Šubik wrote:
This is essential what we want: make *new* IPv4 deployment more expensive, to all migrate to a hopeful brighter IPv6 future.
What you are saying is that the RIPE NCC should price out new entrant from IPv4. Do you think that it may look a lot like a Cartel behaviour falling under european antitrust laws ? (This is a rhetorical question - let’s not start this debate - I just want to show a possible shortcoming of this line of thought)
Old players also have incentive to sell address space, instead of hoarding it, as a possible IPv6 world devalues the asset.
If the price goes up .. I would not SELL such an asset: the transfer or purchase of IP are not the only way to give another organisation access to some IP space. If you have an ASN and IP space you can simply ‘lease it’ by letting the organisation route your traffic and use the IP and milk the asset even more. So whatever rule in put in place it may simply may do NOTHING to prevent cross organisation IP usage. And some serious thought must be given to the real effectiveness of the change proposed. Thomas
On 16.02.2016, at 16:58, Thomas Mangin <thomas.mangin@exa-networks.co.uk> wrote:
On 16 Feb 2016, at 15:13, Matthias Šubik wrote:
This is essential what we want: make *new* IPv4 deployment more expensive, to all migrate to a hopeful brighter IPv6 future.
What you are saying is that the RIPE NCC should price out new entrant from IPv4. Clarification: *new* deployment for *old* LIR (cloned LIR). b/c instead of opening another LIR, just to grow their IPv4 allocation by /22 they would need to maintain that second LIR longer.
read again: a new LIR gets a /22 under /8, and should be interested in using it, not selling it, right?
Do you think that it may look a lot like a Cartel behaviour falling under european antitrust laws ? I think this question is obsolete. (This is a rhetorical question - let’s not start this debate - I just want to show a possible shortcoming of this line of thought) I think you misunderstood my idea. I was talking about old players opening new LIRs *instead* of migrating to IPv6.
Old players also have incentive to sell address space, instead of hoarding it, as a possible IPv6 world devalues the asset.
If the price goes up .. I would not SELL such an asset: the transfer or purchase of IP are not the only way to give another organisation access to some IP space. Clarification: If IPv4 is of value right now, but we succeed in making v6 more attractive, any holder of large unused allocation is tempted to sell them, as they are on their peak of value. If you have an ASN and IP space you can simply ‘lease it’ by letting the organisation route your traffic and use the IP and milk the asset even more. This would suggest that is has perspective to work for a longer period of time.
So whatever rule in put in place it may simply may do NOTHING to prevent cross organisation IP usage. There is no intend to limit usage, there is already an intend to limit new allocations to new players. And exactly that is what we should reach for. I do migrate to v6, I want all others to migrate as well, so there is no unfair competition on old kit (v4 only).
And some serious thought must be given to the real effectiveness of the change proposed. Absolutely. I think nobody doubt that.
Matthias
participants (10)
-
Fergal Cunningham -
Jack -
Lu Heng -
Matthias Šubik -
Max Tulyev -
Misak Khachatryan -
Nick Hilliard -
Pavel Odintsov -
Radu-Adrian Feurdean -
Thomas Mangin