Dear Mattias, responding on «As this only affects LIRs, I doubt there will be significant participation by non-LIRs» I must say that it affects all internet service providers that use IP resources. In Ukraine there are more than 5 000 registered ISPs, but not all of them are LIRs. The situation that we have now is that when russian troops withdraw from our territory, they dismantle and take with them not only washing machines, but also telecom equipment, TV- and radio-transmitters, leaving people who live there without any information channels and means of communication. We have to re-build telecom and internet infrastructure, and yes, we could bring new equipment there, but if the IP addresses of local Internet Providers will be transferred to other parties, we will not be able to restore even our critical infrastructure there, and there is no place to get new IPv4 addresses. Therefore any solutions that involve allowing transfers now and somehow reverting them later are not solving this immediate problem that we have. Viktoriia Opanasiuk чт, 27 окт. 2022 г. в 16:59, Matthias Merkel <matthias.merkel@staclar.com>:

Hi Viktoriia,

RIPE operates on consensus policies. A new policy cannot be adopted if there is a meaningful number of objections like clearly there is here.

As has been explained in the in-person meetings, a freeze cannot be implemented until a corresponding policy is in place, as this may otherwise open up the RIPE NCC to civil liability. Of course, there is also a risk that a freeze could negatively impact Ukrainian LIRs (for example ones who may want to sell parts of their IP space to fund continued operations).

For the reasons above, I personally don’t think that a blanket ban will be a good solution. Instead, the RIPE NCC should conduct increased due diligence on transfers from Ukraine and other high-risk regions. From what I understand, the NCC has already implemented these measures.

Most of the recent emails have already identified themselves as Ukrainian, some including a reg-id or at least mentioning they were an LIR as well. As this only affects LIRs, I doubt there will be significant participation by non-LIRs.

Matthias Merkel

Staclar, Inc.

*From: *ncc-services-wg <ncc-services-wg-bounces@ripe.net> on behalf of Viktoriia Opanasiuk <viktoriia.opanasiuk@gmail.com> *Date: *Thursday, 27. October 2022 at 15:51 *To: *ncc-services-wg@ripe.net <ncc-services-wg@ripe.net> *Subject: *[ncc-services-wg] IP adress transferring in Ukraine

Hi everyone!

Looking at such a broad discussion around the issue of the decision to protect Ukrainian IP resources, I want to add a comment and a wish.

First of all, I would like to clarify the issue a little. We are only talking about temporarily freezing the transfer of IP addresses until a solution to correctly identify and prohibit risky transfers is found and implemented.

And in order to understand who exactly is against the temporary freeze or who supports it , it would be very good if you wrote a few words about who exactly those who express their position represent. For example, does the company have LIR status, is the company an ISP provider, and if so, in which regions of Ukraine does it provide services. If the LIR is not a ISP provider, does it continue its work in Ukraine? This is purely to understand whether the position of the participant in the discussion is from a representative of the Ukrainian community and what part of this community he represents.

Otherwise, this discussion may slightly distort the real problems that exist in Ukraine today.

--

Viktoriia Opanasiuk

-- З повагою, Вікторія Опанасюк

Dear Viktoriia, I don’t think anyone is suggesting to allow transfers and later revert them – there is no real procedure for this and it would likely cause a lot of issues down the line. What most people seem to be advocating now – and what the RIPE NCC is currently doing – is that additional due diligence should be carried out, which means that special care should be taken that identities are verified and sanctions screening is carried out correctly. I understand that IP addresses being stolen could be a problem, however I have not heard of any cases where this has actually happened so far. But here’s an alternative consideration: If a Ukrainian ISP needs additional funding to rebuild and wants to sell IP addresses to enable this, your proposal would potentially cause the exact issues you’re trying to prevent. Your proposal would essentially freeze assets – similar to what sanctions might do – but of the people who you are trying to support. This can have severe financial consequences for the affected parties, and I really think that this would need to be an opt-in thing (but also that it would need to be defined in a separate and clear policy). Matthias Merkel From: Viktoriia Opanasiuk <viktoriia.opanasiuk@gmail.com> Date: Thursday, 27. October 2022 at 17:50 To: Matthias Merkel <matthias.merkel@staclar.com> Cc: ncc-services-wg@ripe.net <ncc-services-wg@ripe.net> Subject: Re: [ncc-services-wg] IP adress transferring in Ukraine Dear Mattias, responding on «As this only affects LIRs, I doubt there will be significant participation by non-LIRs» I must say that it affects all internet service providers that use IP resources. In Ukraine there are more than 5 000 registered ISPs, but not all of them are LIRs. The situation that we have now is that when russian troops withdraw from our territory, they dismantle and take with them not only washing machines, but also telecom equipment, TV- and radio-transmitters, leaving people who live there without any information channels and means of communication. We have to re-build telecom and internet infrastructure, and yes, we could bring new equipment there, but if the IP addresses of local Internet Providers will be transferred to other parties, we will not be able to restore even our critical infrastructure there, and there is no place to get new IPv4 addresses. Therefore any solutions that involve allowing transfers now and somehow reverting them later are not solving this immediate problem that we have. Viktoriia Opanasiuk чт, 27 окт. 2022 г. в 16:59, Matthias Merkel <matthias.merkel@staclar.com<mailto:matthias.merkel@staclar.com>>: Hi Viktoriia, RIPE operates on consensus policies. A new policy cannot be adopted if there is a meaningful number of objections like clearly there is here. As has been explained in the in-person meetings, a freeze cannot be implemented until a corresponding policy is in place, as this may otherwise open up the RIPE NCC to civil liability. Of course, there is also a risk that a freeze could negatively impact Ukrainian LIRs (for example ones who may want to sell parts of their IP space to fund continued operations). For the reasons above, I personally don’t think that a blanket ban will be a good solution. Instead, the RIPE NCC should conduct increased due diligence on transfers from Ukraine and other high-risk regions. From what I understand, the NCC has already implemented these measures. Most of the recent emails have already identified themselves as Ukrainian, some including a reg-id or at least mentioning they were an LIR as well. As this only affects LIRs, I doubt there will be significant participation by non-LIRs. Matthias Merkel Staclar, Inc. From: ncc-services-wg <ncc-services-wg-bounces@ripe.net<mailto:ncc-services-wg-bounces@ripe.net>> on behalf of Viktoriia Opanasiuk <viktoriia.opanasiuk@gmail.com<mailto:viktoriia.opanasiuk@gmail.com>> Date: Thursday, 27. October 2022 at 15:51 To: ncc-services-wg@ripe.net<mailto:ncc-services-wg@ripe.net> <ncc-services-wg@ripe.net<mailto:ncc-services-wg@ripe.net>> Subject: [ncc-services-wg] IP adress transferring in Ukraine Hi everyone! Looking at such a broad discussion around the issue of the decision to protect Ukrainian IP resources, I want to add a comment and a wish. First of all, I would like to clarify the issue a little. We are only talking about temporarily freezing the transfer of IP addresses until a solution to correctly identify and prohibit risky transfers is found and implemented. And in order to understand who exactly is against the temporary freeze or who supports it , it would be very good if you wrote a few words about who exactly those who express their position represent. For example, does the company have LIR status, is the company an ISP provider, and if so, in which regions of Ukraine does it provide services. If the LIR is not a ISP provider, does it continue its work in Ukraine? This is purely to understand whether the position of the participant in the discussion is from a representative of the Ukrainian community and what part of this community he represents. Otherwise, this discussion may slightly distort the real problems that exist in Ukraine today. -- Viktoriia Opanasiuk -- З повагою, Вікторія Опанасюк

Viktoriia,

We have to re-build telecom and internet infrastructure, and yes, we could bring new equipment there, but if the IP addresses of local Internet Providers will be transferred to other parties, we will not be able to restore even our critical infrastructure there, and there is no place to get new IPv4 addresses.

You don't need IPv4 addresses for rebuilding IT infrastructure. There are lot of equipment supplied with Keep Ukraine Connected project, the equipment list is public and I'm pretty sure all of this equipment support IPv6. -- Kind regards, Sergey Myasoedov

On 27. 10. 2022, at 17:44, Viktoriia Opanasiuk <viktoriia.opanasiuk@gmail.com> wrote:

Dear Mattias,

responding on «As this only affects LIRs, I doubt there will be significant participation by non-LIRs» I must say that it affects all internet service providers that use IP resources. In Ukraine there are more than 5 000 registered ISPs, but not all of them are LIRs.

The situation that we have now is that when russian troops withdraw from our territory, they dismantle and take with them not only washing machines, but also telecom equipment, TV- and radio-transmitters, leaving people who live there without any information channels and means of communication. We have to re-build telecom and internet infrastructure, and yes, we could bring new equipment there, but if the IP addresses of local Internet Providers will be transferred to other parties, we will not be able to restore even our critical infrastructure there, and there is no place to get new IPv4 addresses.

Therefore any solutions that involve allowing transfers now and somehow reverting them later are not solving this immediate problem that we have.

Viktoriia Opanasiuk

чт, 27 окт. 2022 г. в 16:59, Matthias Merkel <matthias.merkel@staclar.com>: Hi Viktoriia,

RIPE operates on consensus policies. A new policy cannot be adopted if there is a meaningful number of objections like clearly there is here.

As has been explained in the in-person meetings, a freeze cannot be implemented until a corresponding policy is in place, as this may otherwise open up the RIPE NCC to civil liability. Of course, there is also a risk that a freeze could negatively impact Ukrainian LIRs (for example ones who may want to sell parts of their IP space to fund continued operations).

For the reasons above, I personally don’t think that a blanket ban will be a good solution. Instead, the RIPE NCC should conduct increased due diligence on transfers from Ukraine and other high-risk regions. From what I understand, the NCC has already implemented these measures.

Most of the recent emails have already identified themselves as Ukrainian, some including a reg-id or at least mentioning they were an LIR as well. As this only affects LIRs, I doubt there will be significant participation by non-LIRs.

Matthias Merkel

Staclar, Inc.

From: ncc-services-wg <ncc-services-wg-bounces@ripe.net> on behalf of Viktoriia Opanasiuk <viktoriia.opanasiuk@gmail.com> Date: Thursday, 27. October 2022 at 15:51 To: ncc-services-wg@ripe.net <ncc-services-wg@ripe.net> Subject: [ncc-services-wg] IP adress transferring in Ukraine

Hi everyone!

Looking at such a broad discussion around the issue of the decision to protect Ukrainian IP resources, I want to add a comment and a wish.

First of all, I would like to clarify the issue a little. We are only talking about temporarily freezing the transfer of IP addresses until a solution to correctly identify and prohibit risky transfers is found and implemented.

And in order to understand who exactly is against the temporary freeze or who supports it , it would be very good if you wrote a few words about who exactly those who express their position represent. For example, does the company have LIR status, is the company an ISP provider, and if so, in which regions of Ukraine does it provide services. If the LIR is not a ISP provider, does it continue its work in Ukraine? This is purely to understand whether the position of the participant in the discussion is from a representative of the Ukrainian community and what part of this community he represents.

Otherwise, this discussion may slightly distort the real problems that exist in Ukraine today.

--

Viktoriia Opanasiuk

-- З повагою, Вікторія Опанасюк --

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