[sig-policy] Prop-050 concerns from RIPE

[Sander Steffann <sander@steffann.nl>]

Hello sig-policy,

As co-chair of the RIPE Address Policy Working Group I would like to  
express our concern about prop-050.

We understand that the proposal as it is currently written and is in  
last call, requires no justification from an organisation that will  
receive a transfer from another organisation. It also states that the  
implementation of the proposal, if accepted, is immediate. In other  
words, as soon as the APNIC community accepts the proposal and the  
secretariat implements it, it will be a policy in effect.

We know that there are other policy proposals (prop-071 and 072) to  
prevent abuse of prop-050, but we are still concerned about this  
because of the possibilities of abuse before prop-071 and 072 are  
implemented (assuming they reach consensus)

One case that worries us is the case where Organisation A receives an  
allocation from APNIC, transfers it to Organisation B, request another  
allocation from APNIC, transfer it again, etc. This will result in  
increased usage rate of the APNIC address pools. As a result APNIC  
will need to request more address space from IANA, and IANA will run  
out of IPv4 addresses quicker. This kind of hoarding has effects  
outside of the APNIC region.

It might never happen, but in theory someone could do this if I  
understand the policy correctly. The possibility of draining the IANA  
pool is what worries us.

We also understand that the current text of the proposal enables Inter- 
RIR transfers. Prop-050 states that this will happen "following the  
policies of all the respective RIRs". We are not clear on how APNIC  
will implement this and what effects this will have on other RIRs. We  
don't have an Inter-RIR transfer policy at this time. What would  
happen (for example) if an organisation approaches APNIC with a  
request to transfer RIPE address space to an APNIC RIR. Can APNIC  
still prevent that transfer from happening? If not, this would make it  
possible that space from other regions is hoarded in the APNIC service  
region.

Inter-RIR transfers is not even a concept yet that is discussed in  
other regions. Because it is "between" RIRs, we believe it is a matter  
that requires coordination and discussion beyond a specific region. We  
think a globally-coordinated policy discussion will be best to have  
for this kind of topic.

I know that a lot of these issues have already been raised on the  
mailing list in the past months, but I hope you can understand our  
concern. Implementing prop-050 before prop-071 and/or prop-072 can be  
implemented leaves a big loop hole that could have effects outside the  
APNIC region.

Thank you for listening,
Sander Steffann
RIPE Address Policy Working Group co-chair