Re: [sig-policy] Timeline for implementing the transfer proposal
Hi Akinori,
On 24/02/2009, at 7:14 PM, MAEMURA Akinori wrote:
That is actually one of the concerns we have regarding this
proposal.
Izumi has been sharing opinions of JP Community here on the
sig-policy mailing list - it's JPNIC's commitment to JP
Community to cascade it to AP Community. On the other hand,
JPNIC is an NIR who needs to provide IP address management
as a service, and might have a different idea from those of
ISPs, and this is the case here now.
Please take care when suggesting that the NIR (or RIRs for that
matter) need to provide any service. Certainly they do provide a
valuable service, but that service is for the convenience of your
members and the address administration function as it grew
internationally and beyond the then (1990) central system. (RFC1174)
Please also consider that the country based aspect of the NIR wasn't a
part of the RIR architecture initially and evolved to cope with the
language and cultural diversity of the region. As we know (RFC1174)
that the system was to be region focused.
My point is that while you (JPNIC) exist as a channel for the
collective JP community I don't feel it appropriate that JPNIC assert
its own position contrary to that of its members.
I feel that Izumi has done a brilliant job in presenting the needs of
the JP community, which I believe satisfies the constructs of bottom-
up policy making, and the responsibility of JPNIC.
1)
We agree that some measure must be taken to prevent confusion
in database which inevitably disrupts uniqueness of IP address,
and see the transfer mechanism will help address this problem
to a certain extent.
Then again, if we implement this proposed policy at this stage
when the problem is not substantial, it may create more problems
than the solutions it intends to provide.
I think I would prefer to see issues in an insubstantial problem, and
deal with those as they eventuate then having problems when the
situation is truly substantial and the ramifications much larger.
One things is that it may lead to encouraging the transfer rather
than documenting what's actually happening.
If encouraging IPv4 transfers aides in the development of the internet
globally then I see that as a step forward.
2)
Another issue that concerns us is there isn't any mechanism to
protect ISPs in ensuring fair and trustable transfers to take
place.
We do recognize and understand the proposer's claim that
issues regarding such a mechanism on transfer markets are
outside the scope of this proposal and the policy forum, but
we think this still remains as an issue regardless of where
it should be considered.
We'd therefore like to make following suggestions to help us move
forward in addresssing the remaining issues.
* If APNIC doesn't have the expertise, it should at least make
necessary liasison with experts, or
* keep the community well informed that they should work the
expertise within their economies, etc.
* If APNIC considers none of these actions are necessary,
provide an analysis of how transfers can work without taking
such measures
I think this is a brilliant suggestion and given the reason that the
NIRs were formed, I think that in the above points you should replace
"APNIC" with "APNIC and every NIR". Further, this work should be in
parallel and non-blocking on the policy front.
I don't think APNIC can be expected to know when and where fairness
and trust exists within the constraints of your own laws, customs, and
governmental frameworks and which international treaties and
agreements stand for your members. Within the space of the policy I
believe this should not hamper the policy through the policy life-
cycle but add a level of work for each of the parties to investigate
and provide suitable advise and, where appropriate, instruction that
your members may follow to protect themselves, and in the same space
indemnify your own organisation.
3)
It is not yet very clear if an Internet Registry can provide
the transfer mechanism without any harm on its operation.
A trade might not be always safe and faithful, but sometimes
be with a blunder or of malice, resulting in a significnat
loss in either party. In such a case, an Internet Registry
might be sued or claimed for indeminification. Such a
situation should be avoided by a reinforced disclaimer,
robust and minute process of transfer registration, et cetra.
Unfortunately we live in a litigious world. I would suggest that you
make any necessary contractual changes or organisational changes that
negates the potential for harm.
4)
I am afraid to say, although this proposal has had a good degree
of support within AP and JP Communities, in the reasons such
as above JPNIC cannot support this proposal until it is clear
that there is a concrete plan that remaining issues will be
addressed in an appropriate manner. JPNIC is quite happy to
contribute in such a preparation/consideration/examination in
planning.
Thanks for bringing JPNIC's organisation concerns forward. While I am
empathetic to your concerns for the organisation I believe your role
is to facilitate the interests of your community. Perhaps JPNIC should
partner with the other NIRs and RIRs to create a task force geared to
address the potential issues as they arise from the implementation of
the policy, in parallel to the policy implementation.
Cheers
Terry