This policy proposal has been accepted
The new RIPE Document is: ripe-605
You're looking at an older version: 3
The current (published) version is 4A framework is proposed as the basis for rigorous maintenance of registration data and for delivery of registry services to legacy Internet resource holders in the RIPE NCC service region.
[Following text will result in a new RIPE Policy Document “RIPE NCC Services to Legacy Internet Resource Holders“]
This proposed framework establishes the principles to be applied by the RIPE community in offering and implementing registry services for legacy Internet resource holders. The importance of maintaining accurate records in the RIPE database is recognised as the NCC's principal task. The community of legacy Internet resource holders is defined. Some rights of members of this community are described, as are the principles governing the manner in which the RIPE NCC should engage with and provide services to this community.
Internet resources obtained prior to or otherwise outside the current hierarchical Internet Registry System (involving the RIPE NCC or any of the other Regional Internet Registries) are considered legacy resources. The RIPE NCC maintains and publishes registry data for resources held by its members and by legacy resource holders located in the RIPE NCC service area. It strives to maintain the accuracy of these data. The RIPE NCC also provides reverse DNS delegation and a routing registry for IP address and Autonomous System Numbers, both of which include legacy resources.
Historically, legacy resource holdings have been kept outside anyformal relationship between their holders and the RIPE NCC, even incases where such a relationship covers other resources held by thesame holder. To improve the accuracy and trustworthiness of theregistry data the RIPE NCC and a number of legacy resource holdershave indicated that a formal relationship is desirable.
Some of the legacy holders are also interested in a more formal relationship which would give clarity regarding services and allow them to participate in the RIPE NCC's cost-sharing model.
This framework defines the basis for rigorous maintenance of registration data and for delivery of registry services to legacy Internet resource holders in the RIPE NCC service region.
1.1 Definitions
The following definitions apply in this policy and are of particular importance to the understanding of the goals described in this document.
Internet Resource: An IP address block or Autonomous System number.
Legacy Internet Resource: Any Internet Resource obtained prior to or otherwise outside the current system of hierarchical distribution (by allocation or assignment) through the Regional Internet Registries.
Legacy Internet Resource Holder: The holder of a Legacy Internet Resource. Either by receivingthese resources directly or by receiving (part of) Legacy InternetResources from a Legacy Internet Resource Holder.
Registry Services: Services provided by the RIPE NCC in its capacity as a RegionalInternet Registry, including the following and such additionalservices as may be identified from time to time as registry services:
Registry Service Element: In practice, any Legacy Resource Holder actually avails of a subset of the Registry Services mentioned above. Where it is necessary to distinguish between the entire class of Registry Services and the specific Registry Services actually provided in a particular case, the latter are described as Registry ServiceElements.
1.2 Scope
The framework described in this document applies to the provision of Registry Services by the RIPE NCC in respect of Legacy Internet Resources. Any other services offered by the RIPE NCC (whether different in nature, or relating to other kinds of resources) are out of scope for this policy.
This scope of this policy does not include the resolution of any dispute arising as to the right to use a particular Legacy Internet Resource.
Although specification of charges made by the RIPE NCC is also out of scope here, the appropriate kind of charge corresponding to a specific set of circumstances is identified where this seems useful for clarity.
A direct or indirect contractual relationship between a Legacy Internet Resource Holder and the RIPE NCC provides contractual certainty to both parties regarding services, rights, and responsibilities. Such a relationship also provides for payment of appropriate fees for services provided by the RIPE NCC. Different methods for establishing such a relationship are described below in sections 2.1, 2.2, 2.3, and 2.4.
In exceptional cases where the Legacy Resource Holder wishes to engage with the RIPE NCC but none of the methods just mentioned is feasible, section 2.5 will apply.
Section 2.6 below applies in all other cases.
2.1 Legacy Internet Resource Holder is already a RIPE NCC member
If the Legacy Internet Resource Holder is already a RIPE NCC member then there is already a contractual relationship between the RIPE NCC and the Resource Holder, who may extend the existing contract by registering the Legacy Internet Resources involved subject to the conditions defined in section 3 below.
In this case, the RIPE NCC may require the payment of charges for membership and services according to the RIPE NCC charging plan for the time being in force.
2.2 Option to become a RIPE NCC member
A Legacy Internet Resource Holder who is not already a RIPE NCC member may opt to become a member by establishing a membership contract under which the Legacy Internet Resources involved will then be registered subject to the conditions defined in section 3 below.
In this case, the RIPE NCC may require the payment of charges for membership and services according to the RIPE NCC charging plan for the time being in force.
2.3 Option to engage via sponsoring LIR
A Legacy Internet Resource Holder who either is not already a RIPE NCC member or, being a member, does not wish to extend the membership contract as provided in section 2.1 above may opt to enter into a contract with a RIPE NCC member who is willing to act as a Sponsoring LIR for the purposes of registering the Legacy Resources involved, subject to the conditions defined in section 3 below, and subject to approval by the RIPE NCC of the form of contract between the Resource Holder and the Sponsoring LIR.
In this case, the Sponsoring LIR may require the payment of charges according to the terms of the contract agreed with the Legacy Resource Holder.
2.4 Option to engage directly with the RIPE NCC
A Legacy Internet Resource Holder whose circumstances match those described in section 2.3 above, but cannot find a Sponsoring LIR with which a mutually satisfactory contract of the kind mentioned in that section, may opt to enter a non-member service contract with the RIPE NCC for the purposes of registering the Legacy Resources involved, subject to the conditions defined in Section 3 below.
In this case, the RIPE NCC may require the payment of reasonable charges according to the terms of the non-member service contract.
2.5 When there are obstacles for 2.1/2.2/2.3/2.4
Due to specific enduring or temporary circumstances which are recognised by the RIPE NCC as being outside the resource holder's control, a legacy resource holder may be unable to enter into a relationship of any of the kinds described above (2.1, 2.2, 2.3, 2.4). In such a case, the RIPE NCC will offer and provide registry services as if a contractual relationship of one of the kinds described above had been established, and shall do so for as long as the circumstances continue which constitute an obstruction to the establishment of a contract.
However, notwithstanding the preceding paragraph, the RIPE NCC may refuse to provide any specific registry service for which particular technical requirements apply, which the Resource Holder is unable to meet.
2.6 No relationship
In cases where the current holder of Legacy Internet Resources cannot be contacted, does not reply to contact from the RIPE NCC or is unknown, there is no formal relationship between the holder and the RIPE NCC.
In such a case, the RIPE NCC
- will continue to provide any registry service element already provided in support of each Legacy Internet Resource involved;
- will have no obligation to begin to provide any registry service element not already provided in support of a particular Legacy Internet Resource, even in case the service element is provided in support of any other Legacy Internet Resource held by the same or another Resource Holder;
- and may update the related entries in the RIPE Database from time to time to correspond to the current actual situation.
The service agreement covering registration of a legacy Internet resource between the corresponding Resource Holder and either the Sponsoring LIR or the RIPE NCC must include
The RIPE NCC will offer and provide services in respect of a given Legacy Internet Resource corresponding to the relationship established with the holder of that resource.
In the case of any of the forms of relationship described in sections 2.1, 2.2, or 2.3 above, this policy shall not exclude any service from being offered and/or provided in respect of a Legacy Internet Resource registered under the terms of the corresponding direct or indirect contractual agreement relationship with the RIPE NCC.
In the case of any of the forms of relationship described in sections 2.1, 2.2, 2.3, or 2.4 above, the RIPE NCC shall offer Registry Services as defined in section 1.1 above in respect of each Legacy Internet Resource involved and as requested by the corresponding Resource Holder.
In case the situation corresponds to section 2.6 above, the RIPE NCC shall maintain each Registry Service already provided in respect of any corresponding Legacy Internet Resource.
In case of conflict between a Legacy Internet Resource Holder and the RIPE NCC about any matter within the scope of this policy, the RIPE NCC Conflict Arbitration Procedure is to be applied.
Arguments supporting the proposal
New policy covering provision of services to legacy resource holders is needed because the scope of existing RIPE policies extends only to Internet resources distributed through the RIPE NCC. Such new policy will support the RIPE NCC in addressing what RFC 2050 describes as the "primary function" of a Regional Internet Registry and will give legacy Internet resource holders clarity as to the services they may expect.
Extensions to the RIPE NCC service model are proposed because of the need for a "public registry" (rather than a members-only registry) identified in RFC 2050.
[and as may be received during the discussion phase]
Arguments opposing the proposal
Extensions to the RIPE NCC service model are proposed.
[and as may be received during discussion phase]
The RIPE NCC is hereby publishing an initial impact analysis based on its interpretation of the policy proposal text. This analysis is also intended to highlight the need for more guidance and information from the community in defining a number of fundamental pre-requisites in order to determine the nature of the various implementations, and the impact of the policy proposal itself.
Given the length of this analysis, the following Executive Summary presents some of the interpretations and issues the RIPE NCC outlines in a more concise format. For further detail and the reasoning behind these points, please refer to the relevant section in the impact analysis below.
This policy proposal is meant to be applied by the RIPE NCC to Registration Services, as regards Legacy Internet Resources.
Legacy Internet Resources – as defined in this proposal, are any Internet resources obtained prior to (or otherwise outside of) the current system of hierarchical distribution (by allocation or assignment) through the Regional Internet Registries (RIRs). While this definition is not limited to resources in the RIPE Registry, the RIPE NCC does not have authority over Legacy Internet Resources in other registries. If this proposal is accepted, the RIPE NCC will implement it only to Legacy Internet Resources that are currently registered in the RIPE Registry.
This definition also refers to resources that have been distributed by IANA, InterNIC (or according to the appropriate manner at the time of distribution). This includes Legacy Internet Resources that have been transferred to the RIPE Registry since 1992 and subsequently registered under the umbrella of a RIPE NCC member.
This definition does not include:
Registration Services – as defined in this proposal, are those services provided by the RIPE NCC in its capacity as a RIR. The proposal specifies them as services “including the following and such additional services as may be identified from time to time as registry services (section 1.1). These services include:
This definition gives a non-exclusive list of services. Other services, both current and future, may also be considered Registration Services. This proposal does not specify the process according to which a service (other than those listed) is identified as Registration Services. Therefore, this decision will be made by the RIPE NCC, after consultation with the membership and RIPE Community.
Registration Services Element – the term Registration Services Element is solely used in this document when referring to services that the RIPE NCC already provides with regards to Legacy Internet Resources (section 2.6). Therefore, the RIPE NCC understands that this term contains the following services:
The proposal outlines a number of options for Legacy Resource Holders to enter into a contractual relationship for their resources, so that they can be provided with Registration Services. These options will be analysed in detail below.
The RIPE NCC would like to highlight that it currently receives requests from Legacy Resource Holders who desire for their resources to be registered and maintained as if they had been distributed by the RIPE NCC (losing their legacy status, and becoming subject to RIPE Policies and RIPE NCC procedures). Over the years, the RIPE NCC has approved a number of these requests on a case-by-case basis.
However, this proposal does not provide an option for Legacy Internet Resources to lose their legacy status, nor does it allow Legacy Resource Holders to have their resources maintained as if they had been distributed by the RIPE NCC. Therefore, if the proposal is accepted, the RIPE NCC will have to reject any such requests. This is explained further below (Impact on Registration Services – Legacy Internet Resources Registered Under an LIR Umbrella).
If this proposal becomes policy, the RIPE NCC should enter into a contractual relationship with the Legacy Resource Holder or approve a contractual relationship between the holder and a sponsoring LIR.
This proposal defines the holder of a Legacy Internet Resource as one who has received these resources either directly, or from another Legacy Resource Holder. This definition does not include holders of resources that are not covered by the RIPE NCC’s understanding of the definition of Legacy Internet Resources (see above under Legacy Internet Resources).
The RIPE NCC is entitled to perform due diligence checks in order to enter into a contract with someone that claims to be a Legacy Resource Holder. These due diligence checks will consist of:
If a party claiming to be a Legacy Resource Holder is unable to comply with these due diligence checks by providing satisfactory documentation as required, the RIPE NCC will not accept a contractual relationship as described in this proposal. In cases where there is uncertainty about the resource holder, the RIPE NCC will handle these resources as outlined in section 2.6 of the proposal (see Option 6 below).
Option 1 (section 2.1) - The Holder is a RIPE NCC Member and Extends the Existing Contract to the Legacy Internet Resources
If the Legacy Resource Holder has already signed the RIPE NCC SSA, the proposal provides that the SSA may be extended to cover their Legacy Internet Resources as well. However, the SSA must include certain conditions as defined in section 3.0 of the proposal.
The RIPE NCC offers the same SSA to all of its members. If the proposal becomes policy, the RIPE NCC will have to consider ways to include the extension of the SSA to Legacy Internet Resources in its legal framework. The outlined conditions may require amendments to the SSA, which will require approval by the General Meeting (GM).
One of the specific conditions required by the policy is the following:
“Acknowledgement that the terms and conditions under which the resources were originally granted are outside the scope of and unchanged by, the service agreement”. For such a provision to be implemented, the RIPE NCC will have to be aware of the terms and conditions under which these resources were originally distributed, which means the Legacy Resource Holder will need to provide these to the RIPE NCC.
These terms and conditions may affect the rights and obligations of the Legacy Resource Holder and the RIPE NCC, including the responsibility of the holder to maintain accurate data in the registry, as well as the RIPE NCC’s ability to enforce RIPE Policies and RIPE NCC procedures.
Option 2 (section 2.2) - The Legacy Resource Holder Becomes a RIPE NCC Member
The same applies as in Option 1.
Option 3 (section 2.3) – The Legacy Resource Holder Enters into a Contract With a Sponsoring LIR
According to the proposal, this option should be available for non-LIRs as well as for LIRs that do not wish to include their Legacy Internet Resources under their SSA. In the latter case, however, it should be made clear that the RIPE NCC will not allow the Legacy Resource Holder to become the sponsoring LIR for their own Legacy Internet Resources.
Option 4 (section 2.4) – The Legacy Resource Holder Engages Directly with the RIPE NCC with Another Agreement (Not the SSA)
This option is available for those Legacy Resource Holders that cannot find a sponsoring LIR with which a mutually satisfactory contract can be signed.
The RIPE NCC, through its experience with the implementation of the proposal 2007-01, firmly believes that holders can always find a sponsoring LIR that is suitable. Additionally, holders always have the option to become members of the RIPE NCC. Therefore, it is difficult to see how a Legacy Resource Holder will not be able to include their Legacy Internet Resources in the SSA or find a sponsoring LIR. If this proposal becomes policy, the RIPE NCC will need to set some minimum transparent standards for an agreement to be considered satisfactory.
It is also worth noting that in the past the RIPE NCC used to conclude special agreements with Direct Assignment Users, but in 2012 the GM decided to remove special types of contracts and make RIPE NCC services available to members only. Accordingly, the re-creation of a special agreement for RIPE NCC services to non-members will need approval by the GM.
Option 5 (section 2.5) – The Legacy Resource Holder Concludes No Agreement
According to the proposal, the Legacy Resource Holder may not be required to have an agreement due to specific enduring or temporary circumstances which the RIPE NCC recognises as being beyond the holder’s control. The proposal does not give any examples or indication of what these circumstances may be, so it is at the RIPE NCC’s discretion to decide. However, the RIPE NCC cannot currently identify any special circumstances that would limit the ability of a holder to enter into any of the above agreements (to become member or to find a sponsoring LIR).
According to the proposal, the RIPE NCC will have to keep providing the services it currently provides to Legacy Resource Holders as if there was a contract in place and should do so for as long as the special circumstances still exist. However, it is not clear what services the RIPE NCC is required to provide. In particular, according to the proposal, the RIPE NCC may refuse to provide specific services for which particular technical requirements apply. Some Registration Services may require a technical (legal) control that cannot be performed without a contract in place. In these cases, the RIPE NCC would be unable to provide services beyond those identified above as Registration Services Elements without a contract.
The RIPE NCC would like to point out that currently, in order to provide minimum services for Legacy Internet Resources registered in the RIPE Database (not covered by a contract), it applies a due diligence process to verify that the person requesting the service is (or is acting on behalf of) the one registered in the RIPE Database as the Legacy Resource Holder. If this proposal becomes policy, the RIPE NCC will keep applying this due diligence process. Also, the RIPE NCC has no means of enforcing that the resource holder maintains accurate data in the registry.
Option 6 (section 2.6) – The Legacy Resource Holder is Unknown or Unresponsive so No Contractual Relationship can be Concluded
The proposal describes cases where the Legacy Resource Holder is unknown or cannot be contacted. In this case, the RIPE NCC will have to continue providing any Registration Services Elements that are already provided. The RIPE NCC has defined what it considers to be Registration Services Elements above.
The RIPE NCC would also like to highlight the case of Legacy Resource Holders that, after the potential approval of this proposal, have concluded a contract with the RIPE NCC or a sponsoring LIR and therefore were provided with more Registration Services. In this case, if the holder’s agreement is terminated and the holder is unresponsive, the RIPE NCC will not be obliged to keep providing the holder with services other than those identified above as Registration Services Elements.
What was mentioned above, under Option 5, about the due diligence process applied to Legacy Internet Resources registered in the RIPE Database but not covered by a contract, also applies to this option. In addition, the RIPE NCC has no means of enforcing that the resource holder maintains accurate data in the registry.
The proposal also allows for the RIPE NCC to “update the related entries in the RIPE Database in accordance with the actual situation”. The scope and content of these updates is not specified, so it is at the RIPE NCC’s discretion to decide what this should be.
The provision of some of these services is subject to RIPE Policies and RIPE NCC procedures, and depends on whether the resources are Provider Aggregatable (PA) or Provider Independent (PI). The RIPE NCC should acquire clear guidelines on the terms under which Legacy Internet Resources would be offered these services. Also, it is important to take into account that some of the services mentioned above are only provided with regards to specific kinds of resources (e.g. certification is only available for PA allocations).
The proposal also refers to specific “terms and conditions under which the resources were originally granted”, which are “outside of the scope of, and unchanged by” a service agreement that refers to Legacy Internet Resources. The RIPE NCC must be informed of the details of these terms and conditions so that the terms for the provision of services to Legacy Resource Holders can be further analysed.
Currently arbitration does not apply to Legacy Internet Resources. If this proposal is accepted, the RIPE NCC arbitration procedure will have to be updated. Amendments to the arbitration procedure are subject to approval by the GM.
Legacy Internet Resources Currently Registered Under an LIR Umbrella
As mentioned above (Understanding of the Proposal– Legacy Internet Resources) the proposal includes Legacy Internet Resources that have been transferred to the RIPE Registry since 1992 and subsequently registered under the umbrella of a RIPE NCC member.
Between 1992 and 2011, the RIPE NCC has, at the request of holders, registered Legacy Internet Resources, under the umbrella of an LIR on an ad-hoc basis, without entering into a contractual relationship for these resources.
Between January 2012 and August 2012, the RIPE NCC has accepted statements by Legacy Resource Holders agreeing that their resources are to be considered as having been distributed by the RIPE NCC, and therefore losing their legacy status. These resources have been registered under the umbrella of an LIR at the holders’ request.
If this proposal becomes policy, the RIPE NCC understands that it will have to contact the Legacy Resource Holders that have had their Legacy Internet Resources registered under the umbrella of an LIR, either with or without a signed statement, to offer them the contractual options of the accepted proposal. The RIPE NCC will consider any requests submitted since 1992 and all statements as never having been submitted.
Resource Certification
The RIPE NCC would like to highlight that if the community decides that this proposal should allow for the certification of Legacy Internet Resources, the RIPE NCC will have to create a certification system specific to these resources. This is because of a previous decision by the RIPE NCC Executive Board to limit certification to Provider Aggregatable (PA) address space.
The RIPE NCC is requesting guidance from the RIPE Community on the following points:
Identifying the Legitimate Holder of a Legacy Internet Resource
Background:
Some Legacy Internet Resources were distributed by InterNIC to registries such as academic institutions and National Research and Education Networks (NRENs) with the intention that they would be further distributed to other organisations. Consequently, these Legacy Internet Resource blocks may contain several layers of hierarchy.
Problem:
It is often not clear who the legitimate holder of these resources is. Also, there are cases where the organisation running the registry ceased to exist or ended its registry function.
Guidance requested:
The RIPE NCC would like the community to clarify who it should consider to be the legitimate holder of these Legacy Internet Resources: the registry that originally received these resources for further distribution, or the organisation that later received these resources?
Transparency for Legacy Internet Resources
Background:
Objects in the RIPE Database representing legacy Internet Resources in use in the RIPE NCC Service Region have several "status:" attribute values such as NOT-SET, ASSIGNED, ALLOCATED, EARLY-REGISTRATION.
Problem:
This situation does not allow for a transparent and consistent overview, clearly indicating which resources are legacy. The RIPE NCC receives many inquiries from organisations requesting clarification.
Potential solution for IP addresses
In order to solve this issue, and to increase the level of transparency, consistency and clarity, if this proposal is accepted, the RIPE NCC proposes to change the "status:" attribute value of all INETNUM objects for legacy space to the status LEGACY.
Potential solution for AS numbers
AUT-NUM objects do not currently have a "status:" attribute. For the same reasons described above, if this policy proposal reaches consensus, the RIPE NCC proposes to introduce a mandatory "status:" attribute to the AUT-NUM object. This new attribute would take the value 'LEGACY' for all legacy AS numbers. For all other AS numbers, this value would either be set to 'ASSIGNED' or 'OTHER'. The value 'ASSIGNED' would be for all AS number resources assigned by the RIPE NCC. The value 'OTHER' would be for copies of AS number resources assigned by other RIRs that have been added to the RIPE Database for routing purposes.
The RIPE NCC would like the community to consider this as one possible solution for the issues raised, along with any other options, and advise the RIPE NCC on the best way forward.
The impact on the RIPE NCC to implement the above points is considered as low impact.
Registration Services Operational Impact
The number of legacy Internet Resources in the RIPE Registry is approximately 4200 IP blocks and 740 AS numbers. The Registration Services department will be able to assess the impact on its operations once it has received feedback on the points that need further clarification.