Re: [address-policy-wg] Re: Revised 2007-01 set back to Review Phase (Direct Internet Resource Assignments to End Users from the RIPE NCC)

[Nick Hilliard nick@localhost]

David,

> One concern I have about the current 2007-01 draft is the lack of arguments
> opposing the proposal mentioned under the 'Rationale' section of the document.
> While many such arguments were raised and discussed extensively on this mailing
> list, the draft itself raises only one such argument and proceeds to immediately
> dismiss it.

ok, point noted, although I confess that it would have been more helpful if
you had raised this before - 2007-01 has been around since June last year.

> In the current draft, some of the following objections may still be relevant to
> varying extent:
> 
> - Given the diversity of legal systems the RIPE NCC service region, the success
> of contractually binding existing resource holders to a new contract and fee is
> uncertain, and might be the beginning of a long and expensive exercise in futility.

Possibly.  Ultimately, the decision about whether or not the retroactive
nature of the proposal will actually be put into practice is up to the RIPE
NCC board, because that's an operational matter.  My understanding is that
the RIPE NCC board is taking legal advice on the matter, and if the legal
advice is to stay away from the retroactive assignments clean-up, then that
is probably what they will do.

As regards process length, my understanding is that everyone in the RIPE
NCC expects this to be long and probably troublesome.  There is 16 years of
accumulated detritus in the database, and cleaning it up is neither going
to be cheap nor quick.

The fee will be set using the normal RIPE NCC budgeting process.  There
will probably be some adjustment to the fee calculation model that is used
for PA resource holders, but again that's operational.

> - By attempting to levy a new fee on existing end users of directly assigned
> resources, RIPE NCC risks creating widespread dissent from these very same end
> users which had no voting right on this matter and were likely unaware of the
> proceedings of this WG; in the worst case scenario, this might result in end
> users utilizing resources regardless of their status in the WHOIS database.

I want a pony!

What you're really pointing out is that people have got used to the idea
that they were getting something for free and that they are going to whinge
about this regime coming to an end.  Unfortunately, the free model is
broken - number resources cost money to manage and right now, other people
are footing the bill for this management.  It also creates an environment
where PI addresses are actually a more attractive proposition than PA
address space, which flies in the face of RIPE's current and past number
resource management policies.  Both of these issues are serious problems.

2007-01 requests that this model change and that PI resource holders begin
to assume some of the responsibilities which they are not currently obliged
to.  Do I need to talk about rights and responsibilities being different
sides of the same coin?  Probably not, but it's relevant here.

Resource hi-jacking out of contempt could happen, yes.  But a PI resource
database cleanup will probably help prevent other hijacking vectors.
Overall, my gut feeling is that it will improve things.

The bottom line is: there ain't no such thing as a free lunch.  And much as
I want a pony, I'm not going to get one.  Actually, I'd prefer free
multi-gig ethernet to my house instead of a pony and will gladly accept any
offers for same.  Please reply to the email address above; serious offers
only, if you wouldn't mind.

> - Previous experience (domain reg. world) suggests that by putting an explicit
> price tag on number resources, the "sponsoring LIR" approach in its currently
> presented form might result in the rise of "discount LIRs". These LIRs would
> process the bulk of the assignments with no accountability to keep costs low,
> turning direct assignments into a revenue source and laying waste to many
> potential benefits which could result from this proposal.

This could happen, yes - I don't believe that it's happened to any huge
extent in other RIR catchment areas, but it's not an impossible scenario.

Sponsoring LIRs will be charged for PI resources, probably at a different
rate for end-users who wish to interface with the RIPE NCC directly.  Call
it retail vs. wholesale, if you wish, although those are probably not very
good terms given the context here.

The RIPE NCC does not have any authority to dictate to the sponsoring LIR
what the price to the end-user should be, so there will be effectively an
open market for sponsoring LIRs to charge what they want for acting as a
sponsoring LIR.  As there's lots of competition in the ISP marketplace,
prices will tend to converge on the price that LIRs are charged.  Probably
discount LIRs will appear.  If they do, so what?  They will have to follow
the same rules as anyone else.  The RIPE NCC doesn't have the resources to
micromanage 38000 resource allocations down to the last detail, and we need
to acknowledge this (and if they did, they would be an appalling
organisation to deal with).  There is trust required here, and a
realisation that while some abuse will occur, it should be minimised by
appropriate means.  But again, operational stuff.

> - The issue of resource reclamation when resources fall into disuse can
> potentially be addressed at significantly lower cost and complexity through
> technological solutions similar to those employed by e-retail outfits for
> customer account management (automated verification of electronic and snail-mail
> contacts, IVR verification of phone contacts, regular re-verification).

Indeed, this is correct.  However, your proposal doesn't deal with the
problem that PI resource holders are getting a free lunch paid for by
someone else.  Conversely, there's nothing to stop the RIPE NCC from
implementing direct PI assignments using something like this, but one way
or another, money will be involved.  Again, it's outside the scope of
2007-01 to specify to the NCC how to deal with the issue.

I don't want to sound like I'm sweeping your concerns about implementation
under the carpet by yacking out the "not my problem" line.  But, this is
the way that the RIPE NCC operates: policy is policy, and operations are
operations.   Ultimately, the implementation will be done by them and them
alone, and given their track record in dealing with registration issues
over the past 16 years, I'm pretty happy to see them being given a good
degree of latitude to decide how best to implement the policy.  After all,
they know a lot more about how to manage this sort of stuff than I do.

If it turns out that they do things that people don't like, then they will
be complained at, which action has historically helped things to improve
(e.g. at various stages, hostmaster turnaround times, complexity of forms,
etc).  There's nothing like a brightly flashing red LED to grab someone's
attention.

As part of this feedback process, it would be useful to get updates from
the NCC at RIPE meetings about how the process turns out in practice.
While this isn't the forum to dictate operational matters, that doesn't
mean that people aren't interested.  And again, given their past history, I
would say that it's likely that we'll hear about it from time to time.
There are lots of people in RIPE who take pride in their work, and there
are few ways to express professional pride better than to tell others about
what you do and why it's important to them.

Nick