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Changes to RIPE NCC Services to Legacy Internet Resource Holders

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Summary of Proposal

A framework is proposed as the basis for rigorous maintenance of registration data and for delivery of registry services to legacy legacy  Internet resource holders in the RIPE NCC service region. delete: </p> delete: <h3> delete: <b> insert: <br />
In addition, amendment to existing policy is proposed where this is not consistent with the framework just mentioned. insert: </p>

insert: <h2>

Policy Text delete: </b> delete: </h3> delete: <p> delete: <b> insert: </h2>

insert: <h2>

a. New delete: </b> delete: </p> delete: <p> delete: <i> [Following text will result in a new RIPE Policy Document “RIPE NCC Services to Legacy Internet Resource Holders“] delete: </i> delete: </p> policy insert: </h2>

delete: <b> Abstract: delete: </b> Abstract

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 principal. 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.

delete: <p>   delete: </p> delete: <h3> delete: <b> insert: <h2>

1.0 Introduction and Definitions delete: </b> delete: </h3> delete: <p> The principal purpose of the RIPE NCC is to maintain an accurate insert: </h2>

insert: <p>

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. insert: </p>

insert: <p>

The RIPE NCC maintains and publishes registry of Internet IP number and AS resources in the RIPE service region: Europe, the Middle East, and Central Asia. To this end, the RIPE NCC maintains a registry (the 'RIPE database') of data for resources held by both its members and legacy resource holders. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> Members delete: </b> are those local Internet registries (LIRs) who have signed a contract for services and pay recurring fees to the RIPE NCC for those services. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> Legacy resource holders delete: </b> are those (natural or formal persons) who hold Internet resources assigned before the creation of the RIPE NCC; these have not signed contracts for services for those resources and have not paid corresponding fees. delete: </p> delete: <p> The RIPE NCC maintains accurate registry data for both member resources and legacy resources. In respect of these data, it provides as delete: <b> basic services: delete: </b> the means for resource holders to maintain the registry data relating to their resources; publication, via delete: <i> whois delete: </i> and related services, of this data; and the provisioning of relevant delegation records in the reverse DNS. delete: </p> delete: <p> In addition, the RIPE NCC provides, or may provide, delete: <b> additional services delete: </b> complementing these basic services. delete: </p> delete: <p> Legacy resource holders are willing to contribute to the costs of the services which they use. In addition, provision of new services, such as certification of legacy resources is a desirable goal, and it is understood that such services will have costs. delete: </p> delete: <p> This proposal outlines a framework under which by legacy resource holders may become first class citizens of the family which they founded in the distant past, and pay the reasonable costs of the services which they use. delete: </p> delete: <p>   delete: </p> delete: <h3> 2.0   Legacy Internet Resources and the RIPE Database delete: </h3> delete: <p> delete: <b> 2.1   RIPE NCC as RIR delete: </b> delete: </p> delete: <p> The 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 function of RIPE NCC was originally defined in RIPE-19 [2]: delete: </p> delete: <p> "The RIPE NCC will function as a `Delegated Registry' for IP numbers in Europe, as anticipated and defined in RFC 1174.” delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 2.2   Responsibility of RIR to maintain registry delete: </b> delete: </p> delete: <p> The responsibility of RIPE NCC to maintain a registry of Internet resources, address and Autonomous System Numbers, both for of which include legacy resources. insert: </p>

insert: <p>

Historically, legacy resource holdings have been kept outside any formal relationship between their holders and the RIPE NCC, even in cases where such a relationship covers other resources allocated held by RIPE NCC itself and legacy resources, is acknowledged in RIPE-508 [3]: delete: </p> delete: <p> "The responsibility for record keeping covers Internet number resources allocated to the RIPE NCC by the IANA, as well as Internet number resources that were distributed in the RIPE NCC region by the IANA prior to the RIPE NCC's existence. These resources are known as Early Registration Transfers (ERX), or legacy space." delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 2.3   Benefit of this registry not only to resource holder but to community delete: </b> delete: </p> delete: <p> The maintenance and publication of accurate the same holder. To improve the accuracy and trustworthiness of the registry data for each Internet resource provide necessary information for the RIPE NCC and a number of essential network-management activities, including technical troubleshooting and response to incidents of abuse.  Availability of this data is thus of benefit to the Internet community as a whole, and not just to the holder of the resource. delete: </p> delete: <p> In view of this benefit, neither deliberate removal of nor refusal to allow legitimate updates to registry data should be considered. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 2.4   Joint responsibility between RIR and resource holder for quality of data delete: </b> delete: </p> delete: <p> The joint responsibility for keeping the registry data correct and up to date is recognised in RIPE-508 [3]: delete: </p> delete: <p> "The RIPE NCC has the responsibility for keeping the Registry comprehensive, correct and up-to-date. To do this, the RIPE NCC relies on Resource Holders to supply data that pertains specifically to the Resource Holder, as documented in the RIPE NCC Standard Services Agreement [ripe-435] and/or the Independent Assignment Request and Maintenance Agreement [ripe-462]. For holders of legacy resources this responsibility is derived from the original allocation by the IANA Internet Registry." delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 2.5   Requirement on RIR not to obstruct application of updates by holder delete: </b> delete: </p> delete: <p> The RIR must not obstruct the application of legitimate updates to legacy resource data. It must continue to provide means to authenticate access to holders have indicated that a formal relationship is desirable. insert: </p>

insert: <p>

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. insert: <br />
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. insert: <strong> insert: </strong> insert: </p>

insert: <h3>

1.1 Definitions insert: </h3>

insert: <p>

The following definitions apply in this policy and are of particular importance to the understanding of the goals described in this document. insert: </p>

insert: <p>

insert: <strong> Internet Resource insert: </strong> insert: <br />
An IP address block or Autonomous System number. insert: </p>

insert: <p>

insert: <strong> Legacy Internet Resource insert: </strong> insert: <br />
Any Internet Resource obtained prior to or otherwise outside the current system of hierarchical distribution (by allocation or assignment) through the Regional Internet Registries. insert: </p>

insert: <p>

insert: <strong> Legacy Internet Resource Holder insert: </strong> insert: <br />
The holder of a Legacy Internet Resource. Either by receiving these resources directly or by receiving (part of) Legacy Internet Resources from a Legacy Internet Resource Holder. insert: </p>

insert: <p>

insert: <strong> Registry Services insert: </strong> insert: <br />
Services provided by the RIPE NCC in its capacity as a Regional Internet Registry, including the following and such additional services as may be identified from time to time as registry services: insert: </p>

insert: <ul>
    insert: <li>
  • Maintenance of data relating to Internet Resources  by the NCC in their Internet Resource registry; insert: </li>
  • insert: <li>
  • Access to these data for update by or on behalf of the respective holder; insert: </li>
  • insert: <li>
  • Public availability of registration data; insert: </li>
  • insert: <li>
  • Certification of these data; and insert: </li>
  • insert: <li>
  • Delegation of reverse DNS to the registered DNS servers. insert: </li>
  • insert: </ul>
insert: <p>

insert: <strong> Registry Service Element insert: </strong> insert: <br />
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 Service Elements. insert: </p>

insert: <h3>

1.2 Scope insert: </h3>

insert: <p>

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. insert: </p>

insert: <p>

Any existing or future RIPE policy referring to resources shall not apply to legacy resources unless the policy explicitly includes legacy resources in its scope. insert: </p>

insert: <p>

Rights of the holder to hold, use, or transfer any Legacy Internet Resource are not addressed or restricted by this policy. insert: </p>

insert: <p>

The holder of a Legacy Internet Resource who so wishes may, separately in respect of each such resource held, choose either to return the resource to the appropriate free pool or to have the resource registered without legacy status as if it had been distributed by the RIPE NCC.  In either such case, the resource involved will no longer be subject to this policy or to any other provisions of a RIPE policy which relates exclusively to Legacy Internet Resources, and will no longer be eligible to have its legacy status re-instated as provided for below. insert: </p>

insert: <p>

In case the current holder, and so protect against abusive updates. delete: </p> delete: <p>   delete: </p> delete: <h3> 3.0   Rights and Obligations of Legacy Internet Resource Holders delete: </h3> delete: <p> delete: <b> 3.1   Rights pre-date formation of RIRs delete: </b> delete: </p> delete: <p> Legacy Internet resources were assigned directly to their original holders either or a previous holder, of a resource which was originally a legacy resource (or part of a legacy resource) has, before the coming into effect of this policy, registered the resource as if it had been distributed by IANA itself the RIPE NCC, whether in connection with a transfer of resource or by a global Internet registry acting under IANA's delegated authority prior to the formation of any of the regional Internet registries.  The rights and obligations of otherwise, the current holder of shall be given the opportunity to have the legacy status of the resource re-instated and to choose to have it registered under one of the options available for registering a legacy resource, as set out in this or any such subsequent policy relating specifically to Legacy Internet Resources. insert: </p>

insert: <p>

In the case just mentioned, if the resource are restricted only holder, having been alerted to the other options available, confirms the intent to have a particular resource registered as if it had been distributed by the terms of the original direct assignment, except in case RIPE NCC, the NCC shall apply the RIPE policies about resources it has distributed to these particular resources too, rather than reverting to the legacy status and beginning a fresh engagement with the resource holder from that position. insert: </p>

insert: <p>

The scope of this policy does not include the resolution of any dispute arising as to the right to use a particular Legacy Internet Resource. insert: </p>

insert: <p>

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. insert: </p>

insert: <h2>

2.0 Relationship between Legacy Internet Resource Holder and RIPE NCC insert: </h2>

insert: <p>

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. insert: </p>

insert: <p>

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. insert: </p>

insert: <p>

Section 2.6 will apply in case such a relationship or agreement as described below in sections 2.1, 2.2, 2.3, 2.4, or 2.5 has not been established. insert: </p>

insert: <p>

Section 2.7 will apply in case such a relationship or agreement has been established, but has lapsed. insert: </p>

insert: <h3>

2.1 Legacy Internet Resource Holder is already a RIPE NCC member insert: </h3>

insert: <p>

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. insert: </p>

insert: <p>

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 has freely exercised the right to surrender the resource. delete: </p> delete: <p> The following subsections (3.2 — 3.7) identify, but not exhaustively, those rights which must be understood, in the absence of contemporary documentation relating to the original assignment, to be enjoyed by legacy Internet resource holders with respect to the legacy resources which they hold. delete: </p> delete: <p> In case such documentation is available, the conditions therein specified as to the rights and obligations of the resource holder shall have in force. In case the originally specified conditions make provision for the conditions to be amended and amendments have been made according to such provision, the most recently amended version of the conditions as to rights and obligations shall have force. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 3.2   Right to use delete: </b> delete: </p> delete: <p> Unless otherwise specified in the documentation (if any) mentioned in subsection 3.1 above, legacy Internet resources may be used as their holders see fit. This includes, but insert: </p>

insert: <h3>

2.2 Option to become a RIPE NCC member insert: </h3>

insert: <p>

A Legacy Internet Resource Holder who is not restricted to their use 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. insert: </p>

insert: <p>

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. insert: </p>

insert: <h3>

2.3 Option to engage via sponsoring LIR insert: </h3>

insert: <p>

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 end-point and routing identifiers on the global public Internet. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 3.3 Right to exercise responsibility 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 quality of data delete: </b> 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 any this case, the holder of Sponsoring LIR may require the payment of charges according to the terms of the contract agreed with the Legacy Resource Holder. insert: </p>

insert: <h3>

2.4 Option to engage directly with the RIPE NCC insert: </h3>

insert: <p>

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. insert: </p>

insert: <p>

In this case, the RIPE NCC may require the payment of reasonable charges according to the terms of the non-member service contract. insert: </p>

insert: <h3>

2.5 When there are obstacles for 2.1/2.2/2.3/2.4 insert: </h3>

insert: <p>

Due to specific enduring or temporary circumstances which are recognized by the RIPE NCC as being outside the resource holder's control, a legacy resource shall have the right to exercise the responsibility mentioned in subsection 2.4 above. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 3.4   Right of succession delete: </b> delete: </p> delete: <p> Unless otherwise specified in the documentation (if any) mentioned in subsection 3.1 above, legacy Internet resources may be inherited and assigned. delete: </p> delete: <p> A legacy Internet resource holder may be subject to merger, acquisition, unable to enter into a relationship of any of the kinds described above (2.1 .. 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. insert: </p>

insert: <p>

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. insert: </p>

insert: <h3>

2.6 No relationship insert: </h3>

insert: <p>

In case no formal relationship has been established in support of a particular legacy resource, the RIPE NCC insert: </p>

insert: <ul>
    insert: <li>
  • will continue to provide any registry service element already provided in support of each Legacy Internet Resource involved; insert: </li>
  • insert: <li>
  • 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 change in legal personality.  A another Resource Holder; insert: </li>
  • insert: <li>
  • and may update the related entries in the RIPE Database from time to time to correspond to the current actual situation. insert: </li>
  • insert: </ul>
insert: <h3>

2.7 Lapse of relationship or agreement insert: </h3>

insert: <p>

In case a relationship or agreement as described above in sections 2.1, 2.2, 2.3, 2.4, or 2.5 has lapsed, the RIPE NCC may refuse to continue to provide, in support of each legacy Internet resource involved, any service element which was not being provided immediately before the establishment of the relationship or agreement which has lapsed. insert: </p>

insert: <h2>

3.0 Contractual requirements insert: </h2>

insert: <p>

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 insert: </p>

insert: <ul>
    insert: <li>
  • identification of each resource covered by the service agreement; insert: </li>
  • insert: <li>
  • specification of the service or services offered in respect of each resource identified; insert: </li>
  • insert: <li>
  • the obligation for both parties to comply with this policy and with other RIPE policies which relate to Legacy Internet Resources; insert: </li>
  • insert: <li>
  • a statement of the responsibility of the resource holder who to maintain accurate data in the registry in respect of each resource identified; insert: </li>
  • insert: <li>
  • a statement of the responsibility of the resource holder to assist the RIPE NCC with data-accuracy checks; insert: </li>
  • insert: <li>
  • a statement that the RIPE NCC is a natural person not entitled to deregister the resources for whatever purpose unless so instructed by the resource holder; insert: </li>
  • insert: <li>
  • a statement of the measures which the RIPE NCC is entitled to take in case the resource holder does not meet their contractual responsibilities. insert: </li>
  • insert: </ul>
insert: <h2>

4.0 Services to be offered and provided insert: </h2>

insert: <p>

The RIPE NCC will sooner or later suffer death. delete: </p> delete: <p> In such an event, that holder's heir, successor, or assign (as the case may be) shall immediately after the event enjoy the same rights and be subject to the same obligations offer and provide services in respect of a given Legacy Internet Resource corresponding to the relationship established with regard to each legacy Internet resource involved as the prior the holder enjoyed or was subject to immediately before the event. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 3.5   Right of transfer delete: </b> delete: </p> delete: <p> Unless otherwise specified in the documentation (if any) mentioned in subsection 3.1 above, the holder for the time being of a legacy Internet resource may transfer or sell of that resource.

In such an event, the recipient of the resource the case of any of the forms of relationship described in sections 2.1, 2.2, or 2.3 above, this policy shall immediately after the event enjoy the same rights and 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. insert: </p>

insert: <p>

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. insert: <br />
 In case the situation corresponds to section 2.6 above, the RIPE NCC shall maintain each Registry Service element already provided in respect of any corresponding Legacy Internet Resource. insert: </p>

insert: <h2>

5.0 Arbitration in case of conflict insert: </h2>

insert: <p>

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 subject to the same obligations applied. insert: </p>

insert: <p>

  insert: </p>

insert: <h2>

b. Amendment to existing policy document RIPE-592 insert: </h2>

insert: <p>

It is proposed to replace section 5.5 of RIPE-592, currently insert: </p>

insert: <p>

"Any LIR is allowed to re-allocate complete or partial blocks of IPv4 address space that were previously allocated to them by either the RIPE NCC or the IANA. " insert: </p>

insert: <p>

with regard to each legacy Internet resource involved as the prior holder enjoyed insert: </p>

insert: <p>

"Any LIR is allowed to re-allocate complete or was subject to immediately before the event. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 3.6 Right of surrender delete: </b> delete: </p> delete: <p> Unless partial blocks of IPv4 address space that were previously allocated to them by the RIPE NCC or otherwise specified in the documentation (if any) mentioned in subsection 3.1 above, the holder for the time being of any legacy Internet resource is free to surrender the resource irrevocably at any time and at the holder's sole discretion either directly to IANA or to through the Regional Internet Registry of the holder's choice. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 3.7   Freedom from obligations delete: </b> delete: </p> delete: <p> Unless otherwise specified in the documentation (if any) mentioned in subsection 3.1 above, the holder for the time being of a legacy Internet resource  is not subject to any obligations in relation to the resource. delete: </p> delete: <p>   delete: </p> delete: <h3> 4.0   Engagement with Holders of Legacy Internet Resources delete: </h3> delete: <p> When engaging with the holders of legacy Internet resources, communications from the RIPE NCC should be transparent, so that all parties understand the full situation, and should have respect for any existing relationships between System." insert: </p>

insert: <h2>

Rationale insert: </h2>

insert: <ul>
    insert: <li>
  • insert: <p>

    insert: <strong> Arguments supporting the proposal insert: </strong> insert: </p>

    insert: <p>

    New policy covering provision of services to legacy resource holders and NCC members so 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. insert: </p>

    insert: <p>

    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. insert: <br />
    [and as may be received during the discussion phase] insert: </p>

    insert: </li>
  • insert: <li>
  • insert: <p>

    insert: <strong> Arguments opposing the proposal insert: </strong> insert: </p>

    insert: <p>

    Extensions to the RIPE NCC service model are proposed. insert: <br />
    [and as may be received during discussion phase] insert: </p>

    insert: </li>
  • insert: </ul>
insert: <p>

  insert: </p>

insert: <hr />
insert: <h2>

insert: <a name="impact-analysis"> insert: </a> Impact Analysis insert: </h2>

insert: <h3>

Legacy Internet Resources Proposal October 2013 insert: <b> insert: </b> insert: </h3>

insert: <p>

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. insert: </p>

insert: <h3>

Executive Summary insert: </h3>

insert: <p>

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. insert: </p>

insert: <ol>
    insert: <li>
  1. Due diligence checks will be required to verify the legitimacy of Legacy Resource Holders. If the correct documentation cannot be provided, the RIPE NCC will be unable to enter into a contractual relationship with the Legacy Resource Holder. insert: </li>
  2. insert: <li>
  3. Section 2.1 of the proposal allows Legacy Internet Resources to be covered by the RIPE NCC Standard Service Agreement (SSA). Modifications to the SSA will require approval by the General Meeting (GM). insert: </li>
  4. insert: <li>
  5. Section 2.4 of the proposal allows the Legacy Resource Holder to engage directly with the RIPE NCC through a special contract if they cannot find a sponsoring LIR. While the RIPE NCC cannot think of any circumstances where this might be the case, it concedes that the most appropriate contact channel can this could be used (be that directly or via an existing LIR.) delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 4.1   Transparency: delete: </b> delete: </p> delete: <p> delete: <b> 4.1.1   Acknowledgement of rights delete: </b> delete: </p> delete: <p> RIPE NCC acknowledges that possible. The creation of such a special class of contract would require approval by the GM. insert: </li>
  6. insert: <li>
  7. Section 2.5 allows the Legacy Resource Holder to conclude no contract due to special enduring circumstances. The RIPE NCC will only provide the registration services it currently offers for Legacy Internet Resources without a contract. The RIPE NCC will be unable to force these resource holders to maintain accurate data in the registry. The RIPE NCC will add a remark to the RIPE Database object: no contract. insert: </li>
  8. insert: <li>
  9. In cases where the Legacy Resource Holder has no authority to curtail or modify the rights or obligations of the formal relationship with regards to particular Legacy Internet Resources, the proposal allows for the RIPE NCC to update entries in the RIPE Database. The RIPE NCC will add a remark to the RIPE Database object: no contract. insert: </li>
  10. insert: <li>
  11. If a Legacy Resource Holder that has signed an agreement does not comply with their contractual responsibilities, the RIPE NCC will apply a similar procedure as it does for other resources. If Legacy Resource Holders continue to not comply, their contract may be terminated. insert: </li>
  12. insert: <li>
  13. Currently, The RIPE NCC Arbitration Procedure does not apply to Legacy Internet Resources. Amendments to the arbitration procedure are subject to approval by the GM. insert: </li>
  14. insert: <li>
  15. If the proposal is accepted, the RIPE NCC considers it fair to contact Legacy Resource Holders that have their resources registered under the umbrella of an LIR and offer them the contractual options of the accepted proposal. insert: </li>
  16. insert: <li>
  17. Legacy Internet number resource blocks may contain several layers of hierarchy. It is therefore not clear which of the organisations involved has the right to enter into a contractual agreement. It is the responsibility of the parties involved to find an agreement on which party is the legitimate holder of any legacy resource with regard to that resource. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 4.1.2   Disclosure of options delete: </b> delete: </p> delete: <p> All options available to the legacy resource holder should be disclosed in the initial communication, including those specified in section 5.0. Any difference from the services currently provided to a legacy resource holder should be described. Charges for each option and corresponding services should be clearly described. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 4.1.3   Offer of additional services delete: </b> delete: </p> delete: <p> Additional services, if any, offered by an RIR only to a member or through a member as intermediary, and which the Internet Legacy Resources. Only when the parties involved have not  historically been available available to non-members,  may also be described and offered. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 4.2 Respect delete: </b> delete: </p> delete: <p> delete: <b> 4.2.1 No coercion delete: </b> delete: </p> delete: <p> Legacy Resource Holders may not be rushed or coerced into a quick agreed on a decision because of urgent operational needs. delete: </p> delete: <p> In particular, when the holder of legacy Internet resource requires the data for that resource to be updated for pressing operational reasons, the RIR must not seek to impose the conclusion of a (direct or indirect) will the RIPE NCC evaluate a contractual relationship as a precondition to accepting the update. delete: </p> delete: <p> Each legacy resource holder who has agreed to terms with the RIPE NCC prior to the adoption of this policy must be individually contacted and offered terms consistent with this policy, without the establishment of any deadline to produce a decision. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 4.2.2   Contact via LIR using apparent existing relationships delete: </b> delete: </p> delete: <p> The objective of reliable registration data is most likely to be met if the RIPE NCC uses the help of its existing members to contact legacy resource holders with whom there is an apparent relationship. delete: </p> delete: <p> A phased procedure should be followed similar to that followed in the implementation of RIPE-452. Existing members who contact their legacy holder customers should be given adequate information to describe the available options to their customers, and offer the appropriate services (such as registration through a sponsoring LIR) where preferred. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 4.2.3   Contact directly only in last resort delete: </b> delete: </p> delete: <p> Consistent with phase 3 of the implementation of RIPE-452 for Provider-Independent space holders, the holders of legacy resources that cannot be associated with a likely sponsoring LIR should be contacted directly by the RIPE NCC. delete: </p> delete: <p>   delete: </p> delete: <h3> 5.0   Services for Legacy Internet Resource Holders delete: </h3> delete: <p> delete: <b> 5.1   Reasonable conditions delete: </b> delete: </p> delete: <p> delete: <b> 5.1.1 Maintenance of rights delete: </b> delete: </p> delete: <p> No offer by the NCC of service to the holder of any legacy Internet resource, whether directly or through a sponsoring LIR, may be subject to a condition of waiver or surrender of any of the holder's rights in respect of that resource. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 5.1.2 Protection against abuse of RIR monopoly delete: </b> delete: </p> delete: <p> No basic service which is required to support the effective use of a legacy Internet resource may be withdrawn or withheld from the holder of that resource unless an equivalent service is available at a cost which is reasonably justifiable by reference to current market availability of comparable services. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 5.2   Option to engage via sponsoring LIR delete: </b> delete: </p> delete: <p> The holder of a legacy Internet Resource shall have the option of obtaining NCC services in respect of that resource via a sponsoring LIR. This option will require the signing of a contract between the sponsoring LIR and the holder of the resource, describing which services will be provided.  The contract must explicitly acknowledge that the rights and obligations of the legacy Internet resource holder with regard to the legacy resources involved remain unchanged as they were prior to conclusion of the contract. delete: </p> delete: <p> The sponsoring LIR will be responsible for declaring the existence of each such contract concluded with a legacy Internet resource holder to the RIPE NCC and also for giving sight of the contract to the RIPE NCC if so requested. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 5.3 Option to become a RIPE NCC member delete: </b> delete: </p> delete: <p> The holder of a legacy Internet resource shall have the option of becoming a member of the RIPE NCC.  The contract for membership and service must explicitly acknowledge that the rights and obligations of the legacy Internet resource holder with regard to each legacy resource involved remain unchanged as they were prior to conclusion of the contract. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 5.5 Recommendations as to charging for services delete: </b> delete: </p> delete: <p> Current market prices for a comparable service must be taken as a point of reference in identifying the reasonable cost of a service offered by the RIPE NCC in respect of a legacy Internet resource. delete: </p> delete: <p> It is noted that, as of August 2012, commercial domain-name registrars are able to provide services comparable to the basic services defined above at a tax-inclusive retail price of about twenty euro. delete: </p> delete: <p> In the case that the holder of a legacy Internet resource opts to engage via a sponsoring LIR and wishes to avail only of basic services as defined above, assessment of the billing category of the sponsoring LIR should take account of the legacy resource using a score or rate less than that applicable for a corresponding PI resource. delete: </p> delete: <p> In the case that the holder of a legacy Internet resource opts to engage via a sponsoring LIR and wishes to avail of additional services as defined above, assessment of the billing category of the sponsoring LIR should take account of the legacy resource using a score no greater than that applicable for a corresponding PI resource. delete: </p> delete: <p> Legacy Internet Resource Holders that choose to become RIPE NCC Members shall be charged fees, and enjoy services, in accordance with their RIPE NCC Membership agreement. delete: </p> delete: <p>   delete: </p> delete: <h3> 6.0   Revisions and Extensions to this Policy delete: </h3> delete: <p> delete: <b> 6.1   RIPE NCC may not act in "policy-free zone" delete: </b> delete: </p> delete: <p> The RIPE NCC can develop activities and services for the Internet Community or the RIPE NCC Members without this activity or service being defined in a policy. The management of resources however is a task entrusted to the RIPE NCC by the Internet community. The Memorandum of Understanding with ICANN [5] and specifically the Criteria for Establishment of New Regional Internet Registries [6] state that an RIR must have a "bottom-up self-governance structure for setting local policies". delete: </p> delete: <p> The policies as implemented by the RIPE NCC are developed in the bottom-up Policy Development Process [4]. The RIPE NCC has decided to try to make Legacy Resource Holders sign documents that force them to comply with RIPE policies. While there is no policy that forbids RIPE NCC from doing this, there is also no policy that states request. insert: </li>
  18. insert: <li>
  19. If the community decides that this must be done. RIPE NCC proposal should allow for the certification of Legacy Internet Resources, the RIPE NCC will need to create a certification system specific to these resources. insert: </li>
  20. insert: <li>
  21. The RIPE NCC will contact all Legacy Resource Holders and offer them the options listed in the accepted policy. The total number of legacy Internet Resources in the RIPE Registry is currently acting in a "policy-free zone" which is following a top-down approach instead of the required bottom-up Policy Development Process. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 6.2   Revised or additional policy required for action not covered by present policy delete: </b> delete: </p> delete: <p> This document proposes a framework for future policies. As soon as there is consensus within the RIPE community on this framework any future policy development must be done within the bounds of this framework. delete: </p> delete: <p>   delete: </p> delete: <p> delete: <b> 6.3   Revision by normal RIPE PDP process delete: </b> delete: </p> delete: <p> As for any RIPE policy this framework is also subject to revision by the RIPE Policy Development Process [5]. However, such future revisions must never restrict the rights of Legacy Resource Holders to their legacy resources. delete: </p> delete: <p>   delete: </p> delete: <h3> 7.0 References delete: </h3> delete: <p> [1] delete: <a class="external-link" href="http://www.bbc.com/news/technology-12859585"> Microsoft spends $7.5m on net addresses delete: </a> delete: </p> delete: <p> [2] delete: <a class="internal-link" href="resolveuid/d33301e2f55bc610b1ef1aad5cec299c" data-val="d33301e2f55bc610b1ef1aad5cec299c" data-linktype="internal"> RIPE Network Coordination Centre delete: </a> delete: </p> delete: <p> [3] delete: <a class="external-link" href="http://www.ripe.net/ripe/docs/ripe-registry"> The RIPE Registry delete: </a> delete: </p> delete: <p> [4] delete: <a class="external-link" href="http://www.ripe.net/ripe/docs/pdp"> Policy Development Process in RIPE delete: </a> delete: </p> delete: <p> [5] delete: <a class="external-link" href="http://aso.icann.org/documents/memorandum-of-understanding/"> ICANN Address Supporting Organization (ASO) MoU delete: </a> delete: </p> delete: <p> [6] delete: <a class="external-link" href="http://www.icann.org/en/news/in-focus/global-addressing/new-rirs-criteria"> ICP-2: Criteria for Establishment of New Regional Internet Registries delete: </a> delete: </p> delete: <p>   delete: </p> delete: <h3> Rationale delete: </h3> delete: <p> delete: <b> a. Arguments supporting the proposal delete: </b> delete: </p> delete: <p> Since RIPE 63 (Vienna, Oct-Nov 2011), the RIPE NCC has been approaching legacy resource holders and offering them the opportunity to have the data approximately 4,200 IP blocks and 740 AS numbers, held by the NCC in relation to their approximately 2,500 organisations. insert: </li>
  22. insert: <li>
  23. RIPE Database objects referring to Legacy Internet Resources currently have several different "status:" attribute values. The RIPE NCC proposes changing these to ‘LEGACY’. insert: </li>
  24. insert: <li>
  25. The RIPE NCC also proposes introducing a mandatory "status:" attribute for all AUT-NUM objects, which would take the value 'LEGACY' for all legacy resource holdings updated to ensure accuracy of the records, AS Numbers. For all other AS Numbers the values would be set either to 'ASSIGNED' (assigned by the RIPE NCC) or 'OTHER' (assigned by other RIRs). insert: </li>
  26. insert: <li>
  27. The introduction of the new type of direct engagement of the Legacy Internet Resource Holder with the RIPE NCC will have to be mapped out on terms opportunistically imposed by the NCC.  There was as yet no RIPE policy in place to the RIPE NCC systems that support business processes for this initiative.  Furthermore, the NCC began the activity without first engaging in consultation with the affected resource holders.  Consequently, the activity was perceived by many of those affected as inappropriate and leading to a “destruction of trust”. delete: </p> type of contract. insert: </li>
  28. insert: </ol>
insert: <h2>

A. Understanding of the Policy Proposal insert: </h2>

This policy proposal is meant to be applied by the RIPE NCC to Registration Services, as regards Legacy Internet Resources. insert: </p>

insert: <p>

insert: <b> Legacy Internet Resources insert: </b> , 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 for Legacy Internet Resources that are currently registered in the RIPE Registry. insert: </p>

insert: <p>

This definition also refers to resources that have been distributed by IANA or 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. insert: </p>

insert: <p>

This definition does not include: insert: </p>

insert: <ul>
    insert: <li>
  • Resources that have been distributed or “obtained” in an inappropriate manner (e.g. hijacked resources). insert: </li>
  • insert: <li>
  • Resources transferred from other RIRs that have lost their “legacy” status due to the relevant RIR policies or processes (provided the RIPE NCC has an inter-RIR transfer policy). insert: </li>
  • insert: <li>
  • Resources that no longer have their legacy status after a relevant request by the Legacy Resource Holders (if the Legacy Resource Holders have requested for their resources to be registered and maintained as if they had been distributed by the RIPE NCC). insert: </li>
  • insert: </ul>
insert: <p>

  insert: </p>

insert: <p>

insert: <b> Registration Services insert: </b> , as defined in this proposal, are those services provided by the RIPE NCC in its capacity as an RIR. The proposal specifies them as services “ insert: <i> including the following and such additional services as may be identified from time to time as registry services insert: </i> (section 1.1). These services include: insert: </p>

insert: <ul>
    insert: <li>
  • insert: <b> Maintenance of data relating to Internet Resources by the NCC in their Internet Resource registry. insert: </b> The RIPE NCC understands this as the service to maintain a comprehensive record of the Internet number resources registered within its service region. insert: </li>
  • insert: <li>
  • insert: <b> Access to these data for update by or on behalf of the respective holder. insert: </b> The RIPE NCC understands this as the service of enabling the legitimate holder to update records in the RIPE Registry. The RIPE NCC must ensure that updates are legitimate. For this reason, updates are accepted solely by individuals and organisations authorised by the legitimate holder of the Internet number resource. Access to and updates of this data can be made in by anyone using public tools (such as RIPE Database updates). Additionally, organisations that have entered into a contractual relationship with the RIPE NCC can update these data using member-only tools such as the LIR Portal.   insert: </li>
  • insert: <li>
  • insert: <b> Public availability of registration data. insert: </b> The RIPE NCC understands this as the service of making registration data available through the RIPE Database. insert: </li>
  • insert: <li>
  • insert: <b> Certification of these data. insert: </b> The RIPE NCC understands this as the service of making Legacy Internet Resources in the RIPE Registry eligible for Resource Certification (RPKI). insert: </li>
  • insert: <li>
  • insert: <b> Delegation of Reverse DNS to the registered DNS servers. insert: </b> The RIPE NCC understands this as the service of providing reverse DNS services to Legacy Internet Resources registered in the RIPE Registry. insert: </li>
  • insert: </ul>
insert: <p>

  insert: </p>

insert: <p>

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, the RIPE NCC will make this decision after consultation with the membership and RIPE Community. insert: </p>

insert: <p>

insert: <b> Registration Services Element insert: </b> – 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 any of the following services: insert: </p>

insert: <ul>
    insert: <li>
  • Maintenance of data relating to the Internet number resources registered by the RIPE NCC in its Internet resource registry, as defined above insert: </li>
  • insert: <li>
  • Access to these data for update by or on behalf of the respective holder insert: </li>
  • insert: <li>
  • Public availability of registration data insert: </li>
  • insert: <li>
  • Reverse DNS delegation insert: </li>
  • insert: </ul>
insert: <p>

insert: <b>   insert: </b> insert: </p>

insert: <p>

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 are analysed in detail below. insert: </p>

insert: <h3>

Transfers insert: </h3>

insert: <p>

The policy proposal provides that the rights of the holder to transfer any Legacy Internet Resources are not addressed or restricted by this policy. If the proposal becomes policy, the RIPE NCC may facilitate: insert: </p>

insert: <ul>
    insert: <li>
  • Intra-RIR transfers. The new holder will have to adhere to this policy (i.e. have to sign a new contract so that they receive all registration services). insert: </li>
  • insert: <li>
  • Inter-RIR transfer of Legacy Internet Resources, provided: insert: <ul>
      insert: <li>
    • There is a RIPE inter-RIR transfer policy that does not prohibit such transfers taking place insert: </li>
    • insert: <li>
    • The other RIR facilitates such transfers in accordance with their policies and practices insert: </li>
    • insert: </ul>
    insert: </li>
  • insert: </ul>
insert: <p>

  insert: </p>

insert: <h2>

B. Legal Impact insert: </h2>

insert: <h3>

Contractual Relationship Between Legacy Resource Holder and the RIPE NCC insert: </h3>

insert: <h3>

insert: <b> Legacy Resource Holder insert: </b> insert: </h3>

insert: <p>

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. insert: </p>

insert: <p>

This proposal defines the holder of Legacy Internet Resources 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). insert: </p>

insert: <p>

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: insert: </p>

insert: <ul>
    insert: <li>
  • Verification that the contractual party exists (and is valid) and that it is properly represented in the signing of the agreement in accordance with the RIPE NCC procedural document “ insert: <a href="http://www.ripe.net/ripe/docs/ripe-556"> Due Diligence for the Quality of the RIPE NCC Registration Data insert: </a> ”. insert: </li>
  • insert: <li>
  • Verification that the party claiming to be the Legacy Resource Holder is indeed the legitimate holder of the resources. The holder will need to submit the relevant proof and documentation. The RIPE NCC will need to update the above-mentioned due diligence procedural document to clarify the details of this verification process. insert: </li>
  • insert: </ul>
insert: <p>

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). insert: </p>

insert: <h2>

insert: <b> Different Types of Contractual Relationship insert: </b> insert: </h2>

insert: <h3>

insert: <b> Option 1 (section 2.1) - The Holder is a RIPE NCC Member and Extends the Existing Contract to the Legacy Internet Resources insert: </b> insert: </h3>

insert: <p>

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. insert: </p>

insert: <p>

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). insert: </p>

insert: <h3>

insert: <b> Option 2 insert: </b> insert: <b> (section 2.2) - The Legacy Resource Holder Becomes a RIPE NCC Member insert: </b> insert: </h3>

insert: <p>

The same applies as in Option 1. insert: </p>

insert: <h3>

insert: <b> Option 3 insert: </b> insert: <b> (section 2.3) – The Legacy Resource Holder Enters into a Contract With a Sponsoring LIR insert: </b> insert: </h3>

insert: <p>

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 its own Legacy Internet Resources. insert: </p>

insert: <h3>

insert: <b> Option 4 insert: </b> insert: <b> (section 2.4) – The Legacy Resource Holder Engages Directly with the RIPE NCC with Another Agreement (Not the SSA) insert: </b> insert: </h3>

insert: <p>

This option is available for those Legacy Resource Holders that cannot find a sponsoring LIR with which a mutually satisfactory contract can be signed. While the RIPE NCC cannot think of any circumstances where this might be the case, it concedes that this could be possible. insert: </p>

insert: <p>

The creation of a special agreement for RIPE NCC services to non-members would need approval by the GM. insert: </p>

insert: <h3>

insert: <b> Option 5 (section 2.5) – The Legacy Resource Holder Concludes No Agreement insert: </b> insert: </h3>

insert: <p>

According to the proposal, the Legacy Resource Holder may not be required to have an attempt to recover the unfortunate agreement due to specific enduring or temporary circumstances which the RIPE NCC recognises as being beyond the holder’s control. insert: </p>

insert: <p>

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. In these cases, the RIPE NCC would be unable to provide services beyond the ones already provided to any Legacy Resource Holder (i.e. those identified above as Registration Services Elements) without a contract. insert: </p>

insert: <p>

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 compelling the resource holder to maintain accurate data in the registry. insert: </p>

insert: <p>

The fact that the RIPE NCC has no means of compelling the resource holder, without an agreement, to maintain accurate data in the RIPE Registry is considered a technical limitation related to Resource Certification (RPKI). The resources listed on a certificate are derived from information in the RIPE Registry. In case of Legacy Resource Holders (without an agreement), in practice there is only an entry in the RIPE Database that attests to the holdership. It is currently not technically possible to issue a resource certificate based on this information alone. insert: </p>

insert: <p>

The RIPE NCC will add the remark "No-contract" in the INETNUM object. insert: </p>

insert: <h3>

insert: <b> Option 6 (section 2.6) – No Relationship insert: </b> insert: </h3>

insert: <p>

The proposal describes cases where the Legacy Resource Holder has no formal relationship with regards to particular Legacy Internet Resources. In this case, the RIPE NCC will have to continue providing any Registration Services Elements that are already provided to this specific Legacy Resource Holder. The RIPE NCC has defined what it considers to be Registration Services Elements above. insert: </p>

insert: <p>

This option applies if a relationship or agreement as described in sections 2.1-2.5 has not been established (see section 2.0 of the proposal). insert: </p>

insert: <p>

The situation which applying under Option 5 above, regarding 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 arisen and  in the hope no means of compelling the resource holder to maintain accurate data in the registry. insert: </p>

insert: <p>

The proposal also allows for the RIPE NCC to “ insert: <i> update the related entries in the RIPE Database in accordance with the actual situation insert: </i> ”. The RIPE NCC will add the remark "No-contract" in the RIPE Database resource object. insert: </p>

insert: <h3>

insert: <b> Non-compliance with the Contractual Responsibilities insert: </b> insert: </h3>

insert: <p>

If a Legacy Resource Holder that has signed an agreement as described in options 2.1-.2.4 does not comply with their contractual responsibilities, the RIPE NCC will apply a similar procedure as it does for other resources (see also http://www.ripe.net/ripe/docs/ripe-578#b2). insert: </p>

insert: <p>

In particular, in case of non-compliance: insert: </p>

insert: <ul>
    insert: <li>
  • The RIPE NCC will add the remark "under review" in the RIPE Database resource object. insert: </li>
  • insert: <li>
  • A warning statement is added to the relevant records of the RIPE Database mentioning that the Legacy Internet Resources are not in compliance with data accuracy obligations insert: </li>
  • insert: <li>
  • The RIPE NCC will revoke any certificates generated by the RIPE NCC Certification Service insert: </li>
  • insert: </ul>
insert: <p>

  insert: </p>

insert: <p>

If legacy holders continue to not comply, their contract may be terminated. insert: </p>

insert: <p>

In this case: insert: </p>

insert: <ul>
    insert: <li>
  • The RIPE NCC will add the remark “No-contract” in the RIPE Database resource object; and insert: </li>
  • insert: <li>
  • A warning statement will be added to the relevant records in the RIPE Database mentioning that the Legacy Internet Resources are not covered by a contractual relationship; and insert: </li>
  • insert: <li>
  • The RIPE NCC will withdraw the reverse delegation insert: </li>
  • insert: </ul>
insert: <h3>

insert: <b> Consequences of the termination of the contract insert: </b> insert: </h3>

insert: <p>

In accordance with section 2.7 of the proposal, if the holder’s agreement based on any of the options 2.1-2.4 is terminated for any reason, the RIPE NCC will not be obliged to keep providing the holder with services other than those identified above as Registration Services Elements. insert: </p>

insert: <h3>

insert: <b> Arbitration insert: </b> insert: </h3>

insert: <p>

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. insert: </p>

insert: <h2>

insert: <b> C. Impact on Registration Services insert: </b> insert: </h2>

insert: <h3>

insert: <b> Legacy Internet Resources Currently Registered Under an LIR Umbrella insert: </b> insert: </h3>

insert: <p>

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. insert: </p>

insert: <p>

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. insert: </p>

insert: <p>

Between January 2012 and August 2012, the RIPE NCC accepted statements by Legacy Resource Holders agreeing that their resources are to be considered as having been distributed by the RIPE NCC, therefore losing their legacy status. These resources have been registered under the umbrella of an LIR at the holders’ requests. insert: </p>

insert: <p>

If this proposal becomes policy, the RIPE NCC understands that it will help prevent 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. insert: </p>

insert: <h3>

insert: <b> Identifying the Legitimate Holder of a Legacy Internet Resource insert: </b> insert: </h3>

insert: <p>

Some Legacy Internet Resources were distributed by InterNIC to registries such a 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 number resource blocks may contain several layers of hierarchy. insert: </p>

insert: <p>

It is often not clear if the legitimate holder of these resources is the organisation that received the resources from InterNIC for redistribution, or the subsequent organisation that received the resources. It is therefore not clear which of the organisations involved has the right to enter into a contractual agreement. insert: </p>

insert: <p>

When the situation arising again. delete: </p> delete: <p> Although IPv4 addressing presents itself where there are multiple layers of legacy resources were not originally intended to be object of any kind of trade, practice showed otherwise during the last years [1]. The implicit acceptance of trade practices over IPv4 addresses sets the background distribution, it is the responsibility of the parties involved to find an agreement on which party is the legitimate holder of the legacy resource. Only when the parties involved have agreed on a decision, the RIPE NCC will evaluate a contractual relation request. insert: </p>

insert: <h3>

insert: <b> Resource Certification (RPKI) insert: </b> insert: </h3>

insert: <p>

The RIPE NCC would like to highlight that if the community decides that this proposal should allow for any organisation to consider 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 RIPE NCC members-only address space. insert: </p>

insert: <h3>

insert: <b> Registration Services Operational Impact insert: </b> insert: </h3>

insert: <ul>
    insert: <li>
  • insert: <p>

    The RIPE NCC will contact all Legacy Resource Holders that have registered their legacy Internet resources as described in the section “Legacy Internet Resources Currently Registered Under an asset, LIR Umbrella” and offer them the options listed in the accepted policy. insert: </p>

    insert: <p>

    The impact on the RIPE NCC to implement the above point is considered as low impact. insert: </p>

    insert: </li>
  • insert: <li>
  • insert: <p>

    The RIPE NCC will, via email, inform all other Legacy Resource Holders (contact details registered in the RIPE Database) about the options listed in the accepted policy. A remark “no contract” will be added to RIPE Database objects for Legacy Internet Resources not covered by a contractual agreement. insert: </p>

    insert: <p>

    The impact on the RIPE NCC to implement the above point is considered as low impact. insert: </p>

    insert: </li>
  • insert: <li>
  • insert: <p>

    The total number of Legacy Internet Resources in the RIPE Registry is approximately 4,200 IP blocks and 740 AS numbers, held by approximately 2,500 organisations. insert: </p>

    insert: <p>

    Assuming that all Legacy Resource Holders would want to enter into a contractual relation either with a Sponsoring LIR or with the RIPE NCC, we estimate the effort required to verify the documentation to be between 700 and 900 FTE working days. This estimate is based on experience accumulated through the ERX project, the legacy resource registration project and the implementation of RIPE Policy Proposal 2007-01. insert: </p>

    insert: </li>
  • insert: <li>
  • insert: <p>

    The creation of both internal and external documentation will be a one-time effort. insert: </p>

    insert: </li>
  • insert: </ul>
insert: <h2>

D. Impact on other departments insert: </h2>

insert: <h3>

RIPE Database: insert: </h3>

insert: <p>

Currently, most legacy Internet number resource objects in the RIPE Database have the "status:" attribute value EARLY-REGISTRATION. But there are some that have other values. insert: </p>

insert: <p>

This situation does not allow for a transparent and consistent overview, clearly indicating which resources are Legacy Internet Resources. The RIPE NCC receives many inquiries from organisations requesting clarification. insert: </p>

insert: <p>

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. This includes all more specific objects. Since the way this address space is used may not match the same structure used for RIPE allocated address space, it is considered more important to reflect its legacy status rather than where it fits within any hierarchy. The RIPE NCC can make this change in a single update to all legacy objects and their more specific objects. insert: </p>

insert: <p>

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 potentially traded. delete: </p> delete: <p> delete: <br /> 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. insert: </p>

insert: <p>

The impact on the RIPE NCC to implement the above points is considered low impact. However, adding a mandatory attribute for the AUT-NUM object could have a high impact on the community because these objects are updated frequently by automated processes. Every AS Number resource holder would need to be well informed of such a change with plenty of time to adjust their scripts. insert: </p>

insert: <p>

The RIPE NCC would like the community to consider this as one possible solution, along with any other options, and advise the RIPE NCC on the best way forward. insert: </p>

insert: <p>

If this proposal is accepted then the required RIPE Database changes will be provided separately to the RIPE Database Working Group to discuss implementation using the appropriate and agreed procedures. insert: </p>

insert: <h3>

b. Arguments opposing Business Applications: insert: </b> insert: </h3>

insert: <p>

If approved by the GM, the introduction of the new type of direct engagement of the Legacy Resource Holder with the RIPE NCC (Section 2.4) will have to be mapped out on the RIPE NCC systems supporting business processes for this type of contract. insert: </p>

insert: <p>

Among the processes that will have to be mapped out are: insert: </p>

insert: <ul>
    insert: <li>
  • Sign-up process for Legacy Resource Holders insert: </li>
  • insert: <li>
  • Billing process for Legacy Resource Holders insert: </li>
  • insert: <li>
  • Delivery of certain RIPE NCC Services to Legacy Resource Holders insert: </li>
  • insert: </ul>
insert: <p>

The requirements are not known at the moment, so it is not currently possible to accurately estimate the impact of the proposal on the RIPE NCC software systems. insert: </p>

insert: <p>

The introduction of the new status for INETNUM objects and the addition of a new mandatory attribute to AUT-NUM objects will have little impact on the RIPE NCC software systems. insert: </p>

insert: <h3>

insert: <b> Other: delete: </p> delete: <p> As may insert: </h3>

insert: <p>

Several other departments, such as Customer Services, Finance and Communications, will be received during Discussion Phase. delete: </p> delete: <p>   delete: </p> affected but this will be low impact and on the department level. insert: </p>

insert: <ol class="listTypeLowerAlpha">
    insert: <li>
  1. insert: <a class="internal-link" href="resolveuid/f62e66c3cd4a493694ef8c34f1700a14" target="_self" title="" data-val="f62e66c3cd4a493694ef8c34f1700a14" data-linktype="internal"> New policy insert: </a> insert: </li>
  2. insert: <li>
  3. insert: <a class="internal-link" href="resolveuid/8a2bf1640a454566bb973a9ef423a508" target="_self" title="" data-val="8a2bf1640a454566bb973a9ef423a508" data-linktype="internal"> Amendment to existing policy document ripe-592 insert: </a> insert: </li>
  4. insert: </ol>
Draft documents relating to "RIPE NCC Services to Legacy Internet Resource Holders"
A framework is proposed as the basis for rigorous maintenance of registration data and for delivery of services to legacy Internet resource holders in the 2012-07: RIPE NCC service region. Services to Legacy Internet Resource Holders
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