[address-policy-wg] 2012-02 New Draft Document and Impact Analysis Published (Policy for Inter-RIR Transfers of IPv4 Address Space)

Dear colleagues,

In order to clarify some points of the impact analysis and facilitate
the current community discussion, we would like to highlight some
details about the foreseen implementation activity related to the
proposal 2012-02.

With regards to the two points of the impact analyses that are being
questioned:

"C. Impact of Policy on RIPE NCC Operations/Services
Registration Services:
It is very relevant to note that the implementation of this policy
proposal will require a significant effort of co-ordination between the
RIPE NCC and the other RIRs. It is unclear at the moment how much time
and resources will be needed to fully implement the proposal."

If the proposal is accepted, it should be noted that the RIPE NCC
service region will be the third region involved in inter-RIR transfers,
after ARIN and APNIC. There already exists close coordination between
the RS departments of all RIRs as an ongoing and ordinary activity,
aimed at monitoring trends, issues and solutions related to the resource
registration activities. This policy proposal would increase the
importance and relevance of this existing coordination by broadening its
scope to inter-RIR transfer resources as well. Therefore based on both
ARIN's and APNIC's experience in this area the amount of effort may be
somewhat reduced.

Each inter-RIR transfer will consist of:

- evaluation of RIPE Policy compliance
- evaluation of official documentation
- coordination with the other involved RIR staff
- updating registry entries

Therefore, the only additional step compared to intra-RIR transfers
would be the coordination with the other RIR staff.

With regards to the estimated volume of the potential inter-RIR
transfers, it is difficult to make predictions, as the only data
currently available is the number of transfers currently taking place,
which is less than 20 intra-RIR transfers to date. Based on those
numbers, we do not expect a major increase in effort.

The anticipated number of inter-RIR transfers is unclear and some
members of the RIPE community are suggesting that not all RIPE NCC
members would directly benefit from this policy, as is the case with
many RIPE Policies. However, it is worth emphasising that if no
inter-RIR policy is in place there is a growing risk that some entities
will choose to transfer number resources without informing the relevant
RIRs or reflect these transfers in the relevant registries. This
would dilute the accuracy of the collective RIR registries and have a
direct impact on the entire RIPE NCC membership. Therefore, as both
APNIC and ARIN already have this policy in place, the RIPE community
should consider the consequences of not having an inter-RIR transfer
policy in place.

"D. Legal Impact of Policy
If this policy proposal will be accepted, the RIPE NCC will need to
create appropriate legal procedures and template agreements in order for
all parties to understand and agree on the preconditions and the
consequences of the transfer in accordance with the provisions of this
policy."

Our legal department indicated that any changes to the appropriate legal
procedures and template agreements would fit into the normal work
processes that occur after any RIPE Policy has been implemented.


Regards,

Andrew de la Haye
Chief Operations Officer
RIPE NCC