[address-policy-wg] 2016-03 New Version and Impact Analysis Published (Locking Down the Final /8 Policy)
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Ciprian Nica
office at ip-broker.uk
Fri Oct 21 15:45:21 CEST 2016
I didn't have any popcorn but a few nachos were helpful to read the full e-mail. Very good and detailed explanations. +100 from me to Elvis which can also be read as -100 for the policy. For those of you who pretend working, it's friday so you can't trick anyone ;). You'd better read Elvis's mail entirely. Have a nice weekend, Ciprian On Fri, Oct 21, 2016 at 4:36 PM, Elvis Daniel Velea <elvis at velea.eu> wrote: > Hi, > > On 10/19/16 11:05 AM, Marco Schmidt wrote: > >> The goal of this proposal is to ban transfers of allocations made under >> the final /8 policy. Also the proposal specifies what resources must be >> added to the RIPE NCC IPv4 available pool. >> > I do not agree with this policy proposal and believe it will not fix > anything, instead - it will harm the registry. > >> Some of the differences from version 2.0 include: >> >> - Clarification that changes to holdership of address space as a >> result of company mergers or acquisitions are not affected by proposed >> transfer restriction >> > this fixes only a tiny bit of the problem. > >> - Legacy space handed over to the RIPE NCC will be added to the IPv4 >> available pool >> > this has nothing to do with the policy proposal. I feel it's just some > candy offered to sweeten the proposal itself. > > This was the short version of my response. Those reading this e-mail > during working hours, you can go back to work ;) those that still have some > popcorn left, feel free to read further. > > Below are the 6 most important reasons why I believe this policy proposal > should not become policy: > > 1. This policy proposal will create two types of members. > > a. the members that have received resources before 2012 + the members that > can afford to 'buy' IP addresses allocated until recently (-2y from the > date this policy proposal would be implemented) > b. the members that have only received resources after September 2012 and > can not afford to buy IP IP addresses at the market prices (but they can > buy an unlimited number of these from the RIPE NCC at ~€4,5 (€3,4/1st year > + €1,4/2nd year - redistribution of profit) > > The first type of member would be allowed to participate in an IP transfer > market that was (until the implementation of this policy proposal, if ever) > accessible to everyone and anyone with resources received from the RIPE NCC > or an other member. > The second type of member will not be allowed to participate in this IP > transfer market unless they buy first from an other member. > > Some members have already been able to transfer their /22 received from > the last /8. With the implementation of this policy proposal (if ever) I > feel that we as a community will discriminate between those that have > received their last /22 (and want/need, for various reasons to transfer it) > 2 or more years before implementation and those that have received less > than 2 years before the implementation (or any time after). > > I know some of you do not like analogies. But I would compare this with 2 > people buying their cars. The first can buy the car and sell it 2 years > later, only because the purchase happened even just a few days before the > car industry decides that cars can no longer be sold further. So, those > that have bought their car and used it for 1.5 years will have to return it > (for free) to the car manufacturer while others could have sold it because > they were quick in the purchase process and bought it earlier. > > So, I think that once this policy proposal would be implemented (if ever) > it would discriminate the second type of member as they will not be allowed > to participate in a well established IP transfer market with the IP > addresses received from the RIPE NCC (and only with the IP addresses they > need to buy from the market first). > > > 2. This policy proposal will create yet an other color of IP addresses. > > I believe and hope that in the near future we will start talking about the > removal of colors and not about addition of more colors. Numbers are just > numbers. There is no difference between a number received in 1990, one > received after 1992 or one that has status PI or PA. Now, we want to add a > color for numbers received after 2012... > > My router does not know any difference between these numbers and nobody > really cares. Do you think that PI holders care that they are not supposed > to sub-assign that space to other customers ? Do you think the RIPE NCC has > any say or can really verify who (and most importantly - how someone) is > using any of these numbers? > The community decided to remove most of the barriers when 2013-03, > 2014-02, 2014-05 were approved and implemented. These policy proposals > removed all the 'old' requirements and cleaned up the IPv4 policy so much > that anyone can now do whatever they want with their IPv4 space (not that > they could have not done it in the past, but they would have to lie to the > RIPE NCC if they would have ever needed an additional allocation). This > policy proposal tends to take us back to previous way of thinking, an old > one - I think. > > So, just adding more colors and barriers will only complicate things. And > I've always liked policies and procedures that are clear and simple. As > simple as possible. > > > 3. This policy proposal will drive some IPv4 transfers underground. > > We already know and have seen it in previous presentations that where the > RIR system tries to impose some limitations, the real world invents > something to circumvent those limitations. Currently, with very large > allocations, the invention is called a 'futures contract'. > > While the RIPE NCC policies will say that ALLOCATED FINAL can not be > transferred between LIRs (if this policy proposal will ever make it into > policy), most LIRs will find ways to circumvent the policy (as they have > always done it). They will create contracts that will stay underground and > will be covered by NDAs, they will use loopholes in the M&A process, they > will do whatever they need to in order to (sell/buy) the resources they > needed. > > We've seen that some of the people that participated in the previous > discussion of this policy proposal said they will never do such a thing, > they will never buy a /22 that says ALLOCATED FINAL. Would you change your > mind if your business depended on it? If there was no other way to receive > an IP block that you desperately need ? If you have a very important > customer that would leave if you can not assign a few more IP addresses? > I bet anyone that has a commercial business will think twice and examine > again and again where is that border between profit and loss and whether > respecting the RIPE Policies to the very last letter really matter that > much that they would rather have a loss. > > > 4. This policy proposal will drive the free IPv4 pool to run-out even > faster. > > What will the LIRs do if they won't be able to find affordable IPv4 in the > market any longer? If these /22s that were allocated from the last /8 are > no longer available in the transfer market? Well, they will either buy more > expensive (pre-2012) IP addresses or go to the RIPE NCC and receive a /22 > for less than €5/IP. > The board announced publicly that anyone can open multiple LIRs if they > need more IPs. > > Approving this policy proposal will only remove some 'assets' from the > free market and the supply will shrink, therefore driving prices up for > whatever is pre-2012 and pushing more members to get the IPs they need from > the RIPE NCC by means of setting up multiple LIRs. > > > 5. This policy proposal will affect the registry (in a bad way) > > As said in #3, some transfers will be driven underground. We do not see > many of those in the RIPE Region at this moment because there is no > limitation on who can transfer and when (except for the two years anti-flip > bit). > If this proposal ever becomes policy, the transfers of the /22s will still > happen. If the two parties can not convince the RIPE NCC of their 'M&A' and > can not get the IPs changed in the RIPE Database from a name to an other, > they will keep on using them with the wrong name. > > This will affect the quality of the registry and we will have a registry > with two colors. The bleached IPs will be the ones pre-2012 and the rest > will have various colours of grey. > > 6. Artificial explosion of number members > > The implementation of the members' vote (on the board decision of blocking > the registration of multiple LIRs on the same company name) requires those > that need a second /22 to keep it in a second LIR for at least 2 years > before this second /22 can be transferred to their first LIR. The second > LIR can then, after the transfer, be closed. So the price per IP, has been > set to a minimum 2 years membership + sign-up fee - redistribution. > > It may actually require the company opening multiple LIRs to keep all of > these open if they want to hold on to their IP addresses. It is not very > clear what will happen when these companies will want to consolidate all > the LIRs they have into one. If they will be forced to return the /22 they > got on their second LIR, then they will be forced to keep this second LIR > open. > > If that's the case, the number of LIRs will explode and will not shrink > every time a second LIR ages 2 years and can transfer the /22 to the first. > I am unsure whether Remco, as a private citizen but more, as a Board member > has given this enough thought. I believe that this policy proposal will > make the RIPE NCC more and more unstable with difficulties in making > financial plans on the long run. > > I worry that these companies that will be forced to keep multiple LIRs > open just to hold on to their /22s may take the Board or the NCC to court > because they are not allowed (after 2 years) to consolidate their > membership into one registry. I am unsure what a court would say when they > are told that Remco has multiple hats and his proposal is not made with a > Board hat. To most of the world (and I've talked to quite a few people > about it), this policy proposal seems to come from the RIPE NCC Board. > To many people that I talk to, this policy proposal is seen as a double > standard from the NCC Board. On one hand, the Board decided to advise the > members to vote to allow companies to open multiple LIRs. On the other > hand, one of the Board Members (even if as a private citizen) makes a > policy proposal that forces those to pay a la longue for each /22 they > received. > > > There may be other reasons why I do not like this proposal. The ones > mentioned above are the most important ones. > > Regards, > Elvis > > -------------- next part -------------- An HTML attachment was scrubbed... URL: <https://lists.ripe.net/ripe/mail/archives/address-policy-wg/attachments/20161021/cb97bb42/attachment.html>
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