[address-policy-wg] ripe-682 Transfer Policy Problems

The member cost is however easily eaten by the income of renting a single
/24 in many countries at the moment.

So it is barely an hindrance at all and especially not a hindrance for an
org betting on the finite nature of ipv4 pushing prices in 2-5 years to
crazy levels.

On Thu, Dec 23, 2021, 03:27 Arash Naderpour <arash_mpc at parsun.com> wrote:

> There is a catch,
> 20 LIRs cannot be merged into a single LIR of the new parent company,
> unless it has passed 2years from the /24 allocation date.
> So after the merge, the new parent company still has to pay for 20 LIRs
> till the time /24 can be transferred,
>
> Regards,
>
> Arash
>
> >>So merging a shell company with 20 LIRs, each with a /24, with the
> parent company with a single LIR, allows those 20 /24s to be
> registered with the single LIR of the parent company and closure of
> the 20 LIRs.
>
>
>
> On Thu, Dec 23, 2021 at 2:01 AM denis walker <ripedenis at gmail.com> wrote:
>
>> Colleagues
>>
>> The Transfer Policy ripe-682 is so vague you can drive a train through
>> the holes in it. I have some questions that I hope someone can answer
>> before Christmas as I would like to propose an amendment to this
>> policy in the new year.
>>
>> "Any legitimate resource holder is allowed to transfer"
>> What does 'legitimate' mean in this context? It is not defined in this
>> policy document. It is no use referring to a dictionary or even some
>> other policy document. It needs to be defined in this policy. If it
>> has no specific meaning in the context of this policy, then the word
>> should be removed.
>>
>> My understanding of a 'policy document' is that it is self contained
>> and consistent. None of the terms:
>> -RIPE NCC Member
>> -LIR
>> -Resource holder
>> are defined anywhere in the Transfer Policy or ripe-733, IPv4
>> Allocation... A policy may be dependent on another policy being in
>> place. You cannot transfer a resource unless it has been allocated.
>> You cannot allocate a resource unless there is a RIPE NCC Member and
>> an LIR. But you should not have to backtrack through a whole sequence
>> of documents to find out what a term in this policy means. This policy
>> can only work if people understand 'commonly accepted' definitions of
>> these terms. But that is open to interpretation and mis-understanding.
>> That could make legal enforcement of, for example, restrictions more
>> difficult to apply.
>>
>> [As a side issue I have just quickly read through a whole series of
>> documents and forms on becoming a RIPE NCC Member and getting
>> resources. In every document/form I found:
>> -Legal errors
>> -English grammar errors
>> -Procedural errors
>> -Webpage errors
>> The whole process is a complete mess and needs a serious Legal/Comms
>> review.]
>>
>> I found the definition of a Member in one document but nowhere have I
>> found any definition of LIR. These terms are so fundamental to all
>> these policies, to not define them leaves a massive hole in their
>> meaning and authority. These terms seem to be so interchangeable from
>> one paragraph to the next. In some places the wrong term is used.
>>
>> ripe-733 says allocations are made to LIRs
>> ripe-682 says allocations are transferred to members
>> ripe-682 says transfer restrictions apply to resource holders
>>
>> Then we have this document
>>
>> https://www.ripe.net/manage-ips-and-asns/resource-transfers-and-mergers/transfer-of-ip-addresses-and-as-numbers
>> which talks about 'hodership', another term not defined.
>>
>> Then we have this document
>>
>> https://www.ripe.net/manage-ips-and-asns/resource-transfers-and-mergers/transfer-of-ip-addresses-and-as-numbers/transfers-in-the-ripe-ncc-service-region
>> that conflicts with the Transfer Policy.
>> It also refers to Members as organisations, again without any actual
>> definition.
>>
>> The above document says:
>> "Exception: For transfers between multiple LIR accounts belonging to
>> the same organisation, also referred to as consolidations, the 24
>> months restriction will only apply once after the resources were
>> received from the RIPE NCC or from another organisation."
>>
>> This is NOT what the Transfer Policy says. The policy makes no mention
>> anywhere of consolidation. The only definition we have of a transfer
>> in any POLICY is this one line:
>> "Allocated resources may only be transferred to another RIPE NCC member."
>> This does not even make sense. A Member cannot 'hold' a resource.
>> Resources are held by Member LIRs. So if a resource is transferred to
>> a Member with 5 LIRs, which one receives it? Does it matter? Is it
>> whichever LIR the Member writes on the transfer request form?
>>
>> Now a consolidation is not a transfer. In the policy a transfer is
>> defined as moving a resource to 'another Member'. So consolidating a
>> resource by moving it from one LIR to another LIR of the same Member
>> is by policy definition, not a transfer. So consolidation is not
>> subject to Transfer Restrictions because it is not a transfer.
>>
>> So all the shell companies that have been set up this year to hoover
>> up the last /24s can now be merged with their parent company and then
>> all the /24s can be consolidated into one LIR. The other LIRs can then
>> be closed. Nothing in this policy document says a /24 allocation must
>> remain for 24 months with the LIR that it was allocated to. It says it
>> cannot be transferred, but mergers are allowed and consolidation is
>> not a transfer.
>>
>> This is even confirmed in a procedural document ripe-758, Transfer of
>> Internet Number Resources... (which doesn't appear to be policy)
>> "Internet number resources that are subject to transfer restrictions
>> imposed by the RIPE Policy "RIPE Resource Transfer Policies", and that
>> are transferred due to a change in a member's business structure, must
>> either remain registered with the original LIR account or be
>> registered with a new LIR account."
>>
>> So merging a shell company with 20 LIRs, each with a /24, with the
>> parent company with a single LIR, allows those 20 /24s to be
>> registered with the single LIR of the parent company and closure of
>> the 20 LIRs.
>>
>> Also ripe-758 introduces yet another term, parties, without any
>> definition or clarity.
>>
>> This whole transfer process is totally confused with contradictory,
>> inconsistent and poorly written documents and policies.
>>
>> cheers
>> denis
>> co-chair DB-WG
>>
>> --
>>
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