[address-policy-wg] 2023-04 Review Phase (Add AGGREGATED-BY-LIR status for IPv4 PA assignments)

Dear colleagues,

Though we recognise that most of you are probably busy preparing for the upcoming holidays, we would like to ask you to share your opinion on proposal 2023-04. Remember that Policy Development Process requires any comments made during the Discussion phase must be repeated during the Review phase in order to count towards or against rough consensus, as your views can now take the RIPE NCC’s Impact Analysis into account.

Here are some questions for the WG to get the discussion started: Do you already use AGGREGATED-BY-LIR when registering IPv6 assignments? Would you find it convenient and useful to be able to register IPv4 assignments in the same way? Does 2023-04 address this use case well in its current form, or could you think of any potential improvements?

We hope you will find the time to let your voice be heard!

The Policy Development Process requires the proposers to adequately address any suggestions for changes or objections to the proposal in each phase, which we will do below.
1. Does 2023-04 change the contact registration requirements for assignments?

The argument made is that the statement «When an End User has a network using public address space this must be registered separately with the contact details of the End User» found in the current policy (and removed by 2023-04 in order to bring the wording in line with that of the IPv6 policy), implicitly requires LIRs to register non-delegated/outsourced contact information for the End User in the RIPE database, not necessarily in the mandatory «admin-c» or «tech-c» attributes, but possibly in an optional attribute like «descr», «org» or «remarks».
Proposers’ response:
We do not believe so, for the following reasons, and keeping the current practice and policies in consideration:


  1.
The RIPE NCC does not consider that 2023-04 changes the contact registration requirements in any way[1][2][3]. Absent any (rough) consensus in the Working Group to the contrary, we defer to the RIPE NCC’s judgement on this point.
  2.
The practice of creating assignments with all contact information delegated is already widespread. If this was a policy violation made possible due to the RIPE NCC implementing RIPE policy incorrectly, we would have expected the community to take action to correct this situation. However, no such policy proposal has been put forward by the community.
  3.
Outsourcing and delegation of contact information is a common practice across many industries, including in networking and information technology. There is no policy language that explicitly prohibits this for IPv4 assignments. Absent that, we believe any implicit prohibition found “between the lines” is essentially «void for vagueness»[4].
  4.
An obligation to publish the End User’s contact information in the RIPE database will constitute a violation of Article 6(3) of the RIPE Database Terms and Conditions[5] and Article 6(1)(a) of the GDPR[6], if the End User’s contact person has not given explicit consent to such publication. We believe that the RIPE policy cannot reasonably be interpreted to require LIRs to break EU law (and even if it explicitly did require that, EU law would still take precedence).
  5.
The policy’s stated goal of registering assignments is «to ensure uniqueness and to provide information for Internet troubleshooting at all levels»[7]. Requiring LIRs to publish the contact information of End Users who often will not have any knowledge or capability to aid with troubleshooting does work towards this attaining goal. On the contrary, delegating the contact information to the LIR/ISP may well be the only way to attain this goal.

[1] https://www.ripe.net/ripe/mail/archives/address-policy-wg/2023-September/013856.html
[2] https://www.ripe.net/participate/policies/proposals/2023-04#impact-analysis
[3] https://www.ripe.net/ripe/mail/archives/address-policy-wg/2023-November/013892.html
[4] https://www.law.cornell.edu/wex/void_for_vagueness
[5] https://www.ripe.net/manage-ips-and-asns/db/support/documentation/terms
[6] https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679#d1e1888-1-1
[7] https://www.ripe.net/publications/docs/ripe-804#3
2. The «assignment-size» attribute should be a CIDR prefix length
Leaving it undefined could result in some LIRs using it to represent an IPv4 address count, while others would use it to represent a CIDR prefix length.
Proposers’ response:
We agree «assignment-size» should be a CIDR prefix length. We understand that, if proposal 2023-04 would be accepted, the RIPE NCC could implement the «assignment-size» attribute for IPv4 inetnum objects to be a CIDR prefix length, and document it as such. Therefore we do not believe it is necessary to spell this out explicitly in the policy document (it is not spelled out in the IPv6 policy document either).


Thank you for your attention and enjoy your holidays!

Best regards,
Jeroen and Tore


Op 21 nov. 2023, om 11:13 heeft Angela Dall'Ara <adallara at ripe.net<mailto:adallara at ripe.net>> het volgende geschreven:


Dear colleagues,

Policy proposal 2023-04, “Add AGGREGATED-BY-LIR status for IPv4 PA assignments”, is now in the Review Phase.

The goal of this proposal is to introduce the AGGREGATED-BY-LIR status for IPv4 PA assignments to reduce LIR efforts in registration and maintenance.

This proposal has been updated and it is now at version 2.0. The proposed policy text did not change, the only difference is that the section "Arguments opposing the proposal" includes a reference to the last round of discussion.

The RIPE NCC has prepared an impact analysis on this proposal to support the community’s discussion.

You can find the proposal and impact analysis at:
https://www.ripe.net/participate/policies/proposals/2023-04
https://www.ripe.net/participate/policies/proposals/2023-04#impact-analysis
And the draft document at:
https://www.ripe.net/participate/policies/proposals/2023-04/draft

As per the RIPE Policy Development Process (PDP), the purpose of this four-week Review Phase is to continue the discussion of the proposal taking the impact analysis into consideration, and to review the full draft RIPE Policy Document.

At the end of the Review Phase, the Working Group (WG) Chairs will determine whether the WG has reached rough consensus.
It is therefore important to provide your opinion, even if it is simply a restatement of your input from the previous phase.

We encourage you to read the proposal, impact analysis and draft document and to send any comments to address-policy-wg at ripe.net before 20 December 2023.

Kind regards,
Angela Dall'Ara
Policy Officer
RIPE NCC

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