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 <[email protected]> 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 <[email protected]> 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 >> >> -- >> >> To unsubscribe from this mailing list, get a password reminder, or change >> your subscription options, please visit: >> https://lists.ripe.net/mailman/listinfo/address-policy-wg >> > -- > > To unsubscribe from this mailing list, get a password reminder, or change > your subscription options, please visit: > https://lists.ripe.net/mailman/listinfo/address-policy-wg >
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