Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Erik Bais - A2B Internet]

Hi Gert, 

I know you well enough to not take this personal and if you are not responding 
to me on a couple nudges, you must have a good reason for it. 

Thank you for the work and lets get started on the last call on this. 

Regards,
Erik Bais

> Op 7 feb. 2017 om 17:02 heeft Gert Doering  het volgende 
> geschreven:
> 
> Dear Address Policy WG,
> 
>> On Tue, Sep 27, 2016 at 03:08:32PM +0200, Marco Schmidt wrote:
>> The draft documents for version 4.0 of the policy proposal 2015-04, "RIPE 
>> Resource Transfer Policies" have now been published, along with an impact 
>> analysis conducted by the RIPE NCC.
>> 
>> The goal of this proposal is to create a single document with all relevant 
>> information regarding the transfer of Internet number resources.
>> 
>> Some of the differences from version 3.0 include:
>> 
>> - Adding a reference in all related allocation and assignment policies to 
>> the new transfer policy document
>> - Clarification in the policy text and policy summary regarding transfers 
>> due to a change in the organisation???s business (such as a merger or 
>> acquisition)
> [..]
> 
> 
> first of all, my most sincere apologies for dragging my feet on this
> for such a long time (and special apologies to Erik Bais as the proposer,
> who is not known as a very patient man but showed extraordinary patience).
> 
> 
> Evaluating consensus on this was a bit complicated.
> 
> - there were a few clear voices of support for this fourth version
>   (but since this has been going on for a while, I'm inclined to 
>   consider supporting voices from the last rounds as "still supportive"
>   for this version)
> 
> - there was a fairly long discussion on whether M should be included
>   in this or not - my co-chair Sander Steffann got involved in that 
>   discussion, and thus completely abstained in judging the outcome.
>   Reading through it again, I consider the opposing argument to be
>   *addressed* - especially since these parts were included right from
>   version 1, have been openly communicated at multiple RIPE meetings,
>   and are not "something new and unexpected" in version 4 (Sascha 
>   Luck indeed did oppose this earlier on).
> 
> - there was even more discussion about items unrelated to the proposal
>   itself, more of a whishlist what other bits could be in there (like,
>   listing the broker in the transfer statistics) - changes that are
>   independent on this proposal, which for "normal" transfers does not
>   change policy, just reorganizes text.
> 
> 
> Thus, I declare that we have rough consensus - more rough than in many
> cases, but still rough consensus according to PDP.
> 
> With that, we move 2015-04 to Last Call.  Marco will send the formal 
> announcement for that in the next days.
> 
> For reference, a list of people that voiced support or opposition (or 
> something else) in the previous review phase is appended below.  This is
> what I have based my decision on.
> 
> If you disagree with my interpretation of what has been said and the
> conclusion I have drawn from it, please let us know.
> 
> Gert Doering,
>Address Policy WG Chair
> 
> 
> Review Phase for V4.0, starting September 07, 2016
> 
> 
> During the last Review Phase five persons stated their support for this latest
> version of 2015-04:
> 
> Tore Anderson
> Stefan van Westering
> Remco van Mook
> Havard Eidnes
> Riccardo Gori
> 
> The following people opposed the proposal with the argument that organisations
> should be allowed to transfer resources after they have freed them after a
> company merger and network consolidation process:
> 
> Plesa Niculae
> Ciprian Nica
> Marius Cristea
> Yuri NTX
> Palumbio Flavia
> Sascha Luck repeated his opposition that he don't want anything M related in
> the policy text.
> 
> Havard Eidnes, Radu Adrian and Sander Steffann tried to address this
> opposition by clarifying that the intention of this proposal is to prevent the
> abuse of the merger loophole. Also it was said that a 24 month holding period
> is not really business impacting as a network consolidation needs time anyhow
> and also IP resources could be transferred before the merger takes place in
> the registry. Sander also highlighted that freed 16-bit ASN can always be
> returned to the RIPE NCC if not longer needed.
> 
> There were some side threads, for example Ciprian Nica asking to list the
> broker in the transfer statistic and to remove the date from the allocation
> netname. Erik responded that this should be done in another proposal and that
> he is not taking this on board of his proposal.
> Marius Cristea said that RIPE NCC should not mandate LIRs to pay the full
> membership fee, should only follow policy and don't impose anything else -
> clarified by Sander Steffann that this is membership related and not regulated
> by RIPE policies.
> 
> Roger Jørgensen stated that is correct to use resources with policy limitation
> and not treat it as a normal asset without limitation 

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Gert Doering]

Dear Address Policy WG,

On Tue, Sep 27, 2016 at 03:08:32PM +0200, Marco Schmidt wrote:
> The draft documents for version 4.0 of the policy proposal 2015-04, "RIPE 
> Resource Transfer Policies" have now been published, along with an impact 
> analysis conducted by the RIPE NCC.
>
> The goal of this proposal is to create a single document with all relevant 
> information regarding the transfer of Internet number resources.
> 
> Some of the differences from version 3.0 include:
> 
> - Adding a reference in all related allocation and assignment policies to the 
> new transfer policy document
> - Clarification in the policy text and policy summary regarding transfers due 
> to a change in the organisation???s business (such as a merger or acquisition)
[..]


first of all, my most sincere apologies for dragging my feet on this
for such a long time (and special apologies to Erik Bais as the proposer,
who is not known as a very patient man but showed extraordinary patience).


Evaluating consensus on this was a bit complicated.

 - there were a few clear voices of support for this fourth version
   (but since this has been going on for a while, I'm inclined to 
   consider supporting voices from the last rounds as "still supportive"
   for this version)

 - there was a fairly long discussion on whether M should be included
   in this or not - my co-chair Sander Steffann got involved in that 
   discussion, and thus completely abstained in judging the outcome.
   Reading through it again, I consider the opposing argument to be
   *addressed* - especially since these parts were included right from
   version 1, have been openly communicated at multiple RIPE meetings,
   and are not "something new and unexpected" in version 4 (Sascha 
   Luck indeed did oppose this earlier on).

 - there was even more discussion about items unrelated to the proposal
   itself, more of a whishlist what other bits could be in there (like,
   listing the broker in the transfer statistics) - changes that are
   independent on this proposal, which for "normal" transfers does not
   change policy, just reorganizes text.


Thus, I declare that we have rough consensus - more rough than in many
cases, but still rough consensus according to PDP.

With that, we move 2015-04 to Last Call.  Marco will send the formal 
announcement for that in the next days.

For reference, a list of people that voiced support or opposition (or 
something else) in the previous review phase is appended below.  This is
what I have based my decision on.

If you disagree with my interpretation of what has been said and the
conclusion I have drawn from it, please let us know.

Gert Doering,
Address Policy WG Chair


Review Phase for V4.0, starting September 07, 2016


During the last Review Phase five persons stated their support for this latest
version of 2015-04:

Tore Anderson
Stefan van Westering
Remco van Mook
Havard Eidnes
Riccardo Gori

The following people opposed the proposal with the argument that organisations
should be allowed to transfer resources after they have freed them after a
company merger and network consolidation process:

Plesa Niculae
Ciprian Nica
Marius Cristea
Yuri NTX
Palumbio Flavia
Sascha Luck repeated his opposition that he don't want anything M related in
the policy text.

Havard Eidnes, Radu Adrian and Sander Steffann tried to address this
opposition by clarifying that the intention of this proposal is to prevent the
abuse of the merger loophole. Also it was said that a 24 month holding period
is not really business impacting as a network consolidation needs time anyhow
and also IP resources could be transferred before the merger takes place in
the registry. Sander also highlighted that freed 16-bit ASN can always be
returned to the RIPE NCC if not longer needed.

There were some side threads, for example Ciprian Nica asking to list the
broker in the transfer statistic and to remove the date from the allocation
netname. Erik responded that this should be done in another proposal and that
he is not taking this on board of his proposal.
Marius Cristea said that RIPE NCC should not mandate LIRs to pay the full
membership fee, should only follow policy and don't impose anything else -
clarified by Sander Steffann that this is membership related and not regulated
by RIPE policies.

Roger Jørgensen stated that is correct to use resources with policy limitation
and not treat it as a normal asset without limitation - he didn't stated a
clear support though.


-- 
have you enabled IPv6 on something today...?

SpaceNet AGVorstand: Sebastian v. Bomhard
Joseph-Dollinger-Bogen 14  Aufsichtsratsvors.: A. Grundner-Culemann
D-80807 Muenchen   HRB: 136055 (AG Muenchen)
Tel: +49 (0)89/32356-444   USt-IdNr.: DE813185279


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Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Riccardo Gori]

Hi all,

I want to withdrawn my neutral position on this policy saying I support 
2015-04 'cause my feeling is to support anything goes against 
speculation and not using last IP space to grow the internet.

thank you Erik for your work on it
kind regards
Riccardo


Il 24/10/2016 11:54, Riccardo Gori ha scritto:


Hi Erik,


Il 23/10/2016 18:06, Erik Bais ha scritto:

I’ll entertain your question here, although the question isn’t in relation to 
the policy proposal, but more about how transfers work ..

If a company splits… it is actually very simple … you setup a second LIR .. ( 
Provided that we are talking about RIPE PA space.. )  …

And you transfer the space out that needs to go to the business that is split 
off, to the new LIR …
The new entity / LIR would also receive a free /22 IPv4 and have the right to a 
/29 IPv6 and request an AS number, if they like, in the process …

And also get 2 free access tickets to the next RIPE meeting … and may send 
employees to a new LIR training.

In case you are talking about RIPE PI space .. it is even easier ..
You decide who the sponsoring LIR is going to be for the new entity.. ( the 
split off business.. ) Sign an End-User Agreement with the Sponsoring LIR of 
choice ..
Initiate a transfer to split the original prefix into multiple smaller 
prefixes.. and divide them between the 2 companies..

Send a signed Transfer agreement document and a copy of the End-User Agreement 
to the RIPE NCC or upload it through the portal …
The new entity doesn’t have any additional rights to an extra /22 or other 
stuff or free tickets or trainings.

Similar as with Legacy space .. only a Confirmation of Transfer to the RIPE NCC 
Service Region ( no RIPE NCC or Sponsoring LIR contract required even .. )

I’m not saying that there might be corner cases out there that one might bump 
into however I think that with all the different versions that we worked on, we 
addressed the ones that are common in normal business practices.

The policy proposal doesn’t limit companies from doing M’s …  and if you 
would read point 2.2, it clearly points that out in the text..

The text states :


Scarce resources, which are understood as those resources that are allocated or 
assigned by the RIPE NCC on a restricted basis (such as IPv4 or 16-bit ASNs),
cannot be transferred for 24 months from the date the resource was received by 
the resource holder.
This restriction also applies if the resource was received due to a change in 
the organisation’s business (such as a merger or acquisition).
This restriction does not prevent the resources from being transferred due to 
further mergers or acquisitions within the 24-month period.

So it doesn't prevent future M's .. as that is not possible to restrict and 
not the intention ...
The intention is to avoid speculation by hoarding and combining LIR's and 
transferring IP space out.


I wanted to see this stated in the summary proposal as a goal.
I confess this proposal see me almost neutral but what I don't like is 
that the summary proposal has as primary goal collect transfer 
policies in one document

 but we are mosltly discussing possibile abuses of M procedures.
This policy technically forces business process to take place (this 
makes this policy similar to 2016-03) as example to keep an LIR opened 
while the company has been acquired.
In my point of view is not a good idea to force business processes for 
reasons already expresses by others: future inconsistence of database, 
possible back market behind

and so on
Please consider me neutral today i have to think a little bit more 
about it and maybe need some chat with you.


Said this, text of 2015-04 is wonderfully clean now and is very clear. 
Thank you for you work Erik.

Now I need to go get the plane to get there ;-)
see you in Madrid.

regards
Riccardo

Regards,
Erik Bais

---


Van: address-policy-wg [mailto:address-policy-wg-boun...@ripe.net] Namens 
Ciprian Nica
Verzonden: zaterdag 22 oktober 2016 22:39
Aan: Radu-Adrian feurdeanripe-...@radu-adrian.feurdean.net  
CC: RIPE Address Policy WG List<address-policy-wg@ripe.net>

Onderwerp: Re: [address-policy-wg] 2015-04 New Version and Impact Analysis 
Published (RIPE Resource Transfer Policies)

That's a good point, what would happen when a business splits ?  I think there 
are many situations that need to be discussed and if we want to do something 
good we'd need to cover all situations. And yes, there is definitely the need 
for better policies in order for NCC to do exactly what the community wants and 
not leave room for interpretation.

Ciprian

On Sat, Oct 22, 2016 at 11:33 PM, Radu-Adrian 
FEURDEAN<ripe-...@radu-adrian.feurdean.net>  wrote:
On Fri, Oct 21, 2016, at 13:42, Sascha Luck [ml] wrote:


RIPE NCC recognises that and puts M firmly outside policy.
Where it should remain unless the desire is that every transfer
application or M notification start with filing suit against
the NCC.

On the other hand, si

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Havard Eidnes]

Hi,

just to prevent any remote possibility of misunderstanding, I
support this policy.

Regards,

- Håvard

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Remco van Mook]

I support this version of the policy proposal - all of my concerns I've voiced 
previously have been addressed.


Remco

> On 27 sep. 2016, at 15:08, Marco Schmidt  wrote:
> 
> Dear colleagues,
> 
> The draft documents for version 4.0 of the policy proposal 2015-04, "RIPE 
> Resource Transfer Policies" have now been published, along with an impact 
> analysis conducted by the RIPE NCC.
> 
> The goal of this proposal is to create a single document with all relevant 
> information regarding the transfer of Internet number resources.
> 
> Some of the differences from version 3.0 include:
> 
> - Adding a reference in all related allocation and assignment policies to the 
> new transfer policy document
> - Clarification in the policy text and policy summary regarding transfers due 
> to a change in the organisation’s business (such as a merger or acquisition)
> 
> You can find the full proposal and the impact analysis at:
> https://www.ripe.net/participate/policies/proposals/2015-04
> 
> And the draft documents at:
> https://www.ripe.net/participate/policies/proposals/2015-04/draft
> 
> We encourage you to read the draft document and send any comments to 
>  before 26 October 2016.
> 
> Regards
> 
> Marco Schmidt
> Policy Development Officer
> RIPE NCC
> 
> Sent via RIPE Forum -- https://www.ripe.net/participate/mail/forum
> 



signature.asc
Description: Message signed with OpenPGP using GPGMail

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Mike Burns]

Hi,

We have seen the "contact" method here at ARIN.
In the past we were able to meet the needs of our clients with a Letter of
Agency for ARIN.

Not sure if that would fly anymore, though.

What about a Letter of Agency at RIPE?

Regards,
Mike Burns



-Original Message-
From: address-policy-wg [mailto:address-policy-wg-boun...@ripe.net] On
Behalf Of Sander Steffann
Sent: Monday, October 24, 2016 1:37 PM
To: Ciprian Nica <off...@ip-broker.uk>
Cc: address-policy-wg@ripe.net Working Group <address-policy-wg@ripe.net>
Subject: Re: [address-policy-wg] 2015-04 New Version and Impact Analysis
Published (RIPE Resource Transfer Policies)

Hi,

> I'll be short as I'm assisting an interesting presentation ;)
> 
> What I meant is that it's not "right" to be a contact person for them
since I'm not the one making decisions. I'm an interface and I should be
able to represent, help, interact but I feel by not allowing this, we're
going too far with the "contact person" trick (solution).

Well, the NCC needs to know who is authoritative to speak for the customer.
If it's you then you are a contact, if not then the NCC can not talk to you
because you're not authoritative. In that case you will have to assist the
LIR from the sideline. You can't have both at the same time.

Cheers,
Sander

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Ciprian Nica]

I'll be short as I'm assisting an interesting presentation ;)

What I meant is that it's not "right" to be a contact person for them since
I'm not the one making decisions. I'm an interface and I should be able to
represent, help, interact but I feel by not allowing this, we're going too
far with the "contact person" trick (solution).

Ciprian

On Monday, October 24, 2016, Sander Steffann  wrote:

> Hi Ciprian,
>
> > Actually there were cases where we did like that, being put as a contact
> for the LIR. I don't think this should be the solution as it doesn't seem
> adequate at least. There were also cases where we would have to "speak" on
> behalf of both parties so it would be awkward if not unprofessional to be a
> contact person for both sides.
>
> This sentence does not parse. You have to speak on behalf of parties but
> you cannot be a contact person for them? That doesn't make sense. If you
> feel that is awkward or unprofessional to speak on behalf of both then
> don't. Get a separate broker that represents the other party. But in what
> you wrote above you contradict yourself.
>
> > From our experience the need is just to "translate" (figurative and not)
> the messages between NCC and LIRs. It is a situation we meet often and I
> think it should be addressed in a clear procedural way. I don't agree with
> using tricks.
>
> This is not a trick. If you can speak on behalf of an LIR then you are a
> contact and should be registered as such.
>
> Cheers,
> Sander
>
>

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Sander Steffann]

Hi Ciprian,

> Actually there were cases where we did like that, being put as a contact for 
> the LIR. I don't think this should be the solution as it doesn't seem 
> adequate at least. There were also cases where we would have to "speak" on 
> behalf of both parties so it would be awkward if not unprofessional to be a 
> contact person for both sides.

This sentence does not parse. You have to speak on behalf of parties but you 
cannot be a contact person for them? That doesn't make sense. If you feel that 
is awkward or unprofessional to speak on behalf of both then don't. Get a 
separate broker that represents the other party. But in what you wrote above 
you contradict yourself.

> From our experience the need is just to "translate" (figurative and not) the 
> messages between NCC and LIRs. It is a situation we meet often and I think it 
> should be addressed in a clear procedural way. I don't agree with using 
> tricks.

This is not a trick. If you can speak on behalf of an LIR then you are a 
contact and should be registered as such.

Cheers,
Sander



smime.p7s
Description: S/MIME cryptographic signature

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Ciprian Nica]

Hi,

Actually there were cases where we did like that, being put as a contact
for the LIR. I don't think this should be the solution as it doesn't seem
adequate at least. There were also cases where we would have to "speak" on
behalf of both parties so it would be awkward if not unprofessional to be a
contact person for both sides.

>From our experience the need is just to "translate" (figurative and not)
the messages between NCC and LIRs. It is a situation we meet often and I
think it should be addressed in a clear procedural way. I don't agree with
using tricks.

Ciprian


On Monday, October 24, 2016, Sander Steffann  wrote:

> Hi Ciprian,
>
> > There is, though, an important thing which I think the policy needs to
> address. The broker should be allowed to discuss with ripe on behalf of his
> customers. It has happened several times that we had customers who don't
> understand english very well and many times they would just ask us to write
> the reply and they would simply copy/paste it. It would help if ripe would
> allow us to directly pass on information and answer ripe's questions.
>
> Your customer can add you as an official contact in the LIR Portal if
> necessary. That is the way LIRs can define who is permitted to speak on
> their behalf. I have done that in the past: got added as a contact, handled
> the case for them, and then was removed as a contact again. I can imagine
> that not all LIRs are comfortable doing that, but in that case the
> communication should go through the LIRs existing contacts anyway.
>
> As there are already existing authorisation mechanisms for who can speak
> on behalf of an LIR I don't see the need to create a new one specifically
> for brokers.
>
> Cheers,
> Sander
>
>

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Carsten Schiefner]

Hi Sander,

On 24.10.2016 16:17, Sander Steffann wrote:
> Your customer can add you as an official contact in the LIR Portal if
> necessary. That is the way LIRs can define who is permitted to speak
> on their behalf. I have done that in the past: got added as a
> contact, handled the case for them, and then was removed as a contact
> again. I can imagine that not all LIRs are comfortable doing that,
> but in that case the communication should go through the LIRs
> existing contacts anyway.
> 
> As there are already existing authorisation mechanisms for who can
> speak on behalf of an LIR I don't see the need to create a new one
> specifically for brokers.

excellent idea! Gets rid of all that PoA stuff immediately. At times,
one just cannot see the wood for the all the trees... :-)

Best,

-C.

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Sander Steffann]

Hi Ciprian,

> There is, though, an important thing which I think the policy needs to 
> address. The broker should be allowed to discuss with ripe on behalf of his 
> customers. It has happened several times that we had customers who don't 
> understand english very well and many times they would just ask us to write 
> the reply and they would simply copy/paste it. It would help if ripe would 
> allow us to directly pass on information and answer ripe's questions.

Your customer can add you as an official contact in the LIR Portal if 
necessary. That is the way LIRs can define who is permitted to speak on their 
behalf. I have done that in the past: got added as a contact, handled the case 
for them, and then was removed as a contact again. I can imagine that not all 
LIRs are comfortable doing that, but in that case the communication should go 
through the LIRs existing contacts anyway. 

As there are already existing authorisation mechanisms for who can speak on 
behalf of an LIR I don't see the need to create a new one specifically for 
brokers.

Cheers,
Sander



smime.p7s
Description: S/MIME cryptographic signature

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Riccardo Gori]

Hi Erik,


Il 23/10/2016 18:06, Erik Bais ha scritto:

I’ll entertain your question here, although the question isn’t in relation to 
the policy proposal, but more about how transfers work ..

If a company splits… it is actually very simple … you setup a second LIR .. ( 
Provided that we are talking about RIPE PA space.. )  …

And you transfer the space out that needs to go to the business that is split 
off, to the new LIR …
The new entity / LIR would also receive a free /22 IPv4 and have the right to a 
/29 IPv6 and request an AS number, if they like, in the process …

And also get 2 free access tickets to the next RIPE meeting … and may send 
employees to a new LIR training.

In case you are talking about RIPE PI space .. it is even easier ..
You decide who the sponsoring LIR is going to be for the new entity.. ( the 
split off business.. ) Sign an End-User Agreement with the Sponsoring LIR of 
choice ..
Initiate a transfer to split the original prefix into multiple smaller 
prefixes.. and divide them between the 2 companies..

Send a signed Transfer agreement document and a copy of the End-User Agreement 
to the RIPE NCC or upload it through the portal …
The new entity doesn’t have any additional rights to an extra /22 or other 
stuff or free tickets or trainings.

Similar as with Legacy space .. only a Confirmation of Transfer to the RIPE NCC 
Service Region ( no RIPE NCC or Sponsoring LIR contract required even .. )

I’m not saying that there might be corner cases out there that one might bump 
into however I think that with all the different versions that we worked on, we 
addressed the ones that are common in normal business practices.

The policy proposal doesn’t limit companies from doing M’s …  and if you 
would read point 2.2, it clearly points that out in the text..

The text states :


Scarce resources, which are understood as those resources that are allocated or 
assigned by the RIPE NCC on a restricted basis (such as IPv4 or 16-bit ASNs),
cannot be transferred for 24 months from the date the resource was received by 
the resource holder.
This restriction also applies if the resource was received due to a change in 
the organisation’s business (such as a merger or acquisition).
This restriction does not prevent the resources from being transferred due to 
further mergers or acquisitions within the 24-month period.

So it doesn't prevent future M's .. as that is not possible to restrict and 
not the intention ...
The intention is to avoid speculation by hoarding and combining LIR's and 
transferring IP space out.


I wanted to see this stated in the summary proposal as a goal.
I confess this proposal see me almost neutral but what I don't like is 
that the summary proposal has as primary goal collect transfer policies 
in one document

 but we are mosltly discussing possibile abuses of M procedures.
This policy technically forces business process to take place (this 
makes this policy similar to 2016-03) as example to keep an LIR opened 
while the company has been acquired.
In my point of view is not a good idea to force business processes for 
reasons already expresses by others: future inconsistence of database, 
possible back market behind

and so on
Please consider me neutral today i have to think a little bit more about 
it and maybe need some chat with you.


Said this, text of 2015-04 is wonderfully clean now and is very clear. 
Thank you for you work Erik.

Now I need to go get the plane to get there ;-)
see you in Madrid.

regards
Riccardo


Regards,
Erik Bais

---


Van: address-policy-wg [mailto:address-policy-wg-boun...@ripe.net] Namens 
Ciprian Nica
Verzonden: zaterdag 22 oktober 2016 22:39
Aan: Radu-Adrian FEURDEAN ripe-...@radu-adrian.feurdean.net
CC: RIPE Address Policy WG List <address-policy-wg@ripe.net>
Onderwerp: Re: [address-policy-wg] 2015-04 New Version and Impact Analysis 
Published (RIPE Resource Transfer Policies)

That's a good point, what would happen when a business splits ?  I think there 
are many situations that need to be discussed and if we want to do something 
good we'd need to cover all situations. And yes, there is definitely the need 
for better policies in order for NCC to do exactly what the community wants and 
not leave room for interpretation.

Ciprian

On Sat, Oct 22, 2016 at 11:33 PM, Radu-Adrian FEURDEAN 
<ripe-...@radu-adrian.feurdean.net> wrote:
On Fri, Oct 21, 2016, at 13:42, Sascha Luck [ml] wrote:


RIPE NCC recognises that and puts M firmly outside policy.
Where it should remain unless the desire is that every transfer
application or M notification start with filing suit against
the NCC.

On the other hand, since RIPE NCC *DOES* allow multiple LIRs per single
legal entity, it would make some sense that the M procedure (the one
outside the policy scope) is limited to only changing the name of the
LIR.
Of course that would mean that all movements of  IP addresses between
LIRs, even those related to mergers, acquisition, r

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Ciprian Nica]

Hi,


On Monday, October 24, 2016, Carsten Schiefner 
wrote:

> Hi Ciprian -
>
> On 23.10.2016 16:39, Ciprian Nica wrote:
> > On Sunday, October 23, 2016, Erik Bais  
> > >> wrote:
> > When we made the parts that needed to be published in the transfer
> > statistics, that have crossed my mind, but I failed to see what the
> > benefit is for the community.
> >
> > The benefit would be that the community can make an idea about whether a
> > broker's info can be reliable or not. There are brokers that never
> > brokered a transaction.
>
> from this point of view, I could call myself a mathematician, a knitter,
> a carpenter, a plumber and a rocket scientist at the same time. It's
> just that I haven't yet carried out either one of their usual tasks and
> activities.
>
> The reality is: a broker that hasn't brokered any deal yet, is most
> likely not (yet) a broker, but for the time being just a wannabe-broker
> at best.
>
> Agree, and there are many of them.


> > I can understand from your point why you would ask this, but I'm not
> > going to take this suggestion in this policy.
> >
> > I am also a member of this community, besides being your competitor and
> > although you wouldn't like people to see that I've brokered the most
> > transfers, it's quite possible you would broker more transfers than me
> > in the future. We all do our jobs good and my proposal is not just
> > for advertising, I really think people would like to see it.
>
> I'd also love to get ad space for free from the RIPE NCC for my
> business, but won't and don't even want to. As such, e.g. real estate
> agents are not mentioned in the official land register either.
>
>
The free ad space is already there. There is a list of brokers on ripe
website.


> I do see, however, your point that people may want to background check
> their IP broker of potential choice: for this purpose I'd like to
> suggest the formation of an IP Broker association that would define
> quality definitions, measurements and such - as e.g. the above mentioned
> real estate agents have already given numerous good examples for.
>
>
I don't think that would be easy to achieve but it's a good idea.


> But please do not overload the NCC's tray here - I do fully agree with
> Erik in this regard.
>
>
 There is, though, an important thing which I think the policy needs to
address. The broker should be allowed to discuss with ripe on behalf of his
customers. It has happened several times that we had customers who don't
understand english very well and many times they would just ask us to write
the reply and they would simply copy/paste it. It would help if ripe would
allow us to directly pass on information and answer ripe's questions.

Ciprian

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Carsten Schiefner]

Hi Ciprian -

On 23.10.2016 16:39, Ciprian Nica wrote:
> On Sunday, October 23, 2016, Erik Bais  > wrote:
> When we made the parts that needed to be published in the transfer
> statistics, that have crossed my mind, but I failed to see what the
> benefit is for the community.
> 
> The benefit would be that the community can make an idea about whether a
> broker's info can be reliable or not. There are brokers that never
> brokered a transaction.

from this point of view, I could call myself a mathematician, a knitter,
a carpenter, a plumber and a rocket scientist at the same time. It's
just that I haven't yet carried out either one of their usual tasks and
activities.

The reality is: a broker that hasn't brokered any deal yet, is most
likely not (yet) a broker, but for the time being just a wannabe-broker
at best.

> I can understand from your point why you would ask this, but I'm not
> going to take this suggestion in this policy.
> 
> I am also a member of this community, besides being your competitor and
> although you wouldn't like people to see that I've brokered the most
> transfers, it's quite possible you would broker more transfers than me
> in the future. We all do our jobs good and my proposal is not just
> for advertising, I really think people would like to see it.

I'd also love to get ad space for free from the RIPE NCC for my
business, but won't and don't even want to. As such, e.g. real estate
agents are not mentioned in the official land register either.

I do see, however, your point that people may want to background check
their IP broker of potential choice: for this purpose I'd like to
suggest the formation of an IP Broker association that would define
quality definitions, measurements and such - as e.g. the above mentioned
real estate agents have already given numerous good examples for.

But please do not overload the NCC's tray here - I do fully agree with
Erik in this regard.

Best,

-C.

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Erik Bais]

I’ll entertain your question here, although the question isn’t in relation to 
the policy proposal, but more about how transfers work ..  

If a company splits… it is actually very simple … you setup a second LIR .. ( 
Provided that we are talking about RIPE PA space.. )  …  

And you transfer the space out that needs to go to the business that is split 
off, to the new LIR … 
The new entity / LIR would also receive a free /22 IPv4 and have the right to a 
/29 IPv6 and request an AS number, if they like, in the process … 

And also get 2 free access tickets to the next RIPE meeting … and may send 
employees to a new LIR training.  

In case you are talking about RIPE PI space .. it is even easier .. 
You decide who the sponsoring LIR is going to be for the new entity.. ( the 
split off business.. ) Sign an End-User Agreement with the Sponsoring LIR of 
choice .. 
Initiate a transfer to split the original prefix into multiple smaller 
prefixes.. and divide them between the 2 companies.. 

Send a signed Transfer agreement document and a copy of the End-User Agreement 
to the RIPE NCC or upload it through the portal …  
The new entity doesn’t have any additional rights to an extra /22 or other 
stuff or free tickets or trainings. 

Similar as with Legacy space .. only a Confirmation of Transfer to the RIPE NCC 
Service Region ( no RIPE NCC or Sponsoring LIR contract required even .. )  

I’m not saying that there might be corner cases out there that one might bump 
into however I think that with all the different versions that we worked on, we 
addressed the ones that are common in normal business practices. 

The policy proposal doesn’t limit companies from doing M’s …  and if you 
would read point 2.2, it clearly points that out in the text.. 

The text states : 

> Scarce resources, which are understood as those resources that are allocated 
> or assigned by the RIPE NCC on a restricted basis (such as IPv4 or 16-bit 
> ASNs), 
> cannot be transferred for 24 months from the date the resource was received 
> by the resource holder. 
> This restriction also applies if the resource was received due to a change in 
> the organisation’s business (such as a merger or acquisition).

> This restriction does not prevent the resources from being transferred due to 
> further mergers or acquisitions within the 24-month period.

So it doesn't prevent future M's .. as that is not possible to restrict and 
not the intention ... 
The intention is to avoid speculation by hoarding and combining LIR's and 
transferring IP space out.  

Regards, 
Erik Bais 

---


Van: address-policy-wg [mailto:address-policy-wg-boun...@ripe.net] Namens 
Ciprian Nica
Verzonden: zaterdag 22 oktober 2016 22:39
Aan: Radu-Adrian FEURDEAN ripe-...@radu-adrian.feurdean.net 
CC: RIPE Address Policy WG List <address-policy-wg@ripe.net>
Onderwerp: Re: [address-policy-wg] 2015-04 New Version and Impact Analysis 
Published (RIPE Resource Transfer Policies)

That's a good point, what would happen when a business splits ?  I think there 
are many situations that need to be discussed and if we want to do something 
good we'd need to cover all situations. And yes, there is definitely the need 
for better policies in order for NCC to do exactly what the community wants and 
not leave room for interpretation.

Ciprian

On Sat, Oct 22, 2016 at 11:33 PM, Radu-Adrian FEURDEAN 
<ripe-...@radu-adrian.feurdean.net> wrote:
On Fri, Oct 21, 2016, at 13:42, Sascha Luck [ml] wrote:

> RIPE NCC recognises that and puts M firmly outside policy.
> Where it should remain unless the desire is that every transfer
> application or M notification start with filing suit against
> the NCC.

On the other hand, since RIPE NCC *DOES* allow multiple LIRs per single
legal entity, it would make some sense that the M procedure (the one
outside the policy scope) is limited to only changing the name of the
LIR.
Of course that would mean that all movements of  IP addresses between
LIRs, even those related to mergers, acquisition, restructuring,
consolidation, . would fall under transfer policy. Could someone
detail what would be the problem in this case (except a limited amount
of money of up to 4200 EUR).
Unfortunately this is not where we are, and it doesn't look like it's
where is going.

As for RIPE NCC handling completely on its own the M process this is
exactly what allowed abuse to happen in the first place (and will still
do, even with 2015-01, 2015-04 and 2016-03). And how about a business
split - this doesn't feel like handled by the M procedure.

--
Radu-Adrian FEURDEAN

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Erik Bais]

Hi,

 

Feel free to adjust the policy in a new policy proposal, if you think it is 
vital for the future. 

 

As the author of this policy I’m not going to include it in this one. 

 

The transfer statistics isn’t a contest between brokers/facilitators or a place 
for advertising in my opinion. 

 

But don’t let my opinion on that keep you from writing your own policy 
proposal. 

 

Regards,

Erik Bais 

 

Van: address-policy-wg [mailto:address-policy-wg-boun...@ripe.net] Namens 
Ciprian Nica
Verzonden: zondag 23 oktober 2016 16:40
Aan: Erik Bais <eb...@a2b-internet.com>
CC: address-policy-wg@ripe.net
Onderwerp: Re: [address-policy-wg] 2015-04 New Version and Impact Analysis 
Published (RIPE Resource Transfer Policies)

 

Hi,



On Sunday, October 23, 2016, Erik Bais <eb...@a2b-internet.com 
<mailto:eb...@a2b-internet.com> > wrote:

Hi Ciprian,

> On Monday, October 17, 2016, Ciprian Nica <off...@ip-broker.uk <javascript:;> 
> > wrote:
> Hi,

> I think it would be useful to list on the statistics also the broker that 
> facilitated the transfer.

When we made the parts that needed to be published in the transfer statistics, 
that have crossed my mind, but I failed to see what the benefit is for the 
community.

 

The benefit would be that the community can make an idea about whether a 
broker's info can be reliable or not. There are brokers that never brokered a 
transaction.

 

I can understand from your point why you would ask this, but I'm not going to 
take this suggestion in this policy.

I am also a member of this community, besides being your competitor and 
although you wouldn't like people to see that I've brokered the most transfers, 
it's quite possible you would broker more transfers than me in the future. We 
all do our jobs good and my proposal is not just for advertising, I really 
think people would like to see it.

 

 

The transfers are between offering and receiving parties.. the facilitators are 
not a part in this process, except in the financial agreements.
Price is also not mentioned or what the BGP routing vendor is that is used for 
the new prefix..

I don't know about other brokers but I'm not getting my commission just for 
puttig 2 parties at the table. We are part of the process, we assist both 
seller and buyer and we follow every step of the transaction, although we're 
not allowed by NCC to communicate on behalf of our customers.

 

On the topic of the netname : if you want the netname to be changed, you can 
open a ticket with the Hostmaster during the transfer to make that happen. No 
need to put that in policy.



 

I think the idea would be to have this by default and not request it every 
time. I also think that at least the law enforcement agencies (from my past 
cooperation with them in the past) would benefit of this clarification.

 

Ciprian

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Erik Bais]

Hi Ciprian,  

 

The goal of the policy have been discussed on the list and in the RIPE meetings 
… so trying to de-rail the process this late in the game, while you were 
present at the other meetings by saying that it isn’t clear … it’s valid 
anymore.. 

 

Because as you may remember that was already addressed when it was brought up 
by Elvis 2 RIPE meetings ago .. and it was addressed at that point. 

 

Regards,

Erik Bais 

 

Van: address-policy-wg [mailto:address-policy-wg-boun...@ripe.net] Namens 
Ciprian Nica
Verzonden: woensdag 19 oktober 2016 19:10
Aan: address-policy-wg@ripe.net
Onderwerp: Re: [address-policy-wg] 2015-04 New Version and Impact Analysis 
Published (RIPE Resource Transfer Policies)

 

Regarding this policy I think it clearly states in the beginning: "The goal of 
this proposal is to create a single document with all relevant information 
regarding the transfer of Internet number resources." 

I congratulate Erik for it and I think it is very useful to have a single 
document that would address all situations. But we have to make it clear. Is 
2015-04's purpose just to better organise information or to change policies ? 

If you would have just done what the goal express I think it would have been 
the first policy that would not get only consensus but unanimity.

But when you slip in some changes, then it's a different thing. I agree that 
many things are not very clear and that there are things that can be improved. 
This however should be debated properly and maybe it should be done one step at 
a time through other policy proposals.

To resume, if you would change the policy text to stick to it's goal you'd have 
my +100 (as I see it's getting more popular these days than the classical +1) :)

But since this text brings changes I can only give a -1 for not sticking to the 
goal and for bringing changes that should be treated more careful, not just 
let's do it quickly however we can and we'll figure out on the way. Why not 
make good, permanent changes which are expected by many of the community.

Ciprian

 

 

 

On Wed, Oct 19, 2016 at 1:33 PM, Ciprian Nica <off...@ip-broker.uk 
<mailto:off...@ip-broker.uk> > wrote:

The policy states how the statistics are presented, therefore I think this 
issue should be addressed by the policy.

 

RIPE NCC implements the policies and if we, the RIPE community, want some 
things to be implemented in a certain way then the only way to "ask" it is 
through the policy, otherwise our voices have no value.

 

Regarding the lack of details at point B., that is in my opinion an insult to 
the community, regardless of what the policy is about. We should not accept 
generic statements like that. If nobody bothered to really make an impact 
analysis then just say it.

 

Ciprian



On Wednesday, October 19, 2016, Radu-Adrian FEURDEAN 
<ripe-...@radu-adrian.feurdean.net <mailto:ripe-...@radu-adrian.feurdean.net> > 
wrote:

Hi,

While I do agree with most of the concerns you present there, I'm
wondering if this is not an issue to be discussed in some other working
group (??? services ??? database ???). They don't seem to be related to
the policy itself, but to the way RIPE NCC implements it and reflects
the changes in the database.

Marco ? Chairs ? anybody else ?

--
Radu-Adrian FEURDEAN

On Wed, Oct 19, 2016, at 11:57, Ciprian Nica wrote:

> > Hi,
> >
> > I think it would be useful to list on the statistics also the broker that
> > facilitated the transfer. That might be of interest to the community and I
> > think the NCC should revise the transfer agreement template in order to be
> > able to mention the broker and also to publish it's name on the transfer
> > statistics page. Also the broker should be allowed to communicate with RIPE
> > and pass information on behalf of the customers during the transfer process.
> >
> > There is also a cosmetic thing that I don't know if it needs be mentioned
> > in policy in order to be implemented. The netname of the allocation keeps
> > the original allocation date in it's name which can be confusing although
> > there's the new "created" attribute.
> >
> > For example, the subnet 128.0.52.0/24 <http://128.0.52.0/24>  was 
> > transferred on 14/10/2016 and
> > it was part of an allocation with netname EU-JM-20120914. The new
> > allocation has netname ES-SISTEC-20120914.
> >
> > If the date is no longer relevant in a netname then I think it should be
> > simply ES-SISTEC, otherwise it can be ES-SISTEC-20161014
> >
> > Ciprian
> >
> >
> > On Tue, Sep 27, 2016 at 4:08 PM, Marco Schmidt <mschm...@ripe.net 
> > <mailto:mschm...@ripe.net%0b> 
> > <javascript:_e(%7B%7D,'cvml','mschm...@ripe.net');>> wrote:
> >
> >> Dear colleagues,
> >>
>

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Ciprian Nica]

That's a good point, what would happen when a business splits ?  I think
there are many situations that need to be discussed and if we want to do
something good we'd need to cover all situations. And yes, there is
definitely the need for better policies in order for NCC to do exactly what
the community wants and not leave room for interpretation.

Ciprian

On Sat, Oct 22, 2016 at 11:33 PM, Radu-Adrian FEURDEAN <
ripe-...@radu-adrian.feurdean.net> wrote:

> On Fri, Oct 21, 2016, at 13:42, Sascha Luck [ml] wrote:
>
> > RIPE NCC recognises that and puts M firmly outside policy.
> > Where it should remain unless the desire is that every transfer
> > application or M notification start with filing suit against
> > the NCC.
>
> On the other hand, since RIPE NCC *DOES* allow multiple LIRs per single
> legal entity, it would make some sense that the M procedure (the one
> outside the policy scope) is limited to only changing the name of the
> LIR.
> Of course that would mean that all movements of  IP addresses between
> LIRs, even those related to mergers, acquisition, restructuring,
> consolidation, . would fall under transfer policy. Could someone
> detail what would be the problem in this case (except a limited amount
> of money of up to 4200 EUR).
> Unfortunately this is not where we are, and it doesn't look like it's
> where is going.
>
> As for RIPE NCC handling completely on its own the M process this is
> exactly what allowed abuse to happen in the first place (and will still
> do, even with 2015-01, 2015-04 and 2016-03). And how about a business
> split - this doesn't feel like handled by the M procedure.
>
> --
> Radu-Adrian FEURDEAN
>
>

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Ciprian Nica]

On Fri, Oct 21, 2016 at 6:48 PM, Sander Steffann  wrote:

>
> > So it doesn't matter what the policy says it's scope is, it only matters
> what the chair decides we can discuss or not. Nice "democracy" we have ...
>
> Even in parliament you need a chairperson to keep the discussion on topic
> and to prevent people from hijacking it.
>

And hopefully that's what they do. Anyone who has read the policy can see
what it's goal is and that what I've said is just to stick to that goal. If
that's hijacking then you can call me Don Quijote.

Ciprian

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Ciprian Nica]

On Fri, Oct 21, 2016 at 6:05 PM, Sander Steffann  wrote:

> Hello Ciprian,
>
> > It is also beyond the scope of this policy regulating what can be done
> with resources and we're still discussing it. Let's stick to the policy's
> scope and start a new one with proper debates over this issue.
>
> Please leave it to the chairs to determine what is in scope for being
> discussed and what is not.
>
> So it doesn't matter what the policy says it's scope is, it only matters
what the chair decides we can discuss or not. Nice "democracy" we have ...

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Sander Steffann]

Hello Ciprian,

> It is also beyond the scope of this policy regulating what can be done with 
> resources and we're still discussing it. Let's stick to the policy's scope 
> and start a new one with proper debates over this issue.

Please leave it to the chairs to determine what is in scope for being discussed 
and what is not.

Cheers,
Sander



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Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Ciprian Nica]

On Fri, Oct 21, 2016 at 5:35 PM, Sander Steffann  wrote:

> Hi Sasha,
>
> > In market-based economies, M -including the disposal of
> > assets- are a matter for the parties involved and, occasionally, a state
> regulator, which the NCC is NOT.
> > It is unthinkable in such a society that business decisions are
> > subject to the whim of random people on a mailing list. The
> > RIPE NCC recognises that and puts M firmly outside policy.
>
> I think we need to look at the differences between regulating M, which
> is indeed far outside the scope of this working group, and defining policy
> about what can be done with resources after someone acquires them (M or
> otherwise) which is definitely in scope.
>
>
It is also beyond the scope of this policy regulating what can be done with
resources and we're still discussing it. Let's stick to the policy's scope
and start a new one with proper debates over this issue.

Ciprian

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Ciprian Nica]

Hi Sander,

I hoped you would understand the idea and not hang on details.

Yes, an integration process can take days, weeks, months or years. There
are cases when placing a 24 months hold would make no difference but in
most cases I think (based on the experience with previous acquisitions at
my previous employer) it would affect the business.

Can you agree with me that in most of the cases at least the AS number will
become unuseful and that would be probably a lot sooner than the 24 months ?

Getting back to the fundaments, I will never support any policy that says
"it's better to put everybody in jail even if some are innocent instead of
letting everybody free even some might be criminals". This is wrong and
should be debated properly. The policy's goal has nothing to do with
bringing changes to the rules.

NCC says the changes do not have a notable impact. Then don't make the
changes !

Ciprian

On Friday, October 21, 2016, Sander Steffann  wrote:

> Hi Ciprian,
>
> > As for the takeovers, it's not that I wouldn't get into details. My
> previous employer has acuired probably over 100 other companies. Every case
> was particular and some took years to integrate. You can not sell the IPs
> before integrating their network.
>
> So then what is the problem with the 24 month holding period? It sounds
> like it works exactly as designed: you can't sell addresses immediately,
> but there is no problem selling then after a multi-year integration project.
>
> Cheers,
> Sander
>

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Ciprian Nica]

Agree with Sascha. As with the Allocated PI, in this situation RIPE
community would like to impose some policies which are against the most
common business practices. It is not efficient as it can at any time be
attacked in any civilized justice system. Can anyone bring out some data on
the "huge" abuse that took/takes place ? Let's not stop a supposedly abuse
by adopting abusive policies.

Ciprian

On Friday, October 21, 2016, Sascha Luck [ml]  wrote:

> You would do well to take some lessons in debate culture
> yourself. You're -not even too veiledly- accusing another member
> of abuse, something we have heard altogether too much of lately.
>
> As for 2015-04, I oppose it as it tries yet again to bring M
> under policy regulation (s. 2.2) which the community has no
> business doing. Further, I am fundamentally opposed to the tactic
> of including the unpalatable with the desirable.  I would support
> 2015-04 if it restricted itself to collating transfer policy in
> one document without imposing further restrictions.
>
> rgds,
> Sascha Luck
>
> On Fri, Oct 21, 2016 at 12:45:01PM +0200, Havard Eidnes wrote:
>
>> What you say could be expressed (again it's a metaphor) like
>>> this:
>>>
>>
>> If you're interested in swaying the opinion in your favour you
>> would do well by avoiding arguing by using metaphors or colurful
>> paraphrasing, and instead argue the individual items you
>> apparently so very much disagree with.
>>
>> As for the takeovers, it's not that I wouldn't get into
>>> details. My previous employer has acuired probably over 100
>>> other companies. Every case was particular and some took years
>>> to integrate. You can not sell the IPs before integrating
>>> their network.
>>>
>>> In all the situations, even when we know there was an
>>> agreement for acquisition of company X, it wasn't absorbed
>>> overnight. The process is complex and involves approvals from
>>> various authorities, integration of the network, migration of
>>> customers and in the end you can draw the line and mark as
>>> unused the as number, IPs, computers, etc.
>>>
>>
>> You conveniently side-stepped answering the case I described.
>> Note that I wrote "*solely* for the purpose of of getting a
>> /22...".  In that case there would be no customers to move or
>> networks to merge.  I would say it is incumbent upon you to
>> justify that we should keep this loophole as wide as a truck in
>> the policy.
>>
>> The 24-month holding period puts a damper on this avenue of
>> abuse against the intention of the last /8 policy, and would put
>> a little bit more longevity into the availability of the
>> resources under that policy.  It may be that this diminishes
>> your company's prospects of near-future income, to which I would
>> say that basing your buisness on the abuse of something which is
>> perceived as a common resource is perhaps not worthy of so much
>> sympathy?
>>
>> Regards,
>>
>> - Håvard
>>
>>
>

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Ciprian Nica]

On Friday, October 21, 2016, Havard Eidnes  wrote:

> > What you say could be expressed (again it's a metaphor) like this:
>
> If you're interested in swaying the opinion in your favour you
> would do well by avoiding arguing by using metaphors or colurful
> paraphrasing, and instead argue the individual items you
> apparently so very much disagree with.
>
> I express my ideas the way I think and I don't give lessons to anyone.


> > As for the takeovers, it's not that I wouldn't get into details. My
> > previous employer has acuired probably over 100 other companies. Every
> case
> > was particular and some took years to integrate. You can not sell the IPs
> > before integrating their network.
> >
> > In all the situations, even when we know there was an agreement for
> > acquisition of company X, it wasn't absorbed overnight. The process is
> > complex and involves approvals from various authorities, integration of
> the
> > network, migration of customers and in the end you can draw the line and
> > mark as unused the as number, IPs, computers, etc.
>
> You conveniently side-stepped answering the case I described.  Note
> that I wrote "*solely* for the purpose of of getting a /22...".  In
> that case there would be no customers to move or networks to merge.  I
> would say it is incumbent upon you to justify that we should keep this
> loophole as wide as a truck in the policy.
>
> The 24-month holding period puts a damper on this avenue of abuse
> against the intention of the last /8 policy, and would put a little
> bit more longevity into the availability of the resources under that
> policy.  It may be that this diminishes your company's prospects of
> near-future income, to which I would say that basing your buisness on
> the abuse of something which is perceived as a common resource is
> perhaps not worthy of so much sympathy?
>
>
Again, unfunded personal attacks. Why do you have to analyze the person and
not the idea. Who gives you the right to accuse make such allegations and
what is the purpose of this ? Have I taken advantage of a loophole ? Just
let everyone know about it, like I did in regard to one of the chairs,
don't throw accusations just because you don't agree with me.



> Regards,
>
> - Håvard
>

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Sascha Luck [ml]]

On Fri, Oct 21, 2016 at 01:17:32PM +0200, Havard Eidnes wrote:

As for 2015-04, I oppose it as it tries yet again to bring M
under policy regulation (s. 2.2) which the community has no
business doing.


Please educate me why the community has no business doing this.
I would have thought that was well within scope for the address
policy.


In market-based economies, M -including the disposal of
assets- are a matter for the parties involved and, occasionally, 
a state regulator, which the NCC is NOT.

It is unthinkable in such a society that business decisions are
subject to the whim of random people on a mailing list. The
RIPE NCC recognises that and puts M firmly outside policy.
Where it should remain unless the desire is that every transfer
application or M notification start with filing suit against
the NCC.

rgds,
Sascha Luck

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Sascha Luck [ml]]

You would do well to take some lessons in debate culture
yourself. You're -not even too veiledly- accusing another member
of abuse, something we have heard altogether too much of lately.

As for 2015-04, I oppose it as it tries yet again to bring M
under policy regulation (s. 2.2) which the community has no
business doing. Further, I am fundamentally opposed to the tactic
of including the unpalatable with the desirable.  I would support
2015-04 if it restricted itself to collating transfer policy in
one document without imposing further restrictions.

rgds,
Sascha Luck

On Fri, Oct 21, 2016 at 12:45:01PM +0200, Havard Eidnes wrote:

What you say could be expressed (again it's a metaphor) like
this:


If you're interested in swaying the opinion in your favour you
would do well by avoiding arguing by using metaphors or colurful
paraphrasing, and instead argue the individual items you
apparently so very much disagree with.


As for the takeovers, it's not that I wouldn't get into
details. My previous employer has acuired probably over 100
other companies. Every case was particular and some took years
to integrate. You can not sell the IPs before integrating
their network.

In all the situations, even when we know there was an
agreement for acquisition of company X, it wasn't absorbed
overnight. The process is complex and involves approvals from
various authorities, integration of the network, migration of
customers and in the end you can draw the line and mark as
unused the as number, IPs, computers, etc.


You conveniently side-stepped answering the case I described.
Note that I wrote "*solely* for the purpose of of getting a
/22...".  In that case there would be no customers to move or
networks to merge.  I would say it is incumbent upon you to
justify that we should keep this loophole as wide as a truck in
the policy.

The 24-month holding period puts a damper on this avenue of
abuse against the intention of the last /8 policy, and would put
a little bit more longevity into the availability of the
resources under that policy.  It may be that this diminishes
your company's prospects of near-future income, to which I would
say that basing your buisness on the abuse of something which is
perceived as a common resource is perhaps not worthy of so much
sympathy?

Regards,

- H?vard

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Havard Eidnes]

> Since there were many discussions and yes, I've made the mistake to write
> in a different topic about the 2015-04, I want to state clearly that I
> oppose this policy.
>
> Again, if it would do what it's goal is, then it would be perfect. But it
> doesn't. It brings up important changes which are commented by people with
> no experience in mergers and acquisitions.
>
> While working for RCS I have seen many takovers and acquisitions and I
> know how the process goes. It's not always easy and definitely complicated.

This basically says "I know this process, you don't, I won't tell
you the details, instead trust me!"

I would say that I would completely understand if this doesn't
carry any weight with the majority of the participants here, and
is probably unlikely to sway opinion in your favour.

> Why do we need to put more stones in front of the wagon? An acquisition is
> not just signing a transfer agreement. For regular transfers it's ok to
> have a 24 months hold period, but asimilating a regular transfer with a
> company acquisition is wrong.  Buying a company needs to be documented with
> official, state issued, documents.  That is if I prove that I legally
> acquired a company, why would you think that it's something fishy and the
> purpose was to hide a simple transfer of IPs?  The two are nowhere near to
> be compared. The acquisition process takes time and money which represents
> already enough reasons not to mask a transfer this way.

My guess: because there is a widespread perception (right or wrong)
that the mergers and aquisitions procedure has been abused (in the
past?) to violate the intention of the "last /8" policy.  The ease
with which companies can be formed in some jurisdictions does not
provide what's seen as a sufficient push-back against abusing this
avenue of forming companies solely for the purpose of getting a /22
out of the last /8 with the (not so well hidden) intention of simply
merging this company with another once the resource has been issued,
and then transferring the resource out of the merged company.

Regards,

- Håvard

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Ciprian Nica]

Hi,

Since there were many discussions and yes, I've made the mistake to write
in a different topic about the 2015-04, I want to state clearly that I
oppose this policy.

Again, if it would do what it's goal is, then it would be perfect. But it
doesn't. It brings up important changes which are commented by people with
no experience in mergers and acquisitions.

While working for RCS I have seen many takovers and acquisitions and I
know how the process goes. It's not always easy and definitely complicated.
Why do we need to put more stones in front of the wagon ? An acquisition is
not just signing a transfer agreement. For regular transfers it's ok to
have a 24 months hold period, but asimilating a regular transfer with a
company acquisition is wrong.  Buying a company needs to be documented with
official, state issued, documents. That is if I prove that I legally
acquired a company, why would you think that it's something fishy and the
purpose was to hide a simple transfer of IPs ? The two are nowhere near to
be compared. The acquisition process takes time and money which represents
already enough reasons not to mask a transfer this way.

Ciprian






On Thu, Oct 20, 2016 at 11:37 PM, Stefan van Westering 
wrote:

> Hi,
>
> Just like the other proposal (2016-03) i support this proposal and thus:
> I say +1 for this proposal.
>
> Again if this is not the right place or need extra motivation to be noted,
> let me know.
>
> *With kind regards,*
>
>
>
> *Stefan van Westering*
>
>
>
> *SoftTech Automatisering B.V.*
>
>
>
> Op 19 okt. 2016 om 21:04 heeft Sander Steffann  het
> volgende geschreven:
>
> Hello Marius,
>
> Thank you for the explanations, but I believe you haven't really addressed
> the issues I mentioned.
>
> The first issue is ABOUT Transfer Policies, to pay the annual membership
> fee after you TRANSFER ALL YOUR RESOURCES and maybe even close your
> Company, is about Transfer Policies.
>
>
> No, that is about your contractual agreement with the RIPE NCC.
>
> Your second answer is very subjective, have you ever buy and merge
> Companies? I've done that a couple of times, you never sell the company's
> (you merge) resources before the merge, because that company doesn't belong
> to you before the merge and is not you to decide regarding selling anything
> of that Company resources, either that is IP or fiber optic cable. Is NOT
> AT ALL what you mention:"First acquiring them only to immediately sell them
> again is explicitly not allowed by RIPE policy". What this have to do with
> the situation I mention ??? Please refer to the situation I mention, not on
> other matters that have nothing to do with it.
>
>
> This is exactly the situation you mention: you buy a company, acquiring
> all their assets. One of those assets is an IPv4 allocation from RIPE NCC.
> To prevent speculation with IPv4 resources it is not allowed to sell those
> resources within 24 months of acquiring them.
>
> So in your case: buy the company, keep it running as a separate
> company/LIR for a little while, sort out where you want to transfer the
> resources you don't need, then merge the companies/LIRs.
>
> So, no problem.
> Sander
>
>

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Sander Steffann]

Hello Marius,

> Thank you for the explanations, but I believe you haven't really addressed 
> the issues I mentioned.
> The first issue is ABOUT Transfer Policies, to pay the annual membership fee 
> after you TRANSFER ALL YOUR RESOURCES and maybe even close your Company, is 
> about Transfer Policies.

No, that is about your contractual agreement with the RIPE NCC.

> Your second answer is very subjective, have you ever buy and merge Companies? 
> I've done that a couple of times, you never sell the company's (you merge) 
> resources before the merge, because that company doesn't belong to you before 
> the merge and is not you to decide regarding selling anything of that Company 
> resources, either that is IP or fiber optic cable. Is NOT AT ALL what you 
> mention:"First acquiring them only to immediately sell them again is 
> explicitly not allowed by RIPE policy". What this have to do with the 
> situation I mention ??? Please refer to the situation I mention, not on other 
> matters that have nothing to do with it.

This is exactly the situation you mention: you buy a company, acquiring all 
their assets. One of those assets is an IPv4 allocation from RIPE NCC. To 
prevent speculation with IPv4 resources it is not allowed to sell those 
resources within 24 months of acquiring them.

So in your case: buy the company, keep it running as a separate company/LIR for 
a little while, sort out where you want to transfer the resources you don't 
need, then merge the companies/LIRs.

So, no problem.
Sander



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Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Sander Steffann]

Hello Marius,

> Over the last years RIPE NCC has imposed a "rule" that when the last IPs are 
> transferred the transferring LIR has to pay the full annual membership fee 
> (even if the LIR was not a member of RIPE for that entire year). I think that 
> if this is something everybody agrees with, it should be inserted into the 
> policy text to make this very clear. But if not, then maybe it would be 
> useful to add a text which would simply say that RIPE NCC should relate 
> exclusively on this policy when processing transfer requests and is not 
> mandated by the RIPE community in imposing any kind of abusive taxes.

I'm sorry, but RIPE NCC membership related issues are off-topic for this 
working group. That includes calling the RIPE NCC membership fee structure 
"abusive taxes".

> I also have a problem with the 24 months period of keeping the IPv4 addresses 
> after merging 2 companies. It's exactly our case, we want to buy and merge 
> with a telecom company and we will no longer need all their IPv4 addresses 
> since we have more than enough by merging both companies resources. We want 
> to transfer a part of the IP addresses to other Company that really need 
> them. Why to wait 24 months?

Because the community decided that addresses can only be transferred is the 
intention is to actually use them, and to prevent companies from buying and 
selling address space just to make a profit. Your choices are to sell the 
resources before merging so they can be used by someone else who needs them, or 
keep them and use them yourself. First acquiring them only to immediately sell 
them again is explicitly not allowed by RIPE policy.

Cheers,
Sander



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Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Ciprian Nica]

I totally agree with the AS number situation. When I worked for RCS we
acquired many companies and although we kept some AS numbers, it really
makes no sense in putting a 24 months lock on them.

Ciprian

On Wednesday, October 19, 2016, Plesa Niculae  wrote:

> Dear colleagues,
>
> Regarding the [address-policy-wg] 2015-04 New Version and Impact Analysis
> Published (RIPE Resource Transfer Policies):
>
> The supposed purpose of the policy was to organise more efficiently, in a
> single document, the rules regarding transfer of resources but it brings a
> restriction which has not been properly analysed and debated. In my opinion
> there are many cases when two ISPs would merge. Due to the restructuring
> after the merger it is likely that the IPs could be used more efficiently
> and the resulting company would have spare resources that could be
> transferred like one of the AS numbers and maybe some IPs. If both
> companies have received the IPs and AS numbers many years ago, why should
> they not be able to transfer the resulting unused resources after the
> merger ? There is no logical point in that. Maybe there would not result
> some unused IPs but at least there is a 100% certainty that one of the AS
> numbers would become useless. This policy would force the company to keep
> it for 24 months just because they did a merger ? In today’s market it's
> quite common that smaller ISPs get acquired by larger ones and the policy
> would impose some restrictions which makes no sense.
>
> I have more observations regarding other non-sense and incorrect terms of
> the proposed policy, but first I really want to see if Marco, together with
> the RIPE team, really want to discuss and make modifications according the
> general good and common sense or everybody wants to pass this policy, like
> most of them, with no real answers to the problems raised. We will pass
> this policy in fanfare sounds, without any modifications, like the most of
> the past ones, or we will look seriously at members observations and change
> the policy accordingly?
>
> Best Regards
> Niculae Plesa
>
>
>
>

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Ciprian Nica]

In the published version at point "B. Impact of Policy on Registry and
Addressing System" it just states "After analysing the data that is
currently available, the RIPE NCC does not anticipate that any significant
impact will be caused if this proposal is implemented."

Is it possible that we would get details on that ? What data was analysed
and how was this conclusion reached ?

Ciprian

On Tuesday, September 27, 2016, Marco Schmidt  wrote:

> Dear colleagues,
>
> The draft documents for version 4.0 of the policy proposal 2015-04, "RIPE
> Resource Transfer Policies" have now been published, along with an impact
> analysis conducted by the RIPE NCC.
>
> The goal of this proposal is to create a single document with all relevant
> information regarding the transfer of Internet number resources.
>
> Some of the differences from version 3.0 include:
>
> - Adding a reference in all related allocation and assignment policies to
> the new transfer policy document
> - Clarification in the policy text and policy summary regarding transfers
> due to a change in the organisation’s business (such as a merger or
> acquisition)
>
> You can find the full proposal and the impact analysis at:
> https://www.ripe.net/participate/policies/proposals/2015-04
>
> And the draft documents at:
> https://www.ripe.net/participate/policies/proposals/2015-04/draft
>
> We encourage you to read the draft document and send any comments to <
> address-policy-wg@ripe.net > before 26 October 2016.
>
> Regards
>
> Marco Schmidt
> Policy Development Officer
> RIPE NCC
>
> Sent via RIPE Forum -- https://www.ripe.net/participate/mail/forum
>
>

Re: [address-policy-wg] 2015-04 New Version and Impact Analysis Published (RIPE Resource Transfer Policies)

[Erik Bais]

Hi,  

I would like to ask you to also read the 4th version of the RIPE Resource 
Transfer Policies and ... provide you feedback (even if that is only a +1 ) on 
the list ...  

This phase ends 26 October 2016 (right in the middle of the RIPE73 meeting in 
Madrid )  ... 

> You can find the full proposal and the impact analysis at:
> https://www.ripe.net/participate/policies/proposals/2015-04 

I'm looking forward to see you all in Madrid.  

Regards,
Erik Bais