Dear Collegues!
Looking at the impact analysis, the proposal and reviewing the arguments
- i would like to agree with this proposal.
In the best case scenario it may improve the accuracy of database
entries. I also belive it will aid the goals of the registry because
this way the usage of inetnums can be documented more clearly.
Kind Regards
On 12/13/23 19:14, Jeroen Lauwers wrote:
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
<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
<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
<https://www.ripe.net/ripe/mail/archives/address-policy-wg/2023-November/013892.html>
[4] https://www.law.cornell.edu/wex/void_for_vagueness
<https://www.law.cornell.edu/wex/void_for_vagueness>
[5]
https://www.ripe.net/manage-ips-and-asns/db/support/documentation/terms
<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
<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
<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 <[email protected]>
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 [email protected]
before 20 December 2023.
Kind regards,
Angela Dall'Ara
Policy Officer
RIPE NCC
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