Re: [sig-policy] Timeline for implementing the transfer proposal

  • To: MAEMURA Akinori <maem at nic dot ad dot jp>
  • Subject: Re: [sig-policy] Timeline for implementing the transfer proposal
  • From: Terry Manderson <terry at terrym dot net>
  • Date: Wed, 25 Feb 2009 11:19:42 +1000
  • Cc: APNIC Policy SIG <sig-policy at apnic dot net>
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  • Sender: Terry Manderson <terry.mndrsn@gmail.com>
    • Hi Akinori,
      
      On 24/02/2009, at 7:14 PM, MAEMURA Akinori wrote:
      
      
      That is actually one of the concerns we have regarding this
      proposal.
      
      Izumi has been sharing opinions of JP Community here on the
      sig-policy mailing list - it's JPNIC's commitment to JP
      Community to cascade it to AP Community.  On the other hand,
      JPNIC is an NIR who needs to provide IP address management
      
      as a service, and might have a different idea from those of
      ISPs, and this is the case here now.
      
      
      
      
      Please take care when suggesting that the NIR (or RIRs for that matter) need to provide any service. Certainly they do provide a valuable service, but that service is for the convenience of your members and the address administration function as it grew internationally and beyond the then (1990) central system. (RFC1174)
      
      
      Please also consider that the country based aspect of the NIR wasn't a part of the RIR architecture initially and evolved to cope with the language and cultural diversity of the region. As we know (RFC1174) that the system was to be region focused.
      
      
      My point is that while you (JPNIC) exist as a channel for the collective JP community I don't feel it appropriate that JPNIC assert its own position contrary to that of its members.
      
      
      I feel that Izumi has done a brilliant job in presenting the needs of the JP community, which I believe satisfies the constructs of bottom- up policy making, and the responsibility of JPNIC.
      
      
      
      1)
      We agree that some measure must be taken to prevent confusion
      in database which inevitably disrupts uniqueness of IP address,
      and see the transfer mechanism will help address this problem
      to a certain extent.
      
      
      Then again, if we implement this proposed policy at this stage
      when the problem is not substantial, it may create more problems
      than the solutions it intends to provide.
      
      
      
      I think I would prefer to see issues in an insubstantial problem, and deal with those as they eventuate then having problems when the situation is truly substantial and the ramifications much larger.
      
      
      
      
      One things is that it may lead to encouraging the transfer rather
      than documenting what's actually happening.
      
      
      
      If encouraging IPv4 transfers aides in the development of the internet globally then I see that as a step forward.
      
      
      2)
      Another issue that concerns us is there isn't any mechanism to
      protect ISPs in ensuring fair and trustable transfers to take
      place.
      
      We do recognize and understand the proposer's claim that
      issues regarding such a mechanism on transfer markets are
      outside the scope of this proposal and the policy forum, but
      we think this still remains as an issue regardless of where
      it should be considered.
      
      We'd therefore like to make following suggestions to help us move
      forward in addresssing the remaining issues.
      
      * If APNIC doesn't have the expertise, it should at least make
        necessary liasison with experts, or
      * keep the community well informed that they should work the
        expertise within their economies, etc.
      * If APNIC considers none of these actions are necessary,
        provide an analysis of how transfers can work without taking
        such measures
      
      
      
      
      I think this is a brilliant suggestion and given the reason that the NIRs were formed, I think that in the above points you should replace "APNIC" with "APNIC and every NIR". Further, this work should be in parallel and non-blocking on the policy front.
      
      
      I don't think APNIC can be expected to know when and where fairness and trust exists within the constraints of your own laws, customs, and governmental frameworks and which international treaties and agreements stand for your members. Within the space of the policy I believe this should not hamper the policy through the policy life- cycle but add a level of work for each of the parties to investigate and provide suitable advise and, where appropriate, instruction that your members may follow to protect themselves, and in the same space indemnify your own organisation.
      
      
      
      
      
      3)
      It is not yet very clear if an Internet Registry can provide
      the transfer mechanism without any harm on its operation.
      A trade might not be always safe and faithful, but sometimes
      be with a blunder or of malice, resulting in a significnat
      loss in either party.  In such a case, an Internet Registry
      might be sued or claimed for indeminification.  Such a
      situation should be avoided by a reinforced disclaimer,
      robust and minute process of transfer registration, et cetra.
      
      
      
      
      Unfortunately we live in a litigious world. I would suggest that you make any necessary contractual changes or organisational changes that negates the potential for harm.
      
      
      
      4)
      I am afraid to say, although this proposal has had a good degree
      of support within AP and JP Communities, in the reasons such
      as above JPNIC cannot support this proposal until it is clear
      that there is a concrete plan that remaining issues will be
      addressed in an appropriate manner.   JPNIC is quite happy to
      contribute in such a preparation/consideration/examination in
      planning.
      
      
      
      Thanks for bringing JPNIC's organisation concerns forward. While I am empathetic to your concerns for the organisation I believe your role is to facilitate the interests of your community. Perhaps JPNIC should partner with the other NIRs and RIRs to create a task force geared to address the potential issues as they arise from the implementation of the policy, in parallel to the policy implementation.
      
      Cheers
      Terry