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 <email@example.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.