Hello,

I firmly oppose this policy proposal for the following reasons :

* Interference with routing

I always understood RIPE NCC must not consider routing issues as
legitimate (when justificating address space requests was a thing), the
counterpart could be implicit.

De-agregating a /22 is legitimate in many cases, especially when it's
your only available block. Restricting route objects or RPKI will lead
to *weaken routing's security* and *reduce the registry's quality*.

It would also make it impossible to mitigate BGP hijacking if a
legitimate announce cannot counter a more specific illegitimate one.

* Not concise enough

The proposal actually means "Every /8 PA is now a PI". Such policy
should be written in its simpliest form, which in this case is an 8
words sentence.

* Not adressing the multi-LIR issue

If such proposal AND the re-authorization of multiple LIR account per
member both gets to pass, it would almost feel legitimate to create
multiple LIRs in order to be allowed to secure our networks by
de-agregating some critical prefixes off it.

Encouraging the waste of address space seems incompatible with the
community's best interests.

* Unclear non-transferability

There are two kinds of possible transfers :

- The legitimate one is Mergure and Acquisition, which reflects real
network and business events.
- The crook's one is the listing service, used to get profits off
privatizing the public domain.

Only the second one should be banned, or mergure and acquisitions won't
be properly reflected into the registry.

* Unfairness to new entrants

The issue regarding new entrants with legitimate needs for more than a
/22 beeing unable to compete against incubents, who never had to justify
their dispendious tendancies regarding ERXs and over /16 PAs, could be
considered as unlawfull to some market authorities.



Considering these 4 major points (and the pedantic one), I would hope
for immediate dismissal of the proposal.


Best regards,


-- 
Jérôme Nicolle
+33 6 19 31 27 14

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