ARIN-PPML Message

[arin-ppml] Draft Policy 2011-11: Clarify Justified Need for Transfers

Draft Policy ARIN-2011-11
Clarify Justified Need for Transfers


On 18 August 2011 the ARIN Advisory Council (AC) selected "Clarify 
Justified Need for Transfers" as a  draft policy for adoption discussion 
on the PPML and at the Public Policy Meeting in Philadelphia in October.

The draft was developed by the AC from policy proposal "ARIN-prop-146 
Clarify Justified Need for Transfers." Per the Policy Development 
Process the AC submitted text to ARIN for a staff and legal assessment 
prior to its selection as a draft policy. Below the draft policy is the 
ARIN staff and legal assessment, followed by the text that was submitted 
by the AC.

Draft Policy ARIN-2011-11 is below and can be found at:
https://www.arin.net/policy/proposals/2011_11.html

You are encouraged to discuss Draft Policy 2011-11 on the PPML prior to
the October Public Policy Meeting. Both the discussion on the list and
at the meeting will be used by the ARIN Advisory Council to determine
the community consensus for adopting this as policy.

The ARIN Policy Development Process can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Member Services
American Registry for Internet Numbers (ARIN)


## * ##

Draft Policy ARIN-2011-11
Clarify Justified Need for Transfers

Date: 24 August 2011

Policy statement:

Add to Section 8.3:

"...they can justify under current ARIN policies
showing how the addresses will be utilized within 12 months."

Remove from 4.2.4.4:

"This reduction does not apply to resources
received via section 8.3. An organization receiving a transfer under
section 8.3 may continue to request up to a 12-month supply of IP
addresses."

Rationale:

An organization which is not able to obtain its initial IPv4 address
assignment from ARIN post-runout would otherwise be limited to
purchasing only a 3-month supply (because the language in 4.2.4.4
regarding 8.3 transfers is not triggered).

An organization which has only recently received its first allocation
under the "last /8" criteria is also otherwise limited to purchasing
only a 3-month supply (because the language in 4.2.4.4 is again not
applicable).

There is also ambiguity if 4.2.2.1.3 is applied in that a transfer to
a new organization might only need to show need for a /20 (because that
is what is specifically called out) even though they are receiving a
much larger block.

Previous version of this proposal modified Section 8 to point at 4.2.4,
rather than the shorter and clearer modification to 8.3 now proposed.

There is also ambiguity with regard to transfers under 8.2 where the
receiving organization is a new organization... not at all clear how
"justified need" has been or should be determined, however this proposal
no longer addresses this.

Timetable for implementation: immediate


#####


ARIN STAFF ASSESSMENT

Proposal:  ARIN-prop-146 Clarify Justified Need for Transfers
Date of Assessment: 18 August 2011

1.  Proposal Summary (Staff Understanding)

This proposal would modify existing NRPM policy 8.3 to specifically 
state that all organizations can justify a 12 month supply of IPv4 
addresses.

Currently, the only reference to a timeframe for 8.3 transfers is 
contained in NRPM 4.2.2.4, Subscriber Members After One Year, which says 
that 8.3 transfers are exempt from the 3 month supply limitation that 
all other ISPs who are requesting additional IPv4 space must adhere to - 
“An organization receiving a transfer under section 8.3 may continue to 
request up to a 12-month supply of IP addresses.” This proposal would 
remove this reference and instead, add the 12 month language to the 
proper section of NRPM.


2.  Comments

A. ARIN Staff Comments
•	This proposal would still require an organization requesting an 8.3 
transfer to qualify for the space under current ARIN policies, but would 
exempt them from the 3 month supply limitations currently set forth in 
NRPM 4.2.1.4 “Slow Start” and 4.2.2.1.3 “Three Months” and instead allow 
them to qualify for a 12 month supply of IPv4 address space.
•	If this became policy, it would align well with NRPM 8.2 (Transfers 
due to M&A) since the staff uses a 12 month utilization window when 
analyzing these types of transfer requests.


B. ARIN General Counsel

This policy presents no significant legal issues.

3. Resource Impact

This policy would have minimal resource impact from an implementation 
aspect.  It is estimated that implementation would occur within 3 months 
after ratification by the ARIN Board of Trustees. The following would be 
needed in order to implement:

•	Updated guidelines
•	Staff training

4. Proposal Text

ARIN-prop-146
Clarify Justified Need for Transfers

Policy statement:

Add to Section 8.3 "...they can justify under current ARIN policies
showing how the addresses will be utilized within 12 months."

Remove from 4.2.4.4: "This reduction does not apply to resources
received via section 8.3. An organization receiving a transfer under
section 8.3 may continue to request up to a 12-month supply of IP
addresses."


Rationale:

An organization which is not able to obtain its initial IPv4 address
assignment from ARIN post-runout would otherwise be limited to
purchasing only a 3-month supply (because the language in 4.2.4.4
regarding 8.3 transfers is not triggered).

An organization which has only recently received its first allocation
under the "last /8" criteria is also otherwise limited to purchasing
only a 3-month supply (because the language in 4.2.4.4 is again not
applicable).

There is also ambiguity if 4.2.2.1.3 is applied in that a transfer to
a new organization might only need to show need for a /20 (because that
is what is specifically called out) even though they are receiving a
much larger block.

Previous version of this proposal modified Section 8 to point at 4.2.4,
rather than the shorter and clearer modification to 8.3 now proposed.

There is also ambiguity with regard to transfers under 8.2 where the
receiving organization is a new organization... not at all clear how
"justified need" has been or should be determined, however this proposal
no longer addresses this.

Timetable for implementation: immediate