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[arin-ppml] ARIN-2011-1: ARIN Inter-RIR Transfers - Revised Assessment

Below is a revised staff and legal assessment for 2011-1: ARIN Inter-RIR 
Transfers.

The draft policy text is below and available at:
https://www.arin.net/policy/proposals/2011_1.html

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)


##*##


ARIN STAFF ASSESSMENT 2011-1 (Revised)

Draft Policy:  2011-1 ARIN Inter-RIR Transfers

Date of Assessment:  9 Nov 2011

1.  Proposal Summary (Staff Understanding)

This revised proposal directly modifies section 8.3 "Transfers to 
Specified Recipients" to allow specified transfers to or from 
organizations in other regions, and it eliminates the single aggregate 
language.

2. Comments

_A.    ARIN Staff Comments_

·The phrase, "compatible, needs-based policies" is not specifically 
defined. If adopted, staff would consider a "compatible, needs-based 
policy" for outward transfers as a transfer policy at another RIR that 
requires the recipient to have operational need for the address space, 
and to demonstrate that need to their RIR for transfer approval.

·Allowing the transfer of number resources between RIRs will require 
careful coordination between RIRs in order to avoid reverse DNS zone 
fragmentation and synchronization problems.The ability to maintain the 
necessary coordination between RIRs is unproven if Inter-RIR transfers 
become extremely common.

·This proposal doesn't have any provisions to preclude organizations 
that have recently obtained IPv4 resources from ARIN from immediately 
releasing them for profit to a specified recipient. This policy may 
provide incentive for organizations to game the system by obtaining 
resources based on justified need, when the real intent is to sell them 
for profit. This behavior would directly violate certain terms and 
conditions of the RSA, but may be difficult for staff to distinguish 
from bona fide changes in circumstances.

·General Staff Implementation Plan:

*For transfers from the ARIN region into another RIR region:*

1.ARIN receives the transfer request template from the requestor and 
verifies that they are the authorized registrant of the resources.

2.ARIN verifies that the recipient RIR has been confirmed to have a 
compatible needs-based transfer policy and then forwards the request to 
the recipient RIR.

3.The Recipient RIR determines if the recipient meets its relevant 
policies.

4.The Recipient RIR confirms to ARIN that the customer has met its 
transfer policy as a recipient, and asks ARIN to authorize the release 
of the resource to the recipient RIR.

5.ARIN coordinates with the Recipient RIR to complete the transfer.

*For transfers into the ARIN region from another RIR region:*

1.ARIN receives the transfer request template from the source RIR 
verifying that their customer is authorized to submit the transfer.

2.ARIN contacts the proposed resource recipient to gather initial data 
needed to justify the 8.3 transfer and obtains a signed RSA from the 
resource recipient.

3.ARIN applies its relevant policy criteria to the resource recipient

4.When ready to approve, ARIN will contact the source RIR and have them 
authorize the release of the resource to ARIN.

5.ARIN approves the transfer, receives transfer fee payment from the 
recipient, and will then complete the request by coordinating with the 
source RIR on the final transfer of the resource into the ARIN database 
(and de-registration from the source database), including the DNS zone 
coordination.

_B.ARIN General Counsel Comments_

Adoption of this policy will materially assist ARIN's legal position.

3.Resource Impact

This policy would have major**resource impact from an implementation 
aspect.  It is estimated that implementation would occur within 9-12 
months after ratification by the ARIN Board of Trustees. The following 
would be needed in order to implement:

-Careful coordination between the RIRs on DNS issues and updates

-Updated guidelines

-Staff training

4.Draft Policy 2011-1 Text

8.3 Transfers to Specified Recipients

In addition to transfers under section 8.2, IPv4 number resources may 
be?released to ARIN by the authorized resource holder or another RIR, 
in?whole or in part, for transfer to another specified 
organizational?recipient. Organizations in the ARIN region may receive 
transferred?number resources under RSA if they can demonstrate the need 
for such?resources in the amount which they can justify under current 
ARIN policies.

IPv4 address resources may be transferred to organizations in 
another?RIR's service region if they demonstrate need to their region's 
RIR,?according to that RIR's policies. Inter-regional transfers may 
take?place only via RIRs who agree to the transfer and share 
compatible,?needs-based policies. Such resources must be transferred in 
blocks of?/24 or larger and will become part of the resource holdings of 
the?recipient RIR.

Timetable for implementation: Upon ratification by the ARIN Board of 
Trustees

Note from the AC:

The Advisory Council reviewed the results of feedback from the 
ARIN?XXVIII Public Policy Meeting concerning Draft Policy 2011-1 
Inter-RIR?Transfers. While there were concerns regarding the presented 
wording,?there was significant continued support for a policy 
enabling?Inter-Regional transfers of IPv4 number resources from 
organizations able?to make them available to any organization with valid 
requirements.

In addition to cumbersome wording, the presented text could not 
be?cleanly inserted into the NRPM. The following is new language 
that?directly modifies section 8.3 "Transfers to Specified Recipients" 
to?allow such transfers to or from organizations in other regions.

The first paragraph is a modified version of the current 8.3 
policy?language, envisioning resources being released to ARIN by the 
authorized?resources holder or additionally by another RIR to be 
transferred to a?specified recipient. The second sentence was 
reorganized to emphasize?that it applies to an organization within the 
ARIN region that will?receive such a specified transfer, and to 
eliminate the single aggregate?language per 2011-10 which is also being 
sent to last call.

The new second paragraph adds language enabling transfers to a 
specified?recipient in another RIR's service region. This language 
specifies that?such recipients justify their need to their RIR, 
following that RIR's?policies. ARIN will verify that there is a 
compatible needs based?policy that the other RIR will use to evaluate 
the need of the recipient?and that both RIR's agree to the transfer. 
Implicit in the intent of?the language presented and in conformance with 
statements made, the size?of the block to be transferred is identified 
as /24 or larger, for?obvious practical reasons.

In accordance with concern for immediate adoption, the AC chose 
to?forward this version to last call. Concerns expressed by 
some?stakeholders for further controls were noted by the AC, and are 
being?considered for future policy modification, assuaged in part by 
ARIN?staff assurances that if any significant abuse of this policy were 
to?occur, then the policy could easily be suspended.




On 10/19/11 3:11 PM, ARIN wrote:
> The ARIN Advisory Council (AC) met on 14 October 2011 and decided to
> send an amended version of the following draft policy to an extended 
> last call:
>
>   ARIN-2011-1: ARIN Inter-RIR Transfers
>
> The AC provided the following statement:
>
> ********
> The Advisory Council reviewed the results of feedback from the ARIN
> XXVIII Public Policy Meeting concerning Draft Policy 2011-1 Inter-RIR
> Transfers.  While there were concerns regarding the presented wording,
> there was significant continued support for a policy enabling
> Inter-Regional transfers of IPv4 number resources from organizations 
> able to make them available to any organization with valid requirements.
>
> In addition to cumbersome wording, the presented text could not be
> cleanly inserted into the NRPM.  The following is new language that
> directly modifies section 8.3 "Transfers to Specified Recipients" to
> allow such transfers to or from organizations in other regions.
>
> The first paragraph is a modified version of the current 8.3 policy
> language, envisioning resources being released to ARIN by the authorized
> resources holder or additionally by another RIR to be transferred to a
> specified recipient.  The second sentence was reorganized to emphasize
> that it applies to an organization within the ARIN region that will
> receive such a specified transfer, and to eliminate the single aggregate
> language per 2011-10 which is also being sent to last call.
>
> The new second paragraph adds language enabling transfers to a specified
> recipient in another RIR's service region.  This language specifies that
> such recipients justify their need to their RIR, following that RIR's
> policies.  ARIN will verify that there is a compatible needs based
> policy that the other RIR will use to evaluate the need of the recipient
> and that both RIR's agree to the transfer. Implicit in the intent of
> the language presented and in conformance with statements made, the size
> of the block to be transferred is identified as /24 or larger, for
> obvious practical reasons.
>
> In accordance with concern for immediate adoption, the AC chose to
> forward this version to last call.  Concerns expressed by some
> stakeholders for further controls were noted by the AC, and are being
> considered for future policy modification, assuaged in part by ARIN
> staff assurances that if any significant abuse of this policy were to
> occur, then the policy could easily be suspended.
>
> The AC thanks everyone in the community for their help in crafting this
> important policy and for your statements of support or other comments
> during Last Call.
> ********
>
> Feedback is encouraged during the last call period. All comments should
> be provided to the Public Policy Mailing List. Last call for 2011-1 will
> expire on 16 November 2011. After last call the AC will conduct their 
> last call review.
>
> The draft policy text is below and available at:
> https://www.arin.net/policy/proposals/
>
> The ARIN Policy Development Process is available at:
> https://www.arin.net/policy/pdp.html
>
> Regards,
>
> Communications and Member Services
> American Registry for Internet Numbers (ARIN)
>
>
> ## * ##
>
>
> Draft Policy ARIN-2011-1
> ARIN Inter-RIR Transfers
>
> Date/version: 14 October 2011
>
> Policy statement:
>
> 8.3 Transfers to Specified Recipients
>
> In addition to transfers under section 8.2, IPv4 number resources may be
> released to ARIN by the authorized resource holder or another RIR, in
> whole or in part, for transfer to another specified organizational
> recipient.  Organizations in the ARIN region may receive transferred
> number resources under RSA if they can demonstrate the need for such
> resources in the amount which they can justify under current ARIN 
> policies.
>
> IPv4 address resources may be transferred to organizations in another
> RIR's service region if they demonstrate need to their region's RIR,
> according to that RIR's policies. Inter-regional transfers may take
> place only via RIRs who agree to the transfer and share compatible,
> needs-based policies. Such resources must be transferred in blocks of
> /24 or larger and will become part of the resource holdings of the
> recipient RIR.
>
> Timetable for implementation: immediate


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