[arin-ppml] Recommended Draft Policy 2013-1: Section 8.4 Inter-RIR Transfers of ASNs

[ARIN]

Recommended Draft Policy ARIN-2013-1
Section 8.4 Inter-RIR Transfers of ASNs

On 21 March 2012 the ARIN Advisory Council (AC) recommended ARIN-2013-1 
for adoption, making it a Recommended Draft Policy. ARIN-2013-1 will be 
presented at ARIN 31, and will be eligible for last call afterward.

Draft Policy ARIN-2013-1 is below and can be found at:
https://www.arin.net/policy/proposals/2013_1.html

You are encouraged to discuss Draft Policy 2013-1 on the PPML prior to
the upcoming Public Policy Consultation. 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,

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


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Recommended Draft Policy ARIN-2013-1
Section 8.4 Inter-RIR Transfers of ASNs

Date: 26 Mar 2013

AC's assessment of conformance with the Principles of Internet Number 
Resource Policy:

Draft policy 2013-1 enables fair and impartial resource administration, 
supporting the goals of efficient utilization and accurate registration, 
by allowing for the inter-RIR transfer of ASN resources under the same 
guidelines already allowed for within-ARIN ASN transfers and inter-RIR 
IPv4 number resource transfers. Discussion to date has identified 
moderate support for the proposal. Most opposition to date has centered 
on the argument that the proposal is unnecessary, but the AC shepherds 
believe that it is worthwhile to allow transfers of ASNs, to help insure 
that idle resources are both recovered and utilized efficiently and 
where needed, and to allow the registry to be updated to reflect who is 
actually using which ASNs.

Policy statement:

Modify the following text in Section 8.4

Add "or ASNs to be transferred, as" to the first bullet point under 
Conditions on source of the transfer, so that it reads:

"The source entity must be the current rights holder of the IPv4 address 
resources or ASNs to be transferred, as recognized by the RIR 
responsible for the resources, and not be involved in any dispute as to 
the status of those resources."

Change "IPv4 number resources" to "IPv4 number resources or ASNs", so 
that the fourth bullet point reads:

"Source entities within the ARIN region must not have received a 
transfer, allocation, or assignment of that same resource type (IPv4 
number resource or ASN) from ARIN for the 12 months prior to the 
approval of a transfer request. This restriction does not include M&A 
transfers."

Rationale:

We already allow transfer of ASNs within the ARIN region. The change 
will accomplish two things. First there is inconsistent language in 8.4 
eg "IPv4 Address" v. "IPv4 Number Resource(s)" and second, it will allow 
the transfer of ASNs between RIRs through 8.4 and using the standards we 
have already established for IPv4 transfers. For many of the same 
reasons that we allow transfer of IP addresses, we should allow 
transfers of ASNs and to help insure that idle resources are both 
recovered and utilized efficiently and where needed, and to allow the 
registry to be updated to reflect who is actually using which ASNs.

This version clarifies that the 12-month restriction on having received 
a transfer, allocation, or assignment applies separately to IPv4 number 
resources and ASNs.

Timetable for implementation: Immediately


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ARIN Staff and Legal Assessment

ARIN Staff Assessment
ARIN-2013-1 “Section 8.4 Inter-RIR Transfers of ASNs”
Date of Assessment: 19 Mar 2013

1.	Summary (Staff Understanding)
This proposal would allow the transfer of ASNs along with IPv4 address 
space in an 8.4 Inter-RIR transfer and applies all of the same criteria 
currently listed for IPv4 to ASNs.

2. Comments
A.	ARIN Staff Comments

The policy text reads:  "Source entities within the ARIN region must not 
have received a transfer, allocation, or assignment of IPv4 number 
resources or ASNs from ARIN for the 12 months prior to the approval of a 
transfer request."

   • As worded, the policy will prevent a party who has received a 
transfer, allocation, or assignment of either an IPv4 block or an ASN 
from transferring either one for a period of 12 months.  In other words, 
if an organization receives an ASN in the previous 12 months, this 
policy text would prevent them from transferring their IPv4 addresses 
via an 8.4 transfer.  Was that the intent of the proposal?

   • If that is not the intent, we would suggest revising the text to 
read something like this:

"Source entities within the ARIN region must not have received a 
transfer, allocation, or assignment of that same resource type (IPv4 
number resource or ASN) from ARIN for the 12 months prior to the 
approval of a transfer request."

B.	ARIN General Counsel - Legal Assessment
This proposal poses 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:
  A. Updated guidelines
  B. Staff training

Proposal Text:

ARIN-2013-1: Section 8.4 Inter-RIR Transfers of ASNs

Date: 8 March 2013

Policy statement:

Modify the following text in Section 8.4

Add "or ASNs to be transferred, as" to the first bullet point under 
Conditions on source of the transfer, so that it reads:
"The source entity must be the current rights holder of the IPv4 address 
resources or ASNs to be transferred, as recognized by the RIR 
responsible for the resources, and not be involved in any dispute as to 
the status of those resources."

Change "IPv4 number resources" to "IPv4 number resources or ASNs", so 
that the fourth bullet point reads:
"Source entities within the ARIN region must not have received a 
transfer, allocation, or assignment of IPv4 number resources or ASNs 
from ARIN for the 12 months prior to the approval of a transfer request. 
This restriction does not include M&A transfers."

Rationale:

We already allow transfer of ASNs within the ARIN region. The change 
will accomplish two things. First there is inconsistent language in 8.4 
eg "IPv4 Address" v. "IPv4 Number Resource(s)" and second, it will allow 
the transfer of ASNs between RIRs through 8.4 and using the standards we 
have already established for IPv4 transfers. For many of the same 
reasons that we allow transfer of IP addresses, we should allow 
transfers of ASNs and to help insure that idle resources are both 
recovered and utilized efficiently and where needed, and to allow the 
registry to be updated to reflect who is actually using which ASNs.
This version changes the title, clarifies the resulting policy language 
slightly, and explicitly includes the resulting policy language in the 
policy statement.