[arin-ppml] New Language Proposed for Draft Policy 2014-2 Improving 8.4 Anti-Flip Language

[Bill Darte]

Thank you to everyone who has thus far provided input on this draft policy.

Per feedback from the community and the AC on improving Inter-RIR transfer
language found in section 8.4 of the ARIN NRPM, We are now focusing on the
3rd of three alternative suggestions (see all three far below).

Please review the suggested change below and comment indicating your
position for or against the change.  Given sufficient support for this
proposed language, the next step in the Policy Development Process is for
the Draft to be reviewed by staff and legal on its way to becoming a
Recommended Draft and presentation at the upcoming PPM in Chicago.

Thanks,
Bill Darte
Policy Shepherd for 2014-2

NEW PROPOSED POLICY LANGUAGE...the first sentence of the fourth bullet in
quotes immediately below is the only change from current policy)
8.4. Inter-RIR Transfers to Specified Recipients

Inter-regional transfers may take place only via RIRs who agree to the
transfer and share reciprocal, compatible, needs-based policies.

Conditions on source of the transfer:

   - The source entity must be the current rights holder of the IPv4
   address resources recognized by the RIR responsible for the resources, and
   not be involved in any dispute as to the status of those resources.
   - Source entities outside of the ARIN region must meet any requirements
   defined by the RIR where the source entity holds the registration.
   - Source entities within the ARIN region will not be eligible to receive
   any further IPv4 address allocations or assignments from ARIN for a period
   of 12 months after a transfer approval, or until the exhaustion of ARIN's
   IPv4 space, whichever occurs first.
   - *"Source entities within the ARIN region may not transfer a block or
   portion of a block received within the past 12 months."*  This
   restriction does not include M&A transfers.
   - The minimum transfer size is a /24.

Conditions on recipient of the transfer:

   - The conditions on a recipient outside of the ARIN region will be
   defined by the policies of the receiving RIR.
   - Recipients within the ARIN region will be subject to current ARIN
   policies and sign an RSA for the resources being received.
   - Recipients within the ARIN region must demonstrate the need for up to
   a 24-month supply of IPv4 address space.
   - The minimum transfer size is a /24.


<<<<<<<<Original three alternatives were primarily discussed and I wish to
elicit feedback from the community relative to each.>>>>>>>>

1. Use the existing last sentence as is and ask ARIN staff to be
particularly watchful for seeming abuse and to bring such back to the
community through regular Policy Experience Reports.  There was discussion
about this option suggesting that by the time abuse was recognized and
reported, and given limited existing free pool stocks and the extended
policy development cycle....this option may be moot.

2. Remove the clause 'and its subsidiaries' or modify it in such a way as
to mitigate the risk of a laundering of addresses through fraudulent
transfers, but this may still potentially limit the utility to
organizations who may have complex organizational structures in use
internationally.

3. Take an alternative tack and simply restrict transfers on a per-block
rather than a per-organization basis. e.g. 'No block acquired within the
past 24 months would be eligible for transfer.' (The time frame is of
course an arbitrary number at this point.)
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