[arin-ppml] Draft Policy ARIN-2015-6: Transfers and Multi-national Networks - revised

[ARIN]

On 1 September 2015 the ARIN Advisory Council revised 2015-6. Below you 
will find the the updated ARIN staff assessment.

ARIN-2015-5 is below and can be found at:
https://www.arin.net/policy/proposals/2015_5.html

Regards,

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


## * ##


ARIN STAFF & LEGAL ASSESSMENT
Draft Policy ARIN-2015-6
TRANSFERS AND MULTI-NATIONAL NETWORKS

Date of Assessment: 15 September 2015

___
1. Summary (Staff Understanding)

This proposal states that when evaluating transfer requests, ARIN will 
not consider the geographic location where an organization is utilizing, 
or will utilize, its ARIN-registered addresses if that organization, its 
parent, or a subsidiary are able to satisfy each of the four stated 
criteria.

___
2. Comments

A. ARIN Staff Comments

• During the course of a transfer request, staff will consider and 
review the utilization of any block issued by ARIN to that organization, 
regardless of whether that address space is being used outside of the 
ARIN region.
• This policy enables organizations to qualify as a recipient for 8.3 or 
8.4 transfers in the ARIN region when they might not have otherwise been 
able to do so. ARIN staff would now be able to consider their global 
utilization, instead of only their in-ARIN region use.
• One of the elements ARIN staff uses to determine 24-month need for an 
organization is their historical utilization rate. This proposal allows 
organizations to justify a larger 24-month needs based qualification, 
because staff will consider their utilization globally instead of just 
what was used inside the ARIN region.
• This would be placed in a new section of the NRPM called "8.5 
Additional Transfer Policies".
• This policy could be implemented as written.

B. ARIN General Counsel – Legal Assessment

No material legal issues. If the policy is enacted it will require ARIN 
staff to work with counsel with some attendant increase in costs in the 
first year to manage implementation.

___
3. Resource Impact

 From a request review standpoint, implementation of this policy would 
have minimal resource impact. However, it could have future staffing 
implications based on the amount of additional work the policy could 
present. It is estimated that implementation could occur within 3 months 
after ratification by the ARIN Board of Trustees. The following would be 
needed in order to implement:

* Updated guidelines and internal procedures
* Staff training

Implementation of this policy may allow for registrations in the ARIN 
database that require unicode character sets. From an engineering 
standpoint, implementation of this policy could have a major resource 
impact. It is estimated that implementation would occur within 12 
months, instead of the 3 months cited above, after ratification by the 
ARIN Board of Trustees if ARIN is required to support unicode character 
sets. The following would be needed in order to implement:

* Engineering: Engineering efforts to handle out of region business 
rules may be substantial as our system only supports ascii now. If there 
is a need for unicode character sets, then there is a substantial amount 
of work required to upgrade the DB and applications to support unicode. 
Additionally, we would need to discuss how to display unicode characters 
in port 43 whois.

___
4. Proposal / Draft Policy Text Assessed

Draft Policy ARIN-2015-6

Problem statement:

Some organizations within the ARIN region are currently unable to 
receive IPv4 space via transfer based on current ARIN policy, which 
prohibits address space used outside of the ARIN region from being 
considered efficiently utilized. This proposal would allow organizations 
with a strong and long-standing presence in the ARIN region to be able 
to receive number resources via transfer for their global operations.

Policy statement:

When evaluating transfer requests, ARIN will not consider the geographic 
location where an organization is utilizing, or will utilize, its 
ARIN-registered addresses if that organization, its parent, or a subsidiary:

1. has been an ARIN customer for at least 36 months; AND
2. is currently in good standing with ARIN; AND
3. is currently using IPv4 or IPv6 addresses in the ARIN region; AND
4. can demonstrate it has a meaningful business that operates in the 
ARIN region.



On 9/1/15 1:01 PM, ARIN wrote:
> ARIN-2015-6 has been revised.
>
> You are encouraged to discuss the merits and your concerns of Draft
> Policy 2015-6 on the Public Policy Mailing List.
>
> The AC will evaluate the discussion in order to assess the conformance
> of this draft policy with ARIN's Principles of Internet Number Resource
> Policy as stated in the PDP. Specifically, these principles are:
>
>     * Enabling Fair and Impartial Number Resource Administration
>     * Technically Sound
>     * Supported by the Community
>
> ARIN-2015-6 is below and can be found at:
> https://www.arin.net/policy/proposals/2015_6.html
>
> Regards,
>
> Communications and Member Services
> American Registry for Internet Numbers (ARIN)
>
>
> ## * ##
>
>
> Draft Policy ARIN-2015-6
> Transfers and Multi-national Networks
>
> Date: 25 August 2015
>
> Problem statement:
>
> Some organizations within the ARIN region are currently unable to
> receive IPv4 space via transfer based on current ARIN policy, which
> prohibits address space used outside of the ARIN region from being
> considered efficiently utilized. This proposal would allow organizations
> with a strong and long-standing presence in the ARIN region to be able
> to receive number resources via transfer for their global operations.
>
> Policy statement:
>
> When evaluating transfer requests, ARIN will not consider the geographic
> location where an organization is utilizing, or will utilize, its
> ARIN-registered addresses if that organization, its parent, or a
> subsidiary:
>
> 1. has been an ARIN customer for at least 36 months; AND
>
> 2. is currently in good standing with ARIN; AND
>
> 3. is currently using IPv4 or IPv6 addresses in the ARIN region; AND
>
> 4. can demonstrate it has a meaningful business that operates in the
> ARIN region.
>
> Comments:
>
> Timetable for implementation: Immediate
>
> #####
>
> ARIN STAFF & LEGAL ASSESSMENT
>
> Draft Policy ARIN-2015-6
> TRANSFERS AND MULTI-NATIONAL NETWORKS
> https://www.arin.net/policy/proposals/2015_6.html
>
> Date of Assessment: 18 August 2015
>
> ___
> 1. Summary (Staff Understanding)
>
> This proposal states that when evaluating transfer requests, ARIN will
> not consider the geographic location where an organization is utilizing
> its ARIN-registered addresses if that organization, its parent, or a
> subsidiary are able to satisfy each of the four stated criteria.
>
> ___
> 2. Comments
>
> A. ARIN Staff Comments
>
> •During the course of a transfer request, staff will consider and review
> the utilization of any block issued by ARIN to that organization,
> regardless of whether that address space is being used outside of the
> ARIN region.
> •This policy enables organizations to qualify as a recipient for 8.3 or
> 8.4 transfers in the ARIN region when they might not have otherwise been
> able to do so. ARIN staff would now be able to consider their global
> utilization, instead of only their in-ARIN region use.
> •One of the elements ARIN staff uses to determine 24-month need for an
> organization is their historical utilization rate. This proposal allows
> organizations to justify a larger 24-month needs based qualification,
> because staff will consider their utilization globally instead of just
> what was used inside the ARIN region.
> •The policy proposal text appears to not align with the intent of the
> policy as described in the problem statement. This proposal changes how
> ARIN considers prior utilization of IPv4 address space, but does not
> specify that newly received resources can be used outside of the region.
> Existing policy and practice would dictate ARIN continues to issue space
> for use in the ARIN region. We note that 2015-5, if adopted, could
> change this.
> •This would be placed in a new section of the NRPM called "8.5
> Additional Transfer Policies".
> •This policy could be implemented as written.
>
> B. ARIN General Counsel – Legal Assessment
>
> No material legal issues. If the policy is enacted it will require ARIN
> staff to work with counsel with some attendant increase in costs in the
> first year to manage implementation.
>
> ___
> 3. Resource Impact
> This policy would have minimal resource impact from an implementation
> aspect. However, it could have future staffing implications based on the
> amount of additional work the policy could present. 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 and internal procedures
> * Staff training
>
> ___
> 4. Proposal / Draft Policy Text Assessed
>
> Draft Policy ARIN-2015-6
>
> Date: 23 June 2015
>
> Problem statement:
> Some organizations within the ARIN region are currently unable to
> receive IPv4 space via transfer based on current ARIN policy, which
> prohibits address space used outside of the ARIN region from being
> considered efficiently utilized. This proposal would allow organizations
> with a strong and long-standing presence in the ARIN region to be able
> to receive number resources via transfer for their global operations.
> Policy statement:
> When evaluating transfer requests, ARIN will not consider the geographic
> location where an organization is utilizing its ARIN-registered
> addresses if that organization, its parent, or a subsidiary:
> 1. has been an ARIN customer for at least 36 months; AND
> 2. is currently in good standing with ARIN; AND
> 3. is currently using IPv4 or IPv6 addresses in the ARIN region; AND
> 4. can demonstrate it has a meaningful business that operates in the
> ARIN region.
>