[arin-ppml] LAST CALL for Recommended Draft Policy ARIN-2015-11: Remove transfer language which only applied pre-exhaustion of IPv4 pool

[ARIN]

The ARIN Advisory Council (AC) met on 18 February 2016 and decided to
send the following to last call:

   Recommended Draft Policy ARIN-2015-11: Remove transfer language which 
only applied pre-exhaustion of IPv4 pool

Feedback is encouraged during the last call period. All comments should
be provided to the Public Policy Mailing List. This last call will
expire on 9 March 2016. 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)


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Recommended Draft Policy ARIN-2015-11
Remove transfer language which only applied pre-exhaustion of IPv4 pool

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

ARIN 2015-11 contributes to fair and impartial number resource 
administration by removing from the NRPM text that has become 
inoperative since the depletion of the IPv4 free pool in September 2015, 
thereby avoiding confusion among people applying for 8.3 or 8.4 
transfers. This proposal is technically sound, in that the removal of 
the text in question does not create any contradictions or loopholes in 
the application of policies that still matter. The proposal was 
supported by some community members on PPML and at the ARIN meeting in 
Montreal, and did not generate any opposition.

Problem Statement:

The current policies in NRPM sections 8.3, and 8.4 include language 
which is in effect "until exhaustion." As ARIN is no longer able to 
fulfil IPv4 requests (per 01 July 2015 press release 
https://www.arin.net/about_us/media/releases/20150701.html), exhaustion 
has effectively occurred. This proposal serves to remove the outdated 
language from the NRPM.

Policy statement:

Remove sections of the NRPM which were only affective until IPv4 pool 
exhaustion occurred, as follows:

Section 8.3 Transfers between Specified Recipients within the ARIN Region:
- Remove entirely the second bullet which reads "The source entity will 
be ineligible 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."

Section 8.4 Inter-RIR Transfers to Specified Recipients:
- Remove entirely the third bullet which reads "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."

Comments:
Timetable for implementation: Immediate

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ARIN STAFF & LEGAL ASSESSMENT

Draft Policy ARIN-2015-11
REMOVE TRANSFER LANGUAGE WHICH ONLY APPLIED PRE-EXHAUSTION OF IPV4 POOL


Date of Assessment: 22 October 2015

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1. Summary (Staff Understanding)

This proposal calls for the removal of language in 8.3 and 8.4 of NRPM 
that sets a condition on the amount of time that must pass before the 
source of an 8.3 or 8.4 transfer may request additional IPv4 address 
space as a recipient.

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2. Comments

A. ARIN Staff Comments

* Since ARIN staff considers the depletion of the IPv4 address space as 
a single, one-time, event that has already occurred on September 24, 
2015, the subject language no longer applies to new IPv4 recipient 
requests going forward. As of September 24, 2015, ARIN staff no longer 
applies a 12-month lock-out to organizations requesting to receive IPv4 
who have previously been the source of an IPv4 allocation/assignment 
through an 8.3 or 8.4 transfer.

* ARIN staff considers the removal of policy language to have no effect 
on processing of requests; it appears to be purely removal of 
inoperative policy text.

* ARIN staff notes that both 8.3 and 8.4 have language that prevents 
organizations from being a source in an approved 8.3 or 8.4 transfer if 
they have been a recipient of IPv4 address space in the 12 months prior, 
and this language is presently operative and would remain so even if the 
proposal change is made.

* This policy could be implemented as written.

B. ARIN General Counsel – Legal Assessment

No material legal issues.

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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 and internal procedures
* Staff training