[arin-ppml] LAST CALL for Recommended Draft Policy ARIN-2016-5: Post-IPv4-Free-Pool-Depletion Transfer Policy

[Alexander, Daniel]

Owen,

It would be helpful to clarify why you feel one is a superior alternative
to another beyond just stating so.

Unless my PPML searches are incorrect, the numbers don't support your
assertion that 2016-3 has a higher level of community support.

2016-3 had four people post to PPML with one in favor and one against. The
one in favor being you. The PPM show of hands in Dallas, of 122
participants there were 27 for and one against the question to continue
work on the draft.

2016-5 had eight people post to PPML with two in favor and one against.
The one against being you. The PPM show of hands in Dallas, of 123
participants there were 33 in favor and 6 against this proposal moving
forward. 

I encourage everyone to help the AC with comments to consider during this
last call period. 

Thanks,
-Dan

On 10/27/16, 1:36 AM, "arin-ppml-bounces at arin.net on behalf of Owen
DeLong" <arin-ppml-bounces at arin.net on behalf of owen at delong.com> wrote:

>Speaking strictly for myself and not in my role as a member of the AC..
>
>I remain strongly opposed to this proposal. While it is further along in
>the process, I believe that 2016-3 represents a vastly superior
>alternative with a higher level of community support.
>
>Speaking as a member of the AC, but not for the AC, I believe it would be
>valuable to the AC to get significant community feedback as to any
>preference between the two proposals.
>
>Owen
>
>> On Oct 26, 2016, at 14:16 , ARIN <info at arin.net> wrote:
>> 
>> The ARIN Advisory Council (AC) met on 21 October 2016 and decided to
>>send Recommended Draft Policy ARIN-2016-5: Post-IPv4-Free-Pool-Depletion
>>Transfer Policy to Last Call:
>> 
>> The AC provided the following statement to the community:
>> 
>> This proposal is technically sound, fair, and impartial in that it
>>establishes a new set of qualifying criteria for 8.3 and 8.4 transfers
>>applicable to all requests. It is strongly supported by the community.
>> 
>> 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 November 2016. After Last Call, the AC will conduct their
>>Last Call review.
>> 
>> The full 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)
>> 
>> 
>> 
>> Recommended Draft Policy ARIN-2016-5: Post-IPv4-Free-Pool-Depletion
>>Transfer Policy
>> 
>> AC's assessment of conformance with the Principles of Internet Number
>>Resource Policy:
>> 
>> 2016-5 is one of a set of overlapping policies involving simplification
>>of section 8 specified transfer policy. Each takes a somewhat different
>>approach, and all have a degree of community support. Based on community
>>feedback at the upcoming ARIN 38 meeting in Dallas, we hope to advance
>>whichever of those proposals is best-supported by the community, or
>>craft and advance a unified proposal that incorporates the best
>>attributes of the proposals currently on the docket. Moving 2016-5 to
>>Recommended Draft will facilitate moving the best policy forward in a
>>timely manner.
>> 
>> Problem Statement:
>> 
>> Section 4 of the Number Policy Resource Manual was developed over the
>>past 15+ years primarily to conservatively manage the IPv4 number free
>>pool. Since the IPv4 free pool was depleted in 2015, the policies which
>>developed since ARIN¹s inception may now not be as relevant now that the
>>primary function of the registry, with regard to IPv4 numbers, is to
>>record transfers.
>> 
>> Since section 4 of the NRPM now contains many use cases that are not as
>>relevant, it makes sense to streamline the transfer process and to
>>specifically outline the criteria that should be used to process
>>transfers.
>> 
>> Therefore, we propose the following rewrite of the transfer policy,
>>section 8 of the NRPM.
>> 
>> The goals of this rewrite are as follows:
>> 
>> - Separate the criteria that is found in section 4 of the NRPM from the
>>transfer process.
>> - Provide a clear set of criteria that should be applied across all
>>IPv4 transfers.
>> - Lower the thresholds on utilization and future allocation size to
>>negate the necessity of the corner cases which are currently enumerated
>>in section 4 of the NRPM.
>> - Reduce the complexity that is currently required for transfers, by
>>applying simpler utilization criteria for current usage, and future
>>allocation sizing.
>> 
>> Policy statement:
>> 
>> Add new section 8.5; update sections 8.2-8.4 as follows to reference
>>8.5.
>> 
>> 8.2. Mergers, Acquisitions, and Reorganizations
>> 
>> ARIN will consider requests for the transfer of number resources in the
>>case of mergers, acquisitions, and reorganizations under the following
>>conditions:
>> 
>> - The current registrant must not be involved in any dispute as to the
>>status of the resources to be transferred.
>> - The new entity must sign an RSA covering all resources to be
>>transferred.
>> - The resources to be transferred will be subject to ARIN policies.
>> - The minimum transfer size is the smaller of the original allocation
>>size or the applicable minimum allocation size in current policy.
>> - For mergers and acquisition transfers, the recipient entity must
>>provide evidence that they have acquired assets that use the resources
>>to be transferred from the current registrant. ARIN will maintain an
>>up-to-date list of acceptable types of documentation.
>> ARIN will proceed with processing transfer requests even if the number
>>resources of the combined organizations exceed what can be justified
>>under current ARIN transfer policy as defined in section 8.5. In that
>>event, ARIN will work with the resource holder(s) to transfer the extra
>>number resources to other organization(s) or accept a voluntary return
>>of the extra number resources to ARIN.
>> 
>> 8.3. Transfers between Specified Recipients within the ARIN Region
>> 
>> In addition to transfers under section 8.2, IPv4 numbers resources and
>>ASNs may be transferred according to the following conditions.
>> 
>> Conditions on source of the transfer:
>> 
>> - The source entity must be the current registered holder of the IPv4
>>address resources, and not be involved in any dispute as to the status
>>of those resources.
>> - The source entity must not have received a transfer, allocation, or
>>assignment of IPv4 number resources from ARIN for the 12 months prior to
>>the approval of a transfer request. This restriction does not include
>>M&A transfers.
>> Conditions on recipient of the transfer:
>> 
>> - The recipients must meet the transfer requirements as defined in
>>section 8.5.
>> - The resources transferred will be subject to current ARIN policies.
>> 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 must not have received a
>>transfer, allocation, or assignment of IPv4 number resources from ARIN
>>for the 12 months prior to the approval of a transfer request. This
>>restriction does not include M&A transfers.
>> 
>> 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 must meet the transfer requirements
>>as defined in section 8.5.
>> - Recipients within the ARIN region will be subject to current ARIN
>>policies.
>> 8.5. Specified Transfer Recipient Requirements
>> 
>> 8.5.1. Registration Services Agreement
>> 
>> The receiving entity must sign an RSA covering all resources to be
>>transferred unless that entity has a current (within the last two
>>versions) RSA on file.
>> 
>> 8.5.2. Operational Use
>> 
>> ARIN allocates or assigns number resources to organizations via
>>transfer solely for the purpose of use on an operational network.
>> 
>> 8.5.3. Minimum transfer size
>> 
>> ARIN¹s minimum IPv4 transfer size is a /24.
>> 
>> 8.5.4. Initial block
>> 
>> Organizations without direct assignments or allocations from ARIN
>>qualify for transfer of an initial IPv4 block of ARIN¹s minimum transfer
>>size.
>> 
>> 8.5.5. Block size
>> 
>> Organizations may qualify for the transfer of a larger initial block,
>>or an additional block, by providing documentation to ARIN which details
>>the use of at least 50% of the requested IPv4 block size within 24
>>months. An officer of the organization shall attest to the documentation
>>provided to ARIN.
>> 
>> 8.5.6. Efficient utilization of previous blocks
>> 
>> Organizations with direct assignments or allocations from ARIN must
>>have efficiently utilized at least 50% of their cumulative IPv4 address
>>blocks in order to receive additional space. This includes all space
>>reassigned to their customers.
>> 
>> Comments:
>> 
>> Timetable for implementation: immediately
>> 
>> Anything else: A redline has been provided to help the community
>>understand the changes that have been made to the NRPM.
>> _______________________________________________
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