[arin-ppml] Draft Policy ARIN-2017-6: Improve Reciprocity Requirement for Inter-RIR Transfers

[Mueller, Milton L]

I oppose this policy. I understand and sympathize with the concerns about NIRs, but I think this policy exacerbates the problem of NIRs by reinforcing their tendency to turn themselves into territorial islands. I have read the "problem statement" for this policy and do not believe that a case has been made that there is a real problem here. Even if we accept the pejorative term "loophole" I would like a better description of what actual problem is caused by this so-called loophole.  

Is this policy considered an "answer" or "alternative" to 2017-4?

Dr. Milton L. Mueller
Professor, School of Public Policy
Georgia Institute of Technology



> -----Original Message-----
> From: ARIN-PPML [mailto:arin-ppml-bounces at arin.net] On Behalf Of ARIN
> Sent: Tuesday, June 20, 2017 1:38 PM
> To: arin-ppml at arin.net
> Subject: [arin-ppml] Draft Policy ARIN-2017-6: Improve Reciprocity
> Requirement for Inter-RIR Transfers
> 
> On 15 June 2017, the ARIN Advisory Council (AC) advanced "ARIN-prop-241:
> Improve Reciprocity Requirement for Inter-RIR Transfers" to Draft Policy
> status.
> 
> Draft Policy ARIN-2017-6 is below and can be found at:
> https://www.arin.net/policy/proposals/2017_6.html
> 
> You are encouraged to discuss all Draft Policies on PPML. 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 Policy
> Development Process (PDP). Specifically, these principles are:
> 
> * Enabling Fair and Impartial Number Resource Administration
> * Technically Sound
> * Supported by the Community
> 
> The PDP 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,
> 
> Sean Hopkins
> Policy Analyst
> American Registry for Internet Numbers (ARIN)
> 
> 
> 
> Draft Policy ARIN-2017-6: Improve Reciprocity Requirement for Inter-RIR
> Transfers
> 
> Problem Statement:
> 
> Currently ARIN's requirement that inter-RIR transfer policies be reciprocal has
> a glaring hole in it in that RIRs which have NIRs and/or a two-hop RIR transfer
> process can be used to circumvent the intent of the requirement. Rather than
> eliminate the requirement, a better approach would be to close the loophole.
> 
> Policy statement:
> 
> Amend section 8.4 (included here for reference):
> 
> 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, unless either the source or
> recipient entity owns or controls the other, or both are under common
> ownership or control. This restriction does not include M&A transfers.
> 
> Address resources from a reserved pool (including those designated in Section
> 4.4 and 4.10) are not eligible for transfer.
> 
> 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.
> 
> Make the following change:
> 
> Add an additional bullet to "Conditions on recipient" which states:
> 
> + Recipient RIR policy must not permit transfers to other RIRs or NIRs
> whose policies do not support bi-directional transfers.
> 
> Comments:
> 
> a. Timetable for implementation: Immediate
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