[ppml] Policy Proposal: IPv4 Transfer Policy Proposal - 24 month freeze

[Jason Schiller]

I have concerns about section 8.4.1 and 8.4.2.  At a high level these
sections say if you receive a transfer (act as a transferee) or transfer a
block (act as a transferor) then you will be prevented from requesting
additional address space for 24 months.

This may be problematic if one of the following occurs:

1.  Sell or spin off a portion of the network that is less profitable,
(this includes some network assets, all of its customers on those assets,
and a transfer of the associated addresses) but continue to grow the
remaining network thereby requiring additional addresses.  

2. Purchase another company that represents a profitable niche market or
profitable niche service, (this includes some of its network assets, all
of its customers on those assets and transfer of the associated
addresses) but continue to grow the pre-exist network thereby requiring
additional addresses, while maintaining the purchased customer base or
services and their associated address utilization

3. Performing two or more spin offs or acquisitions with a 24 month period
with no need for additional addresses.

Is this 24 month freeze the intention of the policy, or an over sight?

___Jason

On Tue, 12 Feb 2008 michael.dillon at bt.com wrote:
> Most of the time, when IP addresses are transferred, it is
> coupled to the sale of network assets. 

On Mon, 11 Feb 2008, Member Services wrote:

> 8.4.      Requirements for Simple Transfer of IPv4 Addresses
> 
> After the exhaustion of the IANA IPv4 free pool, ARIN will also process
> IPv4 address transfer requests subject to the following conditions.
> 
> 8.4.1    Conditions on the transferor:
> 
>      * The transferor resides in the ARIN service area.
>      * The transferor has signed an RSA and/or a legacy RSA covering the
>        IPv4 addresses transferred.
>      * The transferor has no outstanding balances with ARIN.
>      * The transferor has not received any IPv4 allocations or
>        assignments from ARIN (through ordinary allocations or
>        assignments, or through this Simple Transfer policy) within the
>        preceding 24 months.
>      * The transferor may not request any IPv4 allocations or assignments
>        from ARIN (through ordinary allocations or assignments, or through
>        this Simple Transfer policy) within the subsequent 24 months.
> 
> 8.4.2    Conditions on the transferee:
> 
>      * The transferee resides in the ARIN service area and intends to use
>        the transferred IPv4 addresses within the ARIN service area.
>      * The transferee has no outstanding balances with ARIN.
>      * The transferee’s need is confirmed by ARIN, according to current
>        ARIN policies, including but not limited to confirmation of
>        utilization rate of any prior IPv4 allocations, assignments, or
>        previously transferred IPv4 addresses held by the transferee.
>      * The transferee signs (or has previously signed) an RSA covering
>        the IPv4 addresses transferred.
>      * The transferee has not provided any IPv4 addresses for transfer
>        through this Simple Transfer process within the preceding 2
>        months.
>      * The transferee may not provide any IPv4 addresses for transfer
>        through this Simple Transfer process within the subsequent 24
>        months, except in the case of business failure.
>      * The transferee may only receive one IPv4 address transfer every 6
>        months.
> 
> 
>