[arin-ppml] Policy Proposal 2008-2 - Staff Assessment

[Scott Leibrand]

Member Services wrote:
> Policy Proposal 2008-2
> Title:  IPv4 Transfer Policy (authors ARIN AC)
> Revised:  18 September 2008	
> Revised Assessment:  8 October 2008
> 
> ARIN Staff Assessment
> 
<snip>
> A.      ARIN Staff Comments:
> 
> 1.	The second paragraph of 8.1 states that “number resources are
> assigned to an organization for its exclusive use for the purpose stated
> in the request, provided the terms of the Registration Services
> Agreement continue to be met”.  Not all number resources involved in a
> transfer are covered under an ARIN RSA.  If this is the intent of this
> policy, it should be explicitly stated.
> 
> 2.	In addition, “the stated purpose” for the original allocation may be
> difficult for an organization to provide given the requester may not be
> the original holder of the number resources.

We have chosen not to change existing transfer policy as part of this 
proposal, except where it directly contradicts the new policy.  I would be 
happy to work with staff, legal, and the community to clean up 8.1, but I 
think that's out of scope here.

> 3.	The newly proposed title for section 8.2 “Transfers as an Artifact of
> Change in Resource Holder Ownership” is overly complex and may be
> difficult for readers to discern what this section pertains to which may
> result in them bypassing this section altogether.

Apparently so ...

> 4.	 In addition, this title refers to “resource holder ownership” – this
> directly conflicts with the existing transfer policy text and the RSA
> which both state that number resources are not “owned”.  Staff suggests
> that the existing title for this section “Transfer Requirements” be
> retained for clarity and consistency.

The intent was to refer to "ownership" of the "resource holder", not the 
"resource".  But we obviously need a simpler title, since its meaning is 
unclear even to ARIN staff.  :)

The problem with the existing title "Transfer Requirements" for section 
8.2 is that it could be construed to apply to section 8.3 as well.  The 
change in title was an attempt to make clear that the two sections are 
completely separate and unrelated.

At one point we considered using the title "M&A Transfers", but folks 
(including staff) didn't like that, since M&A wasn't defined, and its 
common usage (Mergers & Acquisitions) doesn't fully cover all the 
situations this section applies to.

Does anyone have any other suggestions for how to retitle the existing 
transfer policy, to make clear it's distinct from the new "Simple 
Transfer" policy?

> 5.	 The newly proposed title for section 8.2 .1 “Documentation
> Requirement for Transfers as an Artifact of Change in Resource Holder
> Ownership” is overly complex and may be difficult for readers to discern
> what this section pertains to, which may result in them bypassing this
> section altogether.
> 
> 6.	 In addition, the title refers to “resource holder ownership” - this
> directly conflicts with the existing transfer policy text and the RSA
> which state that number resources are not “owned”.  Staff suggests that
> the existing title for this section “Document Requirements” be retained
> for clarity and consistency.

If we can agree on a better title for 8.2, then 8.2.1 can inherit that as 
well.

> 7.	In section 8.3.3 the statement “The IPv4 block must currently be
> registered for use within the ARIN service area” is unclear and should
> be further defined by the author so that staff has a clear understanding
> of how to apply this criteria.

This was discussed on PPML, and the general sentiment seemed to be that we 
should replace this with: "The IPv4 block must be one administered by 
ARIN, either as part of an address block assigned by IANA to ARIN, or as 
part of a legacy address block allocated within the ARIN service area." 
Would that language be sufficiently clear?

As we're so close to the meeting, I don't want to push a new version of 
the policy out, but if there's consensus for the policy, and for this 
change, I intend to the propose that the AC adopt this clarified wording 
as a minor edit after the meeting.

> 8.	This policy proposal addresses the same subject matter as 2008-2.

I think you mean 2008-6.

> They both specify requirements that Transferor and address space be
> recognized by ARIN, Transferee demonstrate need and Transferee sign an
> RSA. Additionally, they both include provisions on deaggregation,
> minimum prefix size and directory services. They differ  in that this
> policy is not limited in duration and it does provide criteria on
> matters such as facilitating and establishing eligibility for the transfer.

Agreed.  The intent is that we'll consider 2008-2 first.  If there's 
consensus there, Bill will withdraw 2008-6.  If 2008-2 fails to get 
consensus, we'll consider 2008-6.

Thanks,
Scott