[arin-ppml] Policy Proposal 2008-2: IPv4 Transfer Policy Proposal - Revised

[Member Services]

Policy Proposal "2008-2: IPv4 Transfer Policy Proposal" has been 
revised. This proposal is open for discussion on this mailing list and 
will be on the agenda at the upcoming ARIN XXII Public Policy Meeting in 
Los Angeles.

The current policy proposal text is provided below and is also available
at: http://www.arin.net/policy/proposals/2008_2.html

Regards,

Member Services
American Registry for Internet Numbers (ARIN)
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Policy Proposal 2008-2

IPv4 Transfer Policy Proposal

Author: ARIN Advisory Council

Proposal Version: 1.4

Date: 09/18/2008

Proposal type: modify

Policy term: permanent

Policy statement:

Modify the current NRPM section 8 as follows --

8. Transfers

[8.1. Transfers – retain as is]

[8.2 – remove the word “only”, and retitle to “Transfers as an Artifact 
of Change in Resource Holder Ownership”]

[Renumber existing 8.3 to 8.2.1 and retitle to “Documentation 
Requirements for Transfers as an Artifact of Change in Resource Holder 
Ownership”]

[Add the following new section:]

8.3. Simple Transfer of IPv4 Addresses

In light of the pending exhaustion of the IANA IPv4 free pool, ARIN will 
also process IPv4 address transfer requests subject to the following 
conditions. These conditions apply only to Simple IPv4 transfers, not to 
transfers performed according to section 8.2.

8.3.1 Conditions on the transferor (the organization providing addresses 
for transfer):

• 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 12 months.

• If the transferor elects to retain a portion of a block pursuant to 
8.3.6, rather than transferring an entire block, the transferor must 
sign (or have previously signed) a RSA or LRSA covering the retained 
portion.

8.3.2 Conditions on the transferee (the organization receiving the 
transferred addresses):

• The transferee 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.

• The transferee signs (or has previously signed) an RSA covering the 
IPv4 addresses transferred.

• The transferee may request and receive a contiguous CIDR block large 
enough to provide a 12 month supply of IPv4 addresses.

• The transferee may only receive one IPv4 address transfer through this 
Simple Transfer process every 6 months.

8.3.3 Conditions on the IPv4 address block to be transferred:

• The IPv4 block must comply with applicable ARIN allocation 
requirements, including minimum allocation size. However, an IPv4 
allocation or assignment of /24 or larger, but smaller than the current 
minimum allocation size, may be transferred as a whole resource (but may 
not be subdivided).

• The IPv4 block must currently be registered for use within the ARIN 
service area.

• There must be no dispute as to the status of the IPv4 block or 
regarding the allocation or assignment of such block to the transferor.

8.3.4 [Section omitted]

8.3.5 Pre-qualification

• An interested transferee must seek pre-qualification from ARIN to 
confirm its eligibility to receive a transfer (including satisfaction of 
need according to current ARIN policies) before making any solicitation 
for transfer. Upon pre-qualification, ARIN will provide the transferee 
with documentation of the pre-qualification, including the size (CIDR 
prefix length) of the largest IPv4 address block the transferee is 
eligible to receive, and the expiration date of the pre-qualification.

• An interested transferor may seek pre-qualification from ARIN to 
confirm its eligibility to offer a transfer before offering IPv4 address 
resources for transfer. Upon pre-qualification, ARIN will provide the 
transferor with documentation of the pre-qualification, including the 
network block and the expiration date of the pre-qualification.

8.3.6 Deaggregation when Permitted by ARIN

ARIN may allow transferors to subdivide network blocks. ARIN will 
attempt to ensure an adequate supply of small blocks while minimizing 
deaggregation.

8.3.7. Safe Harbor

The fact that an IPv4 address holder is making IPv4 addresses available 
for transfer, pursuant to this policy, does not, in and of itself, 
indicate that the address holder lacks the need required for an 
allocation under ARIN policy.

8.3.8. Organizations under Common Ownership or Control

If an IPv4 transferor or transferee is under common ownership or control 
with any other organization that holds one or more IPv4 blocks, the IPv4 
transfer request must report all such organizations under common 
ownership or control. When evaluating compliance with IPv4 Simple 
Transfer conditions, ARIN may consider a transfer request in light of 
requests from other organizations under common ownership or control.

8.3.9. Record-keeping and Publication

ARIN will develop and operate a listing service to assist interested 
transferors and transferees by providing them a centralized location to 
post information about IPv4 blocks available from pre-qualified 
transferors and IPv4 blocks needed by pre-qualified transferees.

Participation in the listing service is voluntary.

After completion of a transfer, ARIN will update the registration and 
WHOIS records pertaining to the IPv4 block. ARIN will also publish a log 
of all transfers, including block, transferor, transferee, and date.


Rationale:

The ARIN Board of Trustees asked the Advisory Council to consider a set 
of questions around the depletion of the free pool of IPv4 addresses, 
the transition to IPv6 for Internet address needs in the future, and 
ARIN's possible role in easing the transition.

Over the course of the year, the Advisory Council has worked to solicit 
input from all parts of the policy-making community, through the ARIN 
XXI public policy meeting, the Public Policy Mailing List (PPML), sector 
meetings, and a poll of PPML subscribers. As a result of the input 
received, this policy has been simplified considerably, removing or 
modifying text and restrictions deemed unnecessary, while preserving 
those aspects that seem to be supported by consensus.

This policy proposal would create a transfer mechanism for IPv4 number 
resources between those who have excess resources and those who have a 
need, thereby allowing ARIN to continue to serve its mission after IANA 
free pool exhaustion. This proposal would also set conditions on such 
transfers intended to preserve as much as possible the existing policy 
related to efficient, needs-based resource issuance, and would leverage 
ARIN's control systems, audit trails, and recognized position as a 
trusted agent to avoid speculation and hoarding and diminish the 
likelihood and extent of an uncontrolled 'black market' where the risk 
and potential for fraud is immeasurably higher.

Many of the transfer conditions are self-explanatory, but some worth 
highlighting are that:

• To discourage speculation, a waiting period (proposed at 12 months) is 
required before a recipient of space can transfer it to another 
organization.

• Transferees must qualify for IPv4 space (just as they do today when 
getting it from ARIN) before they can receive address space by transfer, 
or solicit space on a listing service.

• To discourage unnecessarily rapid growth of routing tables, an 
allocation or assignment may not be arbitrarily deaggregated. To ensure 
an adequate supply of small blocks while minimizing deaggregation, ARIN 
may allow transferors to subdivide network blocks. A suggested starting 
point is to allow transferors to subdivide an IPv4 block into up to four 
smaller blocks on CIDR bit-boundaries, provided each resulting block 
satisfies the minimum allocation size.

• A transferee may receive one transfer every 6 months, and may receive 
at least 12 months worth of space, so they’ll be incented to transfer a 
block appropriately sized for their needs, which will further discourage 
deaggregation and keep smaller blocks available for smaller organizations.

The proposal would also have ARIN develop and operate a listing service 
to facilitate transfers and provide an authoritative central source of 
information on space available and requested for transfer. It would not 
prohibit private party transactions, but would encourage potential 
transferors and transferees be pre-qualified first, so that neither 
party will encounter any surprises when they ask ARIN to process the 
transfer.


Timetable for implementation: immediately upon ratification by the Board 
of Trustees