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

[Milton L Mueller]

You ACs have been working hard. It is improved! A few comments based on
an unfortunately (but necessarily) hasty review

> -----Original Message-----
> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net]
On
> Author: ARIN Advisory Council
> 
> [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

Doesn't conform to my definition of "simple" but I understand the
constraints... ;-)

> * 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.

Clever! Seems a good way to handle one aspect of this vexed question,
Bear in mind however that some prospective sellers might opt out of
transferring when faced with this choice.

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

I think you mean, "The IPv4 block must currently be within the range of
address blocks allocated to ARIN." Who cares _where_ they use it? 

> * 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.

How quickly can ARIN issue this?

> * An interested transferor may seek pre-qualification from ARIN to
> confirm its eligibility to offer a transfer before offering IPv4
address
> resources for transfer. 

I would reword as "...may seek pre-qualification from ARIN to
authenticate its prior assignment or allocation of the address resources
offered for transfer."

> 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.

Good!

> 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.

I see why you might want to apply this provision to recipients (i.e.,
buyers - still afraid of that word, eh?) I don't think it makes any
sense to apply it to transferororors (sellers). 

Do organizations currently have the right to freely transfer IPv4 blocks
among their subsidiaries without approval or review from ARIN? If so, I
guess I understand what this provision is driving at.  

This provision seems to imply that ARIN may use the possibility of
internal transfers as a criterion in approving transfers. If ARIN is
confronted with more transfererereeeees (buyers) than transferorororors
(sellers), then it might say to a prospective transfererereeeee "get the
addresses from other departments in your company." 

You might want to clarify this.

> 
> 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:
> 

This section of the policy is much improved.