[arin-ppml] Policy Proposal: Protective Usage Transfer Policy forIPv4 Address

Ted Mittelstaedt tedm at ipinc.net
Tue Feb 10 15:13:41 EST 2009

I WOULD SUPPORT this policy IF the following changes were made to it:

1)  A definition of what constituted a "Critical infrastructure provider"
(ie: C.I.P.) was added that was REASONABLE.  Someone's webserver with
a couple hundred customers on it does not, IMHO, constitute a CIP.

2) The allocation/assignment to the C.I.P. constituted 50% or greater
of the IPv4 block that was going to be transferred by the owning

3) The transfer to the C.I.P. did not result in further deaggregation of
an IPv4 block - in short, the block is small enough that there is
reasonable expectation that the C.I.P. will be able to fill it in the
future, or the C.I.P. supplies a signed contract by another, larger,
network that guarentees the larger network will indeed use the empty part of
the block and continue to allow the C.I.P. to use their part - and

I totally understand the annoyance that a CIP might have a /24 smack dab
in the middle of a /8 and the owning org of the /8 decides to either
return the block, or sell it as part of an acquisition of a network, etc.
and the CIP wants to throw a monkey wrench into the sale.  Of course, that
should not be permitted.

But what about the situation where, for example, Cable & Wireless pulled
out of the NA market?  C&W had it's large allocations, sure.  But they also
had a number of smaller fragments, /24, /23, /22 allocations and such that
they had obtained directly, before the minimum assignment size was added
the NRPM.  These had been assigned to smaller customers of theirs, some of
them ISP's.

When C&W pulled out, most of it's numbering went directly back to ARIN,
some was sold to other ISP's who gobbled up the usable C&W holdings.

If for example a CIP had a /23 that was part of a /22 that C&W owned, then
why inconvenience them by letting C&W sell the /22 as part of it's 
dissolution?  The fact of the matter was that C&W cancelled a great number
of it's NA contracts anyhow because they hadn't found a buyer for them,
so everyone in the other half of the /22 from the CIP would likely have
quit service anyway.  Is it really necessary to force the CIP to renumber
just to make things slightly easier on C&W's bean-counters who oversaw
the dissolution of their NA holdings?


> -----Original Message-----
> From: arin-ppml-bounces at arin.net 
> [mailto:arin-ppml-bounces at arin.net] On Behalf Of Member Services
> Sent: Tuesday, February 10, 2009 4:58 AM
> To: arin-ppml at arin.net
> Subject: [arin-ppml] Policy Proposal: Protective Usage 
> Transfer Policy forIPv4 Address
> ARIN received the following policy proposal. In accordance 
> with the ARIN Policy Development Process, the proposal is 
> being posted to the ARIN Public Policy Mailing List (PPML).
> This proposal is in the first stage of the ARIN Policy 
> Development Process. ARIN staff will perform the Clarity and 
> Understanding step.
> Staff does not evaluate the proposal itself at this time, 
> their only aim is to make sure that they understand the 
> proposal and believe that the community will as well. Staff 
> will report the results of this step to the ARIN Advisory 
> Council (AC) within 10 days.
> The AC will review this proposal at their next regularly 
> scheduled meeting (if the period before the next regularly 
> scheduled meeting is less than 10 days, then the period may 
> be extended to the subsequent regularly scheduled meeting). 
> The AC will decide how to utilize the proposal. The decision 
> will be announced to the PPML.
> In the meantime, the AC invites everyone to comment on this 
> proposal on the PPML, particularly their support or 
> non-support and the reasoning behind their opinion. Such 
> participation contributes to a thorough vetting and provides 
> important guidance to the AC in their deliberations.
> The ARIN Policy Development Process can be found at:
> https://www.arin.net/policy/pdp.html
> Mailing list subscription information can be found at:
> https://www.arin.net/participate/mailing_lists/index.html
> Regards,
> Member Services
> American Registry for Internet Numbers (ARIN)
> ## * ##
> Policy Proposal Name: Protective Usage Transfer Policy for 
> IPv4 Address
> Proposal Originator : Christopher A Quesada,
> Proposal Version: 1
> Date: 2/9/2009
> Proposal type: New
> Policy term: permanent
> Policy statement:
> Protective Usage Transfer Policy for IPv4 Address
> Critical infrastructure providers may appeal to ARIN for 
> final review and decision of any full or partial transfer of 
> IPv4 address space that has been in use serving the community 
> for consecutive periods of time.
> Rationale:
> Protection of critical infrastructure as defined in ARIN's 
> Number Resource Policy Manual is necessary in order to ensure 
> the continuous operation of the Internet for its global 
> service community. It is possible for an organization to 
> transfer an aggregate IPv4 address resource containing 
> allocations/assignments downstream supporting critical 
> infrastructure. This policy is intended to protect critical 
> infrastructure by not allowing the transfer of those 
> assignments if such transfer would interfere with the 
> continuous and seamless operation of that critical 
> infrastructure or hardship to the provider.
> Timetable for implementation: immediately
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