[arin-ppml] Policy Proposal: Protective Usage Transfer Policy for IPv4 Address - Revised

[David Farmer]

I'd be interested if this revision has changed anyone's mind or answered any 
questions for anyone.

Personally, I believe this only really answered one of my questions included 
below.  I've included a few additional comments in line;

On 11 Feb 2009 David Farmer wrote:

> I would like to bring us back to the text of the proposal for a 
> moment.
> 
> Could the Author or one on the supporters of this please clearify 
> or comment on a few issues for me;
> 
> 1.  What is the remedy you would seek from ARIN in this 
> Appeal of the Transfer?
> 
>       A. An extended delay in execution of the transfer.  If so
>       how long?
> 
>       B. ARIN to assign the block in question directly to the
>       Critical Infrastructure Provider?

It is still unclear to me what remedy you are seeking from ARIN.  I believe 
that this has to be clarified.  I think some kind of delay is about the most I 
could personally support, a reassignment would create a very bad precedent, 
more below;
 
> 2.  What do you mean by "for consecutive periods of time".  I 
> think you intend that the CI Provider should have been using 
> the address block for an extended time period.  So, how long 
> should the addresses have been in use to qualify?

Thank you, this has been clarified, five years.  But please realize that there 
are many end-users that have been using address space for five years or 
more.

> 3.  Who within ARIN should be responsible to hear the appeal?  
> Staff, the Board, a 3rd party arbiter (how would you pick the 
> arbiter), a vote at a member meeting?

I think you intend this to be ARIN Staff, but I think this still needs to be 
clarified.

> 4. Do the CI Providers need to have a relationship with ARIN 
> already?

I'm still concerned about this.

> 5. Have you thought about legal issues like indemnification, will the
> CI Providers have to defend ARIN from law suits and pay any settlement
> to the parties to the transfer?

I'm still concerned about this, too

> 6. How could ARIN possibly defend itself against all the end-
> users in this very same situation if we did this for the CI 
> Providers.  This is a very slippery slope.

I am concerned that this sends the message that renumbering is "TO  
HARD" even for companies in the business of providing network 
infrastructure, with staffs of network professionals, especially if we were to 
allow reassignment.  If we allow CI Providers an exception from 
renumbering, how do we as an industry justify requiring most end-users to 
renumber?  

Below in the rational it says "interfere with the continuous and seamless 
operation of that critical infrastructure or hardship to the provider."  
Unfortunately I believe this is double speak for renumbering, unless you can 
explain how else a transfer would "interfere".

I could maybe support this if renumbering were explicitly defined and not 
interfering or creating a hardship.

I'll add another issue;

7. I believe the text also seems to put the presumption in favor of the CI 
provider, why shouldn't the CI provider have to prove harm first, rather than 
the transferee prove that the transfer is justified.  

> All of these things would have to be dealt with for this proposal to
> make all the way into becoming a policy.  Is it worth it?  Are there
> ways around these issues? 

I would like to see those that support this policy address these issues.

On 5 Mar 2009 Member Services wrote:

> Policy Proposal
> Protective Usage Transfer Policy for IPv4 Address
> 
> The proposal originator submitted a revised version of the proposal.
> 
> The AC will review this proposal at their next regularly scheduled
> meeting and decide how to utilize the proposal. Their 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:
> http://www.arin.net/policy/pdp.html
> 
> Mailing list subscription information can be found at:
> http://www.arin.net/mailing_lists/
> 
> 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: 2
> 
> Date: 5 March 2009
> 
> Policy statement:
> 
> Critical infrastructure providers may appeal to ARIN for final review
> and approval of any full or partial transfer of IPv4 address space
> that has been in use by the critical infrastructure serving the
> community for five consecutive years or more.  Such appeal may result
> in a partial or full approval of the requested transfer, or rejection
> of the transfer if it lacks appropriate rationale, justification, or
> interferes with the seamless operation of such critical infrastructure
> or hardship to the provider.
> 
> Rationale:
> Protection of critical infrastructure providers of the Internet,
> including public exchange points, core DNS service providers (e.g.
> ICANN-sanctioned root, gTLD, and ccTLD operators) as well as the RIRs
> and IANA 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
> (as defined in ARIN´s Number Resource Policy Manual).  This policy is
> intended to protect that critical infrastructure by allowing for the
> review and final approval of such transfer by ARIN, upon appeal by the
> critical infrastructure provider to ARIN, within a sixty day period of
> the transfer notification if such transfer would interfere with the
> continuous and seamless operation of that critical infrastructure or
> hardship to the provider.  Review of the transfer can consist of a
> request by ARIN to the transferring organization for a rationale for
> such transfer.  This may include but not be limited to, a requirement
> for the receiving party to submit the appropriate network request form
> identifying the need and justification for the aggregate IPv4 address
> resource.
> 
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David Farmer				     Email:	farmer at umn.edu
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Networking & Telecomunication Services
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