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

[Heather Schiller]

I think that this text could use some clarification.. Here are my 
questions/concerns:

1) This policy allows a reassignment holder to appeal to ARIN if/when 
the direct allocation holder applies for a transfer?   or does it allow 
someone to appeal to ARIN to convert/transfer the assignment anytime 
after it's been in use for 5 years?


2) who is the 'provider' in the text?  The direct allocation holder? the 
reassignment holder?


3) Also, it seem the text isn't clear that this refers only to CI space 
- the micro-allocations for exchange points or for critical 
infrastructure.   ARIN maintains a list of these netblocks:

https://www.arin.net/knowledge/micro_allocations.html

The text appears to refer to anything that might be CI regardless of 
*where* it is assigned from, which in theory, could include a PA or PI 
block.  Is that the intent?

4) Who is authorized to make an appeal?  Presumably an organization that 
has an assignment in the resource that is up for transfer?  But how do 
you verify that?  I'm spot checking the list of micro-allocations - Most 
appear to be allocations, which allow for reassignments, but so far, 
none have reassignment information.  One way to verify how long a 
reassignment has been in use for that 5 year figure would be to check 
the date on the reassignment.

5) Is the goal to delay the transfer to allow the subdelegation holders 
more time to renumber?  or to put a kabash on the whole transfer or..? 
how do you make someone hold onto space when they don't want to?

  Here were the outcome scenarios outlined in the text:

  partial approval of transfer: what happens to the space that isn't 
approved for transfer?  does it get returned to ARIN? reallocated? or?

  full approval of transfer: gets fully transferred to new org

  rejection of transfer: ?? seems the most bizarre.. what happens here? 
  who is responsible for the space?  If a company or organization 
dissolves or merges with another.. someone has to be responsible for the 
space?

6) What are the valid arguments for an appeal?  What rights does the 
direct allocation holder have in this appeals process?  If they can 
demonstrate that they have provided ample warning and time to renumber 
as recommended in the NRPM, does the organization making an appeal still 
have grounds to appeal?  What role do contracts between the direct 
allocation holder and the reassignment holder play in the appeals 
process?  Should ARIN consider those contracts as part of the appeal? 
Are you asking ARIN to intercede in something that maybe should be 
played out in court?

--Heather

====================================================
  Heather Schiller	Verizon Business
  Customer Security	1.800.900.0241
  IP Address Management	help4u at verizonbusiness.com
=====================================================


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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