[arin-ppml] Policy Question(s)

[John Curran]

On Oct 5, 2010, at 7:14 PM, Ronald F. Guilmette wrote:

> But see, here's the problem... In this case in particular... and also
> in at least one other I'm aware of... I honestly am having trouble
> interpreting what the words... specifically in Section 8.3... actually
> mean.  Can you please give me just a tiny bit of help with that?
> 
>    8.3. Transfers to Specified Recipients
> 
>    In addition to transfers under section 8.2, IPv4 number resources within
>    the ARIN region may be released to ARIN by the authorized resource holder,
>    in whole or in part, for transfer to another specified organizational
>    recipient. 
> 
> This passage appears on the face of it to give you (ARIN) pretty much
> carte blanche to approve inter-company transfers as you think best,
> or not, as you think best.  (Note the use of the word "may".)  The above
> would appear to make ARIN judge, jury, and executioner for all inter-company
> and/or inter-organization transfer requests.  (Does that sound about right?
> Or am I misreading it?)

You somehow omitted the second sentence of the policy, shown below for 
reference:

     Such transferred number resources may only be received under RSA
     by organizations that are within the ARIN region and can demonstrate 
     the need for such resources, as a single aggregate, in the exact 
     amount which they can justify under current ARIN policies.

So, your answer is "No", i.e. ARIN can only approve transfers from one 
party to another once the receiving organization has been approved for
those resources in the same amount as under current address allocation 
policy.

> So anyway, is this what happened with regards to 216.59.128.0/18 ?  I mean
> did you folks simply elect, within your reasonable and authorized discretion,
> to allow a older company to transfer this 11 year old block to a company
> that was newly formed only last year, in October of 2009 ?

Ron - I'm happy to discuss how any section of the policy manual is 
implemented (although we have a registration services help desk which 
is available, both via phone and in person at the ARIN meetings, which 
can help answer any of your questions as well, and is more appropriate
than using the PPML as a help desk...)

In any case, we cannot discuss specific resource actions for another 
party in any circumstance; the information regarding such actions is 
subject to the NDA between ARIN and each resource holder.

> ...
> So again, this is a policy question:  May a company which is still very
> much alive and kicking request that ARIN transfer some block it owns
> to some brand new, newly manufactured company with no history whatsoever?

ARIN will approve a transfer to the new entity of the same amount of space
that it can qualify for today under current policies.  (Since we still
have address space available, it might be simply for them once so approved
to simply accept from ARIN's resource pool, yes?)

> So it would appear that ARIN knowingly approved the transfer of an
> 11-year-old /18 block to what it knew, or could easily have known,
> was a brand new... albeit somewhat dubious... company.)

To repeat for clarity: If you believe that resources were transferred 
contrary to the policies as shown in the Network Resource Policy Manual, 
section 8 (Transfers), then report it on the already noted ARIN Fraud 
reporting link and we'll investigate and correct the Whois entries if 
changed contrary to community policy. 

Thanks!
/John

John Curran
President and CEO
ARIN