[arin-ppml] ARIN-prop-156 Update 8.3 to allow inter-RIR transfers

[Randy Whitney]

On 8/23/2011 2:46 PM, ARIN wrote:
> ARIN-prop-156 Update 8.3 to allow inter-RIR transfers
>
> ## * ##
>
> ARIN-prop-156 Update 8.3 to allow inter-RIR transfers
>
> Proposal Originator: Scott Leibrand
>
> Date: 23 August 2011
>
> Proposal type: Modify
>
> Policy term: Permanent
>
> Policy statement:
>
> 8.3. Transfers to Specified Recipients
>
> In addition to transfers under section 8.2, IPv4 number resources may
> be released to ARIN by the authorized resource holder, in whole or in
> part, for transfer:
>
> + under RSA, to specified organizational recipient(s) within the ARIN
> region that can demonstrate the need for such resources, in the exact
> amount which they can justify under current ARIN policies.

I agree with this point.

> + to another RIR, for transfer to a specified recipient in that RIR's
> service region who demonstrates plans to deploy the resources for the
> justified purpose within 3 months, as long as the request meets the
> policy requirements of both RIRs,

Perhaps I am just confused. If it is going to _another_ RIR, why does it
matter if it meets ARIN's policy requirements? How would you even apply
ARIN's Policies in this case?

> and the recipient (and any
> organizations to which they have transferred or reassigned space) can
> show efficient utilization of all prior allocations, assignments, and
> transfers according to the current policy requirements of both RIRs.

Similar to my previous point: if it is going to be transferred to
another RIR, then this statement either:
A/ Makes no sense, assuming recipient is not an ARIN member, or
B/ Could be construed as ARIN attempting to prevent the transfer or
otherwise interfere with another RIR's transfer approval process, since
the space is being transferred AWAY from the ARIN region.

If the wording was changed to "the destination RIR" I would support this
part of the extension as well.

> Rationale:
>
> A number of RIRs already allow IPv4 address transfers within their
> service regions.  Given that IPv4 address demand is concentrated in
> certain rapidly growing regions,  whereas IPv4 addresses that can be
> made available to supply that demand are concentrated in regions with
> more historical IPv4 deployment, it would be most efficient for
> addresses to be transferred from regions with more supply to regions
> with more demand.  If this is not allowed, prices for IPv4 addresses
> in high-demand regions will be higher, raising overall costs,
> encouraging address holders to transfer addresses outside the RIR
> system, and/or encouraging large corporations to acquire addresses in
> regions with more supply and then use them in regions with more
> demand.  It would be better for the overall Internet industry to allow
> inter-RIR transfers to organizations with demonstrated need for
> addressing for immediate deployment needs.

I agree with the Rationale, although there is no toothy way to enforce
RIR boundaries on Assigned Space, and large corporations would
potentially distribute their space anyhow, in some cases for valid
operational reasons.

>
> This policy text would be intended to replace draft policy 2011-1 ARIN
> Inter-RIR Transfers.
>
> Timetable for implementation:  Immediate
>

Regards,
Randy.