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

[Scott Leibrand]

On Tue, Aug 23, 2011 at 2:25 PM, Paul Wilson <pwilson at apnic.net> wrote:
> I have some practical questions about this policy proposal.

Certainly.  Many of those will be better answered by ARIN staff as
they do their Clarity and Understanding and later a full Staff
Assessment on the proposal, but I'll answer from an
intent-of-the-author perspective.

> Is it proposed that ARIN staff would conduct a full need-based assessment of the each recipient, even in another region, including examination of all prior allocations?

It is proposed that a needs assessment be performed for each request.
Whether that is performed by ARIN, by the recipient RIR, or some
combination of the two will be up to the RIRs to decide.  I would hope
that they would make use of existing documentation held by the
recipient RIR to minimize any duplication of effort.

> Has there been any consideration of the cost and practicality of this approach?

At this point my main consideration is whether we can figure out a way
to allow inter-RIR transfers at all.  If ARIN were to pass draft
policy 2011-1 and APNIC were to adopt a compatible needs-based
transfer policy, that would be one avenue.  But if not, then an
approach like the one proposed here seems to be the only way (within
the existing RIR system) to allow transfers from ARIN registrants to
members of the other RIRs with the highest demand.  I'm not sure I
like all the hoops I put in the policy, but they seem necessary in
light of the strong consensus in the ARIN region in favor of continued
needs-based allocation.

I trust that ARIN will work with any recipient RIRs to implement this
policy in the most cost-effective and practical way possible in light
of those requirements.

> Is it possible that a recipient would be asked to pay ARIN to cover the cost of this service?

For transfers within the ARIN region, I believe ARIN charges a
transfer fee.  They could choose to apply that same fee to transfers
leaving the region as well.

> Would a registration services agreement be required with ARIN?

This is probably a question for ARIN staff or counsel.  My
understanding is that an RSA is required on the recipient of 8.3
transfers today, but that they have recently updated procedures to
allow for an organization to release space for transfer without
signing an RSA.

My intent would be that an organization in another RIR's service
region receiving space via transfer under this policy would need to
have a registration or membership agreement with that RIR per that
RIR's policies and procedures, but not with ARIN.

-Scott

> On 24/08/2011, at 4:46 AM, ARIN wrote:
>
>> ARIN-prop-156 Update 8.3 to allow inter-RIR transfers
>>
>> ARIN received the following policy proposal and is posting it to the
>> Public Policy Mailing List (PPML) in accordance with the Policy
>> Development Process.
>>
>> The ARIN Advisory Council (AC) will review the 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 and announce the decision to the PPML.
>>
>> The AC invites everyone to comment on the 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.
>>
>> Draft Policies and Proposals under discussion can be found at:
>> https://www.arin.net/policy/proposals/index.html
>>
>> 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/mailing_lists/
>>
>> Regards,
>>
>> Communications and Member Services
>> American Registry for Internet Numbers (ARIN)
>>
>> ## * ##
>>
>> 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.
>>
>> + 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, 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.
>>
>>
>> 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.
>>
>> This policy text would be intended to replace draft policy 2011-1 ARIN
>> Inter-RIR Transfers.
>>
>> Timetable for implementation:  Immediate
>>
>> _______________________________________________
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