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

[Randy Whitney]

Hi William,

In general, if this proposal remains unaltered than I remain opposed to
the proposal. Specific points inline. I will not further the debate
after this.

On 8/23/2011 5:38 PM, William Herrin wrote:
> Hi Randy,
>
> On Tue, Aug 23, 2011 at 4:09 PM, Randy Whitney
> <randy.whitney at verizon.com>  wrote:
>>> + 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?
>
> Because our policies define who's qualified to receive our addresses
> and to the extent that our policies are more restrictive than those in
> the receiving region, the recipient must meet our requirements before
> the addresses can leave our control.

First of all, this is a transfer to another Region which has
region-specific needs different in many cases from those in the ARIN
region. This specific sticking point also prevented APNIC from reaching
consensus and passing the corresponding policy due to numerous
objections from the community. Removing it allowed the policy to pass.
Look at this from the perspective on the party willing to transfer this
space in the proper way. With such a sizable amount of overhead, it
would be easier to allow said partner to "borrow" the space than than to
try to do things properly.

>
>> How would you even apply
>> ARIN's Policies in this case?
>
> The exact same way we apply them to folks in the ARIN region.
> Templates. Resource reviews. Registration fees. Sometimes audits.

Offeree is in effect transferring control away from ARIN to another RIR.
Your wording implies that ARIN places no trust in other RIRs to handle
and assign their own resources effectively, which is also the reason why
policies often result in 4+1/ARIN vs other RIRs. Adding a transfer fee
is acceptable. Attempting to enforcing ARIN's policy on another RIRs
registered organization is not realistic.

>>> 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 you want to acquire addresses from your region, you meet your
> region's policies. If you want them from ARIN's region, you meet our
> policies too.

IMO, transfers are supposed to be about cooperation and trust. Enforcing
ARINs rules on other regions shows neither.

> What's the alternative? ARIN-region and out-region registrants would
> be on unequal footing meeting the qualifications to receive an address
> transfer from an ARIN-region registrant, potentially with ARIN-region
> registrants having to meet a stricter standard.

 From the perspective of Provider X with space he wishes to share with a
partner in African, Asia-Pac, Europe, or Latin America:

"Different Region, Different Needs. My ARIN-justified Space, My desire
to transfer it to a more needy partner in another RIR. Why should ARIN's
rules apply to RIR-X where the potential need to establish potential
address pools on more than two national boundaries exists? Aren't
RIR-X's allocation rules sufficient to assure that my resources are
properly and efficiently utilized? I'm offering to transfer the space to
my preferred partner in RIR-X, not add it to an address pool that can be
potentially assigned to my US competitor. In this case, I'd rather sit
on this justified IP space than to give it back to ARIN."

> I'm not sure what's confusing about that or how applying our policies
> while the addresses are still our responsibility could _reasonably_ be
> construed as interference.

See previous case.

> On Tue, Aug 23, 2011 at 5:25 PM, Paul Wilson<pwilson at apnic.net>  wrote:
>> 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?
>
> Hi Paul,
>
> If that's what ARIN region policies call for with address transfers.
> Why would we allow other regions to port out our scarce addresses
> using a less stringent standard than we apply to ourselves?
>
>
>> Has there been any consideration of the cost
>> and practicality of this approach?
>> Is it possible that a recipient would be asked to
>> pay ARIN to cover the cost of this service?
>
> I should hope so, but fees aren't determined by the policy community.
>
>> Would a registration services agreement be required with ARIN?
>
> I would expect so, although it would become moot once the transfer was complete.
>
> Regards,
> Bill Herrin

Since you chose to _also_ include your response to Paul in your
follow-up to my objection. This is perfect case-in-point: the standard
protectionist stance emphasizing that you personally do not trust other
RIRs to apply a fair determination of need to the transferred IP space.
Certainly not in the spirit of cooperation with other RIRs for the
greater good in sharing of sparse resources. But this is, of course,
just my opinion.

Regards,
Randy.