[arin-ppml] Draft Policy 2011-12: Set Transfer Need to 24 months

[ARIN]

Draft Policy ARIN-2011-12
Set Transfer Need to 24 months


On 18 August 2011 the ARIN Advisory Council (AC) selected "Set Transfer 
Need to 24 months" as a  draft policy for adoption discussion on the 
PPML and at the Public Policy Meeting in Philadelphia in October.

The draft was developed by the AC from policy proposal "ARIN-prop-147 
Set Transfer Need to 24 months." Per the Policy Development Process the 
AC submitted text to ARIN for a staff and legal assessment prior to its 
selection as a draft policy. Below the draft policy is the ARIN staff 
and legal assessment, followed by the text that was submitted by the AC.

Draft Policy ARIN-2011-12 is below and can be found at:
https://www.arin.net/policy/proposals/2011_12.html

You are encouraged to discuss Draft Policy 2011-12 on the PPML prior to
the October Public Policy Meeting. Both the discussion on the list and
at the meeting will be used by the ARIN Advisory Council to determine
the community consensus for adopting this as policy.

The ARIN Policy Development Process can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Member Services
American Registry for Internet Numbers (ARIN)


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Draft Policy ARIN-2011-12
Set Transfer Need to 24 months

Date: 24 August 2011

Policy statement:

If ARIN-prop-146 passes, also modify "will be utilized within 12 months" 
to "will be utilized within 24 months"

Rationale:

Due to the complexity of the financial transaction that may be
involved and the associated budgeting on the part of the receiving
organization, 24 months is a more reasonable amount of forecast need to
allow to be fulfilled via the transfer process.

Potential benefit to address aggregation by allowing fewer larger
transfers sooner.

Change from previous version: uses the new language proposed in
ARIN-prop-146 rather than modifying 4.2.4.4. Also no longer modifies
4.2.4.4 to apply to section 8.2 transfers.

Timetable for implementation: immediate


#####


ARIN STAFF ASSESSMENT

Proposal:  ARIN-prop-147 Set Transfer Need to 24 months
Date of Assessment: 18 August 2011

1.  Proposal Summary (Staff Understanding)

This is a conditional policy proposal, germane only if prop-146 
eventually becomes ratified policy. This proposal would modify 
prop-146's changes to NRPM 8.3 to allow 8.3 requestors to show justified 
need for 8.3 transfers within a 24-month window, rather than the 
12-month window proposed by prop-146.

2. Comments

A. ARIN Staff Comments
•	This proposal would still require an organization requesting an 8.3 
transfer to qualify for the space under current ARIN policies, but would 
exempt them from the 3 month supply limitations currently set forth in 
NRPM 4.2.1.4 “Slow Start” and 4.2.2.1.3 “Three Months” and instead allow 
them to qualify for a 24 month supply of IPv4 address space.
•	This change would make the specified transfer policy fit more 
situations, at the risk that addresses may go to parties whose need does 
not actually materialize as expected based on their projected allocation 
rates.

B. ARIN General Counsel

ARIN counsel strongly supports the immediate extension of assessed need 
from 12 to 24 months for proposed transfers. It is clear the longer time 
period will appropriately facilitate legally simpler transactions by 
those who are seeking to follow ARIN's policies. It may also meet goals 
of allowing larger blocs to be transferred to meet the needs of a single 
entity.

3. Resource Impact

This policy would have minimal resource impact from an implementation 
aspect.  It is estimated that implementation would occur within 3 months 
after ratification by the ARIN Board of Trustees. The following would be 
needed in order to implement:

•	Updated guidelines
•	Staff training

4. Proposal Text

ARIN-prop-147
Set Transfer Need to 24 months

Policy statement:

If ARIN-prop-146 passes, also modify "will be utilized within 12 months" 
to "will be utilized within 24 months"

Rationale:

Due to the complexity of the financial transaction that may be
involved and the associated budgeting on the part of the receiving
organization, 24 months is a more reasonable amount of forecast need to
allow to be fulfilled via the transfer process.
Potential benefit to address aggregation by allowing fewer larger
transfers sooner.

Change from previous version: uses the new language proposed in
ARIN-prop-146 rather than modifying 4.2.4.4. Also no longer modifies
4.2.4.4 to apply to section 8.2 transfers.

Timetable for implementation: immediate