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

Owen DeLong owen at delong.com
Tue Aug 23 21:39:22 EDT 2011

> 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.

I'll point out that in this case, it is quite literally a 4+1/APNIC vs other RIRs
where APNIC is the only RIR that abandoned needs basis. APNIC is also
considering Prop 096 at Busan which, if it reaches consensus, would restore
needs basis to the APNIC region.

Frankly, I view this as an attempt (however ill advised it might be) to bend
over backwards and facilitate transfers to the APNIC region in spite of the
fact that they have chosen to abandon needs-basis in their transfer policy.

I think it would be much better to pass 2011-1 even with the flaws that it
still contains and then leave it in the hands of the APNIC community to
determine whether they want to restore needs basis in order to be able
to transfer space in from other regions or not.

I very much hope that APNIC reaches consensus on Prop 096 and I encourage
anyone who is interested in policy in the APNIC region to join their PD WG
mailing list and support Proposal 096.

>>>> 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.

This is not enforcing ARIN's rules on another region. This is enforcing
ARIN's rules on addresses under ARIN stewardship prior to releasing
them to a point outside of ARIN's stewardship.

>> 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."

This is exactly why I think 2011-1 is a better alternative. In 2011-1,
we can enable transfers to any RIR in a trusting manner so long as they
maintain a needs-basis in managing all resources, whether initial issue
or transfer. APNIC stands alone as the only RIR that is currently ineligible
to receive transfers under 2011-1.

> 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.

I think the issue here is that one RIR would not apply ANY determination
of need under their policies for transferred IP space. I believe that if
APNIC chose to apply a needs-basis, we would trust them to administer
that needs-basis fairly. However, since they have stated that they will
not apply ANY needs basis, how can we trust them to apply a needs
basis fairly?


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