[arin-ppml] ARIN-prop-151 Limiting Needs Requirements for IPv4 Transfers

[Azinger, Marla]

I don't support this as written.

1. I would like to see the two parts separated into different proposals.
2. I would need to see how current policy on the table goes before trying to change anything more in section 8.3
3. I would support  policy that says "ARIN will not use utilization as a measure of policy compliance for addresses transferred."  Conservation in the grand scheme has been achieved as much as possible.  At this point in time any hoarding that might occur is really short term in the grand scheme.  The worst case scerio that was used as a fear factor (scenerio was that some large entity would by up all the remaining space on the market and force other business out of business) in the past, doesnt even look possible in the present, so protecting against hoarding on the grand scheme is really pointless.  Taking action to protect against this could even possibly be more damaging then helpful when you consider the services that could end up in a temporary halt because they werent ablet to create a transition time frame.

Cheers
Marla

-----Original Message-----
From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of ARIN
Sent: Wednesday, May 18, 2011 10:06 AM
To: arin-ppml at arin.net
Subject: [arin-ppml] ARIN-prop-151 Limiting Needs Requirements for IPv4 Transfers

ARIN-prop-151 Limiting Needs Requirements for IPv4 Transfers

Corrected proposal name.

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-151 Limiting Needs Requirements for IPv4 Transfers

Proposal Originator: Mike Burns

Proposal Version: 1

Date: 18 May 2011

Proposal type: modify

Policy term: permanent

Policy statement:

Replace Section 8.3 with

8.3 ARIN will process and record IPv4 address transfer requests.

Conditions on the IPv4 address block:

     - The minimum transfer size is a /24

     - The address block must be in the range of addresses administered
       by ARIN

Conditions on source of the transfer:

     - The source entity must be the current rights holder of the
       IPv4 address resources, and not be involved in any dispute as to
       the status of those resources.

     - The source entity will be ineligible to receive any further IPv4
       address allocations or assignments from ARIN for a period of 12
       months after the transfer, or until the exhaustion of ARIN's
       IPv4 space, whichever occurs first.

     - The source entity must not have received an allocation from
       ARIN for the 12 months prior to the transfer.


   Conditions on recipient of the transfer:

     - The recipient entity must be a current ARIN account holder.

     - The recipient must sign an RSA with ARIN.

     - The recipient entity of the transferred resources will be subject
       to current ARIN policies. In particular, in any subsequent ARIN
       IPv4 address allocation request, the recipient will be required
       to account for the efficient utilization of all IPv4 address
       space held, including all transferred resources.

     - If the recipient has already received the equivalent of a /12
       of addresses in the prior 12 months, the recipient must
       demonstrate the need for additional resources in the exact amount
       which they can justify under current ARIN policies.

and request the AC to modify section 8 of the current RSA to remove references to "intended purposes."

Replace
ARIN may review, at any time, Applicant's use of previously allocated or assigned number resources or Services received from ARIN to determine if Applicant is complying with this Agreement and the Policies and is using the Services for their intended purposes.  Without limiting the foregoing, if Applicant is a holder of a direct allocation or assignment from ARIN, Applicant agrees that it will use the number resources solely for uses consistent with its application and this Agreement, including, for example, its internal infrastructure or to provide Internet access to its customer base. If ARIN determines that the number resources or any other Services are not being used in compliance with this Agreement, the Policies, or the purposes for which they are intended, ARIN may: (i) revoke the number resources; (ii) cease providing the Services to Applicant; and/or (iii) terminate this Agreement.

with

ARIN may review, at any time, any Applicant's use of previously allocated or assigned number resources or Services received from ARIN to determine if Applicant is complying with this Agreement and the Policies.  Without limiting the foregoing, if Applicant is a holder of a direct allocation or direct assignment from ARIN, Applicant agrees that it will use the number resources solely for uses consistent with this Agreement, including, for example, its internal infrastructure or to provide Internet access to its customer base. If ARIN determines that the number resources or any other Services are not being used in compliance with this Agreement or the Policies, ARIN may: (i) revoke the number resources; (ii) cease providing the Services to Applicant; and/or
(iii) terminate this Agreement.

and add to the NRPM Section 12:

10.    ARIN will not use utilization as a measure of policy compliance
for addresses transferred under 8.3.


Rationale:

Current ARIN policies relating to the registration of transfer of address holdings limit the eligibility of registration of transfers to those relating to mergers and acquisitions of entities that are administering an operational network, or to those who agree to sign either an RSA or LRSA with ARIN and subject the buyer to needs analysis and the seller to a potential ARIN review under RSA section 8.

It is currently anticipated that the IPv4 unallocated address pool will be exhausted within a couple of years at ARIN, and earlier than that in other regions, and the  transition to IPv6-based service delivery is likely to take longer than the remaining period of unallocated address availability. Accordingly, it is likely that demand for IPv4 addresses will continue beyond the time of unallocated address pool exhaustion, leading to a period of movement of IPv4 address blocks between address holders to meet such continuing demand for IPv4 address blocks.

The underlying proposition behind this policy proposal is that the registry of IPv4 addresses operated by ARIN is of general utility and value only while it accurately describes the current state of address distribution. If a class of address movement transactions are excluded from being entered in the registry, then the registry will have decreasing value to the broader community, and the integrity of the network itself is thereby compromised.  This proposal's central aim is to ensure the continuing utility and value of the ARIN address registry by allowing the registry to record transactions where IPv4 addresses are transfered between ARIN account holders.

It proposes that ARIN will recognise and register a transfer of addresses where the parties to the transfer are 'known' to ARIN and that the address block being transferred is part of ARIN's current address set.

The proposal does not prescribe how such transfers may occur, nor impose any further constraints on the transfer or on the parties involved other than those described in this proposal.

Timetable for implementation: immediate.




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