[arin-ppml] Draft proposal that needs some wordsmithing

Mike Burns mike at nationwideinc.com
Thu May 5 16:43:05 EDT 2011

Hi list,

I tried to put together a proposal to end needs requirements for transfers and I used the APNIC policy as a framework.
The problem is that as the proposal is structured below, there is a problem with the application of ARIN Resource Review policies in section 12.
Even if the transfer happens without regard to need, since the transferred resources would be received by an ARIN account holder and would be subject to ARIN's policies, then ARIN could feasibly do a resource review immediately post transfer to effectively retain a needs requirement.

My intent is that ARIN resource reviews continue to happen for purposes other than need.
So for fraud, for hijackings, for failure to pay ARIN's bills, I support resource review and recovery.
But not for need.
I was hoping not to have to mess with section 12 of the NRPM. Can somebody suggest a way to modify my draft proposal to effect my intent in a graceful manner which doesn't require modifications to section 12?

Thanks for any help you can offer on this matter or any other issues related to this draft.



1. Policy Proposal Name: New IPv4 Transfer policy

2. Proposal Originator:
      a. Name: Mike Burns
      b. Email: mike at sum.net
      c. Phone: 1-863-494-7692 x105
      d. Organization: Nationwide Computer Systems

3. Proposal Version: 1

4. Date: May 5th, 2011

5. Proposal type: modify

6. Policy term: permanent

7. Policy statement:

Replace Section 8 with 

8.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.

  Conditions on recipient of the transfer:

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

    - 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.

8. 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 audit.

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.

9. Timetable for implementation: immediate.

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