[arin-ppml] Draft Proposal for Needs-Free IPv4 Transfers

Mike Burns mike at nationwideinc.com
Tue May 10 11:56:13 EDT 2011


Thanks, John,

>After refreshing the LRSA, we might want to next compare it to the existing
>RSA to see if there are similar changes that can be made in order to keep
>the two documents as closely aligned as possible.



Part of my draft proposal includes a change to the RSA.
What is the process by which changes are made to the RSA or LRSA?
Is it allowable for a policy proposal to include proposed changes to either 
of these documents?
I would also like the documents to be closely aligned, and I think maybe 
there is some room, post-exhaust, to move them together by liberalizing the 
RSA to grant rights now only granted to LRSA signers.
Like the protection from utilization reviews.

My proposal would also allow RSA and LRSA signers to transfer without a 
needs requirement.

Taken together, these changes would give RSA and LRSA the rights to hold 
unused addresses and transfer them without a justification hurdle.

To my mind, the difference between them would blur significantly, and I 
believe more legacy holders would be inclined to sign either agreement if 
these rights were ensured by policy.
And this would serve the purposes of all who look back on legacy 
distributions with some regret over the lack of associated agreements, and 
who hope for an inclusive policy which will bring legacy holders into the 
fold.

Finally, do you concur with my reading of NRPM which does not seem to have 
language in section 12 which clearly allows for a utilization-based resource 
review?
My reading of it is that the reviewers look for policy compliance, but all 
the policy I read about utilization is in the context of an original or 
subsequent allocation.
On the other hand, the RSA has clear language allowing review for compliance 
with the intended purpose of the addresses as expressed on the application 
for resources.
I don't know if it is permissible to change the RSA via the normal policy 
development process, though.

Regards,

Mike








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