[arin-ppml] IPv4 Transfer Policy Change to Keep Whois Accurate

[Owen DeLong]

I oppose the policy as written.

Abandoning our stewardship role for the sake of making it more likely
people will register their misappropriation of community resources is
like legalizing bank robbery in the hopes that the thieves will pay 
income tax on their ill gotten gains.

Owen

On May 11, 2011, at 11:03 AM, Mike Burns wrote:

> 1. Policy Proposal Name: IPv4 Transfer Policy Change to Keep Whois Accurate
>  
> 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 11th, 2011
>  
> 5. Proposal type: modify
>  
> 6. Policy term: permanent
>  
> 7. 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.
>  
> 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.
> 
> 
> 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 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.
>  
> 9. Timetable for implementation: immediate.
>  
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