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

[ARIN]

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.