[arin-ppml] Draft proposal that needs some wordsmithing

Owen DeLong owen at delong.com
Thu May 5 18:10:04 EDT 2011

On May 5, 2011, at 1:43 PM, Mike Burns wrote:

> 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.

I would call it a feature rather than a problem, but I agree that it is contrary to your intent.

> 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?
You could affect your intent by adding the following to your proposal:


- Resources received under this policy are subject to the audits specified
  in section twelve, except that the needs-basis shall not constitute an ability
  for ARIN to reclaim or request return of resources received under this policy.

However, that could have the effect on organizations that have a mixture of section 8 resources
and other resources being forced to renumber into the section 8 resources to support the
reclamation of their other resources that are no longer justified.

I'm not sure of a good or clean way to address the case where you have resources
subject to need and resources not subject to need, preserve the ability to audit, but
somehow only audit need on the resources received outside of section 8 and preserve
the needs-basis consideration for future resources expressed in this policy.

It gets very messy very quickly trying to surgically remove needs basis from a single
part of a body of policy where it has been an integral construct for the duration of that
body of policy's existence.


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