[arin-ppml] ARIN-2011-1: ARIN Inter-RIR Transfers - Revised Assessment

Thu Nov 10 11:30:17 EST 2011

Along with the majority vote at the last conference.  I support this proposal.

Marla

________________________________
From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of ARIN
Sent: Wednesday, November 09, 2011 10:52 AM
To: arin-ppml at arin.net
Subject: [arin-ppml] ARIN-2011-1: ARIN Inter-RIR Transfers - Revised Assessment

Below is a revised staff and legal assessment for 2011-1: ARIN Inter-RIR Transfers.

The draft policy text is below and available at:
https://www.arin.net/policy/proposals/2011_1.html<https://www.arin.net/policy/proposals/>

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)

##*##

ARIN STAFF ASSESSMENT 2011-1 (Revised)
Draft Policy:  2011-1 ARIN Inter-RIR Transfers
Date of Assessment:  9 Nov 2011
1.  Proposal Summary (Staff Understanding)
This revised proposal directly modifies section 8.3 "Transfers to Specified Recipients" to allow specified transfers to or from organizations in other regions, and it eliminates the single aggregate language.
2. Comments
     A.    ARIN Staff Comments

·      The phrase, "compatible, needs-based policies" is not specifically defined.  If adopted, staff would consider a “compatible, needs-based policy" for outward transfers as a transfer policy at another RIR that requires the recipient to have operational need for the address space, and to demonstrate that need to their RIR for transfer approval.

·      Allowing the transfer of number resources between RIRs will require careful coordination between RIRs in order to avoid reverse DNS zone fragmentation and synchronization problems.   The ability to maintain the necessary coordination between RIRs is unproven if Inter-RIR transfers become extremely common.

·      This proposal doesn’t have any provisions to preclude organizations that have recently obtained IPv4 resources from ARIN from immediately releasing them for profit to a specified recipient. This policy may provide incentive for organizations to game the system by obtaining resources based on justified need, when the real intent is to sell them for profit. This behavior would directly violate certain terms and conditions of the RSA, but may be difficult for staff to distinguish from bona fide changes in circumstances.

<!--[if !supportLists]-->·      <!--[endif]-->General Staff Implementation Plan:
For transfers from the ARIN region into another RIR region:

1.     ARIN receives the transfer request template from the requestor and verifies that they are the authorized registrant of the resources.

2.     ARIN verifies that the recipient RIR has been confirmed to have a compatible needs-based transfer policy and then forwards the request to the recipient RIR.

3.     The Recipient RIR determines if the recipient meets its relevant policies.

4.     The Recipient RIR confirms to ARIN that the customer has met its transfer policy as a recipient, and asks ARIN to authorize the release of the resource to the recipient RIR.

5.     ARIN coordinates with the Recipient RIR to complete the transfer.
For transfers into the ARIN region from another RIR region:

1.     ARIN receives the transfer request template from the source RIR verifying that their customer is authorized to submit the transfer.

2.     ARIN contacts the proposed resource recipient to gather initial data needed to justify the 8.3 transfer and obtains a signed RSA from the resource recipient.

3.     ARIN applies its relevant policy criteria to the resource recipient

4.     When ready to approve, ARIN will contact the source RIR and have them authorize the release of the resource to ARIN.

<!--[if !supportLists]-->5.     <!--[endif]-->ARIN approves the transfer, receives transfer fee payment from the recipient, and will then complete the request by coordinating with the source RIR on the final transfer of the resource into the ARIN database (and de-registration from the source database), including the DNS zone coordination.
      B.  ARIN General Counsel Comments
 Adoption of this policy will materially assist ARIN's legal position.
3.  Resource Impact
This policy would have major resource impact from an implementation aspect.  It is estimated that implementation would occur within 9-12 months after ratification by the ARIN Board of Trustees. The following would be needed in order to implement:

<!--[if !supportLists]-->-   <!--[endif]-->Careful coordination between the RIRs on DNS issues and updates

<!--[if !supportLists]-->-   <!--[endif]-->Updated guidelines

-   Staff training
4.  Draft Policy 2011-1 Text
8.3 Transfers to Specified Recipients
In addition to transfers under section 8.2, IPv4 number resources may be
released to ARIN by the authorized resource holder or another RIR, in
whole or in part, for transfer to another specified organizational
recipient. Organizations in the ARIN region may receive transferred
number resources under RSA if they can demonstrate the need for such
resources in the amount which they can justify under current ARIN policies.
IPv4 address resources may be transferred to organizations in another
RIR's service region if they demonstrate need to their region's RIR,
according to that RIR's policies. Inter-regional transfers may take
place only via RIRs who agree to the transfer and share compatible,
needs-based policies. Such resources must be transferred in blocks of
/24 or larger and will become part of the resource holdings of the
recipient RIR.
Timetable for implementation: Upon ratification by the ARIN Board of Trustees
Note from the AC:
The Advisory Council reviewed the results of feedback from the ARIN
XXVIII Public Policy Meeting concerning Draft Policy 2011-1 Inter-RIR
Transfers. While there were concerns regarding the presented wording,
there was significant continued support for a policy enabling
Inter-Regional transfers of IPv4 number resources from organizations able
to make them available to any organization with valid requirements.
In addition to cumbersome wording, the presented text could not be
cleanly inserted into the NRPM. The following is new language that
directly modifies section 8.3 "Transfers to Specified Recipients" to
allow such transfers to or from organizations in other regions.
The first paragraph is a modified version of the current 8.3 policy
language, envisioning resources being released to ARIN by the authorized
resources holder or additionally by another RIR to be transferred to a
specified recipient. The second sentence was reorganized to emphasize
that it applies to an organization within the ARIN region that will
receive such a specified transfer, and to eliminate the single aggregate
language per 2011-10 which is also being sent to last call.
The new second paragraph adds language enabling transfers to a specified
recipient in another RIR's service region. This language specifies that
such recipients justify their need to their RIR, following that RIR's
policies. ARIN will verify that there is a compatible needs based
policy that the other RIR will use to evaluate the need of the recipient
and that both RIR's agree to the transfer. Implicit in the intent of
the language presented and in conformance with statements made, the size
of the block to be transferred is identified as /24 or larger, for
obvious practical reasons.
In accordance with concern for immediate adoption, the AC chose to
forward this version to last call. Concerns expressed by some
stakeholders for further controls were noted by the AC, and are being
considered for future policy modification, assuaged in part by ARIN
staff assurances that if any significant abuse of this policy were to
occur, then the policy could easily be suspended.

On 10/19/11 3:11 PM, ARIN wrote:
The ARIN Advisory Council (AC) met on 14 October 2011 and decided to
send an amended version of the following draft policy to an extended last call:

  ARIN-2011-1: ARIN Inter-RIR Transfers

The AC provided the following statement:

********
The Advisory Council reviewed the results of feedback from the ARIN
XXVIII Public Policy Meeting concerning Draft Policy 2011-1 Inter-RIR
Transfers.  While there were concerns regarding the presented wording,
there was significant continued support for a policy enabling
Inter-Regional transfers of IPv4 number resources from organizations able to make them available to any organization with valid requirements.

In addition to cumbersome wording, the presented text could not be
cleanly inserted into the NRPM.  The following is new language that
directly modifies section 8.3 "Transfers to Specified Recipients" to
allow such transfers to or from organizations in other regions.

The first paragraph is a modified version of the current 8.3 policy
language, envisioning resources being released to ARIN by the authorized
resources holder or additionally by another RIR to be transferred to a
specified recipient.  The second sentence was reorganized to emphasize
that it applies to an organization within the ARIN region that will
receive such a specified transfer, and to eliminate the single aggregate
language per 2011-10 which is also being sent to last call.

The new second paragraph adds language enabling transfers to a specified
recipient in another RIR's service region.  This language specifies that
such recipients justify their need to their RIR, following that RIR's
policies.  ARIN will verify that there is a compatible needs based
policy that the other RIR will use to evaluate the need of the recipient
and that both RIR's agree to the transfer. Implicit in the intent of
the language presented and in conformance with statements made, the size
of the block to be transferred is identified as /24 or larger, for
obvious practical reasons.

In accordance with concern for immediate adoption, the AC chose to
forward this version to last call.  Concerns expressed by some
stakeholders for further controls were noted by the AC, and are being
considered for future policy modification, assuaged in part by ARIN
staff assurances that if any significant abuse of this policy were to
occur, then the policy could easily be suspended.

The AC thanks everyone in the community for their help in crafting this
important policy and for your statements of support or other comments
during Last Call.
********

Feedback is encouraged during the last call period. All comments should
be provided to the Public Policy Mailing List. Last call for 2011-1 will
expire on 16 November 2011. After last call the AC will conduct their last call review.

The draft policy text is below and available at:
https://www.arin.net/policy/proposals/

The ARIN Policy Development Process is available at:
https://www.arin.net/policy/pdp.html

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)

## * ##

Draft Policy ARIN-2011-1
ARIN Inter-RIR Transfers

Date/version: 14 October 2011

Policy statement:

8.3 Transfers to Specified Recipients

In addition to transfers under section 8.2, IPv4 number resources may be
released to ARIN by the authorized resource holder or another RIR, in
whole or in part, for transfer to another specified organizational
recipient.  Organizations in the ARIN region may receive transferred
number resources under RSA if they can demonstrate the need for such
resources in the amount which they can justify under current ARIN policies.

IPv4 address resources may be transferred to organizations in another
RIR's service region if they demonstrate need to their region's RIR,
according to that RIR's policies. Inter-regional transfers may take
place only via RIRs who agree to the transfer and share compatible,
needs-based policies. Such resources must be transferred in blocks of
/24 or larger and will become part of the resource holdings of the
recipient RIR.

Timetable for implementation: immediate

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