[arin-ppml] What do you think of 2011-1 (now in Last Call)?

Andy Linton asjl at ecs.vuw.ac.nz
Wed Nov 9 19:20:37 EST 2011

On Thu, Nov 10, 2011 at 4:31 AM, William Herrin <bill at herrin.us> wrote:

> ARIN doesn't use National Internet Registries (NIRs). LIRs (ISPs) and
> large or multihomed end-users register addresses directly with ARIN.
> APNIC prefers to create NIRs, country-level registries, and then have
> LIRs and end-users register addresses there instead.

I'd be wary of characterising the structure in the APNIC region as
"APNIC prefers to create NIRs...". I don't believe that this is correct.
There are NIRs in the APNIC region but many economies do not have such
an entity e.g. Australia, New Zealand, India (although they are seeking
to create one). Several of the NIRs have been around for many years and
predate APNIC (see the list of founding members at

The NIRs serve a very useful function in this region where English is
not the first language for many of our members and allow people in those
countries that have them to deal with their number registry in their
native language and in a particular cultural framework. It's worth
remembering that in the ARIN region which has a different set of
cultural and language constraints.

> Does the caveat in 096 mean that NIRs in the APNIC region are not
> obligated to allow their registrants to transfer address to an
> ARIN-region registrant even as ARIN is obligated to permit transfers
> to their registrants from ARIN holdings? Without having received an
> authoritative answer from APNIC leadership we can only speculate.

I'd very wary of interpreting Clause 7 of prop-096 as an attempt to
create some loophole to thwart transfer policy. Every policy proposal
that comes before the APNIC Policy SIG has a clause 7 - "Effect on the
RIRs" and this usually reads something like "This will affect NIR
members in the same way as APNIC members."

In this case the authors have chosen to use the phrase Bill has pointed
out, "It is the NIR's choice as to whether to adopt this policy". I can
recall no discussion on this at the two meetings where this policy was
discussed, nor was it raised on the mailing list as an issue and I
believe that this is something that has got through our sanity filters

I think it's worth noting that the APNIC policy document "NIR Criteria"
(http://www.apnic.net/policy/nir-criteria/text) has the following clear

2.3	Policy framework

	All NIRs operate within the policy framework of the APNIC
	region and of the wider global Internet community, and should
	implement and enforce regional and global policies at all

	An NIR may implement local policies, however these should not
	conflict in any way with regional or global policies. Any
	substantial policy change proposed within an NIR�s community
	should be brought to the APNIC community for approval through
	existing open policymaking mechanisms.

2.4	Local procedures

	NIRs are expected to implement operational procedures which
	suit the specific conditions of the environment in which they
	operate, and they should have maximum flexibility and
	autonomy in the development of those procedures. However such
	procedures must be consistent with APNIC operational
	requirements, as detailed below.

So while there's some possibility that this clause *could* be used to
modify this transfer policy in some radical way by an NIR, I think it's
highly unlikely.

I'm happy to raise this for clarification with the APNIC Policy SIG but
I don't believe that this should be used as a mechanism to derail the
current discussions in your region. There may be reasons for ARIN
members to have reservations about transfer policy but I don't believe
this is one of them.

Andy Linton
APNIC Policy SIG Chair

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