[arin-ppml] ARIN-2011-1: ARIN Inter-RIR Transfers - Last Call

[Scott Leibrand]

On Wed, Oct 19, 2011 at 1:33 PM, William Herrin <bill at herrin.us> wrote:

> On Wed, Oct 19, 2011 at 4:02 PM, Owen DeLong <owen at delong.com> wrote:
> > On Oct 19, 2011, at 9:36 PM, William Herrin <bill at herrin.us> wrote:
> >> On Wed, Oct 19, 2011 at 3:11 PM, ARIN <info at arin.net> wrote:
> >>> 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.
> >>
> >>
> >> Am I the only one who doesn't think that transfers between ARIN
> >> registrants and transfers between RIR's should be mashed into the same
> >> policy subsection?
> >
> > They aren't. There is nothing about transfers between RIR's here other
> than the role the RIRs play in transfers between registrants in different
> RIR's service regions.
>
> I don't think in-region transfers between two ARIN registrants and
> out-region transfers between an ARIN registrant and a non-ARIN
> registrant belong in the same subsection. I think mashing them
> together in one section clutters and confuses the issues for both.
>
> Would you like me to find another few ways to restate my objection, or
> are you tracking now despite any other possible ways to interpret the
> words?
>

Objection noted.  The only other thing you might be able to help us with is
actual suggested text changes that you feel makes in more clear.  When I
drafted this text I was striving for as few (new) words as possible, while
being as clear and explicit as possible.  If you can find a better balance
there, I'm all ears.


> >> Besides, doesn't this language prevent inter-region address transfer
> >> due to mergers or acquisitions? If I want to buy a web hosting shop
> >> and move it off shore, why should I be denied?
> >>
> > There remain all the same options that have always existed under section
> 8.2 for such actions.
>
> Which are?
>

I believe there are a handful of companies holding ARIN space outside of the
ARIN region.  This proposal would not necessarily allow them to transfer
their registration to another RIR.  We discussed this in the AC meeting, and
one of the points I recall was that 8.2 transfers are generally only done
when the network assets that justified the number resources are transferred
between organizations.  Since those network assets usually can't be moved
between continents, inter-regional 8.2 transfers should be fairly rare.  In
any case, we felt it would be better to fully consider that issue as a
separate policy proposal, since the question of inter-regional 8.2 transfers
wasn't sufficiently discussed on PPML or at the public policy meeting in
Philly.


>
> 2011-1 as published 9/22/11 applied equally to 8.2 and 8.3 transfers.
>

I believe that is one valid interpretation of the unfortunately vague
language of the 9/22 version of 2011-1.  ARIN staff mentioned that they
couldn't actually do a staff assessment of that text, and instead assessed
what they interpreted our intent to be.


> I also object to the end-run around the PDP. The AC is not empowered
> to insert a proposal directly to Last Call and this proposal is (at
> best) the "same idea" as proposal 2011-1. Structurally, it's a whole
> new proposal which should go through the normal draft and discussion
> process. Should the board feel action is urgent, they alone hold the
> authority to jump that process.
>

Objection noted.  I would argue that there was a consensus at the PPM in
Philadelphia for the AC to make revisions to 2011-1 to address the concerns
discussed at the meeting, and there was an overwhelming consensus in favor
of inter-regional transfers.  So even aside from any urgency concerns, I
believe that the revisions to 2011-1 being discussed today have been
adequately discussed at the public policy meeting, and are appropriate to
send to last call.

If anyone else feels strongly on this subject, or more importantly has any
objections or suggestions to the draft policy text that was just sent out to
last call, please speak up.  I voted for an extended last call to ensure we
captured all of that input, so the AC can evaluate it at our next meeting.
And thanks, Bill, for jumping in with substantive comments so quickly.

-Scott
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