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

[David Farmer]

On 10/19/11 21:54 CDT, Kevin Blumberg wrote:
> I will endeavor to be helpful but I also share the concern about the
> significant changes in the draft policy from the meeting and what was
> brought to last call.

Thank you.

> I see that "entities agreeing to the transfer and which otherwise
> meet both RIR's policies." was removed, which I considered to be a
> bi-lateral justification. That shifted the onus to "share compatible,
> needs based policies".

In my opinion that text created confusion that we wanted to require both 
RIR's criteria for justified need to be satisfied by the organization 
that is receiving the resources.  Rather than the source organization 
meeting the requirements of it RIR and the receiving organization 
meeting the requirements of it RIR.  Even if you believe the text meant 
that both policies were to apply, on both ends, I don't believe that how 
ARIN staff said they would implement that language.

By replacing that with  "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."  we make it 
clear that the recipient justifies their need to their RIR using that 
RIR's policies.  I believe this is in line with how ARIN staff said they 
would implement the language anyway.

I believe It is impractical to have either RIR evaluate based on both 
policies, it is equally impractical to have each RIR evaluate both 
organizations based on there separate policies.  The only reasonable 
option it to have the source organization evaluated based on their RIR's 
policies and the receiving organization evaluated based on their RIR's 
policies.

> If that is the case I don't believe that
> "compatible" is strong enough and in my mind is way to ambiguous. It
> also removes any of the other provisions of the NRPM which might be
> required if abuse of the policy is found.

However, we are also saying that the other RIR must have a compatible 
needs based policy, and yes that is still a little ambiguous.  However, 
by stating that the receiving organization must  "demonstrate need to 
their region's RIR, according to that RIR's policies", "compatible" now 
has much more meaning and context that it didn't have before.

The other RIR must have a needs based policy compatible with the concept 
of receiving organization demonstrating its need to the RIR, and that 
RIR evaluating it.  So, if the other RIR didn't require any kind of 
demonstrated need, or there were no criteria to evaluate against, it 
therefore wouldn't be a compatible policy.  So while some ambiguity 
remains, and probably needs to in order to allow for some room for staff 
to do the right thing, there is now a fundamental basis for determining 
what a compatible needs based policy should be.


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