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

Kevin Blumberg kevinb at thewire.ca
Wed Oct 19 22:54:07 EDT 2011

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.

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". 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.  

Kevin Blumberg
T 416.214.9473 x31
F 416.862.9473
kevinb at thewire.ca

> -----Original Message-----
> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On
> Behalf Of ARIN
> Sent: Wednesday, October 19, 2011 3:12 PM
> To: arin-ppml at arin.net
> Subject: [arin-ppml] ARIN-2011-1: ARIN Inter-RIR Transfers - Last Call
> 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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