[arin-ppml] Draft Policy ARIN-2011-1: ARIN Inter-RIR Transfers - revised

[ARIN]

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

ARIN-2011-1 has been revised. This draft policy is open for discussion
on this mailing list and will be on the agenda at the upcoming ARIN
Public Policy Meeting in Philedelphia.

ARIN-2011-1 is below and can be found at:
https://www.arin.net/policy/proposals/2011_1.html

Following the text is an ARIN staff assessment.

Regards,

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


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

Date: 22 September 2011

Policy statement:

Address resources may be transferred in or out of the ARIN region to 
those who demonstrate need and plan to deploy them for a networking 
purpose within 3 months. Such transfers will take place between RIRs who 
share compatible, needs-based policies supporting entities agreeing to 
the transfer and which otherwise meet both RIR's policies. Transferred 
resources will become part of the resource holdings of the recipient RIR 
unless otherwise agreed by both RIRs.

Rationale: Since individual RIRs now allow transfers, it makes sense to 
be able to transfer between regions as well. Reasoning....It is explicit 
about...

in or out of region,
that transfers are between RIRs that support needs-based policies,
that RIRs have to agree,
that parties meet all of both RIR policies
that it is needs based, and the need is for a networking purpose,
that the receiving RIR is entitled to the addresses

I think all these details were raised as objections at one time or 
another...so it seems best to waste a few more words to be explicit.

It is not explicit about...
block sizes
utilization of prior allocations,
assignments or transfers
RFC 2050
subsequent transfers

Timetable for implementation: Upon ratification by the ARIN Board of 
Trustees


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ARIN Staff Assessment

Draft Policy:  2011-1 ARIN Inter-RIR Transfers

1.  Proposal Summary (Staff Understanding)

This proposal would allow transfers of address space to and from the 
ARIN region as long as both RIRs agree to the transfer, and apply 
compatible, needs-based policies.

2. Comments

A. ARIN Staff Comments

•	The proposed policy language is unclear, vague, and is wide open for 
interpretation.

•	The key phrase, "compatible, needs-based policies" is undefined. While 
many in the ARIN PPML community understand the intent of the phrase, it 
is really important that policy text be clear and understandable to all.
•	The phrase, "which otherwise meet both RIR's policies" is also vague. 
Which policies must the transferor and transferee meet? The text should 
be revised to be precise to fully convey the author's intent.

•	Note that the proper possessive of "RIR's policies" should be "RIRs' 
policies".

•	The last sentence says, " Transferred resources will become part of 
the resource holdings of the recipient RIR unless otherwise agreed by 
both RIRs”.  It is constructed so that it basically says “It will be 
this, unless you want that."   This isn't definitive policy text and 
should be clarified.

•	This policy seems to directly contradict NRPM 8.3, Transfers to
Specified Recipients, which disallows IPv4 number resources to be 
transferred outside of ARIN’s region.  Without a change to NRPM 8.3, 
ARIN would only be able to apply NRPM 8.2, Mergers and Acquisitions when 
reviewing inter-RIR policies.

•	The staff would implement this policy in the following manner:
•	For transfers from the ARIN region into another RIR region, ARIN
would:
•	Confirm that the other RIR has "compatible, needs-based policies
•	Apply the relevant ARIN transfer policy criteria to the resource
registrant
•	Seek confirmation from the other RIR that the requesting
organization is physically located and has a verified legal presence in
the region
•	Closely coordinate with the other RIR, informing them when ARIN
is ready to complete the transfer
•	Complete transfer upon confirmation from the other RIR that the
recipient has met that RIR’s applicable transfer policies

•	For transfers into the ARIN region from another RIR region, ARIN
would:
•	Confirm that the other RIR has "compatible, needs-based
policies
•	Apply the relevant ARIN transfer policy criteria to the resource
recipient
•	Verify that the requesting organization is physically located
and has a verified legal presence in the region
•	Closely coordinate with the other RIR, informing them when ARIN
is ready to complete the transfer
•	Complete transfer upon confirmation from the other RIR that the
registrant has met that RIR’s applicable transfer policies

•	The previous version of this proposal limited these transfers to IPv4 
space while this version does not.  Was that an oversight or did the 
author intend to have this policy apply to both IPv4 and IPv6 addresses?

•	This proposal allows the transfer of any IPv4 resource, whether
it be Legacy/ERX address space or address space that was directly
delegated to the RIR by IANA. Allowing the transfer of directly
delegated number resources between RIRs could cause a variety of issues
including:
• Zone fragmentation
• DNS synchronization problems
• Potential administrative and operational issues in coordinating
    reverse addressing

B. ARIN General Counsel

1.  I suggest one major addition to this policy, which may be totally 
consistent with the drafter's intent. Currently, it is my understanding 
that ARIN policy does not permit transfers within the region unless the 
resources are covered by RSA or LRSA. The language of this section might 
properly be clarified to reinforce that resources not already under 
registration services agreement may not be transferred until ARIN has 
validated the correct resource holder

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:

•	Careful coordination between the RIRs on DNS issues and updates
•	Updated guidelines
•	Staff training