[arin-ppml] Prop-151: Clarifying requirements for IPv4 transfers (was "Limiting needs...")

[Alexander, Daniel]

Hello All,

The Staff and Legal review has been provided to the AC for prop-151. The
review focused mainly on the 12 month needs assessment given that the
Board has recently ratified 2011-12 which changed the transfer needs
assessment to 24 months. This update and a few others are listed below.

Another change that has been suggested is to include transfers in the 12
month restrictions on the source of a transfer. The resulting text would
read as follows.

"The source entity must not have received a transfer, allocation, or
assignment of IPv4 number resources from ARIN for the 12 months prior to
the approval of a transfer request."

The intent of this change would be to limit an organization from
"flipping" transferred resources. Do people feel that this should be
incorporated into the text?

All feedback is appreciated.

Dan Alexander
AC Shepherd


Changes to prop-151 text:

- Restored a needs requirement to the text.
- Eliminated the /12 cap on resources received.
- Removed the suggestions to altering the text of the RSA.
- Removed the section regarding "Conditions on the IPv4 address block".
- Revised the condition of space being administered by ARIN to incorporate
inter-RIR transfers as a result of 2011-1.
- Moved the minimum transfer size requirement down to remaining Conditions.
- Separated in-region and inter-region transfers into separate sections.
- Clarified the starting point of the 12 month restrictions as a result of
staff feedback.
- Changed the proposal title from "Limiting needs..." to "Clarifying
Requirements..." as a result of feedback.
- Updated needs requirement from 12 to 24 months as a result of 2011-12.



Current text:

Replace Section 8.3 with

8.3 Transfers between Specified Recipients within the ARIN Region.

In addition to transfers under section 8.2, IPv4 numbers resources may be
transferred according to the following conditions.

Conditions on source of the transfer:

* The source entity must be the current registered holder of the IPv4
address resources, and not be involved in any dispute as to the status of
those resources.
* The source entity will be ineligible to receive any further IPv4 address
allocations or assignments from ARIN for a period of 12 months after a
transfer approval, or until the exhaustion of ARIN's IPv4 space, whichever
occurs first.
* The source entity must not have received an allocation or assignment of
IPv4 number resources from ARIN for the 12 months prior to the approval of
a transfer request.
* The minimum transfer size is a /24


Conditions on recipient of the transfer:

* The recipient must demonstrate the need for up to a 24 month supply of
IP address resources under current ARIN policies and sign an RSA.
* The resources transferred will be subject to current ARIN policies.


Add Section 8.4 Inter-RIR Transfers to Specified Recipients

Inter-regional transfers may take place only via RIRs who agree to the
transfer and share reciprocal, compatible, needs-based policies.

Conditions on source of the transfer:

* The source entity must be the current rights holder of the IPv4 address
resources recognized by the RIR responsible for the resources, and not be
involved in any dispute as to the status of those resources.
* Source entities outside of the ARIN region must meet any requirements
defined by the RIR where the source entity holds the registration.
* Source entities within the ARIN region will not be eligible to receive
any further IPv4 address allocations or assignments from ARIN for a period
of 12 months after a transfer approval, or until the exhaustion of ARIN's
IPv4 space, whichever occurs first.
* Source entities within the ARIN region must not have received an
allocation or assignment of IPv4 number resources from ARIN for the 12
months prior to the approval of a transfer request.
* The minimum transfer size is a /24.


Conditions on recipient of the transfer:

* The conditions on a recipient outside of the ARIN region will be defined
by the policies of the receiving RIR.
* Recipients within the ARIN region will be subject to current ARIN
policies and sign an RSA for the resources being received.
* Recipients within the ARIN region must demonstrate the need for up to a
24 month supply of IPv4 address space.
* The minimum transfer size is a /24

Rationale:

The original text of this proposal attempted to simplify the requirements
of an IPv4 address transfer while protecting any resources in the ARIN
free pool. This revision is a result of feedback from the mailing list,
and discussions with the original author. The one key point that has been
removed from the original text is that a needs based review remains in
place.

The current text attempts to retain the original concepts of protecting
any ARIN free pool, and incorporating it with the point of bringing
resources under RSA. The resulting text attempts to put safeguards in
place on the practice of paid transfers by creating a black out period for
requests from the free pool. The text also tries to incorporate
discussions regarding inter-RIR transfers and come up with language that
includes the free pool protections for transfers in and out of the Region.

Timetable for implementation: immediate.