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

[Chris Grundemann]

On Fri, Feb 17, 2012 at 09:42, Alexander, Daniel
<Daniel_Alexander at cable.comcast.com> wrote:
> 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?

This inclusion is absolutely mandatory to maintaining a needs-based
system. As such, the question should be reversed: "Is there any reason
to exclude transfers, when allocations and assignments are counted?"

Cheer,
~Chris

> 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.
>
>
>
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-- 
@ChrisGrundemann
http://chrisgrundemann.com