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

[Jeffrey Lyon]

On Tue, Feb 21, 2012 at 3:04 PM, Chris Grundemann <cgrundemann at gmail.com> wrote:
> 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
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That inclusion also permits organizations that require additional
space from obtaining it, which I would oppose.

Jeff

-- 
Jeffrey Lyon, Leadership Team
jeffrey.lyon at blacklotus.net | http://www.blacklotus.net
Black Lotus Communications - AS32421
First and Leading in DDoS Protection Solutions