[arin-ppml] 8.2 Transfers at ARIN

John Curran jcurran at arin.net
Mon Dec 9 19:55:17 EST 2013

On Dec 10, 2013, at 7:43 AM, David Huberman <David.Huberman at microsoft.com> wrote:

> During my 14 years of experience on both sides of the ARIN request desk, and 
> watching Public Policy events for most of that time, it's clear to me that large
> swaths of 8.2 transfers go unapproved because the requestor abandons them. 
> Many of the requests are abandoned because some combination of policy and 
> procedure is considered too onerous and "not worth it" by the requestor. 

Agreed... (note that verification that the requester is actually 
an authorized party is often considered onerous by requesters.)

> Well, I guess we're disagreeing again.  Because as a customer and a former staffer,
> I believe Whois records are grossly out-of-date because of both abandoned transfer
> requests (at both approval and completion phases) and because of a desire to not
> put oneself through the onerous policy and procedural requirements ARIN presents.
> For years we know empirically that requestors were dismotivated from requesting
> 8.2 transfers to clean-up records in Whois because they were fearful of ARIN reclaiming
> parts of their /16s (or what-have-you) which were underutilized (even though no such
> process existed).

And this misunderstanding is certainly worth addressing, since we know it not
to be the case, and actually specifically contrary to the LRSA, for those that 
want that in writing.  

> More policy work on this front is needed, especially as the RSA and
> ARIN policy seem to be out of alignment.

We've signficantly clarified the language in both the LRSA and RSA for this reason, 
e.g. - "Except as set forth in this Legacy Agreement, (i) ARIN will take no action 
to reduce the Services currently provided for Included Number Resources due to lack 
of utilization by the Legacy Holder, and (ii) ARIN has no right to revoke any Included 
Number Resources under this Legacy Agreement due to lack of utilization by Legacy Holder. "  

I am not certain how it could be made clearer - parties not updating their Whois
info per NRPM 8.2 because they are "fearful of ARIN reclaiming (resources)...which 
were underutilized" are definitely confused.  I can think of other reasons not to 
enter into an LRSA (differences of perspectives on rights, t&c's, as discussed in
the LRSA FAQ - <https://www.arin.net/resources/legacy/>) but risk of revocation 
due to lack of use is a red herring.

> That policy work, combined with changes in
> procedures, hopefully leads to easier 8.2 transfers for requestors, and in turn, more 
> accuracy in Whois records.

I look forward to any proposals that come forth in this area...  Anything to improve
usability of the number resource policy (while still keeping with the community's goals)
is worth pursuing.

> So I guess going forward, I'll again say thank you for providing statistics promptly, and
> I'll start making proposals to align section 4.2, 8.2, 8.3, and 8.4 in a way that I hope 
> makes sense for network operators and operations in 2014 and beyond.


John Curran
President and CEO

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