[arin-ppml] Draft Policy 2014-2 Improving 8.4 Anti-Flip Language

[Bill Darte]

Hello,

As policy shepherd for DP-2014-2, I am interested in comments about the
problem statement, need and efficacy of language drafted.  I have included
current information below.  A statement of support or opposition and brief
reasoning would be most helpful, but also suggestions on improvement are
also welcomed if you feel this draft moves our region in a positive
direction, but currently misses the mark.  Thanks!

*Problem Statement:*
*Current NRPM Language*: "Source entities within the ARIN region 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. This restriction does not include M&A transfers."

This prevents anyone who receives BLOCK A in 2014 from transferring to
another RIR a different block, BLOCK B, which was issued 5, 10, 15, 20
years ago. In my company, we needed to move a legacy block being used in
Asia over to APNIC. But because we had gotten a new block in 2013, we were
prevented from moving the old block to a different RIR.

*Proposed Language Modification: (Draft Policy statement) Change undelined*
Source entities within the ARIN region 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. This restriction does
not include M&A transfers. *Restrictions related to recent receipt of
blocks shall not apply to inter-RIR transfers within the same organization
and its subsidiaries.*

One comment has suggested that the clause '*and its subsidiaries*' opens
opportunity for abuse.......another comment attempting to mitigate this
possibility suggested the clause be modified as....'and its
subsidiaries *providing
network services*'

Thank you for sharing your insights and for being part of the ARIN open,
bottom up, policy development process.

Bill Darte
ARIN Advisory Council
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