[arin-ppml] 2014-2 8.4 Anti-flip Language

[Bill Darte]

Thanks to Owen and Scott for beginning a conversation about this Draft.
Scott....given the other restriction that you reference, do you prefer one
alternative over another....does the addition of an operational time frame
associated with option #2 improve its ability to accomplish the problem
statement.....

"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 accidentally 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 block being used
in Asia over to APNIC. The block was legacy. But because we had gotten a
new block in 2013, we were prevented from moving the old block to a
different RIR."

bd


On Sat, Feb 22, 2014 at 5:28 PM, Scott Leibrand <scottleibrand at gmail.com>wrote:

> There is another restriction already in 8.3, which reads "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."  In light of that, do you still see a problem with #3?
>
> -Scott
>
>
> On Sat, Feb 22, 2014 at 3:06 PM, Owen DeLong <owen at delong.com> wrote:
>
>> Several options are being discussed regarding this proposal:
>>
>>>
>> 1. Use the existing last sentence as is and ask ARIN staff to be
>> particularly watchful for seeming abuse and to bring such back to the
>> community through regular Policy Experience Reports.  There was discussion
>> about this option suggesting that by the time abuse was recognized and
>> reported, and given limited existing free pool stocks and the extended
>> policy development cycle....this option is mute.
>>
>> 2. Remove the clause 'and its subsidiaries' and or modify it in such a
>> way as to mitigate the risk of a laundering of addresses through fraudulent
>> transfers, but potentially limit the utility of organizations who may have
>> complex organizations structures in use internationally.
>>
>> 3. Take an alternative tack and simply restrict the Inter-RIR re-org
>> transfer of the 'recently issued block' only, allowing other existing
>> blocks to be transferred without restriction by recent block acquisition.
>> This alternative seems to have been expressed and supported in the recent
>> Atlanta Public Policy Consultation.
>>
>>
>> It is my opinion that option 3 is perilous in that it allows a large
>> resource holder to sell off their address space out of region while
>> backfilling from the ARIN free pool.
>>
>> As such, I am much more comfortable with option 2. One set of language
>> that was suggested which I like is:
>>
>> "...subsidiaries having been operational for a minimum of 18 months."
>>
>> While this might not prevent all possible subsidiary-based rinse-repeat
>> abuse scenarios, it would at least prevent the obvious subsidiary created
>> for this purpose scenario and certainly provides better protections than
>> proposal number 3.
>>
>> I think option 1 is probably an unfair burden for the ARIN staff and
>> makes policy vague in a way that would be difficult, if not impossible, to
>> reliably enforce and may be even harder to defend in the event of
>> litigation. This is strictly my own opinion as a member of the community
>> and I have not discussed the matter with legal council or even the other
>> members of the AC.
>>
>> Owen
>>
>>
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>
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