[arin-ppml] Draft Policy ARIN-2014-15: Allow Inter-RIR ASN Transfers - revised

[Scott Leibrand]

For context, this revision just brings the policy in line with what was
discussed at the PPC, addressing a concern raised with the previous
iteration of this policy (that transferring ASN resources should not block
receipt of IPv4 resources, or vice versa).

-Scott


On Mon, Jul 28, 2014 at 2:26 PM, ARIN <info at arin.net> wrote:

> Draft Policy ARIN-2014-15
> Allow Inter-RIR ASN Transfers
>
> ARIN-2014-15 has been revised.
>
> Draft Policy ARIN-2014-15 is below and can be found at:
> https://www.arin.net/policy/proposals/2014_15.html
>
> We are also attaching a staff assessment.
>
> You are encouraged to discuss the merits and your concerns of Draft
> Policy 2014-15 on the Public Policy Mailing List.
>
> The AC will evaluate the discussion in order to assess the conformance
> of this draft policy with ARIN's Principles of Internet Number Resource
> Policy as stated in the PDP. Specifically, these principles are:
>
>   * Enabling Fair and Impartial Number Resource Administration
>   * Technically Sound
>   * Supported by the Community
>
> The ARIN Policy Development Process (PDP) can be found at:
> https://www.arin.net/policy/pdp.html
>
> Draft Policies and Proposals under discussion can be found at:
> https://www.arin.net/policy/proposals/index.html
>
> Regards,
>
> Communications and Member Services
> American Registry for Internet Numbers (ARIN)
>
>
> ## * ##
>
>
> Draft Policy ARIN-2014-15
> Allow Inter-RIR ASN Transfers
>
> Revised: 19 June 2014
>
> Problem Statement:
>
> We already allow transfer of ASNs within the ARIN region. Recently APNIC
> implemented a policy allowing for Inter-regional ASN transfers to RIRs with
> reciprocal policies. This change in language would allow for ASN transfers
> to and from the APNIC region.
>
> Policy Statement:
>
> Add "or ASNs to be transferred, as" to the first bullet point under
> Conditions on source of the transfer, so that it reads: "The source entity
> must be the current rights holder of the IPv4 address resources or ASNs to
> be transferred, as recognized by the RIR responsible for the resources, and
> not be involved in any dispute as to the status of those resources."
>
> Change "IPv4 number resources" to "that same resource type (IPv4 number
> resources or ASNs)", so that the fourth bullet point reads: "Source
> entities within the ARIN region must not have received a transfer,
> allocation, or assignment of that same resource type (IPv4 number resources
> or ASNs) from ARIN for the 12 months prior to the approval of a transfer
> request. This restriction does not include M&A transfers."
>
> Timetable for implementation: Immediate
>
> ##########
>
> ARIN Staff and Legal Assessment
>
> Proposal: ARIN-2014-15: Allow Inter-RIR ASN Transfers
>
> Date of Assessment: 1 July 2014
>
> 1. Summary (Staff Understanding)
>
> This proposal would:
> •  allow inter-RIR transfer of AS numbers
> •  enforce the 12 month waiting period only on resources of the same type
> exempt resources received via M&A transfer
>
> 2. Comments
>
> A.    ARIN Staff Comments
>
> The impact of inter-RIR transfers of ASNs on ARIN from both an operational
> and development perspective are nominal today, but pose an unknown (but at
> least moderate) impact over the medium-term due to potentially significant
> impacts for additional requirements and/or specifications necessary for
> RPKI support of inter-RIR ASN transfers.
>
> B.    ARIN General Counsel - Legal Assessment
>
> "The only material legal risk relates to the RPKI issue and policy
> consideration can take place as continued work by the management and staff
> of ARIN may be able to fully address this concern before the community
> considers the policy matter in Baltimore."
>
> 3. Resource Impact
>
> This policy would have minimal to moderate resource impact from an
> implementation aspect.  It is estimated that implementation would occur
> within 3 - 9 months after ratification by the ARIN Board of Trustees. The
> following would be needed in order to implement:
>
> Future impact from RPKI  implementation could involve either some kind of
> RIR<->IANA<->RIR coordination system or ERX for ASNs
> Updated guidelines and internal procedures
> Staff training
>
> 4. Proposal/Draft Policy Text Assessed
>
> Draft Policy ARIN-2014-15 Allow Inter-RIR ASN Transfers
> Revised: 19 June 2014
>
> Problem Statement:
> We already allow transfer of ASNs within the ARIN region. Recently APNIC
> implemented a policy allowing for Inter-regional ASN transfers to RIRs with
> reciprocal policies. This change in language would allow for ASN transfers
> to and from the APNIC region.
>
> Policy Statement:
> Add "or ASNs to be transferred, as" to the first bullet point under
> Conditions on source of the transfer, so that it reads: "The source entity
> must be the current rights holder of the IPv4 address resources or ASNs to
> be transferred, as recognized by the RIR responsible for the resources, and
> not be involved in any dispute as to the status of those resources." Change
> "IPv4 number resources" to "that same resource type (IPv4 number resources
> or ASNs)", so that the fourth bullet point reads: "Source entities within
> the ARIN region must not have received a transfer, allocation, or
> assignment of that same resource type (IPv4 number resources or ASNs) from
> ARIN for the 12 months prior to the approval of a transfer request. This
> restriction does not include M&A transfers." Timetable for implementation:
> Immediate
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