[arin-ppml] Draft Policy ARIN-2014-8: Alignment of 8.3 Needs Requirements to Reality of Business

[ARIN]

On 20 February 2014 the ARIN Advisory Council (AC) accepted
"ARIN-prop-193 Alignment of 8.3 Needs Requirements to Reality of 
Business" as a Draft Policy.

Draft Policy ARIN-2014-8 is below and can be found at:
https://www.arin.net/policy/proposals/2014_8.html

You are encouraged to discuss the merits and your concerns of Draft
Policy 2014-8 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)


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Draft Policy ARIN-2014-8
Alignment of 8.3 Needs Requirements to Reality of Business

Date: 4 March 2014

Problem Statement:

8.3 Transfer Policy states: "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." This is
problematic post-exhaustion for two reasons:

1) Existing IPv4 policy for end-users requires that the organization
demonstrate they will use TWENTY-FIVE PERCENT of the space immediately.
ARIN staff interpret "immediately" to mean "within 30 days of obtaining
new numbers." NRPM 8.3, however, allows networks to obtain a 2-year 
supply of
addresses. It is, therefore, not rational to expect businesses to use
25% of the space obtained for a 2-year need within 30 days. Such a
requirement has, consistently, prompted requestors to bend the truth in
their dealings with ARIN in order to qualify for the space they need to
operate their network.

2) IPv4 policy for ISPs requires existing utilization of some number of
IPv4 addresses. There is a barrier to entry for new ISPs, designed in
1996 to ensure that DFZ slots were utilized by bona fide networks.
This requirement freezes out new ISP entrants from the 8.3 transfer
market. This formally disallows new ISPs to obtain properly-sized
blocks for their future needs from the market.

This proposal aims to easily fix the math problem in 1), and the
blocker to business in 2).

Policy statement:

Replace in 8.3:
"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."
with
"The recipient must demonstrate their 24 month needs for number
resources. The transferred block(s) plus the amount of free addresses
currently registered to the organization, must together not be larger
than the demonstrated need. The recipient must sign an RSA."

Comments:
a.Timetable for implementation: Immediate

b.Anything else: Request that ARIN STAFF analyze whether the third
sentence of the proposed text ("The recipient must sign an RSA.") needs
to be in ARIN policy. If not, let's work together to modify this proposal to
remove it.