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

[Bill Darte]

On Feb. 21 I sent the message (far below) to PPML asking the community to
support one of 3 alternatives or propose new language which makes one or
the other better, or a completely new wording which they believe
accomplishes the goal of producing policy language that is needed,
technically sound and improves existing policy in the 8.4 Inter-RIR
transfer realm.

Summary of feedback so far:
2 persons supporting #2 with the removal of "and its subsidiaries".  There
was some support for the extended language of "and its subsidiaries having
been operational for a minimum of xx months" in order to mitigate the
rinse-repeat abuse that might accrue through new shell subsidiaries.

There was some support for the alternative language expressed in #3 at the
PPC in Atlanta and at the ARIN AC meeting on Feb 20.  This language simply
restricts the transfer of the block having been received...which would
allow other existing blocks or components to be transferred.  One view
against #3 was expressed as "An org that currently has a /8 can obtain the
resources it needs and sell off the /8 out of region a few chunks at a time
by backfilling with new space from the ARIN region.". A rejoinder to this
was expressed pointing out that other existing language in 8.4
states...."Source
entities within the ARIN region will not be eligible 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."
<<< end summary >>>>


It is important that I receive a significant measure of support FOR or
AGAINST continuing to work on this Draft and before the ARIN AC meeting on
Mar 20, I would like to have better language to propose if we are to make
this Draft a Recommended Draft prior to the April PPM in Chicago.

I would be grateful for your feedback as early as possible.

bd

<<<<<<<<< earlier email sent to PPML on Feb 21 >>>>>>>>>>>>>>>
At the Advisory Council's meeting of Feb 20, discussion about Draft Policy
2014-2 concluded that there is a real issue with transfer restrictions of
address blocks between RIR jurisdictions for organizations having received
a different block of addresses from ARIN within the last 12 months (per
existing policy).

The current Draft Policy language is as follows with only the last sentence
being added from what is current ARIN policy:
"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."

The last sentence of this language was added to mitigate the problems
related by the author in the problem statement and from experience. The
author supported this change, however, some concern has been expressed on
the PPML and within the AC about the possibility of 'rinse and repeat'
abuse associated with the ease of establishing new subsidiaries and using
those transfers to get around the restrictions of the existing transfer
policy.

Three alternatives were primarily discussed and I wish to elicit feedback
from the community relative to each.

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 may be moot.

2. Remove the clause 'and its subsidiaries' or modify it in such a way as
to mitigate the risk of a laundering of addresses through fraudulent
transfers, but this may still potentially limit the utility to
organizations who may have complex organizational structures in use
internationally.

3. Take an alternative tack and simply restrict transfers on a per-block
rather than a per-organization basis. e.g. 'No block acquired within the
past 24 months would be eligible for transfer.' (The time frame is of
course an arbitrary number at this point.)

If you believe this Draft Policy is improved most significantly by one of
the above alternatives, or through another alternative you can pose....I,
and the community would benefit from your input. Thanks,

Bill Darte
Policy Shepherd for 2014-2 and
Advisory Council member
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