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

[Scott Leibrand]

Why would someone buy a block in ARIN and resell it into APNIC, if the
original seller could've just sold their block to the APNIC buyer?  I don't
see the arbitrage opportunity here, except with regards to the
soon-to-be-exhausted free pool.

-Scott


On Wed, Mar 5, 2014 at 1:02 PM, Owen DeLong <owen at delong.com> wrote:

> I still have concerns in spite of said rejoinder. The rejoinder doesn't
> address the ability to use this as a way to flip less expensive addresses
> into higher profits by transferring out of region. All it does is protect a
> free pool which likely won't exist by the time this becomes policy anyway.
>
> Owen
>
> On Mar 5, 2014, at 07:00 , Bill Darte <billdarte at gmail.com> wrote:
>
> 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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