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

[David Huberman]

As the author of this proposal, and having encountered the real-world consequences of existing 8.4 anti-flip language, I support #3 as the cleanest, simplest approach that best promotes Whois accuracy.



ARIN is a registry, not a regulator.  Let's write policy that promotes accuracy in Whois, please.



David R Huberman
Microsoft Corporation
Senior IT/OPS Program Manager (GFS)
________________________________
From: Bill Darte <billdarte at gmail.com>
Sent: Wednesday, March 5, 2014 7:00 AM
To: arin-ppml at arin.net; David Huberman; Owen DeLong
Subject: ARIN Draft Policy 2014-2 Improved 8.4 Anti-Flip Language

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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