[arin-ppml] anti- flip Draft 2014-2

Fri Mar 7 12:09:48 EST 2014

I support No. 3

Cordially Yours,

Skylar MacMinn
www.crissic.net
<https://bay170.mail.live.com/mail/17.1.6521.6000/Compose/www.crissic.net> 
Crissic Solutions, LLC

From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On
Behalf Of Rudolph Daniel
Sent: Friday, March 7, 2014 11:04 AM
To: arin-ppml at arin.net
Subject: Re: [arin-ppml] anti- flip Draft 2014-2

I can see the logic of supporting "3". I am going inclined to agree with
David. We have to promote accuracy in whois as a policy priority.

I support No. 3

Rudi Daniel 
(information technologist)
784 430 9235

On Mar 5, 2014 10:02 PM, <arin-ppml-request at arin.net
<mailto:arin-ppml-request at arin.net> > wrote:

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Today's Topics:

   1. Re: ARIN Draft Policy 2014-2 Improved 8.4 Anti-Flip       Language
      (David Huberman)
   2. Re: ARIN Draft Policy 2014-2 Improved 8.4 Anti-Flip       Language
      (Spam Auditor)
   3. Re: ARIN Draft Policy 2014-2 Improved 8.4 Anti-Flip       Language
      (Bill Darte)

----------------------------------------------------------------------

Message: 1
Date: Wed, 5 Mar 2014 21:17:58 +0000
From: David Huberman <David.Huberman at microsoft.com
<mailto:David.Huberman at microsoft.com> >
To: Bill Darte <billdarte at gmail.com <mailto:billdarte at gmail.com> >,
"arin-ppml at arin.net <mailto:arin-ppml at arin.net> "
        <arin-ppml at arin.net <mailto:arin-ppml at arin.net> >, Owen DeLong
<owen at delong.com <mailto:owen at delong.com> >
Subject: Re: [arin-ppml] ARIN Draft Policy 2014-2 Improved 8.4
        Anti-Flip       Language
Message-ID:

<87b03e32ad2743559958047e94c94044 at DM2PR03MB398.namprd03.prod.outlook.com
<mailto:87b03e32ad2743559958047e94c94044 at DM2PR03MB398.namprd03.prod.outlook.
com> >

Content-Type: text/plain; charset="us-ascii"

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 <mailto:billdarte at gmail.com> >
Sent: Wednesday, March 5, 2014 7:00 AM
To: arin-ppml at arin.net <mailto: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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Message: 2
Date: Wed, 05 Mar 2014 17:54:34 -0800
From: Spam Auditor <spamauditor at linuxmagic.com
<mailto:spamauditor at linuxmagic.com> >
To: arin-ppml at arin.net <mailto:arin-ppml at arin.net> 
Subject: Re: [arin-ppml] ARIN Draft Policy 2014-2 Improved 8.4
        Anti-Flip       Language
Message-ID: <5317D55A.1030302 at linuxmagic.com
<mailto:5317D55A.1030302 at linuxmagic.com> >
Content-Type: text/plain; charset=ISO-8859-1; format=flowed

On 14-03-05 01:17 PM, David Huberman wrote:
> 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)

Here, Here...

However, even though it isn't a regulator, there should be enforcement
considerations, especially when IP Space is granted and used for
purposes contrary to the application..

------------------------------

Message: 3
Date: Wed, 5 Mar 2014 19:58:50 -0600
From: Bill Darte <billdarte at gmail.com <mailto:billdarte at gmail.com> >
To: Spam Auditor <spamauditor at linuxmagic.com
<mailto:spamauditor at linuxmagic.com> >
Cc: "arin-ppml at arin.net <mailto:arin-ppml at arin.net> " <arin-ppml at arin.net
<mailto:arin-ppml at arin.net> >
Subject: Re: [arin-ppml] ARIN Draft Policy 2014-2 Improved 8.4
        Anti-Flip       Language
Message-ID:
        <CAMApp35hhh=djm_6j0mh-F2MNxWt4GMGLz771JHDUg+zYs0cag at mail.gmail.com
<mailto:djm_6j0mh-F2MNxWt4GMGLz771JHDUg%2BzYs0cag at mail.gmail.com> >
Content-Type: text/plain; charset="iso-8859-1"

Spam Auditor....
Are you FOR or AGAINST the proposal in general....and does your 'Hear,
Here' include David's support for option #3?
Thanks,
bd

On Wed, Mar 5, 2014 at 7:54 PM, Spam Auditor <spamauditor at linuxmagic.com
<mailto:spamauditor at linuxmagic.com> >wrote:

> On 14-03-05 01:17 PM, David Huberman wrote:
>
>> 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)
>>
>
> Here, Here...
>
> However, even though it isn't a regulator, there should be enforcement
> considerations, especially when IP Space is granted and used for purposes
> contrary to the application..
>
>
> _______________________________________________
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