[arin-ppml] Draft Policy ARIN-2015-2: Modify 8.4 (Inter-RIR Transfers to Specified Recipients)

[Jason Schiller]

Owen,

We didn't need a global policy to establish a bilateral inter RIR transfer
policy with APNIC.  Per ARIN policy "APNIC only requires a compatible needs
based distribution mechanism".

Why not per ARIN policy, you can transfer inside your 24 month window, ONLY
IF, the org is a wholly owned subsidiary, and if the org is in an RIR
region whose policy will prevent the transfer of addresses for at least the
remainder of the 24 month term.

__Jason


On Fri, May 29, 2015 at 9:16 PM, Owen DeLong <owen at delong.com> wrote:

> If it were enforceable, it would address my concern.
>
> The problem is that we are then looking to have an ARIN contract enjoin an
> action by the organization in another RIR which I am not sure would give us
> any recourse whatsoever were that contract to be violated.
>
> That’s why I didn’t propose language… I don’t think the issue in question
> can be unilaterally addressed, so I think we should accept that and those
> that are interested can begin work on a globally coordinated policy if they
> desire to do so.
>
> We’ve already seen that attempting to unilaterally influence minimum
> policy requirements on other regions is unlikely to work. Witness RIPEs
> recent “workaround” to “compatible needs basis”. I am not especially
> interested in expanding this problem space.
>
> Owen
>
> On May 29, 2015, at 12:06 PM, Jason Schiller <jschiller at google.com> wrote:
>
> Owen,
>
> So does this text cover your proposal then?
>
> Draft Policy ARIN-2015-2
> Modify 8.4 (Inter-RIR Transfers to Specified Recipients)
>
> Date: 26 May 2015
>
> Problem Statement:
>
> Organizations that obtain a 24 month supply of IP addresses via the
> transfer market and then have an unexpected change in business plan
> are unable to move IP addresses to the proper RIR within the first 12
> months of receipt.
>
> Policy statement:
>
> Replace 8.4, bullet 4, to read:
>
> "> 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.
>      - This restriction does not include a transfer to a wholly owned
>         subsidiary out side of the ARIN service region
>         if the recipient org will be required to not transfer any IP space
>         for the remaining balance of 12 month window."
>
>
> On Fri, May 29, 2015 at 4:06 AM, Owen DeLong <owen at delong.com> wrote:
>
>>
>> On May 28, 2015, at 6:46 AM, Jason Schiller <jschiller at google.com> wrote:
>>
>> Owen,
>>
>> How does that differ from the policy text I sent?
>>
>> Can you send an idea of policy text?
>>
>> I thought the text I sent said that an ARIN org can transfer IPs out to
>> another wholely owned subsidiary in another RIR region if they have been
>> the recipient of transfer in less that 12 months IF the recipient org will
>> be required (read by recipient's RIR policy) to hold the transfered
>> resource for the balance of the 12 months.
>>
>> Your proposal allows substitution.
>>
>> ARIN->Other RIR space A
>> Space B Other RIR-> Money/etc.
>>
>> I want to see substitution transfers prohibited.
>>
>> Owen
>>
>> ___Jason
>> On May 28, 2015 8:31 AM, "Owen DeLong" <owen at delong.com> wrote:
>>
>>> Or simply not permit it under ARIN policy until such exists.
>>>
>>> Owen
>>>
>>> > On May 28, 2015, at 1:49 PM, John Curran <jcurran at arin.net> wrote:
>>> >
>>> > On May 27, 2015, at 11:39 PM, Owen DeLong <owen at delong.com> wrote:
>>> >>
>>> >> My suggestion is that I don't mind (virtually) unrestricted moves of
>>> addresses to different regions staying with the same organization. However,
>>> if we are to allow that, I want us to find a way that you can't merely use
>>> that as a way to move addresses out of flip protection to then flip them to
>>> another organization via an RIR with a less restrictive transfer policy.
>>> >>
>>> >> So... If you transfer addresses to another region, keeping them in
>>> the same organization, no penalty. However, you are not allowed to
>>> subsequently transfer them (or other addresses in that region) to an
>>> external party for at least 12 months.
>>> >
>>> > That second portion that you seek would affect the ongoing operation of
>>> > another RIR, i.e. it requires them having some explicit policy to that
>>> effect.
>>> >
>>> > To obtain the result you seek, we either need globally coordinated
>>> transfer
>>> > policy in this area, or you need to make the inter-RIR transfer policy
>>> explicit
>>> > in this regard in determination of compatibility.
>>> >
>>> > /John
>>> >
>>> > John Curran
>>> > President and CEO
>>> > ARIN
>>> >
>>> >
>>> >
>>> >
>>>
>>>
>>
>
>
> --
> _______________________________________________________
> Jason Schiller|NetOps|jschiller at google.com|571-266-0006
>
>
>


-- 
_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com|571-266-0006
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