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

[Owen DeLong]

> On Jun 2, 2015, at 12:14 AM, Jason Schiller <jschiller at google.com> wrote:
> 
> 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”.

Because we have the anti-flip language that this proposal seeks to eliminate.

> 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.

I could live with that.

Owen

> 
> __Jason
> 
> 
> On Fri, May 29, 2015 at 9:16 PM, Owen DeLong <owen at delong.com <mailto: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 <mailto: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 <mailto:owen at delong.com>> wrote:
>> 
>>> On May 28, 2015, at 6:46 AM, Jason Schiller <jschiller at google.com <mailto: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 <mailto: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 <mailto:jcurran at arin.net>> wrote:
>>> >
>>> > On May 27, 2015, at 11:39 PM, Owen DeLong <owen at delong.com <mailto: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 <mailto:jschiller at google.com>|571-266-0006 <tel:571-266-0006>
>> 
> 
> 
> 
> 
> -- 
> _______________________________________________________
> Jason Schiller|NetOps|jschiller at google.com <mailto:jschiller at google.com>|571-266-0006
> 

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