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

[David Huberman]

Hi Bill,

Ever build and operate a network in China?  Tina Morris and I, the two policy authors, have and do.

There is no BGP in China without IP addresses registered in CNNIC.  It's against the law.  We, and many other ARIN-region operators, have networks to build and run in China.  We cannot do so with the 24 month anti-flip rule in place.  

"Cannot do so" is not acceptable, so it forces us to 'game' the policy intention by doing an 8.2 to a different OrgID, then doing an 8.4 transfer.  So we're paying extra money for extra work by ARIN staff all because of the language in 8.4 -- language which was drafted years ago as a "first-draft" of an anti-flip policy before there was any market.  It's 2015, and we have real experience with the market, and real experience operating networks on multiple continents.  This draft policy seeks to remedy a real problem.

Thanks for listening!
David



> -----Original Message-----
> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On
> Behalf Of William Herrin
> Sent: Tuesday, May 26, 2015 12:51 PM
> Cc: arin-ppml at arin.net
> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-2: Modify 8.4 (Inter-RIR
> Transfers to Specified Recipients)
> 
> On Tue, May 26, 2015 at 2:58 PM, ARIN <info at arin.net> wrote:
> > Draft Policy ARIN-2015-2
> > Modify 8.4 (Inter-RIR Transfers to Specified Recipients)
> >
> > 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 an
> > allocation or assignment of IPv4 number resources from ARIN for the 12
> > months prior to the approval of a transfer request."
> 
> Opposed.
> 
> BGP does not respect RIR boundaries. Barring pretty transparent fraud, there
> is no _operational_ need to transfer addresses acquired in the ARIN region
> to different registry within the 12-month waiting period.
> 
> Unexpected change in business plan? Who do you think you're fooling?
> 
> Regards,
> Bill Herrin
> 
> 
> --
> William Herrin ................ herrin at dirtside.com  bill at herrin.us Owner,
> Dirtside Systems ......... Web: <http://www.dirtside.com/>
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