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

[Azinger, Marla]

PPML discussion on this appeared to go several directions.  Based on interpretation of the published text only, this is what I see.

It needs to retain "This restriction does not include M&A transfers."

I think the real goal here is to permit address movement of address space when needed and at the same time remove any address gaming.  Should the 12 month restrictions be in play dependent on the free pool status of course, Another way to write a guiding principle on this is:
"Source entities within the ARIN region will be restricted from transferring address space within 12 months of its most recent transfer, allocation or assignment barring reasonable business requirements."

I suggest this because there is no reasonable way to document and cover every logical and reasonable business angle that has and will reveal itself.  It's not possible to write policy that tightly dictates every maneuver.  There is a point where policy needs to be written as a guiding principle and then let ARIN staff make decisions based on facts and our guiding principles.  I have felt this text has over reached since day one and since then I have witnessed several business cases effected that are logical and in no way "gaming ip addresses and the market".

Regards
Marla Azinger

-----Original Message-----
From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of ARIN
Sent: Tuesday, May 26, 2015 11:58 AM
To: arin-ppml at arin.net
Subject: [arin-ppml] Draft Policy ARIN-2015-2: Modify 8.4 (Inter-RIR Transfers to Specified Recipients)

Draft Policy ARIN-2015-2
Modify 8.4 (Inter-RIR Transfers to Specified Recipients)

On 21 May 2015 the ARIN Advisory Council (AC) accepted "ARIN-prop-216 Modify 8.4 (Inter-RIR Transfers to Specified Recipients)" as a Draft Policy.

Draft Policy ARIN-2015-2 is below and can be found at:
https://www.arin.net/policy/proposals/2015_2.html

You are encouraged to discuss the merits and your concerns of Draft Policy 2015-2 on the Public Policy Mailing List.

The AC will evaluate the discussion in order to assess the conformance of this draft policy with ARIN's Principles of Internet Number Resource Policy as stated in the PDP. Specifically, these principles are:

   * Enabling Fair and Impartial Number Resource Administration
   * Technically Sound
   * Supported by the Community

The ARIN Policy Development Process (PDP) can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)


## * ##


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 an allocation or assignment of IPv4 number resources from ARIN for the 12 months prior to the approval of a transfer request."

Comments:

The intention of this change is to allow organizations to perform inter-RIR transfers of space received via an 8.3 transfer regardless of the date transferred to ARIN . A common example is that an organization acquires a block located in the ARIN region, transfers it to ARIN, then
3 months later, the organization announces that it wants to launch new services out of region. Under current policy, the organization is prohibited from moving some or all of those addresses to that region's Whois; the numbers are locked in ARIN's Whois. It's important to note that 8.3 transfers are approved for a 24 month supply, and it would not be unheard of for a business model to change within the first 12 months after approval. In addition this will not affect the assignments and allocations issued by ARIN they will still be subject to the 12 month restriction.

a. Timetable for implementation: Immediate

b. Anything else
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