[arin-ppml] ARIN-PPML 2015-6

[Rudolph Daniel]

"In fact, I believe that eliminating needs-basis will likely cause actual
utilization to be reduced in the
long run in favor of financial manipulation....Owen"

Until Proven otherwise, I am inclined to support Owen's view on this. I
think adoption of 2015-6 is likely to legitimize the monetization of ip
addresses, leading to a complex market structure dominated by certain
sections of the business community, whilst possibly delaying the adoption
of Ipv6 and slowing innovation.

The main artery of purpose seems to hang on the need to maintain an
accurate whois, driving RIR s to refocus purely on registration...this
sounds like a free for all, and so far I am not convinced that that is in
the interest of the community as a whole, and may result in the IP wars.

"1. has been an ARIN customer for at least 36 months; AND
2. is currently in good standing with ARIN; AND
3. is currently using IPv4 or IPv6 addresses in the ARIN region; AND
4. can demonstrate it has a meaningful business that operates in the ARIN
region."

Not sure what a "meaningful business" is.

The staff has also indicated some technical issues and cost implications.
Is the proposer seriously suggesting that the increased registrations and
what may be a ghostly expectation of an even more accurate whois will more
than cover the increased cost of implementing 2015-6?
What does the proposer believe is most likely to happen in the short to
medium term were this draft policy not be supported by the community and
what would be the likely impact on ARIN operations, staff, technical,
legal; of what the proposer is trying to avoid?

There maybe a need to do something, but, my thoughts lean towards a global
policy, across all RIRs.

RD

On Sep 24, 2015 3:10 PM, <arin-ppml-request at arin.net> wrote:

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> Today's Topics:
>
>    1. Re: Draft Policy ARIN-2015-6: Transfers and Multi-national
>       Networks - revised (ARIN)
>    2. Re: Draft Policy ARIN-2015-9: Eliminating needs-based
>       evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4
>       netblocks (Leif Sawyer)
>    3. Re: Draft Policy ARIN-2015-9: Eliminating needs-based
>       evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4
>       netblocks (Owen DeLong)
>
>
> ----------------------------------------------------------------------
>
> Message: 1
> Date: Wed, 23 Sep 2015 17:12:13 -0400
> From: ARIN <info at arin.net>
> To: arin-ppml at arin.net
> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-6: Transfers and
>         Multi-national Networks - revised
> Message-ID: <560315AD.5000209 at arin.net>
> Content-Type: text/plain; charset=utf-8; format=flowed
>
> On 1 September 2015 the ARIN Advisory Council revised 2015-6. Below you
> will find the the updated ARIN staff assessment.
>
> ARIN-2015-5 is below and can be found at:
> https://www.arin.net/policy/proposals/2015_5.html
>
> Regards,
>
> Communications and Member Services
> American Registry for Internet Numbers (ARIN)
>
>
> ## * ##
>
>
> ARIN STAFF & LEGAL ASSESSMENT
> Draft Policy ARIN-2015-6
> TRANSFERS AND MULTI-NATIONAL NETWORKS
>
> Date of Assessment: 15 September 2015
>
> ___
> 1. Summary (Staff Understanding)
>
> This proposal states that when evaluating transfer requests, ARIN will
> not consider the geographic location where an organization is utilizing,
> or will utilize, its ARIN-registered addresses if that organization, its
> parent, or a subsidiary are able to satisfy each of the four stated
> criteria.
>
> ___
> 2. Comments
>
> A. ARIN Staff Comments
>
> ? During the course of a transfer request, staff will consider and
> review the utilization of any block issued by ARIN to that organization,
> regardless of whether that address space is being used outside of the
> ARIN region.
> ? This policy enables organizations to qualify as a recipient for 8.3 or
> 8.4 transfers in the ARIN region when they might not have otherwise been
> able to do so. ARIN staff would now be able to consider their global
> utilization, instead of only their in-ARIN region use.
> ? One of the elements ARIN staff uses to determine 24-month need for an
> organization is their historical utilization rate. This proposal allows
> organizations to justify a larger 24-month needs based qualification,
> because staff will consider their utilization globally instead of just
> what was used inside the ARIN region.
> ? This would be placed in a new section of the NRPM called "8.5
> Additional Transfer Policies".
> ? This policy could be implemented as written.
>
> B. ARIN General Counsel ? Legal Assessment
>
> No material legal issues. If the policy is enacted it will require ARIN
> staff to work with counsel with some attendant increase in costs in the
> first year to manage implementation.
>
> ___
> 3. Resource Impact
>
>  From a request review standpoint, implementation of this policy would
> have minimal resource impact. However, it could have future staffing
> implications based on the amount of additional work the policy could
> present. It is estimated that implementation could occur within 3 months
> after ratification by the ARIN Board of Trustees. The following would be
> needed in order to implement:
>
> * Updated guidelines and internal procedures
> * Staff training
>
> Implementation of this policy may allow for registrations in the ARIN
> database that require unicode character sets. From an engineering
> standpoint, implementation of this policy could have a major resource
> impact. It is estimated that implementation would occur within 12
> months, instead of the 3 months cited above, after ratification by the
> ARIN Board of Trustees if ARIN is required to support unicode character
> sets. The following would be needed in order to implement:
>
> * Engineering: Engineering efforts to handle out of region business
> rules may be substantial as our system only supports ascii now. If there
> is a need for unicode character sets, then there is a substantial amount
> of work required to upgrade the DB and applications to support unicode.
> Additionally, we would need to discuss how to display unicode characters
> in port 43 whois.
>
> ___
> 4. Proposal / Draft Policy Text Assessed
>
> Draft Policy ARIN-2015-6
>
> Problem statement:
>
> Some organizations within the ARIN region are currently unable to
> receive IPv4 space via transfer based on current ARIN policy, which
> prohibits address space used outside of the ARIN region from being
> considered efficiently utilized. This proposal would allow organizations
> with a strong and long-standing presence in the ARIN region to be able
> to receive number resources via transfer for their global operations.
>
> Policy statement:
>
> When evaluating transfer requests, ARIN will not consider the geographic
> location where an organization is utilizing, or will utilize, its
> ARIN-registered addresses if that organization, its parent, or a
> subsidiary:
>
> 1. has been an ARIN customer for at least 36 months; AND
> 2. is currently in good standing with ARIN; AND
> 3. is currently using IPv4 or IPv6 addresses in the ARIN region; AND
> 4. can demonstrate it has a meaningful business that operates in the
> ARIN region.
>
>
>
> On 9/1/15 1:01 PM, ARIN wrote:
> > ARIN-2015-6 has been revised.
> >
> > You are encouraged to discuss the merits and your concerns of Draft
> > Policy 2015-6 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
> >
> > ARIN-2015-6 is below and can be found at:
> > https://www.arin.net/policy/proposals/2015_6.html
> >
> > Regards,
> >
> > Communications and Member Services
> > American Registry for Internet Numbers (ARIN)
> >
> >
> > ## * ##
> >
> >
> > Draft Policy ARIN-2015-6
> > Transfers and Multi-national Networks
> >
> > Date: 25 August 2015
> >
> > Problem statement:
> >
> > Some organizations within the ARIN region are currently unable to
> > receive IPv4 space via transfer based on current ARIN policy, which
> > prohibits address space used outside of the ARIN region from being
> > considered efficiently utilized. This proposal would allow organizations
> > with a strong and long-standing presence in the ARIN region to be able
> > to receive number resources via transfer for their global operations.
> >
> > Policy statement:
> >
> > When evaluating transfer requests, ARIN will not consider the geographic
> > location where an organization is utilizing, or will utilize, its
> > ARIN-registered addresses if that organization, its parent, or a
> > subsidiary:
> >
> > 1. has been an ARIN customer for at least 36 months; AND
> >
> > 2. is currently in good standing with ARIN; AND
> >
> > 3. is currently using IPv4 or IPv6 addresses in the ARIN region; AND
> >
> > 4. can demonstrate it has a meaningful business that operates in the
> > ARIN region.
> >
> > Comments:
> >
> > Timetable for implementation: Immediate
> >
> > #####
> >
> > ARIN STAFF & LEGAL ASSESSMENT
> >
> > Draft Policy ARIN-2015-6
> > TRANSFERS AND MULTI-NATIONAL NETWORKS
> > https://www.arin.net/policy/proposals/2015_6.html
> >
> > Date of Assessment: 18 August 2015
> >
> > ___
> > 1. Summary (Staff Understanding)
> >
> > This proposal states that when evaluating transfer requests, ARIN will
> > not consider the geographic location where an organization is utilizing
> > its ARIN-registered addresses if that organization, its parent, or a
> > subsidiary are able to satisfy each of the four stated criteria.
> >
> > ___
> > 2. Comments
> >
> > A. ARIN Staff Comments
> >
> > ?During the course of a transfer request, staff will consider and review
> > the utilization of any block issued by ARIN to that organization,
> > regardless of whether that address space is being used outside of the
> > ARIN region.
> > ?This policy enables organizations to qualify as a recipient for 8.3 or
> > 8.4 transfers in the ARIN region when they might not have otherwise been
> > able to do so. ARIN staff would now be able to consider their global
> > utilization, instead of only their in-ARIN region use.
> > ?One of the elements ARIN staff uses to determine 24-month need for an
> > organization is their historical utilization rate. This proposal allows
> > organizations to justify a larger 24-month needs based qualification,
> > because staff will consider their utilization globally instead of just
> > what was used inside the ARIN region.
> > ?The policy proposal text appears to not align with the intent of the
> > policy as described in the problem statement. This proposal changes how
> > ARIN considers prior utilization of IPv4 address space, but does not
> > specify that newly received resources can be used outside of the region.
> > Existing policy and practice would dictate ARIN continues to issue space
> > for use in the ARIN region. We note that 2015-5, if adopted, could
> > change this.
> > ?This would be placed in a new section of the NRPM called "8.5
> > Additional Transfer Policies".
> > ?This policy could be implemented as written.
> >
> > B. ARIN General Counsel ? Legal Assessment
> >
> > No material legal issues. If the policy is enacted it will require ARIN
> > staff to work with counsel with some attendant increase in costs in the
> > first year to manage implementation.
> >
> > ___
> > 3. Resource Impact
> > This policy would have minimal resource impact from an implementation
> > aspect. However, it could have future staffing implications based on the
> > amount of additional work the policy could present. It is estimated that
> > implementation would occur within 3 months after ratification by the
> > ARIN Board of Trustees. The following would be needed in order to
> > implement:
> >
> > * Updated guidelines and internal procedures
> > * Staff training
> >
> > ___
> > 4. Proposal / Draft Policy Text Assessed
> >
> > Draft Policy ARIN-2015-6
> >
> > Date: 23 June 2015
> >
> > Problem statement:
> > Some organizations within the ARIN region are currently unable to
> > receive IPv4 space via transfer based on current ARIN policy, which
> > prohibits address space used outside of the ARIN region from being
> > considered efficiently utilized. This proposal would allow organizations
> > with a strong and long-standing presence in the ARIN region to be able
> > to receive number resources via transfer for their global operations.
> > Policy statement:
> > When evaluating transfer requests, ARIN will not consider the geographic
> > location where an organization is utilizing its ARIN-registered
> > addresses if that organization, its parent, or a subsidiary:
> > 1. has been an ARIN customer for at least 36 months; AND
> > 2. is currently in good standing with ARIN; AND
> > 3. is currently using IPv4 or IPv6 addresses in the ARIN region; AND
> > 4. can demonstrate it has a meaningful business that operates in the
> > ARIN region.
> >
>
>
>
> ------------------------------
>
> Message: 2
> Date: Thu, 24 Sep 2015 18:55:26 +0000
> From: Leif Sawyer <lsawyer at gci.com>
> To: "arin-ppml at arin.net" <arin-ppml at arin.net>
> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating
>         needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of
> IPv4
>         netblocks
> Message-ID:
>         <EDF941B230F4C446826CF893A9C8CE592956D1 at ex-mbx-prd02.gci.com>
> Content-Type: text/plain; charset=UTF-8
>
> Now that we've reached the magic ZERO in the free pool, what does the
> community
> think about this new draft policy?
>
> Should ARIN begin the process of streamlining the IPv4 policy so that it is
> geared more toward the transfer market, and remove "need" as a criteria in
> certain sections of the NRPM to increase the database accuracy?
>
>
> -----Original Message-----
> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On
> Behalf Of ARIN
> Sent: Wednesday, September 23, 2015 12:54 PM
> To: arin-ppml at arin.net
> Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based
> evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
>
> Draft Policy ARIN-2015-9
> Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers
> of IPv4 netblocks
>
> On 17 September 2015 the ARIN Advisory Council (AC) accepted
> "ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3,
> and 8.4 transfers of IPv4 netblocks" as a Draft Policy.
>
> Draft Policy ARIN-2015-9 is below and can be found at:
> https://www.arin.net/policy/proposals/2015_9.html
>
> You are encouraged to discuss the merits and your concerns of Draft Policy
> 2015-9 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-2015-9
> Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers
> of IPv4 netblocks
>
> Date: 23 September 2015
>
> Problem statement:
>
> The current policies in NRPM sections 8.2, 8.3, and 8.4 regarding transfer
> of IPv4 netblocks from one organization to another are currently a
> hindrance in ensuring database accuracy. In practice, ARIN staff are
> utilizing those polices to refuse to complete database updates which would
> reflect an accurate transfer of control / utilization of netblocks in cases
> where ARIN doesn't agree that the recipient organization has need, or more
> often where the recipient organization bypasses the ARIN registry entirely
> in order to secure the needed IPv4 netblocks in a more timely fashion
> directly from the current holder.
> Additionally, the 8.1 introduction section includes a perceived "threat"
> of reclaim which serves as a hindrance to long-term resource holders
> approaching ARIN with database updates when transferring resources. The
> result is that the data visible in ARIN registry continues to become more
> inaccurate over time.
>
> Policy statement:
>
> This proposal is for the following language changes in the respective NRPM
> sections in order to eliminate all needs-based evaluation for the
> respective transfer type, and allow transfers to be reflected in the
> database as they occur following an agreement of transfer from the resource
> provider to the recipient.
>
> Section 8.1 Principles:
>
> - Strike the 3rd paragraph which begins with "Number resources are issued,
> based on justified need, to organizations. . ." since it mostly reiterates
> other sections of ARIN policy. All transfers are subjected to those
> policies, as called out in 8.2, 8.3, 8.4. Additionally, removing this
> paragraph removes the perceived "threat" of reclaim which serves as a
> hindrance to long-term resource holders approaching ARIN with database
> updates, since in practice ARIN has not been forcibly reclaiming IP
> resources assigned to "failed businesses."
>
> Section 8.2 Mergers and Acquisitions:
>
> - Change the 4th bullet from:
>
> "The resources to be transferred will be subject to ARIN policies."
>
> to:
>
> "The resources to be transferred will be subject to ARIN policies,
> excluding any policies related to needs-based justification or inspection
> of current or future utilization rate."
>
> - Remove entirely the last paragraph which reads "In the event that number
> resources of the combined organizations are no longer justified under ARIN
> policy at the time ARIN becomes aware of the transaction, through a
> transfer request or otherwise, ARIN will work with the resource holder(s)
> to return or transfer resources as needed to restore compliance via the
> processes outlined in current ARIN policy."
>
> Section 8.3 Transfers between Specified Recipients within the ARIN Region:
>
> - Change the first bullet under "Conditions on recipient of the transfer"
> from:
>
> "The recipient must demonstrate the need for up to a 24-month supply of IP
> address resources under current ARIN policies and sign an RSA."
>
> to:
>
> "The recipient must sign an RSA."
>
> - Change the 2nd bullet under "Conditions on recipient of the transfer"
> from:
>
> "The resources to be transferred will be subject to ARIN policies."
>
> to:
>
> "The resources to be transferred will be subject to ARIN policies,
> excluding any policies related to needs-based justification or inspection
> of current or future utilization rate."
>
> Section 8.4 Inter-RIR Transfers to Specified Recipients:
>
> - Change the introductory language from:
>
> "Inter-regional transfers may take place only via RIRs who agree to the
> transfer and share reciprocal, compatible, needs-based policies."
>
> to:
>
> "Inter-regional transfers may take place only via RIRs who agree to the
> transfer and share reciprocal, compatible, policies."
>
> - Change the 2nd bullet under "Conditions on recipient of the transfer"
> from:
>
> "Recipients within the ARIN region will be subject to current ARIN
> policies and sign an RSA for the resources being received."
>
> to:
>
> "Recipients within the ARIN region will be subject to current ARIN
> policies, excluding any policies related to needs-based justification or
> inspection of current or future utilization rate, and sign an RSA for the
> resources being received."
>
> - Remove entirely the 3rd bullet under "Conditions on recipient of the
> transfer" which reads "Recipients within the ARIN region must demonstrate
> the need for up to a 24-month supply of IPv4 address space."
>
> Comments:
>
> a.      Timetable for implementation: Immediate
>
> b.      Anything else
>
> As the "free pool" for 4 of the 5 world's RIRs (APNIC, RIPE, LACNIC, and
> ARIN) has now been exhausted, networks in need of additional IPv4
> addresses have shifted away from the practice of receiving them from the
> RIR's resource pool. Instead, networks in need are seeking out current
> holders of IPv4 resources who are willing to transfer them in order to
> fulfil that need. Accordingly, the RIR's primary responsibility vis-?-vis
> IPv4 netblock governance has shifted from "allocation" to "documentation."
> In other words, the focus must move away from practicing conservation and
> fair distribution (e.g. following guidelines set forth in RFC2050) to
> ensuring an accurate registry database of which organization is utilizing a
> given netblock as a result of transfers which occur between organizations.
>
> The RIPE registry can be used as a reference of one which has evolved over
> the past couple years to shift their focus away from
> conservation/allocation and towards database accuracy. IPv4 netblock
> transfers within that RIR consist merely of validating authenticity of the
> parties requesting a transfer. Provided the organizations meet the basic
> requirement of RIR membership, and that the transferring organization has
> the valid authority to request the transfer, the transaction completes
> without any "needs-based" review.
>
>
> _______________________________________________
> PPML
> You are receiving this message because you are subscribed to the ARIN
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> Unsubscribe or manage your mailing list subscription at:
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>
> ------------------------------
>
> Message: 3
> Date: Thu, 24 Sep 2015 12:09:31 -0700
> From: Owen DeLong <owen at delong.com>
> To: Leif Sawyer <lsawyer at gci.com>
> Cc: "arin-ppml at arin.net" <arin-ppml at arin.net>
> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating
>         needs-based     evaluation for Section 8.2, 8.3, and 8.4 transfers
> of IPv4
>         netblocks
> Message-ID: <C560FFE6-FAAC-45AD-B7EE-A87DF67BF523 at delong.com>
> Content-Type: text/plain; charset=utf-8
>
> Short answer: NO
>
> Longer answer:
>
> Finance alone does not reflect all community values. Eliminating
> needs-based evaluation for transfers
> will foster an environment open to speculation and other artifice used to
> maximize the monetization of
> address resources without providing the benefit to the community of
> maximizing utilization.
>
> In fact, I believe that eliminating needs-basis will likely cause actual
> utilization to be reduced in the
> long run in favor of financial manipulation.
>
> Owen
>
> > On Sep 24, 2015, at 11:55 , Leif Sawyer <lsawyer at gci.com> wrote:
> >
> > Now that we've reached the magic ZERO in the free pool, what does the
> community
> > think about this new draft policy?
> >
> > Should ARIN begin the process of streamlining the IPv4 policy so that it
> is
> > geared more toward the transfer market, and remove "need" as a criteria
> in
> > certain sections of the NRPM to increase the database accuracy?
> >
> >
> > -----Original Message-----
> > From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On
> Behalf Of ARIN
> > Sent: Wednesday, September 23, 2015 12:54 PM
> > To: arin-ppml at arin.net
> > Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based
> evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
> >
> > Draft Policy ARIN-2015-9
> > Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4
> transfers of IPv4 netblocks
> >
> > On 17 September 2015 the ARIN Advisory Council (AC) accepted
> > "ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3,
> and 8.4 transfers of IPv4 netblocks" as a Draft Policy.
> >
> > Draft Policy ARIN-2015-9 is below and can be found at:
> > https://www.arin.net/policy/proposals/2015_9.html
> >
> > You are encouraged to discuss the merits and your concerns of Draft
> Policy 2015-9 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-2015-9
> > Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4
> transfers of IPv4 netblocks
> >
> > Date: 23 September 2015
> >
> > Problem statement:
> >
> > The current policies in NRPM sections 8.2, 8.3, and 8.4 regarding
> transfer of IPv4 netblocks from one organization to another are currently a
> hindrance in ensuring database accuracy. In practice, ARIN staff are
> utilizing those polices to refuse to complete database updates which would
> reflect an accurate transfer of control / utilization of netblocks in cases
> where ARIN doesn't agree that the recipient organization has need, or more
> often where the recipient organization bypasses the ARIN registry entirely
> in order to secure the needed IPv4 netblocks in a more timely fashion
> directly from the current holder.
> > Additionally, the 8.1 introduction section includes a perceived "threat"
> > of reclaim which serves as a hindrance to long-term resource holders
> approaching ARIN with database updates when transferring resources. The
> result is that the data visible in ARIN registry continues to become more
> inaccurate over time.
> >
> > Policy statement:
> >
> > This proposal is for the following language changes in the respective
> NRPM sections in order to eliminate all needs-based evaluation for the
> respective transfer type, and allow transfers to be reflected in the
> database as they occur following an agreement of transfer from the resource
> provider to the recipient.
> >
> > Section 8.1 Principles:
> >
> > - Strike the 3rd paragraph which begins with "Number resources are
> issued, based on justified need, to organizations. . ." since it mostly
> reiterates other sections of ARIN policy. All transfers are subjected to
> those policies, as called out in 8.2, 8.3, 8.4. Additionally, removing this
> paragraph removes the perceived "threat" of reclaim which serves as a
> hindrance to long-term resource holders approaching ARIN with database
> updates, since in practice ARIN has not been forcibly reclaiming IP
> resources assigned to "failed businesses."
> >
> > Section 8.2 Mergers and Acquisitions:
> >
> > - Change the 4th bullet from:
> >
> > "The resources to be transferred will be subject to ARIN policies."
> >
> > to:
> >
> > "The resources to be transferred will be subject to ARIN policies,
> excluding any policies related to needs-based justification or inspection
> of current or future utilization rate."
> >
> > - Remove entirely the last paragraph which reads "In the event that
> number resources of the combined organizations are no longer justified
> under ARIN policy at the time ARIN becomes aware of the transaction,
> through a transfer request or otherwise, ARIN will work with the resource
> holder(s) to return or transfer resources as needed to restore compliance
> via the processes outlined in current ARIN policy."
> >
> > Section 8.3 Transfers between Specified Recipients within the ARIN
> Region:
> >
> > - Change the first bullet under "Conditions on recipient of the
> transfer" from:
> >
> > "The recipient must demonstrate the need for up to a 24-month supply of
> IP address resources under current ARIN policies and sign an RSA."
> >
> > to:
> >
> > "The recipient must sign an RSA."
> >
> > - Change the 2nd bullet under "Conditions on recipient of the transfer"
> > from:
> >
> > "The resources to be transferred will be subject to ARIN policies."
> >
> > to:
> >
> > "The resources to be transferred will be subject to ARIN policies,
> excluding any policies related to needs-based justification or inspection
> of current or future utilization rate."
> >
> > Section 8.4 Inter-RIR Transfers to Specified Recipients:
> >
> > - Change the introductory language from:
> >
> > "Inter-regional transfers may take place only via RIRs who agree to the
> transfer and share reciprocal, compatible, needs-based policies."
> >
> > to:
> >
> > "Inter-regional transfers may take place only via RIRs who agree to the
> transfer and share reciprocal, compatible, policies."
> >
> > - Change the 2nd bullet under "Conditions on recipient of the transfer"
> > from:
> >
> > "Recipients within the ARIN region will be subject to current ARIN
> policies and sign an RSA for the resources being received."
> >
> > to:
> >
> > "Recipients within the ARIN region will be subject to current ARIN
> policies, excluding any policies related to needs-based justification or
> inspection of current or future utilization rate, and sign an RSA for the
> resources being received."
> >
> > - Remove entirely the 3rd bullet under "Conditions on recipient of the
> transfer" which reads "Recipients within the ARIN region must demonstrate
> the need for up to a 24-month supply of IPv4 address space."
> >
> > Comments:
> >
> > a.    Timetable for implementation: Immediate
> >
> > b.    Anything else
> >
> > As the "free pool" for 4 of the 5 world's RIRs (APNIC, RIPE, LACNIC, and
> > ARIN) has now been exhausted, networks in need of additional IPv4
> addresses have shifted away from the practice of receiving them from the
> RIR's resource pool. Instead, networks in need are seeking out current
> holders of IPv4 resources who are willing to transfer them in order to
> fulfil that need. Accordingly, the RIR's primary responsibility vis-?-vis
> IPv4 netblock governance has shifted from "allocation" to "documentation."
> In other words, the focus must move away from practicing conservation and
> fair distribution (e.g. following guidelines set forth in RFC2050) to
> ensuring an accurate registry database of which organization is utilizing a
> given netblock as a result of transfers which occur between organizations.
> >
> > The RIPE registry can be used as a reference of one which has evolved
> over the past couple years to shift their focus away from
> conservation/allocation and towards database accuracy. IPv4 netblock
> transfers within that RIR consist merely of validating authenticity of the
> parties requesting a transfer. Provided the organizations meet the basic
> requirement of RIR membership, and that the transferring organization has
> the valid authority to request the transfer, the transaction completes
> without any "needs-based" review.
> >
> >
> > _______________________________________________
> > PPML
> > You are receiving this message because you are subscribed to the ARIN
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> > Unsubscribe or manage your mailing list subscription at:
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> > Please contact info at arin.net if you experience any issues.
> > _______________________________________________
> > PPML
> > You are receiving this message because you are subscribed to
> > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> > Unsubscribe or manage your mailing list subscription at:
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> > Please contact info at arin.net if you experience any issues.
>
>
>
> ------------------------------
>
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>
> End of ARIN-PPML Digest, Vol 123, Issue 16
> ******************************************
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