[arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Owen DeLong]

While it may have that desirable effect, it certainly also comes with several undesirable effects as well.

Owen

> On Sep 24, 2015, at 14:02 , Matthew Kaufman <matthew at matthew.at> wrote:
> 
> If you're right, doesn't that simply drive v6 adoption, which is the desired goal?
> 
> 
> 
> Matthew Kaufman
> 
> On 9/24/2015 12:09 PM, Owen DeLong wrote:
>> 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-à-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.
>>> 
>>> 
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