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

[Leif Sawyer]

Good afternoon -

  Based on feedback from Montreal as well as internal discussions, I've reworked this policy.
AC members and ARIN staff are looking for additional feedback, as well as your position in terms
of supporting or opposing this draft policy.

  We'll be discussing this policy, as well as any feedback provided on this week's AC teleconference,
so I'm very appreciative of your input.

Thanks,

  Leif Sawyer
  Shepherd - ARIN-2015-9

NRPM section 8: https://www.arin.net/policy/nrpm.html#eight

Most current draft policy text follows:
--

Draft Policy ARIN-2015-9
    Eliminating needs-based evaluation for Section 8.2 and 8.3 transfers of IPv4 netblocks
Original Date: 23 September 2015
Updated: 16 February, 2016

Problem statement:
The current needs-based evaluation language in NRPM sections 8.2 and 8.3, regarding transfer of IPv4
netblocks from one organization to another, may cause a recipient organization to bypass the ARIN
registry entirely in order to secure the needed IPv4 netblocks in a more timely fashion directly from the
current holder. The result is that the data visible in ARIN registry may become more inaccurate over
time.

Policy statement:
This proposal eliminates all needs-based evaluation language for sections 8.2 and 8.3, allowing
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 fragment from the 3rd paragraph which reads
	", based on justified need, " 
so the resulting text reads 
"Number resources are issued to organizations, not to individuals representing those organizations."
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."

- Strike the final paragraph which begins "In the event that number resources of the combined organizations are no longer justified under 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."

Comments:
a. Timetable for implementation: Immediate
b. Anything else
As the "free pool" for 4 of the 5 world's RIR's (APNIC, RIPE, LACNIC, and ARIN) have 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 fulfill that need. Accordingly, the RIR's
primary responsibility vis-à-vis IPv4 netblock governance has shifted from "allocation" to ensuring an
accurate registry database.

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.