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

[Owen DeLong]

+1 — McTim said it very well.

Owen

> On Feb 18, 2016, at 10:34 , McTim <dogwallah at gmail.com> wrote:
> 
> I am opposed.  
> 
> If there are "networks in need of additional IPv4 addresses", surely they should be able to show this, in accord with long standing practice.  
> 
> I'd rather us not move to a situation which enables/encourages speculation and profit taking (or rent-seeking if you will) in re: IP resource distribution.
> 
> Regards,
> 
> McTim
> 
> 
> On Tue, Feb 16, 2016 at 7:12 PM, Leif Sawyer <lsawyer at gci.com <mailto:lsawyer at gci.com>> wrote:
> 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 <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.
> 
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> 
> 
> -- 
> Cheers,
> 
> McTim
> "A name indicates what we seek. An address indicates where it is. A route indicates how we get there."  Jon Postel
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