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

[Vaughn Thurman - Swift Systems]

+1

Sent from my mobile device, please forgive brevity and typos. 

> On Feb 18, 2016, at 2:16 PM, Owen DeLong <owen at delong.com> wrote:
> 
> +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> 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
>>> 
>>> 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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> 
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