[arin-ppml] Recommended Draft Policy ARIN-2016-1: Reserved Pool Transfer Policy

[John Santos]

Support.

On Tue, 21 Jun 2016, ARIN wrote:

> On 16 June 2016 the ARIN Advisory Council (AC) advanced the following 
Draft Policy to Recommended Draft Policy status:

ARIN-2016-1: Reserved Pool Transfer Policy

The text of the Recommended Draft Policy is below, and may also be found at:
https://www.arin.net/policy/proposals/2016_1.html

You are encouraged to discuss all Recommended Draft Policies on PPML 
prior to their presentation at the next ARIN Public Policy Consultation 
(PPC). PPML and PPC discussions are invaluable to the AC when 
determining community consensus.

The 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)

Recommended Draft Policy ARIN-2016-1: Reserved Pool Transfer Policy

Date: 21 June 2016

AC assessment of conformance with the Principles of Internet Number 
Resource Policy:

This proposal enables fair and impartial number resource administration 
by ensuring that IPv4 resources, which are specially designated for 
critical infrastructure and IPv6 transition, are readily available for 
many years into the future. This is done by ensuring the resources 
remain in their originally designated pool rather than being moved into 
the general IPv4 address pool via a transfer.  This proposal is 
technically sound and is supported by the community.

Problem Statement:

Section 8 of the current NRPM does not distinguish between the transfer 
of blocks from addresses that have been reserved for specific uses and 
other addresses that can be transferred. In sections 4.4 and 4.10 there 
are specific address blocks set aside, based on the need for critical 
infrastructure and IPv6 transitions. Two issues arise if transfers of 
reserved address space occur under the current language of section 8. 
First, if transfers of 4.4 or 4.10 space occur under the current policy 
requirements set forth in sections 8.3 and 8.4, the recipients will be 
able to acquire space that was originally reserved for a specific 
purpose without ever providing evidence that they will be using the 
space for either critical infrastructure or IPv6 transition. Second, if 
we allow an allocation or assignment from the block reserved in section 
4.10 to be transferred out of the region, it would complicate the single 
aggregate from which providers are being asked to allow in block sizes 
smaller than a /24. This policy would limit the transfer of addresses 
from reserved pools.

Policy statement:

Add to Section 8.3 and Section 8.4 under the "Conditions on source of 
the transfer:"

Address resources from a reserved pool (including those designated in 
Section 4.4 and 4.10) are not eligible for transfer.

Timetable for implementation: Immediate

##########

ARIN STAFF & LEGAL ASSESSMENT
Draft Policy ARIN-2016-1
RESERVED POOL TRANSFER POLICY
https://www.arin.net/policy/proposals/2016_1.html

Date of Assessment: 13 June 2016
___
1. Summary (Staff Understanding)

This policy would make IPv4 addresses issued under NRPM 4.4 and 4.10 
ineligible for transfer inside the NRPM 8.3 and 8.4 transfer policies.
___
2. Comments

A. ARIN Staff Comments

* If this policy is implemented, ARIN staff would not allow NRPM 8.3 and 
8.4 transfers to include IPv4 addresses previously issued under NRPM 4.4 
and 4.10 policies.

* ARIN staff would continue to allow IPv4 addresses previously issued 
under NRPM 4.4 and 4.10 to be included in Merger and Acquisition (NRPM 
8.2) transfers.

* This policy could be implemented as written.

B. ARIN General Counsel – Legal Assessment

The policy does not create a material legal issue. It should be noted 
that ARIN does permit transfers of IPV4 resources pursuant to 8.3 and 
8.4. This policy is an exception to that transferability and is 
consistent with the intent and of the policy by which these allocations 
were made.
___
3. Resource Impact

Implementation of this policy would have minimal resource impact. 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-2016-1
Reserved Pool Transfer Policy

Date: 22 March 2016

Problem Statement:

Section 8 of the current NRPM does not distinguish between the transfer 
of blocks from addresses that have been reserved for specific uses and 
other addresses that can be transferred. In sections 4.4 and 4.10 there 
are specific address blocks set aside, based on the need for critical 
infrastructure and IPv6 transitions. Two issues arise if transfers of 
reserved address space occur under the current language of section 8. 
First, if transfers of 4.4 or 4.10 space occur under the current policy 
requirements set forth in sections 8.3 and 8.4, the recipients will be 
able to acquire space that was originally reserved for a specific 
purpose without ever providing evidence that they will be using the 
space for either critical infrastructure or IPv6 transition. Second, if 
we allow an allocation or assignment from the block reserved in section 
4.10 to be transferred out of the region, it would complicate the single 
aggregate from which providers are being asked to allow in block sizes 
smaller than a /24. This policy would limit the transfer of addresses 
from reserved pools.

Policy statement:

Add to Section 8.3 and Section 8.4 under the "Conditions on source of 
the transfer:"

Address resources from a reserved pool (including those designated in 
Section 4.4 and 4.10) are not eligible for transfer.

Timetable for implementation: Immediate
_______________________________________________
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-- 
John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539