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

[Owen DeLong]

I support this proposal as written.

Owen

> On Jun 21, 2016, at 09:13 , ARIN <info at arin.net> 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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