[arin-ppml] Draft Policy ARIN-2016-5: Post-IPv4-Free-Pool-Depletion Transfer Policy

[Andrew Dul]

Hi Brett,

On 6/22/2016 11:26 AM, Brett Frankenberger wrote:
> On Wed, Jun 22, 2016 at 11:15:58AM -0500, Scott Leibrand wrote:
>> On Wed, Jun 22, 2016 at 11:00 AM, Mike Burns <mike at iptrading.com> wrote:
>>
>>> Hi Andrew,
>>>
>>> I have a couple of questions about the policy proposal.
>>>
>>>  On Section 8.5.2 Operational Use.
>>>
>>> First, why is this section even in there, does it serve some particular
>>> purpose?
>>>
>> It prevents financial speculators, who have no operational use for the
>> addresses, from acquiring them for speculative purposes.
> If that's the intent, I think it would better to make "operational
> network" part of the actual requirements, rather than have a general
> "ARIN transfers for the purposes of use on an operational network"
> platitude, and then interpret that as a condition of transfer rather
> than a general statement of a goal we consider worthy.
>
> For example, for an entity wanting to get a /24 under 8.5.4, ARIN would
> first validate that the organization had no existing direct assignments
> or allocations, but then what?  How would they implement 8.5.2?  Ask
> "do you plan to use this on an operational network"?  Request officer
> attestation as to plans to use the /24 on an operational network?  Do
> nothing and approve the transfer on the theory that the requester is on
> his honor to abide by 8.5.2 even without being asked about it?  Approve
> the transfer unless ARIN had some specific reason to believe that the
> proposed transfer was for the purposes of financial speculation? 
> Something else?

The point of 8.5.2 is to clarify that the community believes that IPv4
addresses are to be used on operational networks, not as resources to be
held for some other purpose (e.g. financial speculation).  We ask that
an officer of the organization to attest to ensure that the organization
understands the nature of the transaction and doesn't commit its $ in
support of other goals.  I believe having it in section 8 helps
organizations clearly understand the requirements for transfer.  (e.g.
They don't have to hunt around in other sections for other
requirements.) I, personally, believe that the base requirement for any
transfer is that the organization intend to use it on an operational
network. 


>
> As for 8.5.5, would 8.5.2 be of any effect given that documentation is
> already required. 

8.8.5 is used when 8.5.4 is not used.  So if you are a new org w/o any
address space from ARIN, you have to meet requirements 8.5.1-4.  8.5.5 &
8.5.6 are used for organizations which do not have address space from
ARIN or who want more than the minimum.

>  (Is 8.5.2 the thing that would allow ARIN to reject
> documention along the lines of "we will, within 24 months, make use of
> the transferred space for the purposes of financial speculation"?  That
> seems like overkill; before run-out, ARIN didn't need something like
> 8.5.2 to reject requests for free-pool assignments that came in with a
> justification of "financial speculation" -- I don't know that they
> ever received such, but I'm sure they would have rejected it had they
> received such.)

ARIN would have rejected a free-pool request prior to run-out for a
financial speculator because they didn't show evidence (via needs-test)
how they would be using the addresses on a network.  If we don't have
any requirement that IP number resources are to be used on an
operational network, then an organization can come to ARIN and have
resources transferred into their organization.  ARIN follows the
policies we set, so if our policies are silent about the types of
organizations who are eligible for resources, then ARIN must assume that
all organizations are eligible to receive transferred resources.

We are certainly open to other language if you would like to suggest
something, to clarify our intent.

Andrew


> If we want ARIN to impose an operational network requirement, we should
> be clear what that means. 
>
> All that said, I support the goals of this proposal.  I agree that
> 8.5.2 is non- or poorly- operative (but keeping it would not cause me
> to drop my support for the proposal), and have no opinion on Owen's
> proposal to do it in section 4 rather than 8, but I support the
> elimination of justification for the first /24, and the proposed 8.5.5
> requirements for subsequent or larger tansfers.  I note that it's
> possible that there will be small free-pool assignments made going
> forward, so doing this in section 4, as opposed to section 8, is not a
> purely editorial change.
>
> (Proposed sections referenced above are quoted below for reference.)
>
>     8.5.2. Operational Use
>
>     ARIN allocates or assigns blocks of IP addresses to organizations via
>     transfer solely for the purpose of use on an operational network.
>       
>     8.5.4. Initial block
>         
>     Organizations without direct assignments or allocations from ARIN
>     qualify for transfer of an initial block of ARIN's minimum transfer size.
>
>     8.5.5. Block size
>
>     Organizations may qualify for the transfer of a larger initial block,
>     or an additional block, by providing documentation to ARIN which details
>     the use of at least 50% of the requested block size within 24 months. An
>     officer of the organization shall attest to the documentation provided to
>     ARIN.
>
>      --  Brett
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