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

[Brett Frankenberger]

On Wed, Jun 22, 2016 at 06:47:03PM -0700, Andrew Dul wrote:
> Hi Brett,
> 
> On 6/22/2016 11:26 AM, Brett Frankenberger wrote:
> >
> > 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.  

8.5.4 as proposed does not include any officer attestation language. 
Is it your understanding that the implementation of 8.5.4 and 8.5.2
would result, in the case of an 8.5.4 transfer, in ARIN requiring an
officer attestation to the effect that the /24 will be used on an
operational network?  If we want an officer to attest to the usage in
that case, shouldn't that be written into the policy (as was done for
8.5.5)?

> >  (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.

So by this policy, we are:

(a) Stating that transfers -- even 8.5.4 transfers of a /24 to an
organization that currently has no direct assignments or allocations --
are only for organizations that intend to use them on an operational
network.

(b) Leaving it to ARIN staff to determine how to verify that in the
case of 8.5.4?

As a matter of policy, I'm OK with that.  But 8.5.2 seems a misleading
way to get there.

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

     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.

That language suggests that if I am an organization with no direct
assignment or allocation, I qualify for a transfer of a /24.  What you
appear to be saying is that the actual policy (due to the contribution
of 8.5.2) is that I qualify for a /24 if I am an organization with no
direct assignmetns or allocations, *and* I intend to use them on an
operational network.

If the latter is the intended policy, I would write it that way:

   8.5.4:  Organizations without direct assignments or allocations from
           ARIN qualify for a transfer of an initial block of ARIN's
           minimum transfer size, provided the organization intends to
           use the transferred block on an operational network.

8.5.2 could then be removed (or, if it was left, it would at least not
appear inconsistent with 8.5.4.)

(By way of analogy, if our intent is that 8.5.2 would effectively
impose an additional constraint on an 8.5.4 transfer, then we have an
NRPM that is conceptually like:
   SECTION A:  All children are entitled to a lollipop.
   SECTION B:  Actually, only children that plan to consume the lollipop
               are entitled to a lollopop.
That strikes me as poorly drafted.)

     -- Brett