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

Sat Jun 25 18:38:12 EDT 2016

Would it be beneficial to do a rewrite as Andrew did, but simply make it
editorial without changing the intent or implementation of the policy.
Then do a red line for intent changes?

This would enable use to discuss the simplification and re-organization
without getting bogged down in disagreement over changes.

Once we agree on the non-policy impacting editorial re-write, then we could
look at red-line changes, and decide which policy changes have support and
which do not. We could then move forward with the changes that are
supported, tweak the text a bit, and discuss it in the fall without getting
bogged down in discussions about the re-organization.

Andrew, Owen, what do you think?

__Jason

On Wed, Jun 22, 2016 at 1:30 PM, Owen DeLong <owen at delong.com> wrote:

>
> > On Jun 22, 2016, at 08:46 , Andrew Dul <andrew.dul at quark.net> wrote:
> >
> > As the primary author of this draft policy, I respectfully disagree with
> > my AC colleague.
> >
> > Now that the free pool has been depleted, it is time to look toward what
> > future IPv4 (primarily transfer) policy should do.  While this policy
> > looks complicated, its intention is to create a very simple transfer
> > policy which allows businesses to predictably and efficiently transfer
> > IPv4 resources to meet their requirements.
>
> I don’t disagree with your intent, but I disagree that what you have
> proposed achieves that intent.
>
> You are eliminating key safeguards from the transfer policy while
> simultaneously
> changing several of the criteria that have previously applied to transfers
> of
> IPv4 space under section 4.
>
> In addition, there may be unintended effects on the transfer of ASNs.
>
> > I share with you here a redline which shows the changes that would be
> > made to section 8.
>
> The redline doesn’t begin to cover it because it does nothing to evaluate
> how
> removing the existing interactions with section 4 compares to existing
> policy
> implementation.
>
> As a result, the redline ends up looking deceptively minor.
>
> Owen
>
> >
> > Andrew
> >
> > On 6/21/2016 9:16 AM, Owen DeLong wrote:
> >> I am opposed to this policy proposal.
> >>
> >> Given that we are now in a world where the only way to obtain IPv4
> space is through transfers, I think it makes much more sense to put policy
> changes for IPv4 transfers into section 4 and retain the simplified text
> that exists today in section 8 rather than copying most of section 4 into
> section 8 with revisions in the process.
> >>
> >> The likely outcome of such an exercise is to create a number of changes
> which may or may not be fully understood by the community. The interaction
> of this rewrite with other types of transferable resources (AS numbers at
> the moment) must also be carefully considered.
> >>
> >> If we want to change IPv4 policy, then let’s change IPv4 policy in
> section 4.
> >>
> >> If we want to change transfer policy for all resources, we can do that
> cleanly in section 8.
> >>
> >> While the NRPM may not be a perfect model of a structured document,
> this proposal would make it significantly worse.
> >>
> >> Owen
> >>
> >>> On Jun 21, 2016, at 09:01 , ARIN <info at arin.net> wrote:
> >>>
> >>> On 16 June 2016 the ARIN Advisory Council (AC) advanced the following
> Proposal to Draft Policy status:
> >>>
> >>> ARIN-prop-230: Post-IPv4-Free-Pool-Depletion Transfer Policy
> >>>
> >>> This Draft Policy has been numbered and titled:
> >>>
> >>> Draft Policy ARIN-2016-5: Post-IPv4-Free-Pool-Depletion Transfer Policy
> >>>
> >>> Draft Policy ARIN-2016-5 is below and can be found at:
> >>> https://www.arin.net/policy/proposals/2016_5.html
> >>>
> >>> You are encouraged to discuss all Draft Policies on PPML. The AC will
> evaluate the discussion in order to assess the conformance of this draft
> policy with ARIN's Principles of Internet number resource policy as stated
> in the Policy Development Process (PDP). Specifically, these principles are:
> >>>
> >>>     > Enabling Fair and Impartial Number Resource Administration
> >>>     > Technically Sound
> >>>     > Supported by the Community
> >>>
> >>> 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)
> >>>
> >>> ##########
> >>>
> >>> Draft Policy ARIN-2016-5: Post-IPv4-Free-Pool-Depletion Transfer Policy
> >>>
> >>> Date: 21 June 2016
> >>>
> >>> Problem Statement
> >>>
> >>> Section 4 of the Number Policy Resource Manual was developed over the
> past 15+ years primarily to conservatively manage the IPv4 number free
> pool. Since the IPv4 free pool was depleted in 2015, the policies which
> developed since ARIN's inception may now not be as relevant now that the
> primary function of the registry, with regard to IPv4 numbers, is to record
> transfers.
> >>>
> >>> Since section 4 of the NRPM now contains many use cases that are not
> as relevant, it makes sense to streamline the transfer process and to
> specifically outline the criteria that should be used to process transfers.
> >>>
> >>> Therefore, we propose the following rewrite of the transfer policy,
> section 8 of the NRPM.
> >>>
> >>> The goals of this rewrite are as follows:
> >>>
> >>>> Separate the criteria that is found in section 4 of the NRPM from the
> transfer process.
> >>>> Provide a clear set of criteria that should be applied across all
> IPv4 transfers.
> >>>> Lower the thresholds on utilization and future allocation size to
> negate the necessity of the corner cases which are currently enumerated in
> section 4 of the NRPM.
> >>>> Reduce the complexity that is currently required for transfers, by
> applying simpler utilization criteria for current usage, and future
> allocation sizing.
> >>> Policy statement:
> >>>
> >>> Add new section 8.5; update sections 8.2-8.4 as follows to reference
> 8.5.
> >>>
> >>> ######
> >>>
> >>> 8.2. Mergers, Acquisitions, and Reorganizations
> >>>
> >>> ARIN will consider requests for the transfer of number resources in
> the case of mergers, acquisitions, and reorganizations under the following
> conditions:
> >>>
> >>>> The current registrant must not be involved in any dispute as to the
> status of the resources to be transferred.
> >>>> The new entity must sign an RSA covering all resources to be
> transferred.
> >>>> The resources to be transferred will be subject to ARIN policies.
> >>>> The minimum transfer size is the smaller of the original allocation
> size or the applicable minimum allocation size in current policy.
> >>>> For mergers and acquisition transfers, the recipient entity must
> provide evidence that they have acquired assets that use the resources to
> be transferred from the current registrant. ARIN will maintain an
> up-to-date list of acceptable types of documentation.
> >>> ARIN will proceed with processing transfer requests even if the number
> resources of the combined organizations exceed what can be justified under
> current ARIN transfer policy as defined in section 8.5. In that event, ARIN
> will work with the resource holder(s) to transfer the extra number
> resources to other organization(s) or accept a voluntary return of the
> extra number resources to ARIN.
> >>>
> >>> 8.3. Transfers between Specified Recipients within the ARIN Region
> >>>
> >>> In addition to transfers under section 8.2, IPv4 numbers resources and
> ASNs may be transferred according to the following conditions.
> >>>
> >>> Conditions on source of the transfer:
> >>>
> >>>> The source entity must be the current registered holder of the IPv4
> address resources, and not be involved in any dispute as to the status of
> those resources.
> >>>> The source entity must not have received a transfer, allocation, or
> assignment of IPv4 number resources from ARIN for the 12 months prior to
> the approval of a transfer request. This restriction does not include M&A
> transfers.
> >>> Conditions on recipient of the transfer:
> >>>
> >>>> The recipients must meet the transfer requirements as defined in
> section 8.5.
> >>>> The resources transferred will be subject to current ARIN policies.
> >>> 8.4. Inter-RIR Transfers to Specified Recipients
> >>>
> >>> Inter-regional transfers may take place only via RIRs who agree to the
> transfer and share reciprocal, compatible, needs-based policies.
> >>>
> >>> Conditions on source of the transfer:
> >>>
> >>>> The source entity must be the current rights holder of the IPv4
> address resources recognized by the RIR responsible for the resources, and
> not be involved in any dispute as to the status of those resources.
> >>>> Source entities outside of the ARIN region must meet any requirements
> defined by the RIR where the source entity holds the registration.
> >>>> Source entities within the ARIN region must not have received a
> transfer, allocation, or assignment of IPv4 number resources from ARIN for
> the 12 months prior to the approval of a transfer request. This restriction
> does not include M&A transfers.
> >>> Conditions on recipient of the transfer:
> >>>
> >>>> The conditions on a recipient outside of the ARIN region will be
> defined by the policies of the receiving RIR.
> >>>> Recipients within the ARIN region must meet the transfer requirements
> as defined in section 8.5.
> >>>> Recipients within the ARIN region will be subject to current ARIN
> policies.
> >>> 8.5. Specified Transfer Recipient Requirements
> >>>
> >>> 8.5.1. Registration Services Agreement
> >>>
> >>> Transfer recipients must sign an RSA for the resources being received.
> >>>
> >>> 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.
> >>>
> >>> 8.5.3. Minimum transfer size
> >>>
> >>> ARIN's minimum transfer size is a /24.
> >>>
> >>> 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.
> >>>
> >>> 8.5.6. Efficient utilization of previous blocks
> >>>
> >>> Organizations with direct assignments or allocations from ARIN must
> have efficiently utilized at least 50% of every block in order to receive
> additional space. This includes all space reassigned to their customers.
> >>>
> >>> Comments:
> >>>
> >>> Timetable for implementation: immediately
> >>>
> >>> Anything else: A redline has been provided to help the community
> understand the changes that have been made to the NRPM.
> >>> _______________________________________________
> >>> PPML
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> >>> Please contact info at arin.net if you experience any issues.
> >> _______________________________________________
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> >
> >
> > <Post-IPv4 Free-Pool Depletion Transfer Policy (NRPM 8 redline) -
> 20160609.pdf>_______________________________________________
> > PPML
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>
> _______________________________________________
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-- 
_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com|571-266-0006
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