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

[Brian Jones]

I support this proposal as written.
__
Brian Jones
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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