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

[Chris Spears]

I support this proposal as written.

On Tue, Jun 21, 2016 at 12:13 PM, 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
> _______________________________________________
> PPML
> You are receiving this message because you are subscribed to
> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> http://lists.arin.net/mailman/listinfo/arin-ppml
> Please contact info at arin.net if you experience any issues.