[arin-ppml] Draft Policy ARIN-2017-6: Improve Reciprocity Requirement for Inter-RIR Transfers

[Scott Leibrand]

I strongly oppose this draft policy. Preventing transfers because someone else prevents transfers is not helpful. 

Scott

> On Jun 20, 2017, at 10:37 AM, ARIN <info at arin.net> wrote:
> 
> On 15 June 2017, the ARIN Advisory Council (AC) advanced "ARIN-prop-241: Improve Reciprocity Requirement for Inter-RIR Transfers" to Draft Policy status.
> 
> Draft Policy ARIN-2017-6 is below and can be found at:
> https://www.arin.net/policy/proposals/2017_6.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,
> 
> Sean Hopkins
> Policy Analyst
> American Registry for Internet Numbers (ARIN)
> 
> 
> 
> Draft Policy ARIN-2017-6: Improve Reciprocity Requirement for Inter-RIR Transfers
> 
> Problem Statement:
> 
> Currently ARIN's requirement that inter-RIR transfer policies be reciprocal has a glaring hole in it in that RIRs which have NIRs and/or a two-hop RIR transfer process can be used to circumvent the intent of the requirement. Rather than eliminate the requirement, a better approach would be to close the loophole.
> 
> Policy statement:
> 
> Amend section 8.4 (included here for reference):
> 
> 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, unless either the source or recipient entity owns or controls the other, or both are under common ownership or control. This restriction does not include M&A transfers.
> 
> Address resources from a reserved pool (including those designated in Section 4.4 and 4.10) are not eligible for transfer.
> 
> 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.
> 
> Make the following change:
> 
> Add an additional bullet to "Conditions on recipient" which states:
> 
> + Recipient RIR policy must not permit transfers to other RIRs or NIRs whose policies do not support bi-directional transfers.
> 
> Comments:
> 
> a. Timetable for implementation: Immediate
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