[arin-ppml] Draft Policy ARIN-2020-6: Allowance for IPv4 Allocation “Swap” Transactions via 8.3 Specified Transfers and 8.4 Inter-RIR Transfers

[ARIN]

On 18 June 2020, the ARIN Advisory Council (AC) accepted "ARIN-prop-289: 
Allowance for IPv4 Allocation “Swap” Transactions via 8.3 Specified 
Transfers and 8.4 Inter-RIR Transfers" as a Draft Policy.

Draft Policy ARIN-2020-6 is below and can be found at:

https://www.arin.net/participate/policy/drafts/2020_6/

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/participate/policy/pdp/

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/participate/policy/drafts/

Regards,

Sean Hopkins
Policy Analyst
American Registry for Internet Numbers (ARIN)



Draft Policy ARIN-2020-6: Allowance for IPv4 Allocation “Swap” 
Transactions via 8.3 Specified Transfers and 8.4 Inter-RIR Transfers

Problem Statement:

Organizations wishing to “swap out” a larger block for a smaller one in 
the interest of avoiding deaggregation (as opposed to breaking up their 
existing block and transferring only a part of it) are forbidden by 
existing 8.3 policy from being the source of the transfer for their 
larger block after receiving a smaller one for 12 months after receiving 
the smaller block. In practice, ARIN staff has been allowing orgs to 
transfer out blocks after receiving smaller ones inside of the 12-month 
window, but many ARIN resource holders are not aware of this. Some 
resource holders have worked around the restriction by creating a new 
org to receive the smaller block, but this practice has implications on 
waitlist policy, as the new org is now technically eligible to apply for 
wait-list space while the original org cannot.

Similar language is present in NRPM Section 8.4, as such, the practice 
should be sanctioned for those types of transfers as well.

Policy Statement:

Clarify the conditions under 8.3 and 8.4 that explicitly allows transfer 
of a larger block in exchange for a smaller one as part of a renumbering 
plan. This is accomplished by adding a sub-bullet point below in both 
sections:

Section 8.3, under “Conditions on Source Of the Transfer”:

“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 
8.2 transfers.

(ADD)

This requirement may be waived by ARIN if the source entity is 
transferring resources as part of a renumbering plan designed to more 
efficiently utilize number resources, for example, having received a 
smaller block (via waitlist or transfer) with the intention of 
renumbering into that block and then transferring their pre-existing 
larger allocation to another specified recipient.

Section 8.4, under “Conditions on Source Of the Transfer”:

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 8.2 transfers.

(ADD)

This requirement may be waived by ARIN if the source entity is 
transferring resources as part of a renumbering plan designed to more 
efficiently utilize number resources, for example, having received a 
smaller block (via waitlist or transfer) with the intention of 
renumbering into that block and then transferring their pre-existing 
larger allocation to another specified recipient.

Timetable for implementation: Immediate

Comments:

The AC’s understanding is that Registration Services is allowing this 
practice currently via the pre-approval process; this proposal aims to 
officially sanction this practice.