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

[John Santos]

This change would make the policy proposal meaningless.  Can't a large holder 
ALREADY renumber into a small part of their holding and sell the rest of it in 
pieces?  (Resulting in more fragmentation.)

The point of this proposal is to minimize fragmentation of existing allocations 
when the are returned to what is essentially the modern free pool.

I support the policy as written.

-- John

On 2/8/2022 12:29 PM, Mike Burns wrote:
> 
> Hi Rob,
> 
> I am opposed to the policy as written because it requires the larger block to be sold in one piece.
> This isn't always possible or desirable for a seller. What if they have a /14 or larger?
> I prefer allowing the workaround with the new Org for the small block with a restriction on the new Org's access to the waiting list.
> 
> It would be better for ARIN to wake up and realize cluttering the NRPM with these increasingly byzantine rules has been proven to be unnecessary by the RIPE experience. Maybe a decade is long enough for the experiment? In RIPE, we don't have this deaggregation problem because the problem stems from the hoary needs test regime at ARIN.
> 
> Get rid of the needs-test and streamline the NRPM, continuing down the needs-test road will inevitably lead to more confusion as we carve out more and more exceptions.
> 
> Also this policy allows any block holder to buy a smaller block without a needs test by claiming they plan to sell the larger block in the future, they all get one bite at this apple without attestation.
> 
> Regards,
> Mike
> 
> 
> 
> -----Original Message-----
> From: ARIN-PPML <arin-ppml-bounces at arin.net> On Behalf Of Rob Seastrom
> Sent: Saturday, February 05, 2022 11:56 AM
> To: ARIN-PPML List <arin-ppml at arin.net>
> Subject: [arin-ppml] Updated text for ARIN-2020-6 'Allowance for IPv4 Allocation “Swap” Transactions via 8.3 Specified Transfers and 8.4 Inter-RIR Transfers'
> 
> 
> Dear ARIN Community,
> 
> Pursuant to December's Staff and Legal review of ARIN-2020-6, the following changes have been made:
> 
> In section 8.5.5.1, changed
> 
> If the larger block is not transferred within one year of receipt of the smaller block, the smaller block will be ineligible for transfer under sections 8.3 and 8.4, and the organization will be ineligible to receive any further transfers under this policy.
> 
> to
> 
> If the larger block is not transferred within one year of receipt of the smaller block, the organization will be ineligible to receive any further transfers under this section until the larger block is transferred.
> 
> Also:
> * removed reference to officer attestation as a result of last summer's ACSP consultation.
> * Clarified section 8.3 and 8.4 "Conditions on Source of Transfer" to refer directly to proposed section 8.5.5.1
> 
> The new text of the proposal is as follows.  Please share your thoughts.
> 
> 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 by making the following changes in 8.3, 8.4, and 8.5:
> 
> Current text:
> 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 IPv4 block size within 24 months. An officer of the organization shall attest to the documentation provided to ARIN.
> Add:
> 8.5.5.1- Transfer for the Purpose of Renumbering Organizations with larger direct allocations or assignments than they require may receive transfer of a smaller block for the purpose of renumbering onto the smaller block if they transfer the entire larger block to a qualified recipient under section 8 within one year of receipt of transfer of the smaller block. If the larger block is not transferred within one year of receipt of the smaller block, the organization will be ineligible to receive any further transfers under this section until the larger block is transferred.
> 
> 8.5.5.1.1 Smaller Block Size
> Organizations may qualify to receive transfer of a smaller block by providing documentation to ARIN which details the use of at least 50% of the smaller block size within 24 months. Current use of the larger block may be used to satisfy this criteria.
> 
> 
> Current text:
> 8.5.6. Efficient Utilization of Previous Blocks Organizations with direct assignments or allocations from ARIN must have efficiently utilized at least 50% of their cumulative IPv4 address blocks in order to receive additional space. This includes all space reassigned to their customers.
> Add:
> 
> 
> 8.5.6.1 Transfer for the Purpose of Renumbering Organizations receiving transfer of a smaller block under section 8.5.5.1 may deduct the larger block they are transferring to a qualified recipient when calculating their efficient utilization of previous blocks under section 8.5.6.
> 
> 
> Current Text:
> Sections 8.3 and 8.4, 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.
> Change to:
> With the exception of M&A transfers under section 8.2, the source entity must not have received a transfer, allocation, or assignment from ARIN for the past 12 months.  This requirement may be waived by ARIN for transfers made in connection with a renumbering exercise designed to more efficiently utilize number resources under section 8.5.5.1.
>   
> Timetable for Implementation: Immediate
> 
> 
> 
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-- 
John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539