Draft Policy 2012-1 Clarifying requirements for IPv4 transfers (was Re: [arin-ppml] Prop-151: Clarifying requirements for IPv4 transfers)
ARIN
info at arin.net
Wed Feb 22 17:54:52 EST 2012
Draft Policy ARIN-2012-1
Clarifying requirements for IPv4 transfers
On 16 February 2012 the ARIN Advisory Council (AC) selected "Clarifying
requirements for IPv4 transfers" as a draft policy for adoption
discussion on the PPML and at the Public Policy Meeting in Vancouver in
April.
The draft was developed by the AC from policy proposal "ARIN-prop-151
Limiting needs requirements for IPv4 Transfers." Per the Policy
Development Process the AC submitted text to ARIN for a staff and legal
assessment prior to its selection as a draft policy. Below the draft
policy is the ARIN staff and legal assessment, followed by the text that
was submitted by the AC. Note that the AC revised the draft policy text
after they received the assessment from staff.
Draft Policy ARIN-2012-1 is below and can be found at:
https://www.arin.net/policy/proposals/2012_1.html
You are encouraged to discuss Draft Policy 2012-1 on the PPML prior to
the April Public Policy Meeting. Both the discussion on the list and
at the meeting will be used by the ARIN Advisory Council to determine
the community consensus for adopting this as policy.
The ARIN Policy Development Process 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,
Member Services
American Registry for Internet Numbers (ARIN)
## * ##
Draft Policy ARIN-2012-1
Clarifying requirements for IPv4 transfers
Date: 22 February 2012
Policy statement:
Current text:
Replace Section 8.3 with
8.3 Transfers between Specified Recipients within the ARIN Region.
In addition to transfers under section 8.2, IPv4 numbers resources may
be transferred according to the following conditions.
Conditions on source of the transfer:
* The source entity must be the current registered holder of the IPv4
address resources, and not be involved in any dispute as to the status
of those resources.
* The source entity will be ineligible to receive any further IPv4
address allocations or assignments from ARIN for a period of 12 months
after a transfer approval, or until the exhaustion of ARIN's IPv4 space,
whichever occurs first.
* The source entity must not have received an allocation or assignment
of IPv4 number resources from ARIN for the 12 months prior to the
approval of a transfer request.
* The minimum transfer size is a /24
Conditions on recipient of the transfer:
* The recipient must demonstrate the need for up to a 24 month supply of
IP address resources under current ARIN policies and sign an RSA.
* The resources transferred will be subject to current ARIN policies.
Add Section 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 will not be eligible to receive
any further IPv4 address allocations or assignments from ARIN for a
period of 12 months after a transfer approval, or until the exhaustion
of ARIN's IPv4 space, whichever occurs first.
* Source entities within the ARIN region must not have received an
allocation or assignment of IPv4 number resources from ARIN for the 12
months prior to the approval of a transfer request.
* The minimum transfer size is a /24.
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 will be subject to current ARIN
policies and sign an RSA for the resources being received.
* Recipients within the ARIN region must demonstrate the need for up to
a 24 month supply of IPv4 address space.
* The minimum transfer size is a /24
Rationale:
The original text of this proposal attempted to simplify the
requirements of an IPv4 address transfer while protecting any resources
in the ARIN free pool. This revision is a result of feedback from the
mailing list, and discussions with the original author. The one key
point that has been removed from the original text is that a needs based
review remains in place.
The current text attempts to retain the original concepts of protecting
any ARIN free pool, and incorporating it with the point of bringing
resources under RSA. The resulting text attempts to put safeguards in
place on the practice of paid transfers by creating a black out period
for requests from the free pool. The text also tries to incorporate
discussions regarding inter-RIR transfers and come up with language that
includes the free pool protections for transfers in and out of the Region.
Timetable for implementation: immediate.
##########
ARIN STAFF ASSESSMENT
Proposal: ARIN-prop-151 Limiting needs requirements for IPv4 Transfers
Date of Assessment: Feb 15, 2012
1. Proposal Summary (Staff Understanding)
This proposal would modify the 8.3 transfer policy and implement an
inter-RIR transfer policy (both for IPv4 addresses only).
For 8.3 transfers, recipients would be limited to 12 months need, versus
the 24 month need currently in place, and the organization releasing the
resources can't have received additional IPv4 addresses from ARIN in the
previous 12 months and will be ineligible to receive additional IPv4
addresses for 12 months after the transfer.
For transfers from ARIN to another RIR, the releasing org must be the
authorized holder, can't have received additional IPv4 addresses from
ARIN in the previous 12 months, and will be unable to obtain additional
IPv4 addresses from ARIN for 12 months following the transfer, and the
recipient org must qualify to receive the resources under the other
RIR's policies.
For transfers to ARIN from another RIR, the other RIR must verify the
releasing org is the authorized resource holder, and the recipient may
request up to a 12 month supply of IPv4 addresses.
2. Comments
A. ARIN Staff Comments
• The timer for when the 12‐month period before the transfer begins is
undefined. When would staff start the timer? From the day the transfer
request is submitted to ARIN? Or on the future approval date of the
proposed transfer? Staff believes it would be logical to count back 12
months from the date of the transfer approval.
• This proposal imposes a 12-‐month waiting period on organizations
wishing to transfer IPv4 address space from ARIN to another region on
either side of the transfer (both pre‐xfer and post‐xfer). This would be
a good deterrent to organizations intending to “flip” IPv4 address space
via an 8.3 transfer.
• Should this same limitation be imposed on organizations wishing to
transfer IPv4 space from another region into the ARIN region such that
the releasing org cannot have received IPv4 address space from their RIR
within the 12-month period prior to the transfer? This again would deter
flipping IPv4 addresses via an 8.3 transfer and bring parity to the
policy for transfer both to and from the ARIN region.
• The concise language in the phrase, "reciprocal, compatible,
needs‐based
policies" is a very good improvement to this policy text
and makes it very clear. It ensures that both RIRs have reciprocal
inter-RIR policies, inter‐RIR policies which are compatible with one
another, and general number resource policies which are needs‐based.
• Numerous sentences in this policy are not compatible with the current
NRPM 8.3, which now allows for a 24-‐month need to be met. If this
policy proposal is being passed, the community should very carefully
compare and contrast the current NRPM 8.3 with this text to ensure the
changes being proposed are acceptable to the community.
B. ARIN General Counsel
This proposal would reverse a policy just approved days ago that allows
transfers
of up to 24 months’ need under 8.3, and move it back to the
prior policy of 12 months. Counsel had previously recommended to the
Board, AC and community that the 24 month policy was better for ARIN’s
legal needs. Adopting the reversal back to 12 months will make it much
harder for those who are willing to complete transfers in bankruptcy in
accordance with ARIN’s policies to do so. I also do not believe
reversing policy in this way is good on any subject. The electronic ink
is not dry on the change form 12 to 24 months. This proposed change
would substantially increase legal fees and legal risks for ARIN, and
therefore I would recommend to the Board that it not ratify the reversal
from 24 months to 12 months. If this problem is resolved there are no
legal concerns regarding the policy except for some logical suggestions
counsel has made to the policy text regarding inter region
transfers
Other changes in the policy appear to have solved other legal
concerns expressed in previous comments on earlier versions of this policy.
3. Resource Impact
This policy would have major resource impact from an implementation
aspect. It is estimated that implementation would occur within 12 months
after ratification by the ARIN Board of Trustees. The following would be
needed in order to implement:
• Careful coordination between the RIRs on DNS issues and updates for
the inter-rir transfers
• Potential issues include:
o Zone fragmentation
o DNS synchronization
problems
o Potential administrative and operational issues in
coordinating reverse addressing
• RPKI implications
• Updated guidelines
• Staff training
4. Proposal Text
Replace Section 8.3 with
8.3 Transfers between Specified Recipients
within the ARIN Region.
In addition to transfers under section 8.2,
IPv4 numbers resources may be transferred according to the following
conditions.
Conditions on source of the transfer:
* The source entity must be the current registered holder of the IPv4
address resources, and not be involved in any dispute as to the status
of those resources.
* The source entity will be ineligible to receive any further IPv4
address allocations or assignments from ARIN for a period of 12 months
after the transfer, or until the exhaustion of ARIN's IPv4 space,
whichever occurs first.
* The source entity must not have received an allocation or assignment
of IPv4 number resources from ARIN for the 12 months prior to the transfer.
* The minimum transfer size is a /24 Conditions on recipient of the
transfer:
* The recipient must demonstrate the need for up to a 12 month supply of
IP address resources under current ARIN policies and sign an RSA.
* The resources transferred will be subject to current ARIN policies.
Add Section 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 will not be eligible to receive
any further IPv4 address allocations or assignments from ARIN for a
period of 12 months after the transfer, or until the exhaustion of
ARIN's IPv4 space, whichever occurs first.
* Source entities within the ARIN region must not have received an
allocation or assignment of IPv4 number resources from ARIN for the 12
months prior to the transfer.
* The minimum transfer size is a /24 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 will be subject to current ARIN
policies and sign an RSA for the resources being received.
* Recipients within the ARIN region must demonstrate the need for up to
a 12 month supply of IPv4 address space.
* The minimum transfer size is a /24
Rationale:
The original text of this proposal attempted to impose few constraints
on the transfer or on the parties involved other than than allowing the
registry to record transactions where IPv4 addresses are transfered
between ARIN account holders.
This revision is a result of feedback from the mailing list, and
discussions with the original author. The one key point that has been
removed from the original text is that a needs based review remains in
place.
The current text attempts to retain the original concepts of protecting
any ARIN free pool, and incorporating it with the point of bringing
resources under RSA. The resulting text attempts to put safeguards in
place on the practice of paid transfers by creating a black out period
for requests from the free pool. The text also tries to incorporate
discussions regarding inter-‐RIR transfers and come up with language
that includes the free pool protections for transfers in and out of the
Region.
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