Draft Policy ARIN-2014-15: Allow Inter-RIR ASN Transfers - revised

[ARIN]

Draft Policy ARIN-2014-15
Allow Inter-RIR ASN Transfers

ARIN-2014-15 has been revised.

Draft Policy ARIN-2014-15 is below and can be found at:
https://www.arin.net/policy/proposals/2014_15.html

We are also attaching a staff assessment.

You are encouraged to discuss the merits and your concerns of Draft
Policy 2014-15 on the Public Policy Mailing List.

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 PDP. Specifically, these principles are:

   * Enabling Fair and Impartial Number Resource Administration
   * Technically Sound
   * Supported by the Community

The ARIN Policy Development Process (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)


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Draft Policy ARIN-2014-15
Allow Inter-RIR ASN Transfers

Revised: 19 June 2014

Problem Statement:

We already allow transfer of ASNs within the ARIN region. Recently APNIC 
implemented a policy allowing for Inter-regional ASN transfers to RIRs 
with reciprocal policies. This change in language would allow for ASN 
transfers to and from the APNIC region.

Policy Statement:

Add "or ASNs to be transferred, as" to the first bullet point under 
Conditions on source of the transfer, so that it reads: "The source 
entity must be the current rights holder of the IPv4 address resources 
or ASNs to be transferred, as recognized by the RIR responsible for the 
resources, and not be involved in any dispute as to the status of those 
resources."

Change "IPv4 number resources" to "that same resource type (IPv4 number 
resources or ASNs)", so that the fourth bullet point reads: "Source 
entities within the ARIN region must not have received a transfer, 
allocation, or assignment of that same resource type (IPv4 number 
resources or ASNs) from ARIN for the 12 months prior to the approval of 
a transfer request. This restriction does not include M&A transfers."

Timetable for implementation: Immediate

##########

ARIN Staff and Legal Assessment

Proposal: ARIN-2014-15: Allow Inter-RIR ASN Transfers

Date of Assessment: 1 July 2014

1. Summary (Staff Understanding)

This proposal would:
•  allow inter-RIR transfer of AS numbers
•  enforce the 12 month waiting period only on resources of the same 
type exempt resources received via M&A transfer

2. Comments

A.    ARIN Staff Comments

The impact of inter-RIR transfers of ASNs on ARIN from both an 
operational and development perspective are nominal today, but pose an 
unknown (but at least moderate) impact over the medium-term due to 
potentially significant impacts for additional requirements and/or 
specifications necessary for RPKI support of inter-RIR ASN transfers.

B.    ARIN General Counsel - Legal Assessment

"The only material legal risk relates to the RPKI issue and policy 
consideration can take place as continued work by the management and 
staff of ARIN may be able to fully address this concern before the 
community considers the policy matter in Baltimore."

3. Resource Impact

This policy would have minimal to moderate resource impact from an 
implementation aspect.  It is estimated that implementation would occur 
within 3 - 9 months after ratification by the ARIN Board of Trustees. 
The following would be needed in order to implement:

Future impact from RPKI  implementation could involve either some kind 
of RIR<->IANA<->RIR coordination system or ERX for ASNs
Updated guidelines and internal procedures
Staff training

4. Proposal/Draft Policy Text Assessed

Draft Policy ARIN-2014-15 Allow Inter-RIR ASN Transfers
Revised: 19 June 2014

Problem Statement:
We already allow transfer of ASNs within the ARIN region. Recently APNIC 
implemented a policy allowing for Inter-regional ASN transfers to RIRs 
with reciprocal policies. This change in language would allow for ASN 
transfers to and from the APNIC region.

Policy Statement:
Add "or ASNs to be transferred, as" to the first bullet point under 
Conditions on source of the transfer, so that it reads: "The source 
entity must be the current rights holder of the IPv4 address resources 
or ASNs to be transferred, as recognized by the RIR responsible for the 
resources, and not be involved in any dispute as to the status of those 
resources." Change "IPv4 number resources" to "that same resource type 
(IPv4 number resources or ASNs)", so that the fourth bullet point reads: 
"Source entities within the ARIN region must not have received a 
transfer, allocation, or assignment of that same resource type (IPv4 
number resources or ASNs) from ARIN for the 12 months prior to the 
approval of a transfer request. This restriction does not include M&A 
transfers." Timetable for implementation: Immediate