LAST CALL for Recommended Draft Policy ARIN-2016-5: Post-IPv4-Free-Pool-Depletion Transfer Policy

[ARIN]

The ARIN Advisory Council (AC) met on 21 October 2016 and decided to 
send Recommended Draft Policy ARIN-2016-5: Post-IPv4-Free-Pool-Depletion 
Transfer Policy to Last Call:

The AC provided the following statement to the community:

This proposal is technically sound, fair, and impartial in that it 
establishes a new set of qualifying criteria for 8.3 and 8.4 transfers 
applicable to all requests. It is strongly supported by the community.

Feedback is encouraged during the Last Call period. All comments should 
be provided to the Public Policy Mailing List. This Last Call will 
expire on 9 November 2016. After Last Call, the AC will conduct their 
Last Call review.

The full text is below and available at:
https://www.arin.net/policy/proposals/

The ARIN Policy Development Process is available at:
https://www.arin.net/policy/pdp.html

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)



Recommended Draft Policy ARIN-2016-5: Post-IPv4-Free-Pool-Depletion 
Transfer Policy

AC's assessment of conformance with the Principles of Internet Number 
Resource Policy:

2016-5 is one of a set of overlapping policies involving simplification 
of section 8 specified transfer policy. Each takes a somewhat different 
approach, and all have a degree of community support. Based on community 
feedback at the upcoming ARIN 38 meeting in Dallas, we hope to advance 
whichever of those proposals is best-supported by the community, or 
craft and advance a unified proposal that incorporates the best 
attributes of the proposals currently on the docket. Moving 2016-5 to 
Recommended Draft will facilitate moving the best policy forward in a 
timely manner.

Problem Statement:

Section 4 of the Number Policy Resource Manual was developed over the 
past 15+ years primarily to conservatively manage the IPv4 number free 
pool. Since the IPv4 free pool was depleted in 2015, the policies which 
developed since ARIN’s inception may now not be as relevant now that the 
primary function of the registry, with regard to IPv4 numbers, is to 
record transfers.

Since section 4 of the NRPM now contains many use cases that are not as 
relevant, it makes sense to streamline the transfer process and to 
specifically outline the criteria that should be used to process transfers.

Therefore, we propose the following rewrite of the transfer policy, 
section 8 of the NRPM.

The goals of this rewrite are as follows:

- Separate the criteria that is found in section 4 of the NRPM from the 
transfer process.
- Provide a clear set of criteria that should be applied across all IPv4 
transfers.
- Lower the thresholds on utilization and future allocation size to 
negate the necessity of the corner cases which are currently enumerated 
in section 4 of the NRPM.
- Reduce the complexity that is currently required for transfers, by 
applying simpler utilization criteria for current usage, and future 
allocation sizing.

Policy statement:

Add new section 8.5; update sections 8.2-8.4 as follows to reference 8.5.

8.2. Mergers, Acquisitions, and Reorganizations

ARIN will consider requests for the transfer of number resources in the 
case of mergers, acquisitions, and reorganizations under the following 
conditions:

- The current registrant must not be involved in any dispute as to the 
status of the resources to be transferred.
- The new entity must sign an RSA covering all resources to be transferred.
- The resources to be transferred will be subject to ARIN policies.
- The minimum transfer size is the smaller of the original allocation 
size or the applicable minimum allocation size in current policy.
- For mergers and acquisition transfers, the recipient entity must 
provide evidence that they have acquired assets that use the resources 
to be transferred from the current registrant. ARIN will maintain an 
up-to-date list of acceptable types of documentation.
ARIN will proceed with processing transfer requests even if the number 
resources of the combined organizations exceed what can be justified 
under current ARIN transfer policy as defined in section 8.5. In that 
event, ARIN will work with the resource holder(s) to transfer the extra 
number resources to other organization(s) or accept a voluntary return 
of the extra number resources to ARIN.

8.3. Transfers between Specified Recipients within the ARIN Region

In addition to transfers under section 8.2, IPv4 numbers resources and 
ASNs 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 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 
M&A transfers.
Conditions on recipient of the transfer:

- The recipients must meet the transfer requirements as defined in 
section 8.5.
- The resources transferred will be subject to current ARIN policies.
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. This 
restriction does not include M&A transfers.

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.
8.5. Specified Transfer Recipient Requirements

8.5.1. Registration Services Agreement

The receiving entity must sign an RSA covering all resources to be 
transferred unless that entity has a current (within the last two 
versions) RSA on file.

8.5.2. Operational Use

ARIN allocates or assigns number resources to organizations via transfer 
solely for the purpose of use on an operational network.

8.5.3. Minimum transfer size

ARIN’s minimum IPv4 transfer size is a /24.

8.5.4. Initial block

Organizations without direct assignments or allocations from ARIN 
qualify for transfer of an initial IPv4 block of ARIN’s minimum transfer 
size.

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.

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.

Comments:

Timetable for implementation: immediately

Anything else: A redline has been provided to help the community 
understand the changes that have been made to the NRPM.