Draft Policy ARIN-2020-6

Allowance for IPv4 Allocation “Swap” Transactions via 8.3 Specified Transfers and 8.4 Inter-RIR Transfers

Status: Under Discussion
Shepherds: Amy Potter, Owen DeLong

Current Text (23 June 2020)

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.

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.

Timetable for Implementation: Immediate

Summary (Staff Understanding)

ARIN-2020-6 would allow organizations, by request, to receive a smaller IPv4 block to renumber into prior to conducting a specified transfer under NRPM 8.3. or 8.4. Further, it seeks to prevent organizations from creating new Org IDs just to receive a smaller block so that the larger block may be transferred.

Comments

ARIN Staff Comments

ARIN-2020-6 would effectively codify the practice of obtaining and renumbering into a smaller block prior to conducting a transfer as a source, preventing the need for workarounds.

Staff suggests considering three points as a community:

  • Upper limits for these smaller allocations
  • Acceptable timeframe within which the organization must transfer the larger block
  • Restricting waitlist space from use in these scenarios

ARIN General Counsel – Legal Assessment

No material legal issue.

Resource Impact

Implementation of this policy would have minimal resource impact. It is estimated that implementation would occur within three months after ratification by the ARIN Board of Trustees. The following would be needed in order to implement:

  • Staff training
  • Updated guidelines and internal procedures
  • Standard documentation updates

Proposal/Draft Policy Text Assessed: 23 June 2020 Version

History and Earlier Versions

History
Action Date
Proposal 31 May 2020
Draft Policy 23 June 2020

Advisory Council

Board of Trustees

ARIN Public Policy Meetings