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: Rob Seastrom, Amy Potter
Current Text (26 August 2021)
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.
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:
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.
220.127.116.11- 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 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.
18.104.22.168.1 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. 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.
22.214.171.124 Transfer for the Purpose of Renumbering
Organizations receiving transfer of a smaller block under section 126.96.36.199 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.
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.
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 188.8.131.52.
Timetable for Implementation: Immediate
Staff and Legal Review (22 July 2020)
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.
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.
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