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Draft Policies and Proposals

Policy Proposal 2008-2: IPv4 Transfer Policy Proposal
Policy Proposal Evaluation Status: Author
Abandoned ARIN Advisory Council
Discussion Tracking
Mailing List:
Formal introduction on PPML on 26 February 2008

Revised - 7 March 2008
Staff Assessment - 21 March 2008
To be revised - 14 April 2008
Discussed at ARIN Caribbean Sector Meeting - 2 June 2008

Transfer Policy Survey Results
Discussed at ARIN Bahamas Caribbean Sector Meeting - 17 September 2008
Revised - 18 September 2008
Staff Assessment - 8 October 2008
Abandoned - 22 October 2008

Public Policy Mailing List
ARIN Public Policy Meeting:

ARIN XXI

Kingston, Jamaica

Nassau, Bahamas
ARIN XXII

ARIN Advisory Council:

AC Shepherds:
Scott Leibrand and Stacy Taylor

21 February 2008
20 March 2008
9 April 2008
15 May 2008

19 June 2008
17 July 2008
21 August 2008
18 September 2008
17 October 2008

ARIN Board of Trustees:
Revisions Implementation
Previous version(s)

Proposal

Policy Proposal 2008-2
IPv4 Transfer Policy Proposal

Author: ARIN Advisory Council

Proposal Version: 1.4

Date: 18 September 2008

Proposal type: modify

Policy term: permanent

Policy statement:

Modify the current NRPM section 8 as follows --

8.      Transfers

[8.1.   Transfers – retain as is]

[8.2 – remove the word “only”, and retitle to “Transfers as an Artifact of
Change in Resource Holder Ownership”]

[Renumber existing 8.3 to 8.2.1 and retitle to “Documentation Requirements
for Transfers as an Artifact of Change in Resource Holder Ownership”]

[Add the following new section:]
8.3.    Simple Transfer of IPv4 Addresses

In light of the pending exhaustion of the IANA IPv4 free pool, ARIN will
also process IPv4 address transfer requests subject to the following
conditions.  These conditions apply only to Simple IPv4 transfers, not to
transfers performed according to section 8.2.

8.3.1   Conditions on the transferor (the organization providing addresses
for transfer):
•       The transferor has no outstanding balances with ARIN.
•       The transferor has not received any IPv4 allocations or assignments from
ARIN (through ordinary allocations or assignments, or through this Simple
Transfer policy) within the preceding 12 months.
•       If the transferor elects to retain a portion of a block pursuant to
8.3.6, rather than transferring an entire block, the transferor must sign
(or have previously signed) a RSA or LRSA covering the retained portion.

8.3.2   Conditions on the transferee (the organization receiving the
transferred addresses):
•       The transferee intends to use the transferred IPv4 addresses within the
ARIN service area.
•       The transferee has no outstanding balances with ARIN.
•       The transferee’s need is confirmed by ARIN, according to current ARIN
policies.
•       The transferee signs (or has previously signed) an RSA covering the IPv4
addresses transferred.
•       The transferee may request and receive a contiguous CIDR block large
enough to provide a 12 month supply of IPv4 addresses.
•       The transferee may only receive one IPv4 address transfer through this
Simple Transfer process every 6 months.

8.3.3   Conditions on the IPv4 address block to be transferred:
•       The IPv4 block must comply with applicable ARIN allocation requirements,
including minimum allocation size.  However, an IPv4 allocation or
assignment of /24 or larger, but smaller than the current minimum
allocation size, may be transferred as a whole resource (but may not be
subdivided).
•       The IPv4 block must currently be registered for use within the ARIN
service area.
•       There must be no dispute as to the status of the IPv4 block or regarding
the allocation or assignment of such block to the transferor.

8.3.4   [Section omitted]

8.3.5   Pre-qualification

•       An interested transferee must seek pre-qualification from ARIN to
confirm its eligibility to receive a transfer (including satisfaction of
need according to current ARIN policies) before making any solicitation
for transfer.  Upon pre-qualification, ARIN will provide the transferee
with documentation of the pre-qualification, including the size (CIDR
prefix length) of the largest IPv4 address block the transferee is
eligible to receive, and the expiration date of the pre-qualification.
•       An interested transferor may seek pre-qualification from ARIN to confirm
its eligibility to offer a transfer before offering IPv4 address resources
for transfer.  Upon pre-qualification, ARIN will provide the transferor
with documentation of the pre-qualification, including the network block
and the expiration date of the pre-qualification.

8.3.6   Deaggregation when Permitted by ARIN

ARIN may allow transferors to subdivide network blocks.  ARIN will attempt
to ensure an adequate supply of small blocks while minimizing deaggregation.

8.3.7.  Safe Harbor

The fact that an IPv4 address holder is making IPv4 addresses available
for transfer, pursuant to this policy, does not, in and of itself,
indicate that the address holder lacks the need required for an allocation
under ARIN policy.

8.3.8.  Organizations under Common Ownership or Control

If an IPv4 transferor or transferee is under common ownership or control
with any other organization that holds one or more IPv4 blocks, the IPv4
transfer request must report all such organizations under common ownership
or control. When evaluating compliance with IPv4 Simple Transfer
conditions, ARIN may consider a transfer request in light of requests from
other organizations under common ownership or control.

8.3.9.  Record-keeping and Publication

ARIN will develop and operate a listing service to assist interested
transferors and transferees by providing them a centralized location to
post information about IPv4 blocks available from pre-qualified
transferors and IPv4 blocks needed by pre-qualified transferees.
Participation in the listing service is voluntary.

After completion of a transfer, ARIN will update the registration and
WHOIS records pertaining to the IPv4 block.  ARIN will also publish a log
of all transfers, including block, transferor, transferee, and date.

Rationale:
The ARIN Board of Trustees asked the Advisory Council to consider a set of
questions around the depletion of the free pool of IPv4 addresses, the
transition to IPv6 for Internet address needs in the future, and ARIN's
possible role in easing the transition.
Over the course of the year, the Advisory Council has worked to solicit
input from all parts of the policy-making community, through the ARIN XXI
public policy meeting, the Public Policy Mailing List (PPML), sector
meetings, and a poll of PPML subscribers.  As a result of the input
received, this policy has been simplified considerably, removing or
modifying text and restrictions deemed unnecessary, while preserving those
aspects that seem to be supported by consensus.
This policy proposal would create a transfer mechanism for IPv4 number
resources between those who have excess resources and those who have a
need, thereby allowing ARIN to continue to serve its mission after IANA
free pool exhaustion. This proposal would also set conditions on such
transfers intended to preserve as much as possible the existing policy
related to efficient, needs-based resource issuance, and would leverage
ARIN's control systems, audit trails, and recognized position as a trusted
agent to avoid speculation and hoarding and diminish the likelihood and
extent of an uncontrolled 'black market' where the risk and potential for
fraud is immeasurably higher.
Many of the transfer conditions are self-explanatory, but some worth
highlighting are that:
• To discourage speculation, a waiting period (proposed at 12 months) is
required before a recipient of space can transfer it to another organization.
• Transferees must qualify for IPv4 space (just as they do today when
getting it from ARIN) before they can receive address space by transfer,
or solicit space on a listing service.
• To discourage unnecessarily rapid growth of routing tables, an
allocation or assignment may not be arbitrarily deaggregated.  To ensure
an adequate supply of small blocks while minimizing deaggregation, ARIN
may allow transferors to subdivide network blocks.  A suggested starting
point is to allow transferors to subdivide an IPv4 block into up to four
smaller blocks on CIDR bit-boundaries, provided each resulting block
satisfies the minimum allocation size.
• A transferee may receive one transfer every 6 months, and may receive at
least 12 months worth of space, so they’ll be incented to transfer a block
appropriately sized for their needs, which will further discourage
deaggregation and keep smaller blocks available for smaller organizations.
The proposal would also have ARIN develop and operate a listing service to
facilitate transfers and provide an authoritative central source of
information on space available and requested for transfer. It would not
prohibit private party transactions, but would encourage potential
transferors and transferees be pre-qualified first, so that neither party
will encounter any surprises when they ask ARIN to process the transfer.

Timetable for implementation: immediately upon ratification by the
Board of Trustees

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