Draft Policies and Proposals
Formal introduction on PPML on 29 January 2014
Origin - ARIN-prop-194
Draft Policy - 29 January 2014
Revised - 12 March 2014
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Draft Policy ARIN-2014-2
Improving 8.4 Anti-Flip Language
Date: 12 March 2014
NEW PROPOSED POLICY LANGUAGE...the first sentence of the fourth bullet in quotes immediately below is the only change from current policy)
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 will not be eligible to receive any further IPv4 address allocations or assignments from ARIN for a period of 12 months after a transfer approval, or until the exhaustion of ARIN's IPv4 space, whichever occurs first.
- "Source entities within the ARIN region may not transfer a block or portion of a block received within the past 12 months." This restriction does not include M&A transfers.
- The minimum transfer size is a /24.
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 will be subject to current ARIN policies and sign an RSA for the resources being received.
- Recipients within the ARIN region must demonstrate the need for up to a 24-month supply of IPv4 address space.
- The minimum transfer size is a /24.
<<<<<<<<Original three alternatives were primarily discussed and I wish to elicit feedback from the community relative to each.>>>>>>>>
1. Use the existing last sentence as is and ask ARIN staff to be particularly watchful for seeming abuse and to bring such back to the community through regular Policy Experience Reports. There was discussion about this option suggesting that by the time abuse was recognized and reported, and given limited existing free pool stocks and the extended policy development cycle....this option may be moot.
2. Remove the clause 'and its subsidiaries' or modify it in such a way as to mitigate the risk of a laundering of addresses through fraudulent transfers, but this may still potentially limit the utility to organizations who may have complex organizational structures in use internationally.
3. Take an alternative tack and simply restrict transfers on a per-block rather than a per-organization basis. e.g. 'No block acquired within the past 24 months would be eligible for transfer.' (The time frame is of course an arbitrary number at this point.)
Date: 29 January 2014
8.4 anti-flipping language states:
"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."
This accidentally prevents anyone who receives BLOCK A in 2014 from transferring to another RIR a different block, BLOCK B, which was issued 5, 10, 15, 20 years ago. In my company, we needed to move a block being used in Asia over to APNIC. The block was legacy. But because we had gotten a new block in 2013, we were prevented from moving the old block to a different RIR.
With exhaustion imminent, I think we should remove this policy statement to:
1) Stop the unintentional road blocks of real network situations
2) Recognize that policy must adapt to post-exhaustion, so text like this will only cover very corner cases, and in those corner cases, may unintended bad consequences.
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. Restrictions related to recent receipt of blocks shall not apply to inter-RIR transfers within the same organization and its subsidiaries.
a.Timetable for implementation: Immediate