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Draft Policies and Proposals

Draft Policy ARIN-2015-6: Transfers and Multi-national Networks
Status:

Abandoned by the AC

 
Discussion Tracking
Mailing List:
Formal introduction on PPML on 23 June 2015

Origin - ARIN-prop-220

Draft Policy - 23 June 2015

Revised - 1 September 2015

Revised assessment - 23 September 2015

Abandoned by the AC - 22 March 2016

 

Public Policy Mailing List
ARIN Public Policy Meeting:

ARIN 36

ARIN Advisory Council:

AC Shepherds:
Kevin Blumberg, John Springer

ARIN Board of Trustees:
Revisions Implementation

Draft Policy ARIN-2015-6
Transfers and Multi-national Networks

Date: 25 August 2015

Problem statement:

Some organizations within the ARIN region are currently unable to receive IPv4 space via transfer based on current ARIN policy, which prohibits address space used outside of the ARIN region from being considered efficiently utilized. This proposal would allow organizations with a strong and long-standing presence in the ARIN region to be able to receive number resources via transfer for their global operations.

Policy statement:

When evaluating transfer requests, ARIN will not consider the geographic location where an organization is utilizing, or will utilize, its ARIN-registered addresses if that organization, its parent, or a subsidiary:

1. has been an ARIN customer for at least 36 months; AND

2. is currently in good standing with ARIN; AND

3. is currently using IPv4 or IPv6 addresses in the ARIN region; AND

4. can demonstrate it has a meaningful business that operates in the ARIN region.

Comments:

Timetable for implementation: Immediate

#####

ARIN STAFF & LEGAL ASSESSMENT
Draft Policy ARIN-2015-6
TRANSFERS AND MULTI-NATIONAL NETWORKS

Date of Assessment: 15 September 2015

___
1. Summary (Staff Understanding)

This proposal states that when evaluating transfer requests, ARIN will not consider the geographic location where an organization is utilizing, or will utilize, its ARIN-registered addresses if that organization, its parent, or a subsidiary are able to satisfy each of the four stated criteria.

___
2. Comments

A. ARIN Staff Comments

• During the course of a transfer request, staff will consider and review the utilization of any block issued by ARIN to that organization, regardless of whether that address space is being used outside of the ARIN region.
• This policy enables organizations to qualify as a recipient for 8.3 or 8.4 transfers in the ARIN region when they might not have otherwise been able to do so. ARIN staff would now be able to consider their global utilization, instead of only their in-ARIN region use.
• One of the elements ARIN staff uses to determine 24-month need for an organization is their historical utilization rate. This proposal allows organizations to justify a larger 24-month needs based qualification, because staff will consider their utilization globally instead of just what was used inside the ARIN region.
• This would be placed in a new section of the NRPM called "8.5 Additional Transfer Policies".
• This policy could be implemented as written.

B. ARIN General Counsel – Legal Assessment

No material legal issues. If the policy is enacted it will require ARIN staff to work with counsel with some attendant increase in costs in the first year to manage implementation.

___
3. Resource Impact

>From a request review standpoint, implementation of this policy would have minimal resource impact. However, it could have future staffing implications based on the amount of additional work the policy could present. It is estimated that implementation could occur within 3 months after ratification by the ARIN Board of Trustees. The following would be needed in order to implement:

* Updated guidelines and internal procedures
* Staff training

Implementation of this policy may allow for registrations in the ARIN database that require unicode character sets. From an engineering standpoint, implementation of this policy could have a major resource impact. It is estimated that implementation would occur within 12 months, instead of the 3 months cited above, after ratification by the ARIN Board of Trustees if ARIN is required to support unicode character sets. The following would be needed in order to implement:

* Engineering: Engineering efforts to handle out of region business rules may be substantial as our system only supports ascii now. If there is a need for unicode character sets, then there is a substantial amount of work required to upgrade the DB and applications to support unicode. Additionally, we would need to discuss how to display unicode characters in port 43 whois.

___
4. Proposal / Draft Policy Text Assessed

Draft Policy ARIN-2015-6

Problem statement:

Some organizations within the ARIN region are currently unable to receive IPv4 space via transfer based on current ARIN policy, which prohibits address space used outside of the ARIN region from being considered efficiently utilized. This proposal would allow organizations with a strong and long-standing presence in the ARIN region to be able to receive number resources via transfer for their global operations.

Policy statement:

When evaluating transfer requests, ARIN will not consider the geographic location where an organization is utilizing, or will utilize, its ARIN-registered addresses if that organization, its parent, or a subsidiary:

1. has been an ARIN customer for at least 36 months; AND
2. is currently in good standing with ARIN; AND
3. is currently using IPv4 or IPv6 addresses in the ARIN region; AND
4. can demonstrate it has a meaningful business that operates in the ARIN region.

 

Earlier staff and legal assessment

#####

ARIN STAFF & LEGAL ASSESSMENT

Draft Policy ARIN-2015-6
TRANSFERS AND MULTI-NATIONAL NETWORKS
https://www.arin.net/policy/proposals/2015_6.html

Date of Assessment: 18 August 2015

___
1. Summary (Staff Understanding)

This proposal states that when evaluating transfer requests, ARIN will not consider the geographic location where an organization is utilizing its ARIN-registered addresses if that organization, its parent, or a subsidiary are able to satisfy each of the four stated criteria.

___
2. Comments

A. ARIN Staff Comments

•During the course of a transfer request, staff will consider and review the utilization of any block issued by ARIN to that organization, regardless of whether that address space is being used outside of the ARIN region.
•This policy enables organizations to qualify as a recipient for 8.3 or 8.4 transfers in the ARIN region when they might not have otherwise been able to do so. ARIN staff would now be able to consider their global utilization, instead of only their in-ARIN region use.
•One of the elements ARIN staff uses to determine 24-month need for an organization is their historical utilization rate. This proposal allows organizations to justify a larger 24-month needs based qualification, because staff will consider their utilization globally instead of just what was used inside the ARIN region.
•The policy proposal text appears to not align with the intent of the policy as described in the problem statement. This proposal changes how ARIN considers prior utilization of IPv4 address space, but does not specify that newly received resources can be used outside of the region. Existing policy and practice would dictate ARIN continues to issue space for use in the ARIN region. We note that 2015-5, if adopted, could change this.
•This would be placed in a new section of the NRPM called "8.5 Additional Transfer Policies".
•This policy could be implemented as written.

B. ARIN General Counsel – Legal Assessment

No material legal issues. If the policy is enacted it will require ARIN staff to work with counsel with some attendant increase in costs in the first year to manage implementation.

___
3. Resource Impact
This policy would have minimal resource impact from an implementation aspect. However, it could have future staffing implications based on the amount of additional work the policy could present. It is estimated that implementation would occur within 3 months after ratification by the ARIN Board of Trustees. The following would be needed in order to implement:

* Updated guidelines and internal procedures
* Staff training

___
4. Proposal / Draft Policy Text Assessed

Draft Policy ARIN-2015-6

Date: 23 June 2015

Problem statement:
Some organizations within the ARIN region are currently unable to receive IPv4 space via transfer based on current ARIN policy, which prohibits address space used outside of the ARIN region from being considered efficiently utilized. This proposal would allow organizations with a strong and long-standing presence in the ARIN region to be able to receive number resources via transfer for their global operations.
Policy statement:
When evaluating transfer requests, ARIN will not consider the geographic location where an organization is utilizing its ARIN-registered addresses if that organization, its parent, or a subsidiary:
1. has been an ARIN customer for at least 36 months; AND
2. is currently in good standing with ARIN; AND
3. is currently using IPv4 or IPv6 addresses in the ARIN region; AND
4. can demonstrate it has a meaningful business that operates in the ARIN region.

 

#####

Earlier version

Draft Policy ARIN-2015-6
Transfers and Multi-national Networks

Date: 23 June 2015

Problem statement:

Some organizations within the ARIN region are currently unable to receive IPv4 space via transfer based on current ARIN policy, which prohibits address space used outside of the ARIN region from being considered efficiently utilized. This proposal would allow organizations with a strong and long-standing presence in the ARIN region to be able to receive number resources via transfer for their global operations.

Policy statement:

When evaluating transfer requests, ARIN will not consider the geographic location where an organization is utilizing its ARIN-registered addresses if that organization, its parent, or a subsidiary:

1. has been an ARIN customer for at least 36 months; AND

2. is currently in good standing with ARIN; AND

3. is currently using IPv4 or IPv6 addresses in the ARIN region; AND

4. can demonstrate it has a meaningful business that operates in the ARIN region.

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