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Draft Policies and Proposals

Recommended Draft Policy ARIN-2015-7: Simplified requirements for demonstrated need for IPv4 transfers
Status:

Abandoned by the AC

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

Origin - ARIN-prop-221

Draft Policy - 23 June 2015

Revised - 16 June 2016

Recommended Draft Policy - 20 September 2016

Abandoned - 26 October 2016

Public Policy Mailing List
ARIN Public Policy Meeting:

ARIN 36
ARIN PPC at NANOG 66
ARIN 37

ARIN 38

ARIN Advisory Council:

AC Shepherds:
Robert Seastrom, Milton Mueller

ARIN Board of Trustees:
Revisions Implementation

Recommended Draft Policy ARIN-2015-7: Simplified requirements for demonstrated need for IPv4 transfers

Date: 20 September 2016

AC's assessment of conformance with the Principles of Internet Number Resource Policy:

2015-7 is one of a set of overlapping policies involving simplification of section 8 specified transfer policy. Each takes a somewhat different approach, and all have a degree of community support. Based on community feedback at the upcoming ARIN 38 meeting in Dallas, we hope to advance whichever of those proposals is best-supported by the community, or craft and advance a unified proposal that incorporates the best attributes of the proposals currently on the docket. Moving 2015-7 to Recommended Draft will facilitate moving the best policy forward in a timely manner.

Problem statement:

ARIN transfer policy currently inherits all its demonstrated need requirements for IPv4 transfers from NRPM sections 4. Because that section was written primarily to deal with free pool allocations, it is much more complicated than is really necessary for transfers. In practice, ARIN staff applies much more lenient needs assessment to section 8 IPv4 transfer requests than to free pool requests, as 24-month needs are much more difficult to assess to the same level of detail.

This proposal seeks to dramatically simplify the needs assessment process for 8.3 transfers, while still allowing organizations with corner-case requirements to apply under existing policy if necessary.

Policy statement:

Append the follwing bullet point to "Conditions on recipient of the transfer" section in NRPM 8.3 and 8.4
A recipient of IPv4 number resources may, at its option, demonstrate need by having an officer of the requesting organization attest that they will use at least 50% of their aggregate IPv4 addresses (including the requested resources) on an operational network within 24 months, rather than the criteria enumerated in Section 4 of the NRPM.

Comments:

a. Timetable for implementation: Immediate

b. Anything else

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Earlier Version

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Draft Policy ARIN-2015-7: Simplified requirements for demonstrated need for IPv4 transfers

Date: 16 June 2016

Problem statement:

ARIN transfer policy currently inherits all its demonstrated need requirements for IPv4 transfers from NRPM sections 4. Because that section was written primarily to deal with free pool allocations, it is much more complicated than is really necessary for transfers. In practice, ARIN staff applies much more lenient needs assessment to section 8 IPv4 transfer requests than to free pool requests, as 24-month needs are much more difficult to assess to the same level of detail.

This proposal seeks to dramatically simplify the needs assessment process for 8.3 transfers, while still allowing organizations with corner-case requirements to apply under existing policy if necessary.

Policy statement:

Append the follwing bullet point to "Conditions on recipient of the transfer" section in NRPM 8.3 and 8.4

A recipient of IPv4 number resources may, at its option, demonstrate need by having an officer of the requesting organization attest that they will use at least 50% of their aggregate IPv4 addresses (including the requested resources) on an operational network within 24 months, rather than the criteria enumerated in Section 4 of the NRPM.

Comments:

a. Timetable for implementation: Immediate

b. Anything else

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ARIN STAFF & LEGAL ASSESSMENT
Draft Policy ARIN-2015-7
SIMPLIFIED REQUIREMENTS FOR DEMONSTRATED NEED FOR IPv4 TRANSFERSS
https://www.arin.net/policy/proposals/2015_7.html

Date of Assessment: 28 June 2016

___
1. Summary (Staff Understanding)

Staff interpretation of this new policy language is that it gives the requesting organization the option of demonstrating need by having an officer of the requesting organization attest that they will use at least 50% of their aggregate IPv4 addresses (including the requested resources and all previously held resourcess) on an operational network within 24 months.

In the cases 8.3 and 8.4 recipient organizations choose this option, staff would no longer conduct a needs assessment for the requested IPv4 block size in accordance with criteria enumerated in Section 4 of the NRPM. Staff would fully stand down on conducting any needs assessment activity and will accept the attestation of an officer as full justification for the requested IPv4 block size.

___
2. Comments

A. ARIN Staff Comments

* Staff would apply this policy language to 24-month needs assessments for 8.3 transfers, 8.4 transfers, and transfer pre-approval requests.

* This policy could be implemented as written.

B. ARIN General Counsel – Legal Assessment

No material legal issue exists if the policy is adopted.

Counsel's Comment:
Permitting receipt of resources based solely on attestation by an officer permits some amount of fraud, as it enables those willing to make a fraudulent statement the ability to obtain resources. The present combination of officer attestation and staff verification provides stronger assurance of compliance with policy intent.

___
3. Resource Impact

This policy would have minimal resource impact from an implementation aspect. 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-2015-7
Simplified Requirements for Demonstrated Need for IPv4 Transfers

Date: 16 June 2016

Problem statement:

ARIN transfer policy currently inherits all its demonstrated need requirements for IPv4 transfers from NRPM sections 4. Because that section was written primarily to deal with free pool allocations, it is much more complicated than is really necessary for transfers. In practice, ARIN staff applies much more lenient needs assessment to section 8 IPv4 transfer requests than to free pool requests, as 24-month needs are much more difficult to assess to the same level of detail.

This proposal seeks to dramatically simplify the needs assessment process for 8.3 transfers, while still allowing organizations with corner-case requirements to apply under existing policy if necessary.

Policy statement:

Append the following bullet point to "Conditions on recipient of the transfer" section in NRPM 8.3 and 8.4.

A recipient of IPv4 number resources may, at its option, demonstrate need by having an officer of the requesting organization attest that they will use at least 50% of their aggregate IPv4 addresses (including the requested resources) on an operational network within 24 months, rather than the criteria enumerated in Section 4 of the NRPM.

Comments:

a. Timetable for implementation: Immediate

b. Anything else

##### END

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Earlier Version

###########################

Draft Policy ARIN-2015-7
Simplified requirements for demonstrated need for IPv4 transfers

Date: 23 June 2015

Problem statement:

ARIN transfer policy currently inherits all its demonstrated need requirements for IPv4 transfers from NRPM sections 4. Because that section was written primarily to deal with free pool allocations, it is much more complicated than is really necessary for transfers. In practice, ARIN staff applies much more lenient needs assessment to section 8 IPv4 transfer requests than to free pool requests, as 24-month needs are much more difficult to assess to the same level of detail.

This proposal seeks to dramatically simplify the needs assessment process for 8.3 transfers, while still allowing organizations with corner-case requirements to apply under existing policy if necessary.

Policy statement:

8.1.x Simplified requirements for demonstrated need for IPv4 transfers

IPv4 transfer recipients must demonstrate (and an officer of the requesting organization must attest) that they will use at least 50% of their aggregate IPv4 addresses (including the requested resources) on an operational network within 24 months.

Organizations that do not meet the simplified criteria above may instead demonstrate the need for number resources using the criteria in section 4 of the NRPM.

Comments:

a. Timetable for implementation: Immediate

b. Anything else

#####

ARIN STAFF & LEGAL ASSESSMENT
Draft Policy ARIN-2015-7
Simplified Requirements for Demonstrated Need for IPv4 Transfers

Date of Assessment: 10 September 2015

___
1. Summary (Staff Understanding)

This proposal aims to simplify the 24-month needs assessment and review process for 8.3 recipients and 8.4 recipients. Even though organizations will still have to demonstrate how they will utilize their newly acquired IPv4 address space going forward, this proposal provides an alternative to the current NRPM Section 4 requirements (80% of aggregate and 50% of each block). Instead, the organization must demonstrate how they will utilize 50% of their total holdings, which includes all previous allocations/assignments plus the newly requested resources, within 24 months, and provide officer attestation.

___
2. Comments

A. ARIN Staff Comments
Staff would apply this policy language to 24-month needs assessments for 8.3 transfers, 8.4 transfers, and pre-approval requests.
In order for staff to verify the demonstrated need of 50% of the total aggregate of IPv4 address space holdings by an organization, the policy criteria in NRPM Section 4 would continue to be utilized.
This policy would allow organizations to potentially qualify for a larger amount of IPv4 address space than they can under existing policy.
This policy could be implemented as written.
The proposal indicates placement as "8.1.x". Staff would add the proposed policy language as sub-bullets to recipient need sections of both NRPM 8.3 and NRPM 8.3, specifically 8.3 bullet 5 and 8.4 bullet 8 as follows:
IPv4 transfer recipients must demonstrate (and an officer of the requesting organization must attest) that they will use at least 50% of their aggregate IPv4 addresses (including the requested resources) on an operational network within 24 months.

Organizations that do not meet the simplified criteria above may instead demonstrate the need for number resources using the criteria in section 4 of the NRPM.

B. ARIN General Counsel – Legal Assessment

No material legal issue exists if the policy is adopted.

Counsel's Comment and Question: This policy if adopted would significantly lower the degree of utilization required and permit significantly larger transfers of resources than existing policy. This is in effect a bridge between maintaining a 'lighter' needs based structure, that permits substantially greater transfers. An issue that does not have to be resolved before the policy is voted upon, but may be of importance to address is ARIN making clear whether an acquiring party taking appropriate advantage of such a policy change ought to have a corollary duty to fully disclose to ARIN whether they have use of any other number resources (by agreement) that effectively reduce their overall number resource needs.

___
3. Resource Impact

This policy would have minimal resource impact from an implementation aspect. 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-2015-7

Simplified requirements for demonstrated need for IPv4 transfers

Date: 23 June 2015

Problem statement:

ARIN transfer policy currently inherits all its demonstrated need requirements for IPv4 transfers from NRPM sections 4. Because that section was written primarily to deal with free pool allocations, it is much more complicated than is really necessary for transfers. In practice, ARIN staff applies much more lenient needs assessment to section 8 IPv4 transfer requests than to free pool requests, as 24-month needs are much more difficult to assess to the same level of detail.

This proposal seeks to dramatically simplify the needs assessment process for 8.3 transfers, while still allowing organizations with corner-case requirements to apply under existing policy if necessary.

Policy statement:

8.1.x Simplified requirements for demonstrated need for IPv4 transfers

IPv4 transfer recipients must demonstrate (and an officer of the requesting organization must attest) that they will use at least 50% of their aggregate IPv4 addresses (including the requested resources) on an operational network within 24 months.

Organizations that do not meet the simplified criteria above may instead demonstrate the need for number resources using the criteria in section 4 of the NRPM.

Comments:
a. Timetable for implementation: Immediate
b. Anything else

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