ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks [Archived]

ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

Proposal Originator: Dani Roisman

Date: 1 September 2015

Problem Statement:

The current policies in NRPM sections 8.2, 8.3, and 8.4 regarding transfer of IPv4 netblocks from one organization to another are currently a hindrance in ensuring database accuracy. In practice, ARIN staff are utilizing those polices to refuse to complete database updates which would reflect an accurate transfer of control / utilization of netblocks in cases where ARIN doesn’t agree that the recipient organization has need, or more often where the recipient organization bypasses the ARIN registry entirely in order to secure the needed IPv4 netblocks in a more timely fashion directly from the current holder. The result is that the data visible in ARIN registry continues to become more inaccurate over time.

Policy statement:

This proposal is for the following language changes in the respective NRPM sections in order to eliminate all needs-based evaluation for the respective transfer type, and allow transfers to be reflected in the database as they occur following an agreement of transfer from the resource provider to the recipient.

Section 8.1 Principles:

• Strike the 3rd paragraph which begins with “Number resources are issued, based on justified need, to organizations. . .” since it mostly reiterates other sections of ARIN policy. All transfers are subjected to those policies, as called out in 8.2, 8.3, 8.4. Additionally, removing this paragraph removes the perceived “threat” of reclaim which serves as a hindrance to long-term resource holders approaching ARIN with database updates, since in practice ARIN has not been forcibly reclaiming IP resources assigned to “failed businesses.”

Section 8.2 Mergers and Acquisitions:

• Change the 4th bullet from:

“The resources to be transferred will be subject to ARIN policies.”
to:
“The resources to be transferred will be subject to ARIN policies, excluding any policies related to needs-based justification or inspection of current or future utilization rate.”

• Remove entirely the last paragraph which begins “In the event that number resources . . .”

Section 8.3 Transfers between Specified Recipients within the ARIN Region:

• Remove entirely the first bullet under “Conditions on recipient of the transfer” which begins “The recipient must demonstrate the need . . .”

• Change the 2nd bullet under “Conditions on recipient of the transfer” from:
  “The resources to be transferred will be subject to ARIN policies.”
  to:
  “The resources to be transferred will be subject to ARIN policies, excluding any policies related to needs-based justification or inspection of current or future utilization rate.”

Section 8.4 Inter-RIR Transfers to Specified Recipients:

• Change the introductory language from:

“Inter-regional transfers may take place only via RIRs who agree to the transfer and share reciprocal, compatible, needs-based policies”
to:
“Inter-regional transfers may take place only via RIRs who agree to the transfer and share reciprocal, compatible, policies”

• Remove entirely the 3rd bullet under “Conditions on recipient of the transfer” which begins “Recipients within the ARIN region must demonstrate the need . . .”

Comments:

a. Timetable for implementation: Immediate

b. Anything else
As the “free pool” for 4 of the 5 world’s RIRs (APNIC, RIPE, LACNIC, and ARIN) has now been exhausted, networks in need of additional IPv4 addresses have shifted away from the practice of receiving them from the RIR’s resource pool. Instead, networks in need are seeking out current holders of IPv4 resources who are willing to transfer them in order to fulfil that need. Accordingly, the RIR’s primary responsibility vis-à-vis IPv4 netblock governance has shifted from “allocation” to “documentation.” In other words, the focus must move away from practicing conservation and fair distribution (e.g. following guidelines set forth in RFC2050) to ensuring an accurate registry database of which organization is utilizing a given netblock.

The RIPE registry can be used as a reference of one which has evolved over the past couple years to shift their focus away from conservation/allocation and towards database accuracy. IPv4 netblock transfers within that RIR consist merely of validating authenticity of the parties requesting a transfer. Provided the organizations meet the basic requirement of RIR membership, and that the transferring organization has the valid authority to request the transfer, the transaction completes without any “needs-based” review.