I still have concerns in spite of said rejoinder. The rejoinder doesn't address the ability to use this as a way to flip less expensive addresses into higher profits by transferring out of region. All it does is protect a free pool which likely won't exist by the time this becomes policy anyway.
Owen On Mar 5, 2014, at 07:00 , Bill Darte <[email protected]> wrote: > On Feb. 21 I sent the message (far below) to PPML asking the community to > support one of 3 alternatives or propose new language which makes one or the > other better, or a completely new wording which they believe accomplishes the > goal of producing policy language that is needed, technically sound and > improves existing policy in the 8.4 Inter-RIR transfer realm. > > Summary of feedback so far: > 2 persons supporting #2 with the removal of "and its subsidiaries". There > was some support for the extended language of "and its subsidiaries having > been operational for a minimum of xx months" in order to mitigate the > rinse-repeat abuse that might accrue through new shell subsidiaries. > > There was some support for the alternative language expressed in #3 at the > PPC in Atlanta and at the ARIN AC meeting on Feb 20. This language simply > restricts the transfer of the block having been received...which would allow > other existing blocks or components to be transferred. One view against #3 > was expressed as "An org that currently has a /8 can obtain the resources it > needs and sell off the /8 out of region a few chunks at a time by backfilling > with new space from the ARIN region.". A rejoinder to this was expressed > pointing out that other existing language in 8.4 states...."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." > <<< end summary >>>> > > > It is important that I receive a significant measure of support FOR or > AGAINST continuing to work on this Draft and before the ARIN AC meeting on > Mar 20, I would like to have better language to propose if we are to make > this Draft a Recommended Draft prior to the April PPM in Chicago. > > I would be grateful for your feedback as early as possible. > > bd > > <<<<<<<<< earlier email sent to PPML on Feb 21 >>>>>>>>>>>>>>> > At the Advisory Council's meeting of Feb 20, discussion about Draft Policy > 2014-2 concluded that there is a real issue with transfer restrictions of > address blocks between RIR jurisdictions for organizations having received a > different block of addresses from ARIN within the last 12 months (per > existing policy). > > The current Draft Policy language is as follows with only the last sentence > being added from what is current ARIN policy: > "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." > > The last sentence of this language was added to mitigate the problems related > by the author in the problem statement and from experience. The author > supported this change, however, some concern has been expressed on the PPML > and within the AC about the possibility of 'rinse and repeat' abuse > associated with the ease of establishing new subsidiaries and using those > transfers to get around the restrictions of the existing transfer policy. > > 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.) > > If you believe this Draft Policy is improved most significantly by one of the > above alternatives, or through another alternative you can pose....I, and the > community would benefit from your input. Thanks, > > Bill Darte > Policy Shepherd for 2014-2 and > Advisory Council member
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