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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