Speaking strictly for myself and not in my role as a member of the AC.. I remain strongly opposed to this proposal. While it is further along in the process, I believe that 2016-3 represents a vastly superior alternative with a higher level of community support.
Speaking as a member of the AC, but not for the AC, I believe it would be valuable to the AC to get significant community feedback as to any preference between the two proposals. Owen > On Oct 26, 2016, at 14:16 , ARIN <[email protected]> wrote: > > The ARIN Advisory Council (AC) met on 21 October 2016 and decided to send > Recommended Draft Policy ARIN-2016-5: Post-IPv4-Free-Pool-Depletion Transfer > Policy to Last Call: > > The AC provided the following statement to the community: > > This proposal is technically sound, fair, and impartial in that it > establishes a new set of qualifying criteria for 8.3 and 8.4 transfers > applicable to all requests. It is strongly supported by the community. > > Feedback is encouraged during the Last Call period. All comments should be > provided to the Public Policy Mailing List. This Last Call will expire on 9 > November 2016. After Last Call, the AC will conduct their Last Call review. > > The full text is below and available at: > https://www.arin.net/policy/proposals/ > > The ARIN Policy Development Process is available at: > https://www.arin.net/policy/pdp.html > > Regards, > > Communications and Member Services > American Registry for Internet Numbers (ARIN) > > > > Recommended Draft Policy ARIN-2016-5: Post-IPv4-Free-Pool-Depletion Transfer > Policy > > AC's assessment of conformance with the Principles of Internet Number > Resource Policy: > > 2016-5 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 2016-5 to Recommended Draft will > facilitate moving the best policy forward in a timely manner. > > Problem Statement: > > Section 4 of the Number Policy Resource Manual was developed over the past > 15+ years primarily to conservatively manage the IPv4 number free pool. Since > the IPv4 free pool was depleted in 2015, the policies which developed since > ARIN’s inception may now not be as relevant now that the primary function of > the registry, with regard to IPv4 numbers, is to record transfers. > > Since section 4 of the NRPM now contains many use cases that are not as > relevant, it makes sense to streamline the transfer process and to > specifically outline the criteria that should be used to process transfers. > > Therefore, we propose the following rewrite of the transfer policy, section 8 > of the NRPM. > > The goals of this rewrite are as follows: > > - Separate the criteria that is found in section 4 of the NRPM from the > transfer process. > - Provide a clear set of criteria that should be applied across all IPv4 > transfers. > - Lower the thresholds on utilization and future allocation size to negate > the necessity of the corner cases which are currently enumerated in section 4 > of the NRPM. > - Reduce the complexity that is currently required for transfers, by applying > simpler utilization criteria for current usage, and future allocation sizing. > > Policy statement: > > Add new section 8.5; update sections 8.2-8.4 as follows to reference 8.5. > > 8.2. Mergers, Acquisitions, and Reorganizations > > ARIN will consider requests for the transfer of number resources in the case > of mergers, acquisitions, and reorganizations under the following conditions: > > - The current registrant must not be involved in any dispute as to the status > of the resources to be transferred. > - The new entity must sign an RSA covering all resources to be transferred. > - The resources to be transferred will be subject to ARIN policies. > - The minimum transfer size is the smaller of the original allocation size or > the applicable minimum allocation size in current policy. > - For mergers and acquisition transfers, the recipient entity must provide > evidence that they have acquired assets that use the resources to be > transferred from the current registrant. ARIN will maintain an up-to-date > list of acceptable types of documentation. > ARIN will proceed with processing transfer requests even if the number > resources of the combined organizations exceed what can be justified under > current ARIN transfer policy as defined in section 8.5. In that event, ARIN > will work with the resource holder(s) to transfer the extra number resources > to other organization(s) or accept a voluntary return of the extra number > resources to ARIN. > > 8.3. Transfers between Specified Recipients within the ARIN Region > > In addition to transfers under section 8.2, IPv4 numbers resources and ASNs > may be transferred according to the following conditions. > > Conditions on source of the transfer: > > - The source entity must be the current registered holder of the IPv4 address > resources, and not be involved in any dispute as to the status of those > resources. > - The source entity 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. > Conditions on recipient of the transfer: > > - The recipients must meet the transfer requirements as defined in section > 8.5. > - The resources transferred will be subject to current ARIN policies. > 8.4. Inter-RIR Transfers to Specified Recipients > > Inter-regional transfers may take place only via RIRs who agree to the > transfer and share reciprocal, compatible, needs-based policies. > > Conditions on source of the transfer: > > - The source entity must be the current rights holder of the IPv4 address > resources recognized by the RIR responsible for the resources, and not be > involved in any dispute as to the status of those resources. > - Source entities outside of the ARIN region must meet any requirements > defined by the RIR where the source entity holds the registration. > - 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. > > Conditions on recipient of the transfer: > > - The conditions on a recipient outside of the ARIN region will be defined by > the policies of the receiving RIR. > - Recipients within the ARIN region must meet the transfer requirements as > defined in section 8.5. > - Recipients within the ARIN region will be subject to current ARIN policies. > 8.5. Specified Transfer Recipient Requirements > > 8.5.1. Registration Services Agreement > > The receiving entity must sign an RSA covering all resources to be > transferred unless that entity has a current (within the last two versions) > RSA on file. > > 8.5.2. Operational Use > > ARIN allocates or assigns number resources to organizations via transfer > solely for the purpose of use on an operational network. > > 8.5.3. Minimum transfer size > > ARIN’s minimum IPv4 transfer size is a /24. > > 8.5.4. Initial block > > Organizations without direct assignments or allocations from ARIN qualify for > transfer of an initial IPv4 block of ARIN’s minimum transfer size. > > 8.5.5. Block size > > Organizations may qualify for the transfer of a larger initial block, or an > additional block, by providing documentation to ARIN which details the use of > at least 50% of the requested IPv4 block size within 24 months. An officer of > the organization shall attest to the documentation provided to ARIN. > > 8.5.6. Efficient utilization of previous blocks > > Organizations with direct assignments or allocations from ARIN must have > efficiently utilized at least 50% of their cumulative IPv4 address blocks in > order to receive additional space. This includes all space reassigned to > their customers. > > Comments: > > Timetable for implementation: immediately > > Anything else: A redline has been provided to help the community understand > the changes that have been made to the NRPM. > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List ([email protected]). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact [email protected] if you experience any issues. _______________________________________________ PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]). Unsubscribe or manage your mailing list subscription at: http://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected] if you experience any issues.
