On 18 June 2020, the ARIN Advisory Council (AC) accepted "ARIN-prop-289:
Allowance for IPv4 Allocation “Swap” Transactions via 8.3 Specified
Transfers and 8.4 Inter-RIR Transfers" as a Draft Policy.
Draft Policy ARIN-2020-6 is below and can be found at:
https://www.arin.net/participate/policy/drafts/2020_6/
You are encouraged to discuss all Draft Policies on PPML. The AC will
evaluate the discussion in order to assess the conformance of this draft
policy with ARIN's Principles of Internet number resource policy as
stated in the Policy Development Process (PDP). Specifically, these
principles are:
* Enabling Fair and Impartial Number Resource Administration
* Technically Sound
* Supported by the Community
The PDP can be found at:
https://www.arin.net/participate/policy/pdp/
Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/participate/policy/drafts/
Regards,
Sean Hopkins
Policy Analyst
American Registry for Internet Numbers (ARIN)
Draft Policy ARIN-2020-6: Allowance for IPv4 Allocation “Swap”
Transactions via 8.3 Specified Transfers and 8.4 Inter-RIR Transfers
Problem Statement:
Organizations wishing to “swap out” a larger block for a smaller one in
the interest of avoiding deaggregation (as opposed to breaking up their
existing block and transferring only a part of it) are forbidden by
existing 8.3 policy from being the source of the transfer for their
larger block after receiving a smaller one for 12 months after receiving
the smaller block. In practice, ARIN staff has been allowing orgs to
transfer out blocks after receiving smaller ones inside of the 12-month
window, but many ARIN resource holders are not aware of this. Some
resource holders have worked around the restriction by creating a new
org to receive the smaller block, but this practice has implications on
waitlist policy, as the new org is now technically eligible to apply for
wait-list space while the original org cannot.
Similar language is present in NRPM Section 8.4, as such, the practice
should be sanctioned for those types of transfers as well.
Policy Statement:
Clarify the conditions under 8.3 and 8.4 that explicitly allows transfer
of a larger block in exchange for a smaller one as part of a renumbering
plan. This is accomplished by adding a sub-bullet point below in both
sections:
Section 8.3, under “Conditions on Source Of the Transfer”:
“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
8.2 transfers.
(ADD)
This requirement may be waived by ARIN if the source entity is
transferring resources as part of a renumbering plan designed to more
efficiently utilize number resources, for example, having received a
smaller block (via waitlist or transfer) with the intention of
renumbering into that block and then transferring their pre-existing
larger allocation to another specified recipient.
Section 8.4, under “Conditions on Source Of the Transfer”:
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, unless
either the source or recipient entity owns or controls the other, or
both are under common ownership or control. This restriction does not
include 8.2 transfers.
(ADD)
This requirement may be waived by ARIN if the source entity is
transferring resources as part of a renumbering plan designed to more
efficiently utilize number resources, for example, having received a
smaller block (via waitlist or transfer) with the intention of
renumbering into that block and then transferring their pre-existing
larger allocation to another specified recipient.
Timetable for implementation: Immediate
Comments:
The AC’s understanding is that Registration Services is allowing this
practice currently via the pre-approval process; this proposal aims to
officially sanction this practice.
_______________________________________________
ARIN-PPML
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