Re: [arin-ppml] LAST CALL for Recommended Draft Policy ARIN-2016-5: Post-IPv4-Free-Pool-Depletion Transfer Policy

[Owen DeLong]

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  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 
> 

[arin-ppml] LAST CALL for Recommended Draft Policy ARIN-2016-1: Reserved Pool Transfer Policy

[ARIN]

The ARIN Advisory Council (AC) met on 21 October 2016 and decided to 
send Recommended Draft Policy ARIN-2016-1: Reserved Pool Transfer Policy 
to Last Call:


The AC provided the following statement to the community:

This proposal is technically sound and enables fair and impartial number 
policy by ensuring that the number resources are used in accordance with 
the terms under which they were granted.  There is significant support 
for this change within the Internet community. Re: Merge into 2016-5. 
The new text "Address resources from a reserved pool (including those 
designated in Section 4.4 and 4.10) are not eligible for transfer." 
should be added to the revised 2016-5 sections 8.3 & 8.4 "Conditions on 
source of the transfer:”.


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-2016-1: Reserved Pool Transfer Policy

AC assessment of conformance with the Principles of Internet Number 
Resource Policy:


This proposal enables fair and impartial number resource administration 
by ensuring that IPv4 resources, which are specially designated for 
critical infrastructure and IPv6 transition, are readily available for 
many years into the future. This is done by ensuring the resources 
remain in their originally designated pool rather than being moved into 
the general IPv4 address pool via a transfer. This proposal is 
technically sound and is supported by the community.


Problem Statement:

Section 8 of the current NRPM does not distinguish between the transfer 
of blocks from addresses that have been reserved for specific uses and 
other addresses that can be transferred. In sections 4.4 and 4.10 there 
are specific address blocks set aside, based on the need for critical 
infrastructure and IPv6 transitions. Two issues arise if transfers of 
reserved address space occur under the current language of section 8. 
First, if transfers of 4.4 or 4.10 space occur under the current policy 
requirements set forth in sections 8.3 and 8.4, the recipients will be 
able to acquire space that was originally reserved for a specific 
purpose without ever providing evidence that they will be using the 
space for either critical infrastructure or IPv6 transition. Second, if 
we allow an allocation or assignment from the block reserved in section 
4.10 to be transferred out of the region, it would complicate the single 
aggregate from which providers are being asked to allow in block sizes 
smaller than a /24. This policy would limit the transfer of addresses 
from reserved pools.


Policy statement:

Add to Section 8.3 and Section 8.4 under the "Conditions on source of 
the transfer:"


Address resources from a reserved pool (including those designated in 
Section 4.4 and 4.10) are not eligible for transfer.


Timetable for implementation: Immediate
___
PPML
You are receiving this message because you are subscribed to
the ARIN Public Policy Mailing List (ARIN-PPML@arin.net).
Unsubscribe or manage your mailing list subscription at:
http://lists.arin.net/mailman/listinfo/arin-ppml
Please contact i...@arin.net if you experience any issues.

[arin-ppml] LAST CALL for Recommended Draft Policy ARIN-2015-2: Modify 8.4 (Inter-RIR Transfers to Specified Recipients)

[ARIN]

The ARIN Advisory Council (AC) met on 21 October 2016 and decided to 
send Recommended Draft Policy ARIN-2015-2: Modify 8.4 (Inter-RIR 
Transfers to Specified Recipients) to Last Call:


The AC provided the following statement to the community:

Recommended Draft Policy ARIN 2015-2 contributes to fair and impartial 
number resources administration by removing an impediment to the 
transfer of IPv4 numbering resources to other RIRs when business needs 
change.  This recommended draft allows for an entity to transfer 
addresses within the first 12 months after receiving a 24 month supply 
via the transfer market. It is technically sound in that it balances 
removing limits on transfers of IPv4 numbering resources to other RIRs 
with safeguards related to common ownership and control of the source 
and recipient to reduce the likelihood of fraudulent transactions. There 
is strong community support for this recommended draft policy as written.


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 2015-2: Modify 8.4 (Inter-RIR Transfers to 
Specified Recipients)


AC's assessment of conformance with the Principles of Internet Number 
Resource Policy:


Draft Policy ARIN 2015-2 contributes to fair and impartial number 
resources administration by removing an impediment to the transfer of 
IPv4 numbering resources to other RIRs when business needs change within 
the first 12 months of receipt of a 24 month supply of IP addresses by 
an entity via the transfer market. It is technically sound in that it 
balances removing limits on transfers of IPv4 numbering resources to 
other RIRs with safeguards related to ownership and control described in 
the draft policy to reduce the likelihood of fraudulent transactions. 
There was strong community support for this draft policy at the NANOG 66 
PPC and ARIN 37, subject only to some suggested editorial changes which 
have now been implemented in the latest version.


Problem Statement:

Organizations that obtain a 24 month supply of IP addresses via the 
transfer market and then have an unexpected change in business plan are 
unable to move IP addresses to the proper RIR within the first 12 months 
of receipt.


Policy statement:

Replace 8.4, bullet 3, to read: "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 M transfers."


Comments: Organizations that obtain a 24 month supply of IP addresses 
via the transfer market and then have an unexpected change in business 
plan are unable to move IP addresses to the proper RIR within the first 
12 months of receipt. The need to move the resources does not flow from 
ARIN policy, but rather from the requirement of certain registries 
outside the ARIN region to have the resources moved in order to be used 
there.


The intention of this change is to allow organizations to perform 
inter-RIR transfers of space received via an 8.3 transfer regardless of 
the date transferred to ARIN. A common example is that an organization 
acquires a block located in the ARIN region, transfers it to ARIN, then 
3 months later, the organization announces that it wants to launch new 
services out of region. Under current policy, the organization is 
prohibited from moving some or all of those addresses to that region's 
Whois if there is a need to move them to satisfy the rules of the other 
region requiring the movement of the resources to that region in order 
for them to be used there. Instead, the numbers are locked in ARIN's 
Whois. It's important to note that 8.3 transfers are approved for a 24 
month supply, and it would not be unheard of for a business model to 
change within the first 12 months after approval. The proposal also 
introduces a requirement for an affiliation relationship between the 
source and recipient entity, based on established corporate law 
principles, so as to make it reasonably likely that eliminating the 12 
month anti-flip period in that situation will meet the needs of 
organizations that operate networks in more than one region without 
encouraging abuse.


a. Timetable for implementation: Immediate

b. Anything else: N/A
___
PPML
You are receiving this message because you are subscribed to
the ARIN 

[arin-ppml] LAST CALL for Recommended Draft Policy ARIN-2016-6: Eliminate HD-Ratio from NRPM

[ARIN]

The ARIN Advisory Council (AC) met on 21 October 2016 and decided to 
send Recommended Draft Policy ARIN-2016-6: Eliminate HD-Ratio from NRPM 
to Last Call:


The AC provided the following statement to the community:

This proposal is technically sound and enables fair and impartial number 
policy by reducing any confusion caused by HD-Ratio remaining in the 
NRPM. According to the staff and legal assessment, these changes align 
with current practice of ARIN staff. There is support and no concerns 
have been raised by the community regarding this proposal on PPML. 
During the Public Policy Meeting at ARIN 38 in Dallas, a concern was 
raised regarding the inclusion of comments on the fee structure in the 
policy statement. To address this issue an editorial change has been 
made while sending the policy to Last Call, removing the following 
unnecessary text from the proposed section 6.5.9.2, "(both policy and 
fee structure) unless or until the board adopts a specific more 
favorable fee structure for community networks."


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-2016-6: Eliminate HD-Ratio from NRPM

AC's assessment of conformance with the Principles of Internet Number 
Resource Policy:


This proposal is technically sound and enables fair and impartial number 
policy by reducing any confusion caused by HD-Ratio remaining in the 
NRPM. According to the staff and legal assessment, these changes align 
with current practice of ARIN staff. There is support and no concerns 
have been raised by the community regarding this proposal on PPML.


Problem Statement:

The HD-Ratio has become an anachronism in the NRPM and some of the 
vestigial references to it create confusion about recommended prefix 
sizes for IPv6 resulting in a belief in the community that ARIN endorses 
the idea of /56s as a unit of measure in IPv6 assignments. While there 
are members of the community that believe a /56 is a reasonable choice, 
ARIN policy has always allowed and still supports /48 prefixes for any 
and all end-sites without need for further justification. More 
restrictive choices are still permitted under policy as well. This 
proposal does not change that, but it attempts to eliminate some 
possible confusion.


The last remaining vestigial references to HD-Ratio are contained in the 
community networks policy (Section 6.5.9). This policy seeks to replace 
6.5.9 with new text incorporating end user policy by reference (roughly 
equivalent to the original intent of 6.5.9 prior to the more recent 
changes to end-user policy). While this contains a substantial rewrite 
to the Community Networks policy, it will not have any negative impact 
on community networks. It may increase the amount of IPv6 space a 
community network could receive due to the change from HD-Ratio, but not 
more than any other similar sized end-user would receive under existing 
policy.


Policy statement:

Replace section 6.5.9 in its entirety as follows:

6.5.9 Community Network Assignments

While community networks would normally be considered to be ISP type 
organizations under existing ARIN criteria, they tend to operate on much 
tighter budgets and often depend on volunteer labor. As a result, they 
tend to be much smaller and more communal in their organization rather 
than provider/customer relationships of commercial ISPs. This section 
seeks to provide policy that is more friendly to those environments by 
allowing them to use end-user criteria.


6.5.9.1 Qualification Criteria

To qualify under this section, a community network must demonstrate to 
ARIN’s satisfaction that it meets the definition of a community network 
under section 2.11 of the NRPM.


6.5.9.2 Receiving Resources

Once qualified under this section, a community network shall be treated 
as an end-user assignment for all ARIN purposes.


Community networks shall be eligible under this section only for IPv6 
resources and the application process and use of those resources shall 
be governed by the existing end-user policy contained in section 6.5.8 
et. seq.


Community networks seeking other resources shall remain subject to the 
policies governing those resources independent of their election to use 
this policy for IPv6 resources.


Delete section 2.8 — This section is non-operative and conflicts with 
the definitions of utilization contained in current policies.


Delete section 2.9 — This section is no longer operative.

Delete section 6.7 — This section is no longer applicable.

Comments:

[arin-ppml] Draft Policy ARIN-2016-7: Integration of Community Networks into existing ISP policy

[ARIN]

On 21 October 2016 the ARIN Advisory Council (AC) advanced ARIN-prop-232 
to Draft Policy status.


This Draft Policy has been numbered and titled:

Draft Policy ARIN-2016-7: Integration of Community Networks into 
existing ISP policy


Draft Policy ARIN-2016-7 is below and can be found at:

https://www.arin.net/policy/proposals/2016_7.html

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/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)



Draft Policy ARIN-2016-7: Integration of Community Networks into 
existing ISP policy


Problem Statement:

The current Community Networks (Section 6.5.9) has not been utilized by 
organizations. The definition of a Community Network is overly narrow in 
scope and has complicated requirements. The existing text does not 
specify whether an Organization will be considered an end-user or ISP. 
This policy change would relax the definition of a Community Network, 
while still retaining modest controls. As well it would integrate the 
key components into the existing policy without requiring a specific 
section.


Policy statement:

Current NRPM Text
2.11. Community Network
A community network is any network organized and operated by a volunteer
group operating as or under the fiscal support of a nonprofit organization
or university for the purpose of providing free or low-cost connectivity to
the residents of their local service area. To be treated as a community
network under ARIN policy, the applicant must certify to ARIN that the
community network staff is 100% volunteers.

New NRPM Text
2.11. Community Network
A community network is any network organized and operated by a volunteer
group operating as or under the fiscal support of a nonprofit or equivalent
organization or accredited educational institution for the purpose of
providing free or low-cost connectivity in their local service area.

Current NRPM Text
6.5.2.1 (b) In no case shall an LIR receive smaller than a /32 unless they
specifically request a /36. In no case shall an ISP receive more than a /16
initial allocation.

New NRPM Text
6.5.2.1 (b) In no case shall an LIR receive smaller than a /32 unless they
specifically request a /36. In no case shall an ISP receive more than a /16
initial allocation. A Community Network may request a /48 or larger
depending on qualification.

Add to NRPM
6.5.2.2 (d) A Community Network that does not qualify under the previous
requirements can provide a plan detailing anticipated assignments to users
for one, two and five year periods, with a minimum of 50 assignments within
5 years.

Remove Section 6.5.9 from NRPM

Comments:
Timetable for implementation: Immediate
___
PPML
You are receiving this message because you are subscribed to
the ARIN Public Policy Mailing List (ARIN-PPML@arin.net).
Unsubscribe or manage your mailing list subscription at:
http://lists.arin.net/mailman/listinfo/arin-ppml
Please contact i...@arin.net if you experience any issues.

[arin-ppml] Advisory Council Meeting Results - October 2016

[ARIN]

The Advisory Council met on 21 October in accordance with the Policy 
Development Process (PDP), and moved the following to Last Call (each 
will be posted separately):


Recommended Draft Policy ARIN-2015-2: Modify 8.4 (Inter-RIR Transfers
to Specified Recipients)

Recommended Draft Policy ARIN-2016-1: Reserved Pool Transfer Policy

Recommended Draft Policy ARIN-2016-2: Change timeframes for IPv4
requests to 24 months

Recommended Draft Policy ARIN-2016-4: Transfers for new entrants

Recommended Draft Policy ARIN-2016-5: Post-IPv4-Free-Pool-Depletion
Transfer Policy

Recommended Draft Policy ARIN-2016-6: Eliminate HD-Ratio from NRPM



The AC abandoned the following:

Recommended Draft Policy ARIN-2015-7: Simplified requirements for
demonstrated need for IPv4 transfers

The AC provided the following statement regarding ARIN-2015-7:

The Advisory Council decided to abandon ARIN-2015-7: Simplified 
requirements for demonstrated need for IPv4 transfers due to a lack of 
support, when compared to other alternative proposals at the Public 
Policy Meeting at ARIN 38 in Dallas.


Anyone dissatisfied with this decision may initiate a petition. The 
deadline to begin a petition will be five business days after the AC's 
draft meeting minutes are published.




The AC accepted the following Proposal as a Draft Policy (to be posted 
separately for discussion):


ARIN-prop-232: Integration of Community Networks into existing ISP policy

The AC advances Proposals to Draft Policy status once they are found to 
be within the scope of the PDP, and contain a clear problem statement 
and suggested changes to number resource policy text.




The AC is continuing to work on:

Draft Policy ARIN-2016-3: Alternative simplified criteria for
justifying small IPv4 transfers

The AC provided the following statement regarding ARIN-2016-3:

With regard to merging with other Recommended Draft Policies, 2016-3 
includes a change to NRPM Section 8.4, bullet 3. Recommended Draft 
Policy ARIN-2016-5 includes the movement of bullet 3 to bullet 2. 
Recommended Draft Policy ARIN-2016-1: Reserved Pool Transfer Policy 
includes the addition of a bullet to Section 8.4 Should 2016-5 be 
implemented, the aforementioned changes from 2016-3 and 2016-1 should be 
incorporated into Section 4 as appropriate.




The PDP can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)
___
PPML
You are receiving this message because you are subscribed to
the ARIN Public Policy Mailing List (ARIN-PPML@arin.net).
Unsubscribe or manage your mailing list subscription at:
http://lists.arin.net/mailman/listinfo/arin-ppml
Please contact i...@arin.net if you experience any issues.