ARIN-prop-289: Allowance for IPv4 Allocation “Swap” Transactions via 8.3 Specified Transfers and 8.4 Inter-RIR Transfers [Archived]

Date: 31 May 2020

Proposal Originator: Chris Woodfield

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.