Draft Policy ARIN-2017-4: Remove Bidirectional Requirement for Inter-RIR Transfers [Archived]

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Status: Abandoned

Tracking Information

Discussion Tracking

Mailing List:

Formal introduction on PPML on 10 April 2017

Origin - ARIN-prop-236

Draft Policy - 10 April 2017

Abandoned - 31 January 2018

Public Policy Mailing List

ARIN Public Policy Meeting:

ARIN Advisory Council:

AC Shepherds:
Rob Seastrom, Joe Provo

ARIN Board of Trustees:

Revisions:

Revised -6 September 2017

Revised/Retitled - 17 November 2017

Revised - 22 November 2017

Implementation:

Version Date: 22 November 2017

Problem Statement:

ARIN’s inter-RIR transfer policy is functionally one-way, so the assertion of a reciprocal two-way requirement is gratuitous.

Policy statement:

Replace the first sentence of NRPM 8.4 thus:

Inter-RIR transfers may take place only via RIRs who agree to the transfer and share compatible, needs-based policies.

Timetable for implementation: Immediate.

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ARIN STAFF & LEGAL ASSESSMENT

Draft Policy ARIN-2017-04

Remove Reciprocity Requirements for Inter-RIR Transfers

https://arin.net/policy/proposals/2017_4.html

Date of Assessment: 5 December 2017

Summary (Staff Understanding)

Draft Policy 2017-04 will allow ARIN to approve inter-regional source transfers to any RIR who agrees to the transfer and share compatible, needs-based policies; in effect removing the present requirement that the other RIR has a policy that allows transfers from their region to the ARIN region in to allow any transfers from the ARIN region outward.

Comments

A. ARIN Staff Comments

* The Problem Statement is misleading where it asserts “ARIN’s inter-RIR transfer policy is functionally one-way”, as ARIN’s present inter-RIR transfer policy has been used for transfers both into and out of the region. If the problem statement is trying to convey that the vast majority of the use of the inter-RIR transfer policy is to transfer out of the ARIN region, then it should state that explicitly.

* This policy, if adopted, would enable transfers to any RIR that has a compatible, needs-based Inter-RIR transfer policy in place, even if the transfer policy was not reciprocal in allowing transfers to the ARIN region (i.e. unidirectional.) No RIR’s have a unidirectional, compatible, needs-based Inter-RIR transfer policy in place at this time and as such this policy would have no effect on current operations.

* This policy would have no impact on transfers with RIRs that already have a reciprocal, compatible, needs-based policy. If adopted, ARIN would continue transfers to and from those RIRs (currently RIPE NCC and APNIC), the policy change could encourage the two RIR’s with bi-directional policies to change their policies to drop reciprocity in transfers.

* This policy, if adopted, could make it easier for RIRs presently without reciprocal, compatible, needs-based transfer policy to create an ARIN-compatible inter-RIR transfer policy, as there would no longer be a requirement for reciprocity policy reciprocity regarding direction of transfer.

* This policy could be implemented as written.

B. ARIN General Counsel – Legal Assessment

* The policy does not create material legal issues.

Resource Impact

Implementation of this policy would have minimal resource impact. It is estimated that implementation could occur within 3 months after ratification by the ARIN Board of Trustees and any RIR adopting a unidirectional, compatible, needs-base Inter-RIR transfer policy. The following would be needed in order to implement:

* Updated guidelines and internal procedures

* Staff training

* Minimal engineering work

4 . Proposal / Draft Policy Text Assessed

Draft Policy ARIN-2017-4: Remove Bidirectional Requirement for Inter-RIR Transfers

Version Date: 22 November 2017

Problem Statement:

ARIN’s inter-RIR transfer policy is functionally one-way, so the assertion of a reciprocal two-way requirement is gratuitous.

Policy statement:

Replace the first sentence of NRPM 8.4 thus:

Inter-RIR transfers may take place only via RIRs who agree to the transfer and share compatible, needs-based policies.

Timetable for implementation :

Immediate.

##########

Earlier Version

##########

Problem Statement:

ARIN’s inter-RIR transfer policy is functionally one-way, so the assertion of a reciprocal two-way requirement is gratuitous.

Policy statement:

Add the following sentence after the first sentence of NRPM 8.4:

Inter-RIR transfers may take place only via RIRs who agree to the transfer and share compatible, needs-based policies.

Timetable for Implementation:

Immediate

##########

Earlier Version

##########

Version Date: 6 September 2017

Problem Statement:

AFRINIC and LACNIC are currently considering one-way inter-RIR transfer proposals. Those RIR communities feel a one-way policy a policy that allows network operators in their regions to obtain space from another region and transfer it into AFRINIC and LACNIC may best meet the needs of the operators in that region.

ARIN staff, in reply to an inquiry from AFRINIC, have formally indicated that ARINs 8.4 policy language will not allow ARIN to participate in such one-way transfers. The staff formally indicate to AFRINIC that the word reciprocal in 8.4 prohibits ARIN from allowing ARIN-registered space to transfer directly to AFRINIC (in this context).

ARIN as a community should recognize that other RIR operator communities have different needs than we do. We should recognize that:

network operators in AFRINIC in LACNIC have need to obtain space in the market;
have reasons they think are important to not allow two-way transfers; and
we should understand that the history of the RIR system has led to LACNIC and AFRINIC having multiple orders of magnitude less IPv4 address space than ARIN does.

Policy statement:

Add the following sentence after the first sentence of NRPM 8.4:

Inter-RIR transfers may take place to an RIR with a non-reciprocal inter-RIR transfer policy only when the recipient RIR has an IPv4 total inventory less than the average (mean) of the IPv4 total inventory among all of the RIRs.

Timetable for implementation: Upon the ratification of any inter-RIR transfer policy at another RIR that is one-way as described in the problem statement.

##########

ARIN STAFF & LEGAL ASSESSMENT

Draft Policy ARIN-2017-04

Remove Reciprocity Requirements for Inter-RIR Transfers

https://arin.net/policy/proposals/2017_4.html

Date of Assessment: 7 September 2017

Summary (Staff Understanding)

Draft Policy 2017-04 will allow ARIN to approve inter-regional source transfers to any RIR whose IPv4 address space inventory is below that of the global average of all RIR IPv4 address inventories when that RIR has an inter-regional transfer policy which is not bidirectional in nature. A snapshot of the current existing “total” RIR IPv4 inventories computed based on the extended stats file are:

ARIN has 1,686,159,104 billion IPv4 addresses in its inventory.

APNIC has 881,734,912 million IPv4 addresses in its inventory.

RIPE has 822,316,800 million IPv4 addresses in its inventory.

LACNIC has 190,775,552 million IPv4 addresses in its inventory.

AFRINIC has 121,242,624 million IPv4 addresses in its inventory.

Global average: 740,445,798 million IPv4 addresses.

Based on the computations above Draft Policy 2017-04 will specifically allow ARIN to approve source transfers out to both LACNIC and AFRINIC even if they do not have a bidirectional inter-RIR transfer policy that would allow for IPv4 addresses to be transferred in to ARIN. Each RIR would need to have an actual “transfer policy” in place in order to be considered under this policy. Further, it is staff’s understanding that this policy does not change the requirement for a compatible, needs-based Inter-RIR transfer policy.

Comments

A. ARIN Staff Comments

* Consider changing “Remove” in the title to a more appropriate verb such as modify, particularly since the requirement remains in place under some circumstances.

* Quarterly, ARIN will compute the average of the total inventory and assess each RIR’s total inventory against that average. The resulting assessment will be posted online.

* This policy would be implemented to work only with RIRs that have a unidirectional, compatible, needs-based Inter-RIR transfer policy in place and meet the address pool criteria of this policy.

* To eliminate any possible confusion of the meaning of ‘reciprocity’ it is recommended that ‘with a non-reciprocal Inter-RIR transfer policy’ would be better phrased as ‘with a unidirectional, compatible, needs-based Inter-RIR transfer policy.’

* A corollary recommendation is to change section 8.4 of the NRPM so that the word “reciprocal” is changed to “bidirectional” in the first sentence. Similarly, the word “reciprocal” in the title of the draft policy could be changed to “bidirectional”.

* This proposed policy may be more complex than necessary, since there is a modest number of transfers of number resources coming into the ARIN region via NRPM 8.4, which suggests a very small potential impact if the policy change were to remove the bidirectional policy requirement in its entirety.

* This policy could be implemented as written with the recommended changes.

B. ARIN General Counsel – Legal Assessment

* The staff’s interpretation spelled out above, that removing “reciprocal” does not remove “compatible” and “needs based” is a legally critical aspect of how this policy would be implemented. Absent such an understanding counsel would recommend against an unlimited transfer policy.

Resource Impact

Implementation of this policy would have minimal resource impact. It is estimated that implementation would occur within 3 months after ratification by the ARIN Board of Trustees. The following would be needed in order to implement:

* Updated guidelines and internal procedures

* Staff training

* Minimal engineering work

Proposal / Draft Policy Text Assessed

Draft Policy ARIN-2017-4: Remove Reciprocity Requirement for Inter-RIR Transfers

Version Date: 6 September 2017

Problem Statement:

ARIN as a community should recognize that other RIR operator communities have different needs than we do.

We should recognize that:

network operators in AFRINIC in LACNIC have need to obtain space in the market;
have reasons they think are important to not allow two-way transfers; and
we should understand that the history of the RIR system has led to LACNIC and AFRINIC having multiple orders of magnitude less IPv4 address space than ARIN does.

Policy statement:

Add the following sentence after the first sentence of NRPM 8.4:

Timetable for implementation: Upon the ratification of any inter-RIR transfer policy at another RIR that is one-way as described in the problem statement.

#########

Earlier Version

#########

V** ersion Date:** 10 April 2017

Problem Statement:

ARIN as a community should recognize that other RIR operator communities have different needs than we do. We should recognize that:

network operators in AFRINIC in LACNIC have need to obtain space in the market;
have reasons they think are important to not allow two-way transfers; and
we should understand that the history of the RIR system has led to LACNIC and AFRINIC having multiple orders of magnitude less IPv4 address space than ARIN does.

Policy statement:

Add the following sentence after the first sentence of NRPM 8.4:

Inter-regional transfers may take place to an RIR without a reciprocal inter-regional transfer policy only when the recipient RIR has less IPv4 address space in its inventory than the global average of RIR IPv4 address inventories.

Timetable for implementation: Upon the ratification of any inter-RIR transfer policy at another RIR that is one-way as described in the problem statement.

###################

ARIN STAFF & LEGAL ASSESSMENT

Draft Policy ARIN-2017-04

Remove Reciprocity Requirements for Inter-RIR Transfers

https://arin.net/policy/proposals/2017_4.html

Date of Assessment: 22 May 2017

Summary (Staff Understanding)

Draft Policy 2017-04 will allow ARIN to approve inter-regional source transfers to any RIR whose IPv4 address space inventory is below that of the global average of all RIR IPv4 address inventories without that RIR having a reciprocal inter-regional transfer policy. A snapshot of the current existing “total” RIR IPv4 inventories computed based on the extended stats file are:

ARIN has 1.687 billion IPv4 addresses in its inventory.
APNIC has 881 million IPv4 addresses in its inventory.
RIPE has 822 million IPv4 addresses in its inventory.
LACNIC has 191 million IPv4 addresses in its inventory.
AFRINIC has 121 million IPv4 addresses in its inventory.

Global average: 740 million IPv4 addresses.

Based on the computations above Draft Policy 2017-04 will specifically allow ARIN to approve source transfers out to both LACNIC and AFRINIC even if they do not have a reciprocal inter-RIR transfer policy that would allow for IPv4 addresses to be transferred in to ARIN. Each RIR would need to have an actual “transfer policy” in place in order to be considered under this policy.

If the intent is that the ability to transfer is based on “available” inventory then the outcome would be as below:

AFRINIC has 16.9 million IPv4 addresses available/reserved.
RIPE has 13.0 million IPv4 addresses available/reserved.
APNIC has 10.6 million IPv4 addresses available/reserved.
ARIN has 6.2 million IPv4 addresses available/reserved.
LACNIC has 4.7 million IPv4 addresses available/reserved.

Global average: 10.3 million IPv4 addresses available/reserved.

Based on the computations above Draft Policy 2017-04 will specifically allow ARIN to approve source transfers out to only LACNIC even if they do not have a reciprocal inter-RIR transfer policy that would allow for IPv4 addresses to be transferred in to ARIN. They would need to have an actual “transfer policy” in place in order to be considered under this policy.

Comments

A. ARIN Staff Comments

* Recommend that the term “total inventory” be used if the intent is to count all of the RIR’s IPv4 holdings (assigned, allocated, available and reserved) toward eligibility of this policy or “available inventory” if that is the intent of this policy.

* Consider changing “Remove” in the title to a more appropriate verb such as modify.

* ARIN will compute the average of either “total” or “available” inventory monthly and post it online in order to ensure compliance with the policy.

* This policy would be implemented to work only with RIRs that have a non-reciprocal Inter-RIR transfer policy in place and meet the address pool criteria of this policy. While the intent is to permit the possibility of transfers from the ARIN region to LACNIC and AFRINIC region, nothing would preclude other RIRs from changing their existing reciprocal transfer policies should their “total” or “available” inventories fall below the average of the five RIRs. NOTE: If using “available” inventory then only LACNIC would qualify today while using “total” inventory AFRINIC and LACNIC would both qualify.

* Using “total” inventory adds stability to the policy as the “total” inventories will not change very often while the “available” inventory will change almost daily.

* The phrase ‘without a reciprocal inter-regional transfer policy’ would be better phrased as ‘with a non-reciprocal Inter-RIR transfer policy’.

* This policy could be implemented as written once the intent of the policy with regard to address pool is clarified.

B. ARIN General Counsel – Legal Assessment

* Counsel sees no material legal issues in this policy.

Resource Impact

* Updated guidelines and internal procedures

* Staff training

* Minimal engineering work

Proposal / Draft Policy Text Assessed

Draft Policy 2017-04: Remove Reciprocity Requirements for Inter-RIR Transfers

Problem Statement:

ARIN as a community should recognize that other RIR operator communities have different needs than we do.

We should recognize that:

network operators in AFRINIC in LACNIC have need to obtain space in the market;
have reasons they think are important to not allow two-way transfers; and
we should understand that the history of the RIR system has led to LACNIC and AFRINIC having multiple orders of magnitude less IPv4 address space than ARIN does.

Policy statement:

Add the following sentence after the first sentence of NRPM 8.4:

Timetable for implementation : Upon the ratification of any inter-RIR transfer policy at another RIR that is one-way as described in the problem statement.