I support this proposal as written.

Owen

> On Jun 21, 2016, at 09:13 , ARIN <i...@arin.net> wrote:
> 
> On 16 June 2016 the ARIN Advisory Council (AC) advanced the following Draft 
> Policy to Recommended Draft Policy status:
> 
> ARIN-2016-1: Reserved Pool Transfer Policy
> 
> The text of the Recommended Draft Policy is below, and may also be found at:
> https://www.arin.net/policy/proposals/2016_1.html
> 
> You are encouraged to discuss all Recommended Draft Policies on PPML prior to 
> their presentation at the next ARIN Public Policy Consultation (PPC). PPML 
> and PPC discussions are invaluable to the AC when determining community 
> consensus.
> 
> 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)
> 
> Recommended Draft Policy ARIN-2016-1: Reserved Pool Transfer Policy
> 
> Date: 21 June 2016
> 
> 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
> 
> ##########
> 
> ARIN STAFF & LEGAL ASSESSMENT
> Draft Policy ARIN-2016-1
> RESERVED POOL TRANSFER POLICY
> https://www.arin.net/policy/proposals/2016_1.html
> 
> Date of Assessment: 13 June 2016
> ___
> 1. Summary (Staff Understanding)
> 
> This policy would make IPv4 addresses issued under NRPM 4.4 and 4.10 
> ineligible for transfer inside the NRPM 8.3 and 8.4 transfer policies.
> ___
> 2. Comments
> 
> A. ARIN Staff Comments
> 
> * If this policy is implemented, ARIN staff would not allow NRPM 8.3 and 8.4 
> transfers to include IPv4 addresses previously issued under NRPM 4.4 and 4.10 
> policies.
> 
> * ARIN staff would continue to allow IPv4 addresses previously issued under 
> NRPM 4.4 and 4.10 to be included in Merger and Acquisition (NRPM 8.2) 
> transfers.
> 
> * This policy could be implemented as written.
> 
> B. ARIN General Counsel – Legal Assessment
> 
> The policy does not create a material legal issue. It should be noted that 
> ARIN does permit transfers of IPV4 resources pursuant to 8.3 and 8.4. This 
> policy is an exception to that transferability and is consistent with the 
> intent and of the policy by which these allocations were made.
> ___
> 3. 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
> ___
> 4. Proposal / Draft Policy Text Assessed
> 
> Draft Policy ARIN-2016-1
> Reserved Pool Transfer Policy
> 
> Date: 22 March 2016
> 
> 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
> _______________________________________________
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