This new language has my support, with a few comments:

- If I’m reading this properly, the prohibition on transferring the smaller 
block kicks in if the larger block isn’t transferred within a year. Have we 
considered the option of having that restriction kick in immediately until the 
larger block is transferred? Or was that considered too onerous?

- I’ve noticed that officer attestation language is present in the new 
8.5.5.1.1 subsection; I’m assuming this will remain in place despite the 
separate discussion on removing the need for officer attestations, and removed 
via a future policy proposal if that action is taken. Please advise if that 
assumption is incorrect.

Thanks,

-C

> On Aug 26, 2021, at 6:54 AM, Rob Seastrom <rs-li...@seastrom.com> wrote:
> 
> 
> Dear ARIN Community,
> 
> Please read the updated text for policy proposal ARIN 2020-6 Swap Policy 
> (below) and offer your thoughts and comments.
> 
> All the best,
> 
> -r
> 
> -=-=-=-=-
> 
> ARIN 2020-6 Swap Policy
> 
> Current text:
> 
> 8.5.5. Block Size
> Organizations may qualify for the transfer of a larger initial block, or an 
> additional block, by providing documentation to ARIN which details the use of 
> at least 50% of the requested IPv4 block size within 24 months. An officer of 
> the organization shall attest to the documentation provided to ARIN.
> 
> 
> Add:
> 
> 8.5.5.1- Transfer for the Purpose of Renumbering 
> Organizations with larger direct allocations or assignments than they require 
> may receive transfer of a smaller block for the purpose of renumbering onto 
> the smaller block if they transfer the entire larger block to a qualified 
> recipient under section 8 within one year of receipt of transfer of the 
> smaller block. If the larger block is not transferred within one year of 
> receipt of the smaller block, the smaller block will be ineligible for 
> transfer under sections 8.3 and 8.4, and the organization will be ineligible 
> to receive any further transfers under this policy. 
> 
>       8.5.5.1.1 Smaller Block Size
>       Organizations may qualify to receive transfer of a smaller block by 
> providing documentation to ARIN which details the use of at least 50% of the 
> smaller block size within 24 months. Current use of the larger block may be 
> used to satisfy this criteria. An officer of the organization shall attest to 
> the documentation provided to ARIN
> 
> Current text:
> 8.5.6. Efficient Utilization of Previous Blocks
> Organizations with direct assignments or allocations from ARIN must have 
> efficiently utilized at least 50% of their cumulative IPv4 address blocks in 
> order to receive additional space. This includes all space reassigned to 
> their customers.
> 
> Add:
> 
> 8.5.6.1 Transfer for the Purpose of Renumbering 
> Organizations receiving transfer of a smaller block under section 8.5.5.1 may 
> deduct the larger block they are transferring to a qualified recipient when 
> calculating their efficient utilization of previous blocks under section 
> 8.5.6. 
> 
> Current Text:
> Sections 8.3 and 8.4, 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 for transfers made in connection with 
> a renumbering exercise designed to more efficiently utilize number resources 
> under section 8.5.5.1.
> 
> 
> 
> 
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