Temporary Transfers - Transferencias-Temporales

General information

Español
08/04/2024
First consensus
29 %. The next step will depend on moderator's decision.

Jordi Palet Martinez - Version [1, 2]
In discussion
15/04/2024 - 10/06/2024
First consensus
10/06/2024 - 24/06/2024

Public comments by LACNIC staff for this version

Interpretación de la propuesta por el staff de LACNIC

Autores: Jordi Palet

Aplicación de la propuesta:
Esta propuesta establece cambios en el manual de políticas.

Modificación del texto actual:
La propuesta hace una modificación al punto “2.3.2.18. Transferencias de direcciones IPv4”

Comentarios del Staff:
1) Hacemos énfasis en el comentario del análisis de impacto de la versión anterior: "Creemos que en las transferencias temporales, LACNIC debe hacer explícito el status de transferencia temporal en el WHOIS, incluyendo la relación con el bloque original y publicando la información del titular y del arrendatario."
El registro como subasignación es necesario para que el receptor pueda cumplir con requisitos como DNS reverso o creación de ROAs.
Por lo tanto, el staff asumirá que las transferencias temporales tienen que ser tratadas como sub asignaciones. Para esto debe ser un requisito que estas transferencias sean registradas como tal.
2) La propuesta, bajo el punto 2.3.2.18.11, incluye obligaciones para las transferencias temporales que actualmente no se aplican a las transferencias definitivas, e incluso no se aplican a las distribuciones normales. Aún y cuando este control lo deba realizar la fuente, es importante notar la diferencia de criterio.

Recomendaciones del Staff:
1) Recomendamos que el registro de la transferencia temporal como subasignación, quede explícito en el manual de políticas para facilitar el entendimiento de quien decida hacer esta transferencia.

Impacto en el sistema de registro y/u otros sistemas:
Esta propuesta tiene un fuerte impacto en los sistemas de registro, la base de datos de LACNIC y sistemas internos. Requiere coordinación con los NIRs.


Summary

LACNIC's current policies consider only permanent IPv4 address transfers.

This proposal specifies a policy change to allow temporary transfers.

Rationale (Describe the problem you intend to solve)

Mixed feelings exist among the community when we discuss the need to allow the leasing of addresses (broadly understood as any of its possible modalities) as a mechanism for transitioning to IPv6 or to allow new entrants. However, we are forgetting that a community-accepted mechanism already exists. This mechanism could be slightly modified to be equivalent to leasing, and yet have multiple advantages for both parties: temporary transfers.

The goal is to guarantee compliance with the policies through a system equivalent to leasing, which allows avoiding security issues, control by the RIR/NIR, and the guarantee that the addresses will be returned at the conclusion of the lease period.

At the same time, the proposal seeks to address the need for flexibility without excessive operational burden for the RIR/NIR, so that the lease period can simply be extended, in the understanding that there may be situations where the initially agreed-upon term is not sufficient to cover the initial need.

It is important to stress that those who need these transfers by way of a “lease” tend to be smaller entities or entities where initial investments are more moderate and, consequently, financially weaker. Therefore, given that the ultimate goal must be IPv6 deployment, using IPv6-only and IPv4aaS, the number of IPv4 addresses that may be needed will be actually reduced.

Finally, the proposal seeks to prioritize regional benefit, which is why it makes sense that it should apply only to transactions carried out in the region. Furthermore, this prevents permanent transfers from losing reciprocity with those regions that require reciprocity.

The Board could establish specific rates for this type of transfer and/or for their extension.

Current text

2.3.2.18. IPv4 Address Transfers

IPv4 block transfers shall be allowed between LIRs and/or End Users (hereinafter organizations) in accordance with the conditions set forth in this section.

This policy applies both to transfers where one of the organizations involved is part of another region (inter-RIR transfers) as well as to transfers within the LACNIC region (intra-RIR transfers).

2.3.2.18.1. The minimum block size that may be transferred is a /24.

2.3.2.18.2. In order for an organization within the LACNIC region to qualify for receiving a transfer, it must first go through the process of justifying its IPv4 resources before LACNIC. That is to say, the organization must justify before LACNIC the initial/additional allocation/assignment, as applicable, according to the policies in force.

If the receiving organization is part of another region, it will be subject to the criteria, verifications, and requirements of the corresponding RIR.

2.3.2.18.3. LACNIC or the corresponding RIR (depending on whether the transfer is inbound or outbound) will verify the holder of the resources to be transferred and check that they are not involved in any dispute.

In the case of intra-RIR transfers, both organizations must submit to LACNIC a signed copy of the legal document supporting the transfer.

In the case of inter-RIR transfers, the documentation supporting the operation will be agreed between the two RIRs.

2.3.2.18.4. LACNIC shall maintain a publicly accessible transfer log of all IPv4 address block transfers registered before LACNIC. This log will be used to record the date on which the transaction took place, the organization that originated the transfer, the receiving organization, the transferred addresses and, in the case of inter-RIR transfers, the source and destination RIRs.

2.3.2.18.5. The organization that originated the transfer shall automatically be ineligible to receive IPv4 resource allocations and/or assignments from LACNIC for a period of one year as of the transaction date registered in the transfer log.

2.3.2.18.6. Addresses that have previously been transferred may not subsequently be transferred again (in full or in part) for a period of one year as of the transaction date specified in the transfer log.

2.3.2.18.7. Once the transfer is complete, LACNIC shall modify the information on the transferred resource in order to reflect the change of holder.

2.3.2.18.8. Both the transferring and the receiving entities will be subject to the policies and membership terms and conditions of the corresponding RIR.

2.3.2.18.9. Addresses from allocations or assignments from LACNIC, whether initial or additional, may not be transferred (in full or in part) for a period of three years as of their allocation or assignment date.

2.3.2.18.10. Legacy resources transferred into the LACNIC region will no longer be considered legacy resources.

New text
Analyze diff

2.3.2.18. Temporary and Permanent IPv4 Address Transfers

Both temporary and permanent IPv4 address transfers will be allowed between LIRs and/or end users (hereinafter “entities”), under the conditions below.

This policy applies both to transfers where one of the entities involved is part of another region (inter-RIR transfers) as well as to transfers within the LACNIC region (intra-RIR transfers). However, temporary transfers will only be allowed within the region (temporary intra-RIR transfers).

2.3.2.18.1. The minimum block size that may be transferred is a /24.

2.3.2.18.2. In order for an entity within the LACNIC region to qualify for receiving a transfer, it must first go through the process of justifying its IPv4 resources before LACNIC. In other words, the entity must justify before LACNIC the initial/additional allocation/assignment, as applicable, according to the policies in force.

However, in the case of temporary transfers, a specific recipient may only receive (in total) a maximum of a /20.

If the receiving entity is in another region, it will be subject to the criteria, verifications, and requirements of the corresponding RIR.

2.3.2.18.3. LACNIC or the corresponding RIR (depending on whether the transfer is inbound or outbound) will verify the holder of the resources to be transferred and check that they are not involved in any dispute.

In the case of intra-RIR transfers, both entities must submit to LACNIC a signed copy of the legal document supporting the transfer. In the case of inter-RIR transfers, the documentation supporting the transaction will be agreed between the two RIRs.

2.3.2.18.4. LACNIC shall maintain a publicly accessible transfer log of all IPv4 address block transfers registered before LACNIC. This log will be used to record the initial date on which the transaction took place, the entity that originated the transfer, the receiving entity, the transferred addresses, the end date of the transaction, and in the case of inter-RIR transfers, the source and destination RIRs.

In the case of permanent transfers, the end date of the transaction will be left blank. For temporary transfers, the specific end date of the transfer will be specified. This value shall be updated in the event of an agreement to extend the initially agreed-upon term, a decision that must be formally endorsed by both parties and verified by LACNIC.

An extension of the term must be requested at least 30 days before the end date of the previously agreed-upon transaction.

2.3.2.18.5. The entity that originated the transfer shall automatically be ineligible to receive IPv4 resource allocations and/or assignments from LACNIC for a period of one year as of the transaction date recorded in the transfer log.

2.3.2.18.6. In the case of permanent transfers, addresses that have previously been transferred may not subsequently be transferred again (in full or in part) for a period of one year as of the transaction date recorded in the transfer log.

2.3.2.18.7. Once the transfer is complete, LACNIC shall modify the information on the transferred resource in order to reflect the change of holder.

In the case of temporary transfers, LACNIC shall restore this information to its original values (the values prior to the transfer) on the transaction’s end date.

2.3.2.18.8. Both the transferring and the receiving entities will be subject to the policies and membership terms and conditions of the corresponding RIR.

2.3.2.18.9. Addresses from allocations or assignments from LACNIC, whether initial or additional, may not be transferred (in full or in part) for a period of three years as of their allocation or assignment date.

2.3.2.18.10. Legacy resources transferred into the LACNIC region will no longer be considered legacy resources.

2.3.2.18.11. Temporary transfers must meet additional conditions. Failure to adhere to these conditions will serve as immediate grounds for the revocation of the transfer:
• The agreement must include clauses for revoking the transfer in case of misuse or abuse of the resources.
• Having an ASN to announce these resources.
• Having operational IPv6 at the time of announcing the transferred IPv4 resources.
• Having RPKI for these resources.
• Updating geolocation and IRR data.
Complying with the best practices established by MANRS.

Additional information

As far as we know, only the RIPE NCC allows temporary transfers. At the same time, the RIPE NCC does not consider leasing, but does not explicitly prohibit the practice.

APNIC and AFRINIC do not consider leasing or temporary transfers.

ARIN does not consider temporary transfers, and leasing is not a valid justification of need. Once addresses are leased, no additional addresses may be requested. Additionally, certain blocks cannot be leased.

Timetable

-

References

-

Presented at:

-


Summary

LACNIC's current policies consider only permanent IPv4 address transfers.

This proposal specifies a policy change to allow temporary transfers.

Rationale (Describe the problem you intend to solve)

Mixed feelings exist among the community when we discuss the need to allow the leasing of addresses (broadly understood as any of its possible modalities) as a mechanism for transitioning to IPv6 or to allow new entrants. However, we are forgetting that a community-accepted mechanism already exists. This mechanism could be slightly modified to be equivalent to leasing, but have multiple advantages for both parties: temporary transfers.

The goal is to guarantee compliance with the policies through a system equivalent to leasing, which allows avoiding security issues, control by the RIR/NIR, and the guarantee that the addresses will be returned at the conclusion of the lease period.

At the same time, the proposal seeks to address the need for flexibility without excessive operational burden for the RIR/NIR, so that the lease period can simply be extended, in the understanding that there may be situations where the initially agreed-upon term is not sufficient to cover the initial need.

It is important to stress that those who need these transfers by way of a “lease” tend to be smaller entities or entities with more moderate initial investments and, consequently, financially weaker. Therefore, given that the ultimate goal must be IPv6 deployment, using IPv6-only and IPv4aaS, the number of necessary IPv4 addresses will actually decrease.

Finally, the proposal seeks to prioritize regional benefit, which is why it makes sense that it should apply only to transactions within the region. Furthermore, it prevents permanent transfers from losing reciprocity with those regions that require it.

The Board might establish specific rates for this type of transfer and/or for their extension.

Current text

2.3.2.18. IPv4 Address Transfers

IPv4 block transfers shall be allowed between LIRs and/or End Users (hereinafter organizations) in accordance with the conditions set forth in this section.

This policy applies both to transfers where one of the organizations involved is part of another region (inter-RIR transfers) as well as to transfers within the LACNIC region (intra-RIR transfers).

2.3.2.18.1. The minimum block size that may be transferred is a /24.

2.3.2.18.2. In order for an organization within the LACNIC region to qualify for receiving a transfer, it must first go through the process of justifying its IPv4 resources before LACNIC. That is to say, the organization must justify before LACNIC the initial/additional allocation/assignment, as applicable, according to the policies in force.

If the receiving organization is part of another region, it will be subject to the criteria, verifications, and requirements of the corresponding RIR.

2.3.2.18.3. LACNIC or the corresponding RIR (depending on whether the transfer is inbound or outbound) will verify the holder of the resources to be transferred and check that they are not involved in any dispute.

In the case of intra-RIR transfers, both organizations must submit to LACNIC a signed copy of the legal document supporting the transfer.
In the case of inter-RIR transfers, the documentation supporting the operation will be agreed between the two RIRs.

2.3.2.18.4. LACNIC shall maintain a publicly accessible transfer log of all IPv4 address block transfers registered before LACNIC. This log will be used to record the date on which the transaction took place, the organization that originated the transfer, the receiving organization, the transferred addresses and, in the case of inter-RIR transfers, the source and destination RIRs.

2.3.2.18.5. The organization that originated the transfer shall automatically be ineligible to receive IPv4 resource allocations and/or assignments from LACNIC for a period of one year as of the transaction date registered in the transfer log.

2.3.2.18.6. Addresses that have previously been transferred may not subsequently be transferred again (in full or in part) for a period of one year as of the transaction date specified in the transfer log.

2.3.2.18.7. Once the transfer is complete, LACNIC shall modify the information on the transferred resource in order to reflect the change of holder.

2.3.2.18.8. Both the transferring and the receiving entities will be subject to the policies and membership terms and conditions of the corresponding RIR.

2.3.2.18.9. Addresses from allocations or assignments from LACNIC, whether initial or additional, may not be transferred (in full or in part) for a period of three years as of their allocation or assignment date.

2.3.2.18.10. Legacy resources transferred into the LACNIC region will no longer be considered legacy resources.

New text
Analyze diff

2.3.2.18. Temporary and Permanent IPv4 Address Transfers

Both temporary and permanent IPv4 address transfers will be allowed between LIRs and/or end users (hereinafter “entities”), as provided for below.

This policy applies to transfers where one of the entities involved is part of another region (inter-RIR transfers) as well as to transfers within the LACNIC region (intra-RIR transfers). However, temporary transfers will only be allowed within the region (temporary intra-RIR transfers).

2.3.2.18.1. The minimum block size that may be transferred is a /24.

2.3.2.18.2. In order for an entity within the LACNIC region to qualify for receiving a transfer, it must first go through the process of justifying its IPv4 resources before LACNIC. In other words, the entity must justify before LACNIC the initial/additional allocation/assignment, as applicable, according to the policies in force.

However, in the case of temporary transfers, a specific recipient may only receive (in total) a maximum of a /20.

If the receiving entity is in another region, it will be subject to the criteria, verifications, and requirements of the corresponding RIR.

2.3.2.18.3. LACNIC or the corresponding RIR (depending on whether the transfer is inbound or outbound) will verify the holder of the resources to be transferred and ensure that the resources are free from any disputes.

In the case of intra-RIR transfers, both entities must submit to LACNIC a signed copy of the legal document supporting the transfer.
In the case of inter-RIR transfers, the documentation supporting the transaction will be agreed between both RIRs.

2.3.2.18.4. LACNIC shall maintain a publicly accessible transfer log of all permanent IPv4 address block transfers. This log will be used to record the date on which the transaction took place, the entity that originated the transfer, the receiving entity, the transferred addresses, and, in the case of inter-RIR transfers, the source and destination RIRs.

LACNIC will maintain another publicly accessible log equivalent to the one described above for temporary transfers, where the start and end dates of the transfers will also be recorded.

The end date of a temporary transfer is the date on which the transfer finalizes. This date shall be updated in the event of an agreement to extend the initially agreed-upon term, a decision that must be formally endorsed by both parties and verified by LACNIC.

2.3.2.18.5. The entity that originated the transfer shall automatically be ineligible to receive IPv4 resource allocations and/or assignments from LACNIC for a period of one year as of the transaction date recorded in the transfer log.

2.3.2.18.6. In the case of permanent transfers, addresses that have already been transferred may not subsequently be transferred again (in full or in part) for a period of one year as of the transaction date recorded in the transfer log.

2.3.2.18.7. Once the transfer is complete, LACNIC shall modify the information on the transferred resource to reflect the change of holder.

In the case of temporary transfers, LACNIC shall restore this information to its original values (the values prior to the transfer) on the transaction’s end date.

2.3.2.18.8. Both the transferring and the receiving entities will be subject to the policies and membership terms and conditions of the corresponding RIR.

2.3.2.18.9. Addresses received as allocations or assignments from LACNIC, whether initial or additional, may not be transferred (in full or in part) for a period of three years as of their allocation or assignment date.

2.3.2.18.10. Legacy resources transferred into the LACNIC region will no longer be considered legacy resources.

2.3.2.18.11. Temporary transfers are subject to additional conditions that must be guaranteed by the agreement between both parties:
• The agreement must include clauses for revoking the transfer in case of misuse or abuse of the resources.
• The receiving entity must have an ASN to announce the resources.
• The receiving entity must have operational IPv6 at the time of announcing the transferred IPv4 resources.
• The receiving entity must have RPKI for the resources.
• The receiving entity must update the geolocation and IRR information.
• The receiving entity must comply with the best practices established by MANRS.

The entity originating the transfer is responsible for overseeing that these conditions are met. LACNIC may establish operational practices to ensure compliance.

If the originating entity fails to exercise due diligence, even with different temporary transfers or receiving entities, LACNIC may issue a warning. Ignoring such warning may result in the immediate revocation of the resources involved.

Additional information

As far as we know, only the RIPE NCC allows temporary transfers. At the same time, the RIPE NCC does not consider leasing, but does not explicitly prohibit the practice.

APNIC and AFRINIC do not consider leasing or temporary transfers.

ARIN does not consider temporary transfers, and leasing is not a valid justification of need. Once addresses are leased, no additional addresses may be requested. Additionally, certain blocks cannot be leased.

Timetable

-

References

-

Presented at:

LACNIC 41 (08/05/2024)

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