From info at arin.net Wed Feb 1 13:37:03 2012 From: info at arin.net (ARIN) Date: Wed, 01 Feb 2012 13:37:03 -0500 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> Message-ID: <4F29864F.8090603@arin.net> ARIN-prop-163 Dedicated resources for initial ISP allocations ARIN received the following policy proposal and is posting it to the Public Policy Mailing List (PPML) in accordance with the Policy Development Process. The ARIN Advisory Council (AC) will review the proposal at their next regularly scheduled meeting (if the period before the next regularly scheduled meeting is less than 10 days, then the period may be extended to the subsequent regularly scheduled meeting). The AC will decide how to utilize the proposal and announce the decision to the PPML. The AC invites everyone to comment on the proposal on the PPML, particularly their support or non-support and the reasoning behind their opinion. Such participation contributes to a thorough vetting and provides important guidance to the AC in their deliberations. Draft Policies and Proposals under discussion can be found at: https://www.arin.net/policy/proposals/index.html The ARIN Policy Development Process can be found at: https://www.arin.net/policy/pdp.html Mailing list subscription information can be found at: https://www.arin.net/mailing_lists/ Regards, Communications and Member Services American Registry for Internet Numbers (ARIN) ## * ## ARIN-prop-163 Dedicated resources for initial ISP allocations Proposal Originator: Joe Maimon Proposal Version: 1.0 Date: 1 February 2012 Proposal type: New Policy term: Temporary Policy statement: Add 4.2.2.4. Resources dedicated for initial ISP allocations. Prior to any allocation or assignment that will cause ARIN's total available, unreserved and non-dedicated resources to fall under a total of a /8, ARIN will first ensure that dedicated resources equivalent to a /10 are available from the remainder of the available resources. These resources are to be used solely for initial ISP allocations that cannot be fulfilled from any other available ARIN resources. 4.2.2.4.1 Restrictions ARIN may require qualifying organizations to demonstrate that they were not created solely to receive resources from these dedicated resources. 4.2.2.4.2 Replenishment ARIN will replenish the available dedicated resources, up to the total of a /10 of available resources, whenever there are sufficient available resources, with no more than 25% of the available resources going for this purpose. 4.2.2.4.3 Reporting ARIN will keep numbers and statistics available as to the total size of the dedicated resources, allocated and unallocated and to how many members allocations were made, available annually. 4.2.2.4.4 Retirement ARIN will retire this section whenever two full calendar years go by that no allocations are made from these resources, following their creation. Rationale: I believe it is important to ensure access to new entities to the IPv4 resources ARIN maintains stewardship over. Without a policy like this one, they are unlikely to have any alternative other then to use PA space or utilize transfers that may be prohibitively burdensome. I also believe it is important to ARIN to be an essential and relevant entity to the process of getting these new ISP's to their footing with IPv4 resources. ARIN informal numbers: Total first time IPv4 allocations to ISPs approved in 2011: 318 Total IPv4 space approved for: 2,812 /24s Total additional IPv4 allocations to ISPs in 2011: 497 ISP accounts received at least one additional IPv4 allocation. Total IPv4 space approved for: 70,569 /24s This suggests that maintaining resources for these new ISPs can ensure a steady influx of new members who would otherwise have much more limited options, and that a /10 can provide an estimated 4 years of access to these resources. This same /10 would last for additional allocations less than a year. Timetable for implementation: Before ARIN has less than a /8 in its free pool. From info at arin.net Wed Feb 1 13:37:57 2012 From: info at arin.net (ARIN) Date: Wed, 01 Feb 2012 13:37:57 -0500 Subject: [arin-ppml] ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion In-Reply-To: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> Message-ID: <4F298685.8050603@arin.net> ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion ARIN received the following policy proposal and is posting it to the Public Policy Mailing List (PPML) in accordance with the Policy Development Process. The ARIN Advisory Council (AC) will review the proposal at their next regularly scheduled meeting (if the period before the next regularly scheduled meeting is less than 10 days, then the period may be extended to the subsequent regularly scheduled meeting). The AC will decide how to utilize the proposal and announce the decision to the PPML. The AC invites everyone to comment on the proposal on the PPML, particularly their support or non-support and the reasoning behind their opinion. Such participation contributes to a thorough vetting and provides important guidance to the AC in their deliberations. Draft Policies and Proposals under discussion can be found at: https://www.arin.net/policy/proposals/index.html The ARIN Policy Development Process can be found at: https://www.arin.net/policy/pdp.html Mailing list subscription information can be found at: https://www.arin.net/mailing_lists/ Regards, Communications and Member Services American Registry for Internet Numbers (ARIN) ## * ## ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion Proposal Originator: Joe Maimon Proposal Version: 1.0 Date: 1 February 2012 Proposal type: New Policy term: Temporary Policy statement: Add a section to 4 Upon the last calendar date of the year that this proposal is adopted, ARIN will disburse all of its available IPv4 resources to its existing members, in proportion to their fee schedule, with the smallest allocation of size /24, to be effective immediately. Rationale: Many people feel that ARIN has too much available resources. Many people also believe that the uncertainty as to when ARIN will run out of these resources is not good. This proposal seeks to resolve both of these concerns. Timetable for implementation: Immediate From scottleibrand at gmail.com Wed Feb 1 15:04:12 2012 From: scottleibrand at gmail.com (Scott Leibrand) Date: Wed, 1 Feb 2012 12:04:12 -0800 Subject: [arin-ppml] ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion In-Reply-To: <4F298685.8050603@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F298685.8050603@arin.net> Message-ID: Opposed. Giving addresses to organizations that don't need them is not good stewardship. -Scott On Wed, Feb 1, 2012 at 10:37 AM, ARIN wrote: > ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion > > ARIN received the following policy proposal and is posting it to the > Public Policy Mailing List (PPML) in accordance with the Policy > Development Process. > > The ARIN Advisory Council (AC) will review the proposal at their next > regularly scheduled meeting (if the period before the next regularly > scheduled meeting is less than 10 days, then the period may be extended > to the subsequent regularly scheduled meeting). The AC will decide how > to utilize the proposal and announce the decision to the PPML. > > The AC invites everyone to comment on the proposal on the PPML, > particularly their support or non-support and the reasoning > behind their opinion. Such participation contributes to a thorough > vetting and provides important guidance to the AC in their deliberations. > > Draft Policies and Proposals under discussion can be found at: > https://www.arin.net/policy/proposals/index.html > > The ARIN Policy Development Process can be found at: > https://www.arin.net/policy/pdp.html > > Mailing list subscription information can be found > at: https://www.arin.net/mailing_lists/ > > Regards, > > Communications and Member Services > American Registry for Internet Numbers (ARIN) > > > ## * ## > > > ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion > > Proposal Originator: Joe Maimon > > Proposal Version: 1.0 > > Date: 1 February 2012 > > Proposal type: New > > Policy term: Temporary > > Policy statement: > > Add a section to 4 > > Upon the last calendar date of the year that this proposal is adopted, > ARIN will disburse all of its available IPv4 resources to its existing > members, in proportion to their fee schedule, with the smallest > allocation of size /24, to be effective immediately. > > Rationale: > > Many people feel that ARIN has too much available resources. Many people > also believe that the uncertainty as to when ARIN will run out of these > resources is not good. This proposal seeks to resolve both of these > concerns. > > Timetable for implementation: Immediate > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From jeffrey.lyon at blacklotus.net Wed Feb 1 15:20:54 2012 From: jeffrey.lyon at blacklotus.net (Jeffrey Lyon) Date: Wed, 1 Feb 2012 15:20:54 -0500 Subject: [arin-ppml] ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F298685.8050603@arin.net> Message-ID: Opposed. Even if this were a good idea, it presumes adoption of prop 163, otherwise no new applicants could ever be considered for IPv4 space. Jeff On Feb 1, 2012 3:04 PM, "Scott Leibrand" wrote: > Opposed. Giving addresses to organizations that don't need them is > not good stewardship. > > -Scott > > On Wed, Feb 1, 2012 at 10:37 AM, ARIN wrote: > > ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion > > > > ARIN received the following policy proposal and is posting it to the > > Public Policy Mailing List (PPML) in accordance with the Policy > > Development Process. > > > > The ARIN Advisory Council (AC) will review the proposal at their next > > regularly scheduled meeting (if the period before the next regularly > > scheduled meeting is less than 10 days, then the period may be extended > > to the subsequent regularly scheduled meeting). The AC will decide how > > to utilize the proposal and announce the decision to the PPML. > > > > The AC invites everyone to comment on the proposal on the PPML, > > particularly their support or non-support and the reasoning > > behind their opinion. Such participation contributes to a thorough > > vetting and provides important guidance to the AC in their deliberations. > > > > Draft Policies and Proposals under discussion can be found at: > > https://www.arin.net/policy/proposals/index.html > > > > The ARIN Policy Development Process can be found at: > > https://www.arin.net/policy/pdp.html > > > > Mailing list subscription information can be found > > at: https://www.arin.net/mailing_lists/ > > > > Regards, > > > > Communications and Member Services > > American Registry for Internet Numbers (ARIN) > > > > > > ## * ## > > > > > > ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion > > > > Proposal Originator: Joe Maimon > > > > Proposal Version: 1.0 > > > > Date: 1 February 2012 > > > > Proposal type: New > > > > Policy term: Temporary > > > > Policy statement: > > > > Add a section to 4 > > > > Upon the last calendar date of the year that this proposal is adopted, > > ARIN will disburse all of its available IPv4 resources to its existing > > members, in proportion to their fee schedule, with the smallest > > allocation of size /24, to be effective immediately. > > > > Rationale: > > > > Many people feel that ARIN has too much available resources. Many people > > also believe that the uncertainty as to when ARIN will run out of these > > resources is not good. This proposal seeks to resolve both of these > > concerns. > > > > Timetable for implementation: Immediate > > > > _______________________________________________ > > PPML > > You are receiving this message because you are subscribed to > > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > > Unsubscribe or manage your mailing list subscription at: > > http://lists.arin.net/mailman/listinfo/arin-ppml > > Please contact info at arin.net if you experience any issues. > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. > -------------- next part -------------- An HTML attachment was scrubbed... URL: From owen at delong.com Wed Feb 1 16:48:34 2012 From: owen at delong.com (Owen DeLong) Date: Wed, 1 Feb 2012 13:48:34 -0800 Subject: [arin-ppml] ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F298685.8050603@arin.net> Message-ID: +1 While I believe that the asymmetry of runout is causing problems and that there are additional problems of abuse related to the interactions between a free pool and a transfer market, this is a case where the proffered cure is worse than the disease. Owen On Feb 1, 2012, at 12:04 PM, Scott Leibrand wrote: > Opposed. Giving addresses to organizations that don't need them is > not good stewardship. > > -Scott > > On Wed, Feb 1, 2012 at 10:37 AM, ARIN wrote: >> ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion >> >> ARIN received the following policy proposal and is posting it to the >> Public Policy Mailing List (PPML) in accordance with the Policy >> Development Process. >> >> The ARIN Advisory Council (AC) will review the proposal at their next >> regularly scheduled meeting (if the period before the next regularly >> scheduled meeting is less than 10 days, then the period may be extended >> to the subsequent regularly scheduled meeting). The AC will decide how >> to utilize the proposal and announce the decision to the PPML. >> >> The AC invites everyone to comment on the proposal on the PPML, >> particularly their support or non-support and the reasoning >> behind their opinion. Such participation contributes to a thorough >> vetting and provides important guidance to the AC in their deliberations. >> >> Draft Policies and Proposals under discussion can be found at: >> https://www.arin.net/policy/proposals/index.html >> >> The ARIN Policy Development Process can be found at: >> https://www.arin.net/policy/pdp.html >> >> Mailing list subscription information can be found >> at: https://www.arin.net/mailing_lists/ >> >> Regards, >> >> Communications and Member Services >> American Registry for Internet Numbers (ARIN) >> >> >> ## * ## >> >> >> ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion >> >> Proposal Originator: Joe Maimon >> >> Proposal Version: 1.0 >> >> Date: 1 February 2012 >> >> Proposal type: New >> >> Policy term: Temporary >> >> Policy statement: >> >> Add a section to 4 >> >> Upon the last calendar date of the year that this proposal is adopted, >> ARIN will disburse all of its available IPv4 resources to its existing >> members, in proportion to their fee schedule, with the smallest >> allocation of size /24, to be effective immediately. >> >> Rationale: >> >> Many people feel that ARIN has too much available resources. Many people >> also believe that the uncertainty as to when ARIN will run out of these >> resources is not good. This proposal seeks to resolve both of these >> concerns. >> >> Timetable for implementation: Immediate >> >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From randy.whitney at verizon.com Wed Feb 1 16:51:56 2012 From: randy.whitney at verizon.com (Randy Whitney) Date: Wed, 01 Feb 2012 16:51:56 -0500 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: <4F29864F.8090603@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F29864F.8090603@arin.net> Message-ID: <4F29B3FC.1090106@verizon.com> I'm generally in support of this policy. Needs some work, IMO, but right now I do not have time to explore in more depth. -- Randy. On 2/1/2012 1:37 PM, ARIN wrote: > ARIN-prop-163 Dedicated resources for initial ISP allocations > > ARIN received the following policy proposal and is posting it to the > Public Policy Mailing List (PPML) in accordance with the Policy > Development Process. > > The ARIN Advisory Council (AC) will review the proposal at their next > regularly scheduled meeting (if the period before the next regularly > scheduled meeting is less than 10 days, then the period may be extended > to the subsequent regularly scheduled meeting). The AC will decide how > to utilize the proposal and announce the decision to the PPML. > > The AC invites everyone to comment on the proposal on the PPML, > particularly their support or non-support and the reasoning > behind their opinion. Such participation contributes to a thorough > vetting and provides important guidance to the AC in their deliberations. > > Draft Policies and Proposals under discussion can be found at: > https://www.arin.net/policy/proposals/index.html > > The ARIN Policy Development Process can be found at: > https://www.arin.net/policy/pdp.html > > Mailing list subscription information can be found > at: https://www.arin.net/mailing_lists/ > > Regards, > > Communications and Member Services > American Registry for Internet Numbers (ARIN) > > > ## * ## > > > ARIN-prop-163 Dedicated resources for initial ISP allocations > > Proposal Originator: Joe Maimon > > Proposal Version: 1.0 > > Date: 1 February 2012 > > Proposal type: New > > Policy term: Temporary > > Policy statement: > > Add > > 4.2.2.4. Resources dedicated for initial ISP allocations. > > Prior to any allocation or assignment that will cause ARIN's total > available, unreserved and non-dedicated resources to fall under a total > of a /8, ARIN will first ensure that dedicated resources equivalent to a > /10 are available from the remainder of the available resources. These > resources are to be used solely for initial ISP allocations that cannot > be fulfilled from any other available ARIN resources. > > 4.2.2.4.1 Restrictions > > ARIN may require qualifying organizations to demonstrate that they were > not created solely to receive resources from these dedicated resources. > > 4.2.2.4.2 Replenishment > > ARIN will replenish the available dedicated resources, up to the total > of a /10 of available resources, whenever there are sufficient available > resources, with no more than 25% of the available resources going for > this purpose. > > 4.2.2.4.3 Reporting > > ARIN will keep numbers and statistics available as to the total size of > the dedicated resources, allocated and unallocated and to how many > members allocations were made, available annually. > > 4.2.2.4.4 Retirement > > ARIN will retire this section whenever two full calendar years go by > that no allocations are made from these resources, following their creation. > > Rationale: > > I believe it is important to ensure access to new entities to the IPv4 > resources ARIN maintains stewardship over. Without a policy like this > one, they are unlikely to have any alternative other then to use PA > space or utilize transfers that may be prohibitively burdensome. > > I also believe it is important to ARIN to be an essential and relevant > entity to the process of getting these new ISP's to their footing with > IPv4 resources. > > ARIN informal numbers: > > Total first time IPv4 allocations to ISPs approved in 2011: 318 > Total IPv4 space approved for: 2,812 /24s > > Total additional IPv4 allocations to ISPs in 2011: 497 ISP accounts > received at least one additional IPv4 allocation. > Total IPv4 space approved for: 70,569 /24s > > This suggests that maintaining resources for these new ISPs can ensure a > steady influx of new members who would otherwise have much more limited > options, and that a /10 can provide an estimated 4 years of access to > these resources. > > This same /10 would last for additional allocations less than a year. > > Timetable for implementation: Before ARIN has less than a /8 in > its free pool. > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From randy.whitney at verizon.com Wed Feb 1 16:48:34 2012 From: randy.whitney at verizon.com (Randy Whitney) Date: Wed, 01 Feb 2012 16:48:34 -0500 Subject: [arin-ppml] ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion In-Reply-To: <4F298685.8050603@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F298685.8050603@arin.net> Message-ID: <4F29B332.7030900@verizon.com> Opposed. To me seems like it is stating that we'd rather give away space to ARIN region orgs regardless of current state, HD ratio of existing resources, want, or justified need than risk having these resources transferred out of the region (should we ever agree on a transfers policy!), where there *is* real need. Place in the In-sink-erator and flip the switch. -- Randy. On 2/1/2012 1:37 PM, ARIN wrote: > ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion > > ARIN received the following policy proposal and is posting it to the > Public Policy Mailing List (PPML) in accordance with the Policy > Development Process. > > The ARIN Advisory Council (AC) will review the proposal at their next > regularly scheduled meeting (if the period before the next regularly > scheduled meeting is less than 10 days, then the period may be extended > to the subsequent regularly scheduled meeting). The AC will decide how > to utilize the proposal and announce the decision to the PPML. > > The AC invites everyone to comment on the proposal on the PPML, > particularly their support or non-support and the reasoning > behind their opinion. Such participation contributes to a thorough > vetting and provides important guidance to the AC in their deliberations. > > Draft Policies and Proposals under discussion can be found at: > https://www.arin.net/policy/proposals/index.html > > The ARIN Policy Development Process can be found at: > https://www.arin.net/policy/pdp.html > > Mailing list subscription information can be found > at: https://www.arin.net/mailing_lists/ > > Regards, > > Communications and Member Services > American Registry for Internet Numbers (ARIN) > > > ## * ## > > > ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion > > Proposal Originator: Joe Maimon > > Proposal Version: 1.0 > > Date: 1 February 2012 > > Proposal type: New > > Policy term: Temporary > > Policy statement: > > Add a section to 4 > > Upon the last calendar date of the year that this proposal is adopted, > ARIN will disburse all of its available IPv4 resources to its existing > members, in proportion to their fee schedule, with the smallest > allocation of size /24, to be effective immediately. > > Rationale: > > Many people feel that ARIN has too much available resources. Many people > also believe that the uncertainty as to when ARIN will run out of these > resources is not good. This proposal seeks to resolve both of these > concerns. > > Timetable for implementation: Immediate > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From hannigan at gmail.com Wed Feb 1 17:12:08 2012 From: hannigan at gmail.com (Martin Hannigan) Date: Wed, 1 Feb 2012 17:12:08 -0500 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: <4F29B3FC.1090106@verizon.com> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F29864F.8090603@arin.net> <4F29B3FC.1090106@verizon.com> Message-ID: I'm interested in this, but shy of support for now. Also, If this were to go into the AC masher, it would be torn apart for multiple cycles and probably be too late for any good by the time that it was able to be useful. Less text if possible would be very helpful. I think it's possible. This is primarily a discussion about redistribution of cost, not necessarily new entrants. Using the authors and ARIN's address breakdown, each entrant averages needing a /21. At roughly $20 an address currently and perhaps for as long as such a /10 might last, you're looking at ramping into a $45K expense. Once could argue that if a business could justify a /21 that they should be able to justify the financing of the same. Providing equal access to new entrants and others alike would seem to present a level playing field. It's not like exhaustion was a forethought of design that was intended to create a scenario where an end game may preclude some. I'm not 100% sure that I see the value in creating inequality for a special class. More discussion needed. Best, -M< On Wed, Feb 1, 2012 at 4:51 PM, Randy Whitney wrote: > I'm generally in support of this policy. Needs some work, IMO, but right > now I do not have time to explore in more depth. > -- > Randy. > > > On 2/1/2012 1:37 PM, ARIN wrote: >> >> ARIN-prop-163 Dedicated resources for initial ISP allocations >> >> ARIN received the following policy proposal and is posting it to the >> Public Policy Mailing List (PPML) in accordance with the Policy >> Development Process. >> >> The ARIN Advisory Council (AC) will review the proposal at their next >> regularly scheduled meeting (if the period before the next regularly >> scheduled meeting is less than 10 days, then the period may be extended >> to the subsequent regularly scheduled meeting). The AC will decide how >> to utilize the proposal and announce the decision to the PPML. >> >> The AC invites everyone to comment on the proposal on the PPML, >> particularly their support or non-support and the reasoning >> behind their opinion. Such participation contributes to a thorough >> vetting and provides important guidance to the AC in their deliberations. >> >> Draft Policies and Proposals under discussion can be found at: >> https://www.arin.net/policy/proposals/index.html >> >> The ARIN Policy Development Process can be found at: >> https://www.arin.net/policy/pdp.html >> >> Mailing list subscription information can be found >> at: https://www.arin.net/mailing_lists/ >> >> Regards, >> >> Communications and Member Services >> American Registry for Internet Numbers (ARIN) >> >> >> ## * ## >> >> >> ARIN-prop-163 Dedicated resources for initial ISP allocations >> >> Proposal Originator: Joe Maimon >> >> Proposal Version: 1.0 >> >> Date: 1 February 2012 >> >> Proposal type: New >> >> Policy term: Temporary >> >> Policy statement: >> >> Add >> >> 4.2.2.4. Resources dedicated for initial ISP allocations. >> >> Prior to any allocation or assignment that will cause ARIN's total >> available, unreserved and non-dedicated resources to fall under a total >> of a /8, ARIN will first ensure that dedicated resources equivalent to a >> /10 are available from the remainder of the available resources. These >> resources are to be used solely for initial ISP allocations that cannot >> be fulfilled from any other available ARIN resources. >> >> 4.2.2.4.1 Restrictions >> >> ARIN may require qualifying organizations to demonstrate that they were >> not created solely to receive resources from these dedicated resources. >> >> 4.2.2.4.2 Replenishment >> >> ARIN will replenish the available dedicated resources, up to the total >> of a /10 of available resources, whenever there are sufficient available >> resources, with no more than 25% of the available resources going for >> this purpose. >> >> 4.2.2.4.3 Reporting >> >> ARIN will keep numbers and statistics available as to the total size of >> the dedicated resources, allocated and unallocated and to how many >> members allocations were made, available annually. >> >> 4.2.2.4.4 Retirement >> >> ARIN will retire this section whenever two full calendar years go by >> that no allocations are made from these resources, following their >> creation. >> >> Rationale: >> >> I believe it is important to ensure access to new entities to the IPv4 >> resources ARIN maintains stewardship over. Without a policy like this >> one, they are unlikely to have any alternative other then to use PA >> space or utilize transfers that may be prohibitively burdensome. >> >> I also believe it is important to ARIN to be an essential and relevant >> entity to the process of getting these new ISP's to their footing with >> IPv4 resources. >> >> ARIN informal numbers: >> >> Total first time IPv4 allocations to ISPs approved in 2011: ?318 >> Total IPv4 space approved for: ? ? 2,812 /24s >> >> Total additional IPv4 allocations to ISPs in 2011: ?497 ISP accounts >> received at least one additional IPv4 allocation. >> Total IPv4 space approved for: ? 70,569 /24s >> >> This suggests that maintaining resources for these new ISPs can ensure a >> steady influx of new members who would otherwise have much more limited >> options, and that a /10 can provide an estimated 4 years of access to >> these resources. >> >> This same /10 would last for additional allocations less than a year. >> >> Timetable for implementation: Before ARIN has less than a /8 in >> its free pool. >> >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. > > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From jmaimon at chl.com Wed Feb 1 20:00:23 2012 From: jmaimon at chl.com (Joe Maimon) Date: Wed, 01 Feb 2012 20:00:23 -0500 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F29864F.8090603@arin.net> <4F29B3FC.1090106@verizon.com> Message-ID: <4F29E027.6080109@chl.com> Martin Hannigan wrote: > I'm interested in this, but shy of support for now. Also, If this were > to go into the AC masher, it would be torn apart for multiple cycles > and probably be too late for any good by the time that it was able to > be useful. Less text if possible would be very helpful. I think it's > possible. Well, that would really depend on the fate of the three month window. > Best, > > -M< > From jmaimon at chl.com Wed Feb 1 20:01:52 2012 From: jmaimon at chl.com (Joe Maimon) Date: Wed, 01 Feb 2012 20:01:52 -0500 Subject: [arin-ppml] ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F298685.8050603@arin.net> Message-ID: <4F29E080.3040401@chl.com> Scott Leibrand wrote: > Opposed. Giving addresses to organizations that don't need them is > not good stewardship. > > -Scott > Thats what the transfer market is for. Joe From jmaimon at chl.com Wed Feb 1 20:02:52 2012 From: jmaimon at chl.com (Joe Maimon) Date: Wed, 01 Feb 2012 20:02:52 -0500 Subject: [arin-ppml] ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F298685.8050603@arin.net> Message-ID: <4F29E0BC.6090901@chl.com> Jeffrey Lyon wrote: > Opposed. Even if this were a good idea, it presumes adoption of prop > 163, otherwise no new applicants could ever be considered for IPv4 space. > > Jeff If the three month window is rescinded, that will be the case in a matter of months, regardless. Joe From jmaimon at chl.com Wed Feb 1 20:07:51 2012 From: jmaimon at chl.com (Joe Maimon) Date: Wed, 01 Feb 2012 20:07:51 -0500 Subject: [arin-ppml] ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F298685.8050603@arin.net> Message-ID: <4F29E1E7.6020705@chl.com> Owen DeLong wrote: > +1 > > While I believe that the asymmetry of runout is causing problems and that > there are additional problems of abuse related to the interactions between > a free pool and a transfer market, this is a case where the proffered cure > is worse than the disease. > > Owen > Owen, I am crushed. This was supposed to be the proposal you should have written. The point of this proposal is that if we are considering reverting to 12 month allocation window, the ARIN free pool wont last a year, and only in light of that eventuality does this proposal's appeal start to shine forth. Best, Joe From jmaimon at chl.com Wed Feb 1 20:28:45 2012 From: jmaimon at chl.com (Joe Maimon) Date: Wed, 01 Feb 2012 20:28:45 -0500 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: <4F29B3FC.1090106@verizon.com> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F29864F.8090603@arin.net> <4F29B3FC.1090106@verizon.com> Message-ID: <4F29E6CD.5090308@chl.com> Randy Whitney wrote: > I'm generally in support of this policy. Needs some work, IMO, but right > now I do not have time to explore in more depth. > -- > Randy. Randy, Thank you for your support. The policy proposal was written and submitted quickly, and has only today arrived off the hopper. In my defense, I did have the experience of writing a somewhat more complete proposal, so this one flowed fairly quickly. I welcome any feedback, positive or negative. Best, Joe From gary.buhrmaster at gmail.com Wed Feb 1 20:51:44 2012 From: gary.buhrmaster at gmail.com (Gary Buhrmaster) Date: Thu, 2 Feb 2012 01:51:44 +0000 Subject: [arin-ppml] ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion In-Reply-To: <4F298685.8050603@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F298685.8050603@arin.net> Message-ID: On Wed, Feb 1, 2012 at 18:37, ARIN wrote: > ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion Opposed. This reminds me of ARIN-prop-129. The same discussion seems to apply. From hannigan at gmail.com Wed Feb 1 22:19:31 2012 From: hannigan at gmail.com (Martin Hannigan) Date: Wed, 1 Feb 2012 22:19:31 -0500 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: <4F29E027.6080109@chl.com> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F29864F.8090603@arin.net> <4F29B3FC.1090106@verizon.com> <4F29E027.6080109@chl.com> Message-ID: On Wed, Feb 1, 2012 at 8:00 PM, Joe Maimon wrote: > > > Martin Hannigan wrote: >> >> I'm interested in this, but shy of support for now. Also, If this were >> to go into the AC masher, it would be torn apart for multiple cycles >> and probably be too late for any good by the time that it was able to >> be useful. Less text if possible would be very helpful. I think it's >> possible. > > > > Well, that would really depend on the fate of the three month window. > > They're not connected at all. I'm on the inside of the masher and I can tell you that the more text that you provide, the more that people will want to "help". Speaking as an AC member, I'm happy to help you condense this and to help you reduce the opportunity to grind it into oblivion. Best, -M< From jmaimon at chl.com Wed Feb 1 23:20:57 2012 From: jmaimon at chl.com (Joe Maimon) Date: Wed, 01 Feb 2012 23:20:57 -0500 Subject: [arin-ppml] ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F298685.8050603@arin.net> Message-ID: <4F2A0F29.3080502@chl.com> Gary Buhrmaster wrote: > On Wed, Feb 1, 2012 at 18:37, ARIN wrote: >> ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion > > Opposed. > > This reminds me of ARIN-prop-129. The same > discussion seems to apply. This proposal is vastly better then that one at getting rid of all unused ARIN IPv4. Plus, it does it predictably. I felt certain that there would be many more supporters of the concept. Joe From jmaimon at chl.com Wed Feb 1 23:35:18 2012 From: jmaimon at chl.com (Joe Maimon) Date: Wed, 01 Feb 2012 23:35:18 -0500 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F29864F.8090603@arin.net> <4F29B3FC.1090106@verizon.com> <4F29E027.6080109@chl.com> Message-ID: <4F2A1286.1090809@chl.com> Martin Hannigan wrote: > On Wed, Feb 1, 2012 at 8:00 PM, Joe Maimon wrote: >> >> Well, that would really depend on the fate of the three month window. >> >> > > They're not connected at all. I'm on the inside of the masher and I > can tell you that the more text that you provide, the more that people > will want to "help". Speaking as an AC member, I'm happy to help you > condense this and to help you reduce the opportunity to grind it into > oblivion. > > Best, > > -M< > The time this proposal remains relevant depends very much on the three month window staying in effect. Joe From hannigan at gmail.com Thu Feb 2 00:00:38 2012 From: hannigan at gmail.com (Martin Hannigan) Date: Thu, 2 Feb 2012 00:00:38 -0500 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: <4F2A1286.1090809@chl.com> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F29864F.8090603@arin.net> <4F29B3FC.1090106@verizon.com> <4F29E027.6080109@chl.com> <4F2A1286.1090809@chl.com> Message-ID: Support. Needs more discussion, but shouldn't be dropped. On Wednesday, February 1, 2012, Joe Maimon wrote: > > > Martin Hannigan wrote: >> >> On Wed, Feb 1, 2012 at 8:00 PM, Joe Maimon wrote: >>> >>> Well, that would really depend on the fate of the three month window. >>> >>> >> >> They're not connected at all. I'm on the inside of the masher and I >> can tell you that the more text that you provide, the more that people >> will want to "help". Speaking as an AC member, I'm happy to help you >> condense this and to help you reduce the opportunity to grind it into >> oblivion. >> >> Best, >> >> -M< >> > > The time this proposal remains relevant depends very much on the three month window staying in effect. > > > > Joe > > > -- Sent via a mobile device -------------- next part -------------- An HTML attachment was scrubbed... URL: From jeffrey.lyon at blacklotus.net Thu Feb 2 05:19:09 2012 From: jeffrey.lyon at blacklotus.net (Jeffrey Lyon) Date: Thu, 2 Feb 2012 05:19:09 -0500 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F29864F.8090603@arin.net> <4F29B3FC.1090106@verizon.com> <4F29E027.6080109@chl.com> <4F2A1286.1090809@chl.com> Message-ID: On Thu, Feb 2, 2012 at 12:00 AM, Martin Hannigan wrote: > > > Support. Needs more discussion, but shouldn't be dropped. > > On Wednesday, February 1, 2012, Joe Maimon wrote: >> >> >> Martin Hannigan wrote: >>> >>> On Wed, Feb 1, 2012 at 8:00 PM, Joe Maimon ?wrote: >>>> >>>> Well, that would really depend on the fate of the three month window. >>>> >>>> >>> >>> They're not connected at all. I'm on the inside of the masher and I >>> can tell you that the more text that you provide, the more that people >>> will want to "help". Speaking as an AC member, ?I'm happy to help you >>> condense this and to help you reduce the opportunity to grind it into >>> oblivion. >>> >>> Best, >>> >>> -M< >>> >> >> The time this proposal remains relevant depends very much on the three >> month window staying in effect. >> >> >> >> Joe >> >> >> > > -- > Sent via a mobile device > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. I may be inclined to support, but really the free pool should be further restricted. Companies with the financial resources should be encouraged to use the transfer market. New applicants who are also small businesses, non-profit, etc. should be given priority on the free pool. This could go many ways, but I wanted to at least open it up for discussion. Thanks, -- Jeffrey Lyon, Leadership Team jeffrey.lyon at blacklotus.net | http://www.blacklotus.net Black Lotus Communications - AS32421 First and Leading in DDoS Protection Solutions From jeffrey.lyon at blacklotus.net Thu Feb 2 05:24:50 2012 From: jeffrey.lyon at blacklotus.net (Jeffrey Lyon) Date: Thu, 2 Feb 2012 05:24:50 -0500 Subject: [arin-ppml] ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion In-Reply-To: <4F2A0F29.3080502@chl.com> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F298685.8050603@arin.net> <4F2A0F29.3080502@chl.com> Message-ID: On Wed, Feb 1, 2012 at 11:20 PM, Joe Maimon wrote: > > > Gary Buhrmaster wrote: >> >> On Wed, Feb 1, 2012 at 18:37, ARIN ?wrote: >>> >>> ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion >> >> >> Opposed. >> >> This reminds me of ARIN-prop-129. ?The same >> discussion seems to apply. > > > This proposal is vastly better then that one at getting rid of all unused > ARIN IPv4. > > Plus, it does it predictably. > > I felt certain that there would be many more supporters of the concept. > > > Joe > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. Joe, I must disagree that IPv4 needs to be cannibalized. Encourage IPv6 adoption, and this will happen as IPv4 becomes naturally more scarce and vendors ramp up support for v6. -- Jeffrey Lyon, Leadership Team jeffrey.lyon at blacklotus.net | http://www.blacklotus.net Black Lotus Communications - AS32421 First and Leading in DDoS Protection Solutions From wesley.george at twcable.com Thu Feb 2 13:01:41 2012 From: wesley.george at twcable.com (George, Wes) Date: Thu, 2 Feb 2012 13:01:41 -0500 Subject: [arin-ppml] ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F298685.8050603@arin.net> Message-ID: Opposed. +1 to the below. Thanks, Wes > -----Original Message----- > From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf > Of Scott Leibrand > Sent: Wednesday, February 01, 2012 3:04 PM > To: ARIN-PPML List > Subject: Re: [arin-ppml] ARIN-prop-164 Predictable ARIN IPv4 Resource > exhaustion > > Opposed. Giving addresses to organizations that don't need them is > not good stewardship. > > -Scott > > On Wed, Feb 1, 2012 at 10:37 AM, ARIN wrote: > > ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion > > > > ARIN received the following policy proposal and is posting it to the > > Public Policy Mailing List (PPML) in accordance with the Policy > > Development Process. > > > > The ARIN Advisory Council (AC) will review the proposal at their next > > regularly scheduled meeting (if the period before the next regularly > > scheduled meeting is less than 10 days, then the period may be extended > > to the subsequent regularly scheduled meeting). The AC will decide how > > to utilize the proposal and announce the decision to the PPML. > > > > The AC invites everyone to comment on the proposal on the PPML, > > particularly their support or non-support and the reasoning > > behind their opinion. Such participation contributes to a thorough > > vetting and provides important guidance to the AC in their deliberations. > > > > Draft Policies and Proposals under discussion can be found at: > > https://www.arin.net/policy/proposals/index.html > > > > The ARIN Policy Development Process can be found at: > > https://www.arin.net/policy/pdp.html > > > > Mailing list subscription information can be found > > at: https://www.arin.net/mailing_lists/ > > > > Regards, > > > > Communications and Member Services > > American Registry for Internet Numbers (ARIN) > > > > > > ## * ## > > > > > > ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion > > > > Proposal Originator: Joe Maimon > > > > Proposal Version: 1.0 > > > > Date: 1 February 2012 > > > > Proposal type: New > > > > Policy term: Temporary > > > > Policy statement: > > > > Add a section to 4 > > > > Upon the last calendar date of the year that this proposal is adopted, > > ARIN will disburse all of its available IPv4 resources to its existing > > members, in proportion to their fee schedule, with the smallest > > allocation of size /24, to be effective immediately. > > > > Rationale: > > > > Many people feel that ARIN has too much available resources. Many people > > also believe that the uncertainty as to when ARIN will run out of these > > resources is not good. This proposal seeks to resolve both of these > > concerns. > > > > Timetable for implementation: Immediate > > > > _______________________________________________ > > PPML > > You are receiving this message because you are subscribed to > > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > > Unsubscribe or manage your mailing list subscription at: > > http://lists.arin.net/mailman/listinfo/arin-ppml > > Please contact info at arin.net if you experience any issues. > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. 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From jmaimon at chl.com Thu Feb 2 15:47:29 2012 From: jmaimon at chl.com (Joe Maimon) Date: Thu, 02 Feb 2012 15:47:29 -0500 Subject: [arin-ppml] ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F298685.8050603@arin.net> Message-ID: <4F2AF661.1060508@chl.com> George, Wes wrote: > > Opposed. +1 to the below. > > Thanks, > > Wes > > >> -----Original Message----- >> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf >> Of Scott Leibrand >> Sent: Wednesday, February 01, 2012 3:04 PM >> To: ARIN-PPML List >> Subject: Re: [arin-ppml] ARIN-prop-164 Predictable ARIN IPv4 Resource >> exhaustion >> >> Opposed. Giving addresses to organizations that don't need them is >> not good stewardship. >> >> -Scott The probability that any ARIN member can justify space approaches one as we lengthen the justification period. So how long does it need to be before the vast majority of the recipients under this policy would have need of the space? I will go with 48. Whats your number? Best, Joe From jmaimon at chl.com Thu Feb 2 15:53:22 2012 From: jmaimon at chl.com (Joe Maimon) Date: Thu, 02 Feb 2012 15:53:22 -0500 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F29864F.8090603@arin.net> <4F29B3FC.1090106@verizon.com> <4F29E027.6080109@chl.com> <4F2A1286.1090809@chl.com> Message-ID: <4F2AF7C2.6050608@chl.com> Jeffrey Lyon wrote: > On Thu, Feb 2, 2012 at 12:00 AM, Martin Hannigan wrote: > I may be inclined to support, but really the free pool should be > further restricted. Companies with the financial resources should be > encouraged to use the transfer market. New applicants who are also > small businesses, non-profit, etc. should be given priority on the > free pool. This could go many ways, but I wanted to at least open it > up for discussion. > > Thanks, Jeff, I agree with you, but that turkey never got airborne when I last tried it. See http://lists.arin.net/pipermail/arin-ppml/2010-April/017321.html Perhaps you would have better luck -- jump in the water is fine! Best, Joe From jeffrey.lyon at blacklotus.net Thu Feb 2 15:55:54 2012 From: jeffrey.lyon at blacklotus.net (Jeffrey Lyon) Date: Thu, 2 Feb 2012 15:55:54 -0500 Subject: [arin-ppml] ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion In-Reply-To: <4F2AF661.1060508@chl.com> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F298685.8050603@arin.net> <4F2AF661.1060508@chl.com> Message-ID: On Feb 2, 2012 3:48 PM, "Joe Maimon" wrote: > > > > George, Wes wrote: >> >> >> Opposed. +1 to the below. >> >> Thanks, >> >> Wes >> >> >>> -----Original Message----- >>> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf >>> Of Scott Leibrand >>> Sent: Wednesday, February 01, 2012 3:04 PM >>> To: ARIN-PPML List >>> Subject: Re: [arin-ppml] ARIN-prop-164 Predictable ARIN IPv4 Resource >>> exhaustion >>> >>> Opposed. Giving addresses to organizations that don't need them is >>> not good stewardship. >>> >>> -Scott > > > > The probability that any ARIN member can justify space approaches one as we lengthen the justification period. > > So how long does it need to be before the vast majority of the recipients under this policy would have need of the space? > > I will go with 48. > > Whats your number? > > Best, > > Joe > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. Joe, Are you actively trying to kill the free pool? For the record, I oppose any and all measures that would create this hazard. Jeff -------------- next part -------------- An HTML attachment was scrubbed... URL: From jmaimon at chl.com Thu Feb 2 16:03:20 2012 From: jmaimon at chl.com (Joe Maimon) Date: Thu, 02 Feb 2012 16:03:20 -0500 Subject: [arin-ppml] ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F298685.8050603@arin.net> <4F2A0F29.3080502@chl.com> Message-ID: <4F2AFA18.2010706@chl.com> Jeffrey Lyon wrote: > > Joe, > > I must disagree that IPv4 needs to be cannibalized. Encourage IPv6 > adoption, and this will happen as IPv4 becomes naturally more scarce > and vendors ramp up support for v6. Jeffrey, While I agree with you, however I view this proposals outcome as an improvement over an outcome that sees the free pool drained in the same manner and same speed as had been done prior to the three month policy taking effect. In both scenarios the free pool is likely gone in a matter of (6-18) months, not (2-4) years, as is currently (re)projected for ARIN. I had expected to garner support from those who have voiced opinions in that very fashion, that ipv4 must make way for ipv6, the sooner the better, even if they are not my own. I dont know why they have been so strangely silent at this turn. Is the proposal just too blatant? Best, Joe From jmaimon at chl.com Thu Feb 2 16:06:29 2012 From: jmaimon at chl.com (Joe Maimon) Date: Thu, 02 Feb 2012 16:06:29 -0500 Subject: [arin-ppml] ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F298685.8050603@arin.net> <4F2AF661.1060508@chl.com> Message-ID: <4F2AFAD5.1000903@chl.com> Jeffrey Lyon wrote: > > > Joe, > > Are you actively trying to kill the free pool? For the record, I > oppose any and all measures that would create this hazard. > > Jeff > What do you think prop 161 will do? My proposal is much more humane - and it fulfills the goals of 161 much more decisively and definitively. Joe From cgrundemann at gmail.com Thu Feb 2 16:09:08 2012 From: cgrundemann at gmail.com (Chris Grundemann) Date: Thu, 2 Feb 2012 14:09:08 -0700 Subject: [arin-ppml] If it ain't broke... [WAS: Re: ARIN-prop-163 Dedicated resources for initial ISP allocations] Message-ID: > Jeffrey Lyon wrote: >> I may be inclined to support, but really the free pool should be >> further restricted. Companies with the financial resources should be >> encouraged to use the transfer market. New applicants who are also >> small businesses, non-profit, etc. should be given priority on the >> free pool. This could go many ways, but I wanted to at least open it >> up for discussion. Joe Maimon wrote: > Jeff, > I agree with you, but that turkey never got airborne when I last tried it. > See > http://lists.arin.net/pipermail/arin-ppml/2010-April/017321.html > Perhaps you would have better luck -- jump in the water is fine! Another angle to consider in this debate is that the current state of affairs is already conducive to this precise behavior. Currently we have a three month window for allocations from the free pool and a soon to be 24 month window for transfers. This disparity creates the encouragement and thus priority that Jeffrey calls for. I say this because the 3-month window creates an administrative burden and a limited planning horizon, thus encouraging folks to look elsewhere for addresses. Companies with large enough networks are finding new ways to optimize their internal usage to free up addresses for use, rather than return to the free pool. Other companies with large enough bank accounts are starting to turn to the transfer market, where they can "dip" less often; creating lower administrative overhead and a better planning horizon (24 months vs. 3). The net affect seems to be that larger, more established players are going elsewhere, leaving the free pool available for smaller and newer players. The difference in allocation windows actually creates a free pool reserve, quite on accident, but effective none the less. Something to consider. Cheers, ~Chris > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. -- @ChrisGrundemann weblog.chrisgrundemann.com www.burningwiththebush.com www.theIPv6experts.net www.coisoc.org From jeffrey.lyon at blacklotus.net Thu Feb 2 16:18:07 2012 From: jeffrey.lyon at blacklotus.net (Jeffrey Lyon) Date: Thu, 2 Feb 2012 16:18:07 -0500 Subject: [arin-ppml] If it ain't broke... [WAS: Re: ARIN-prop-163 Dedicated resources for initial ISP allocations] In-Reply-To: References: Message-ID: On Thu, Feb 2, 2012 at 4:09 PM, Chris Grundemann wrote: >> Jeffrey Lyon wrote: >>> I may be inclined to support, but really the free pool should be >>> further restricted. Companies with the financial resources should be >>> encouraged to use the transfer market. New applicants who are also >>> small businesses, non-profit, etc. should be given priority on the >>> free pool. This could go many ways, but I wanted to at least open it >>> up for discussion. > > Joe Maimon wrote: >> Jeff, >> I agree with you, but that turkey never got airborne when I last tried it. >> See >> http://lists.arin.net/pipermail/arin-ppml/2010-April/017321.html >> Perhaps you would have better luck -- jump in the water is fine! > > Another angle to consider in this debate is that the current state of > affairs is already conducive to this precise behavior. > > Currently we have a three month window for allocations from the free > pool and a soon to be 24 month window for transfers. This disparity > creates the encouragement and thus priority that Jeffrey calls for. I > say this because the 3-month window creates an administrative burden > and a limited planning horizon, thus encouraging folks to look > elsewhere for addresses. Companies with large enough networks are > finding new ways to optimize their internal usage to free up addresses > for use, rather than return to the free pool. Other companies with > large enough bank accounts are starting to turn to the transfer > market, where they can "dip" less often; creating lower administrative > overhead and a better planning horizon (24 months vs. 3). The net > affect seems to be that larger, more established players are going > elsewhere, leaving the free pool available for smaller and newer > players. The difference in allocation windows actually creates a free > pool reserve, quite on accident, but effective none the less. > > Something to consider. > > Cheers, > ~Chris > > >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. > > > > -- > @ChrisGrundemann > weblog.chrisgrundemann.com > www.burningwiththebush.com > www.theIPv6experts.net > www.coisoc.org Chris, Personally, that's already how I do business. I would much rather have a 24 month supply, so will be waiting for full adoption of said policy and use the transfer market vs. free pool. -- Jeffrey Lyon, Leadership Team jeffrey.lyon at blacklotus.net | http://www.blacklotus.net Black Lotus Communications - AS32421 First and Leading in DDoS Protection Solutions From jmaimon at chl.com Thu Feb 2 17:16:37 2012 From: jmaimon at chl.com (Joe Maimon) Date: Thu, 02 Feb 2012 17:16:37 -0500 Subject: [arin-ppml] If it ain't broke... [WAS: Re: ARIN-prop-163 Dedicated resources for initial ISP allocations] In-Reply-To: References: Message-ID: <4F2B0B45.60005@chl.com> Chris Grundemann wrote: >> Jeffrey Lyon wrote: >>> I may be inclined to support, but really the free pool should be >>> further restricted. Companies with the financial resources should be >>> encouraged to use the transfer market. New applicants who are also >>> small businesses, non-profit, etc. should be given priority on the >>> free pool. This could go many ways, but I wanted to at least open it >>> up for discussion. > Joe Maimon wrote: >> Jeff, >> I agree with you, but that turkey never got airborne when I last tried it. >> See >> http://lists.arin.net/pipermail/arin-ppml/2010-April/017321.html >> Perhaps you would have better luck -- jump in the water is fine! > Another angle to consider in this debate is that the current state of > affairs is already conducive to this precise behavior. Chris, I brought this up in the recent discussion on prop 161 and prop 162, that the current behavior was actually working much better then expected even as some like myself may consider it to have still only been a mediocre effort and that more could have and possibly should still have been done. That is what I based my opposition to the proposals on. Joe > > Currently we have a three month window for allocations from the free > pool and a soon to be 24 month window for transfers. This disparity > creates the encouragement and thus priority that Jeffrey calls for. I > say this because the 3-month window creates an administrative burden > and a limited planning horizon, thus encouraging folks to look > elsewhere for addresses. Companies with large enough networks are > finding new ways to optimize their internal usage to free up addresses > for use, rather than return to the free pool. Other companies with > large enough bank accounts are starting to turn to the transfer > market, where they can "dip" less often; creating lower administrative > overhead and a better planning horizon (24 months vs. 3). The net > affect seems to be that larger, more established players are going > elsewhere, leaving the free pool available for smaller and newer > players. The difference in allocation windows actually creates a free > pool reserve, quite on accident, but effective none the less. > > Something to consider. > > Cheers, > ~Chris I agree that these effects exist and we have definitive evidence of the ARIN burn rate undergoing a considerable reformation, but I dont share your belief that all these benefits are securely and tangibly realized just by accident. I think something more secure and less ephemeral should be on the table and that is what this proposal is. Joe From michael+ppml at burnttofu.net Thu Feb 2 18:19:51 2012 From: michael+ppml at burnttofu.net (Michael Sinatra) Date: Thu, 02 Feb 2012 15:19:51 -0800 Subject: [arin-ppml] If it ain't broke... [WAS: Re: ARIN-prop-163 Dedicated resources for initial ISP allocations] In-Reply-To: References: Message-ID: <4F2B1A17.5040209@burnttofu.net> On 2/2/12 1:09 PM, Chris Grundemann wrote: >> Jeffrey Lyon wrote: >>> I may be inclined to support, but really the free pool should be >>> further restricted. Companies with the financial resources should be >>> encouraged to use the transfer market. New applicants who are also >>> small businesses, non-profit, etc. should be given priority on the >>> free pool. This could go many ways, but I wanted to at least open it >>> up for discussion. > > Joe Maimon wrote: >> Jeff, >> I agree with you, but that turkey never got airborne when I last tried it. >> See >> http://lists.arin.net/pipermail/arin-ppml/2010-April/017321.html >> Perhaps you would have better luck -- jump in the water is fine! > > Another angle to consider in this debate is that the current state of > affairs is already conducive to this precise behavior. > > Currently we have a three month window for allocations from the free > pool and a soon to be 24 month window for transfers. This disparity > creates the encouragement and thus priority that Jeffrey calls for. I > say this because the 3-month window creates an administrative burden > and a limited planning horizon, thus encouraging folks to look > elsewhere for addresses. Companies with large enough networks are > finding new ways to optimize their internal usage to free up addresses > for use, rather than return to the free pool. Other companies with > large enough bank accounts are starting to turn to the transfer > market, where they can "dip" less often; creating lower administrative > overhead and a better planning horizon (24 months vs. 3). The net > affect seems to be that larger, more established players are going > elsewhere, leaving the free pool available for smaller and newer > players. The difference in allocation windows actually creates a free > pool reserve, quite on accident, but effective none the less. > > Something to consider. Chris: You have managed to do a much better job of explaining the rationale behind the disparity between free-pool-protectionism and transfer-market-liberalization than has been done in this forum recently. I am still not sure I totally agree with it (for example, what does it do to middle-tier ISPs, as opposed to large/small ISPs or new entrants?), and I am still concerned that rather than a "soft landing" we will never actually land, but will instead get shot down by others. But I definitely appreciate the clear and generally-unbiased explanation of the rationale that you have given, as I also appreciate in-person discussions I have had with Mr. Farmer. Thanks to you both. michael From narten at us.ibm.com Fri Feb 3 00:53:02 2012 From: narten at us.ibm.com (Thomas Narten) Date: Fri, 03 Feb 2012 00:53:02 -0500 Subject: [arin-ppml] Weekly posting summary for ppml@arin.net Message-ID: <201202030553.q135r2EV008078@rotala.raleigh.ibm.com> Total of 65 messages in the last 7 days. script run at: Fri Feb 3 00:53:02 EST 2012 Messages | Bytes | Who --------+------+--------+----------+------------------------ 30.77% | 20 | 24.61% | 124516 | jmaimon at chl.com 9.23% | 6 | 11.82% | 59795 | owen at delong.com 9.23% | 6 | 11.30% | 57177 | hannigan at gmail.com 9.23% | 6 | 10.47% | 52972 | jeffrey.lyon at blacklotus.net 7.69% | 5 | 7.42% | 37554 | cgrundemann at gmail.com 7.69% | 5 | 7.08% | 35817 | info at arin.net 4.62% | 3 | 4.44% | 22449 | jcurran at arin.net 4.62% | 3 | 4.32% | 21852 | michael+ppml at burnttofu.net 3.08% | 2 | 3.50% | 17692 | randy.whitney at verizon.com 1.54% | 1 | 2.82% | 14290 | mysidia at gmail.com 1.54% | 1 | 2.03% | 10283 | farmer at umn.edu 1.54% | 1 | 1.81% | 9152 | wesley.george at twcable.com 1.54% | 1 | 1.71% | 8635 | cja at daydream.com 1.54% | 1 | 1.62% | 8187 | mike at nationwideinc.com 1.54% | 1 | 1.48% | 7503 | scottleibrand at gmail.com 1.54% | 1 | 1.33% | 6742 | narten at us.ibm.com 1.54% | 1 | 1.24% | 6265 | heather.skanks at gmail.com 1.54% | 1 | 1.01% | 5092 | gary.buhrmaster at gmail.com --------+------+--------+----------+------------------------ 100.00% | 65 |100.00% | 505973 | Total From info at arin.net Fri Feb 3 13:39:03 2012 From: info at arin.net (ARIN) Date: Fri, 03 Feb 2012 13:39:03 -0500 Subject: [arin-ppml] Petition for Discussion of ARIN-prop-160 In-Reply-To: <4F22C09B.802@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F22C09B.802@arin.net> Message-ID: <4F2C29C7.6060404@arin.net> > The duration of the petition is until five business days after the AC's > draft meeting minutes are published. ARIN staff will post the result of > the petition to PPML. The minutes of the AC's 20 January 2012 meeting have been published to the ARIN website at: https://www.arin.net/about_us/ac/index.html This petition will end on 10 February 2012. Regards, Communications and Member Services American Registry for Internet Numbers (ARIN) On 1/27/12 10:19 AM, ARIN wrote: > The message below started a petition regarding the ARIN Advisory > Council's decision to abandon ARIN-prop-160. The AC's decision was > posted by ARIN staff to PPML on 25 January 2012. > > If successful, this petition will change ARIN-prop-160 into a Draft > Policy which will be published for adoption discussion on the PPML and > at the Public Policy Meeting in April 2012. If the petition fails, the > proposal will be closed. > > For this petition to be successful, the petition needs statements of > support from at least 10 different people from 10 different > organizations. If you wish to support this petition, post a statement of > support to PPML on this thread. > > The duration of the petition is until five business days after the AC's > draft meeting minutes are published. ARIN staff will post the result of > the petition to PPML. > > For more information on starting and participating in petitions, see PDP > Petitions at: > https://www.arin.net/policy/pdp_petitions.html > > The proposal text is below and at: > https://www.arin.net/policy/proposals/index.html > > The ARIN Policy Development Process can be found at: > https://www.arin.net/policy/pdp.html > > Regards, > > Communications and Member Services > American Registry for Internet Numbers (ARIN) > > > ##### > > >> Petition for 160 please. >> >> >> On Wednesday, January 25, 2012, ARIN wrote: >>> In accordance with the ARIN Policy Development Process, the ARIN >>> Advisory Council (AC) held a meeting on 20 January 2012 and made >>> decisions about several draft policies and proposals. >>> >>> The AC recommended the following draft policies to the ARIN Board for >>> adoption: >>> >>> ARIN-2011-11: Clarify Justified Need for Transfers >>> ARIN-2011-12: Set Transfer Need to 24 months >>> >>> The following proposal was added to the AC's docket for development >>> and evaluation: >>> >>> ARIN-prop-161 Normalize Free pool and Transfer justification periods >>> >>> The AC abandoned the following proposal: >>> >>> ARIN-prop-160 Clarification of Section 4.2.3.4.1. Utilization >>> >>> Regarding proposal 160, the AC stated, "This proposal represented a >>> significant change to the justification requirements in 4.2.3.4.1 >>> for receiving PA space. The AC did not see significant support for >>> such a change on PPML, and felt the proposal was not justified at >>> this time." >>> >>> The AC thanks the authors and the community for their continuing effort >>> and contributions to these and all other policy considerations. >>> >>> The AC abandoned proposal 160. Anyone dissatisfied with this >>> decision may initiate a petition. The petition to advance this >>> proposal would be the "Discussion Petition." The deadline to begin a >>> petition will be five business days after the AC's draft meeting >>> minutes are published. For more information on starting and >>> participating in petitions, see PDP Petitions at: >>> https://www.arin.net/policy/pdp_petitions.html >>> >>> Draft Policy and Proposal texts are available at: >>> https://www.arin.net/policy/proposals/index.html >>> >>> The ARIN Policy Development Process can be found at: >>> https://www.arin.net/policy/pdp.html >>> >>> Regards, >>> >>> Communications and Member Services >>> American Registry for Internet Numbers (ARIN) >>> _______________________________________________ >>> PPML >>> You are receiving this message because you are subscribed to >>> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >>> Unsubscribe or manage your mailing list subscription at: >>> http://lists.arin.net/mailman/listinfo/arin-ppml >>> Please contact info at arin.net if you experience any issues. >>> >> >> -- >> Sent via a mobile device > > > ARIN-prop-160 Clarification of Section 4.2.3.4.1. Utilization > > Proposal Originator: Martin Hannigan > > Proposal Version: 1 > > Date: 22 DEC 2011 > > Proposal type: MODIFY > > Policy term: PERMANENT > > Policy statement: > > Change policy statement from: > > 4.2.3.4.1. Utilization > > Reassignment information for prior allocations must show that each > customer meets the 80% utilization criteria and must be available via > SWIP / RWhois prior to your issuing them additional space. > > To: > > 4.2.3.4.1. Utilization > > Reassignment information for prior allocations made from the same > ISP's inventory must show that each customer meets the 80% utilization > criteria and must be available via SWIP / RWhois prior to your issuing > them additional number resources. > > Rationale: > > Existing policy is vague. > > Timetable for implementation: Immediate > > From andrew.dul at quark.net Mon Feb 6 16:14:11 2012 From: andrew.dul at quark.net (Andrew Dul) Date: Mon, 06 Feb 2012 13:14:11 -0800 Subject: [arin-ppml] Nanog IPV4 Panel Discussion and 8.3 transfers Message-ID: <4F3042A3.5070202@quark.net> Nanog hosted a panel discussion this morning which included a number of different aspects of the transfer policy. I'd encourage people to review the video and/or transcript once it is published. http://www.nanog.org/meetings/nanog54/abstracts.php?pt=MTg5MiZuYW5vZzU0&nm=nanog54 One thing area of discussion that I thought was interesting and somewhat different than I expected is the following and that probably needs some discussion. Someone asked what happens if... Vendor A sells a /16 to Vendor B. Vendor B can justify a /20 under current policy. ARIN's response (channeling John Curran's response to this question) to this transfer would be to update the WHOIS to reflect that Vendor B now has a /20. This leaves a very uncomfortable situation of what happens to the rest of the /16. Does the remainder of the /16 become "unallocated" from a WHOIS perspective or does Vendor A still have some claim on it (e.g. the original /16 record remains)? Later can Vendor B come back to ARIN and say now I can justify a /18, please update my WHOIS record? From jcurran at arin.net Mon Feb 6 21:22:37 2012 From: jcurran at arin.net (John Curran) Date: Tue, 7 Feb 2012 02:22:37 +0000 Subject: [arin-ppml] Nanog IPV4 Panel Discussion and 8.3 transfers In-Reply-To: <4F3042A3.5070202@quark.net> References: <4F3042A3.5070202@quark.net> Message-ID: On Feb 6, 2012, at 4:14 PM, Andrew Dul wrote: > Vendor A sells a /16 to Vendor B. Vendor B can justify a /20 under > current policy. ARIN's response (channeling John Curran's response to > this question) to this transfer would be to update the WHOIS to reflect > that Vendor B now has a /20. To be very clear, the most likely course of events is as follows: Vendor B puts in a transfer request to ARIN for a /16 and it is denied because they only need a /20 under current policies. They reapply to transfer specific /20 from vendor A (which concurs) and that is approved and the registry is updated to reflect that the specific /20 is now held by Vendor B. > This leaves a very uncomfortable situation of what happens to the rest > of the /16. > > Does the remainder of the /16 become "unallocated" from a WHOIS > perspective or does Vendor A still have some claim on it (e.g. the > original /16 record remains)? The remainder of the /16 is remains registered to vendor A. > Later can Vendor B come back to ARIN and say now I can justify a /18, > please update my WHOIS record? Vendor B can certainly submit a second request at a later time; we would ask for concurrence from Vendor A before we processed the request. I hope this helps, /John John Curran President and CEO ARIN From farmer at umn.edu Wed Feb 8 21:25:53 2012 From: farmer at umn.edu (David Farmer) Date: Wed, 08 Feb 2012 20:25:53 -0600 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: <4F29864F.8090603@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F29864F.8090603@arin.net> Message-ID: <4F332EB1.8050000@umn.edu> I support the general concept of this proposal and would like to see it discussed in Vancouver. Furthermore, I think it is really important for this be discussed by the community before any policy to relax the current three-month window is implemented. On 2/1/12 12:37 CST, ARIN wrote: > ARIN-prop-163 Dedicated resources for initial ISP allocations > > Proposal Originator: Joe Maimon > > Proposal Version: 1.0 > > Date: 1 February 2012 > > Proposal type: New > > Policy term: Temporary > > Policy statement: > > Add > > 4.2.2.4. Resources dedicated for initial ISP allocations. > > Prior to any allocation or assignment that will cause ARIN's total > available, unreserved and non-dedicated resources to fall under a total > of a /8, ARIN will first ensure that dedicated resources equivalent to a > /10 are available from the remainder of the available resources. These > resources are to be used solely for initial ISP allocations that cannot > be fulfilled from any other available ARIN resources. > > 4.2.2.4.1 Restrictions > > ARIN may require qualifying organizations to demonstrate that they were > not created solely to receive resources from these dedicated resources. > > 4.2.2.4.2 Replenishment > > ARIN will replenish the available dedicated resources, up to the total > of a /10 of available resources, whenever there are sufficient available > resources, with no more than 25% of the available resources going for > this purpose. > > 4.2.2.4.3 Reporting > > ARIN will keep numbers and statistics available as to the total size of > the dedicated resources, allocated and unallocated and to how many > members allocations were made, available annually. > > 4.2.2.4.4 Retirement > > ARIN will retire this section whenever two full calendar years go by > that no allocations are made from these resources, following their > creation. > > Rationale: > > I believe it is important to ensure access to new entities to the IPv4 > resources ARIN maintains stewardship over. Without a policy like this > one, they are unlikely to have any alternative other then to use PA > space or utilize transfers that may be prohibitively burdensome. > > I also believe it is important to ARIN to be an essential and relevant > entity to the process of getting these new ISP's to their footing with > IPv4 resources. > > ARIN informal numbers: > > Total first time IPv4 allocations to ISPs approved in 2011: 318 > Total IPv4 space approved for: 2,812 /24s > > Total additional IPv4 allocations to ISPs in 2011: 497 ISP accounts > received at least one additional IPv4 allocation. > Total IPv4 space approved for: 70,569 /24s > > This suggests that maintaining resources for these new ISPs can ensure a > steady influx of new members who would otherwise have much more limited > options, and that a /10 can provide an estimated 4 years of access to > these resources. > > This same /10 would last for additional allocations less than a year. > > Timetable for implementation: Before ARIN has less than a /8 in > its free pool. > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. -- =============================================== David Farmer Email:farmer at umn.edu Networking & Telecommunication Services Office of Information Technology University of Minnesota 2218 University Ave SE Phone: 612-626-0815 Minneapolis, MN 55414-3029 Cell: 612-812-9952 =============================================== From hannigan at gmail.com Wed Feb 8 22:02:23 2012 From: hannigan at gmail.com (Martin Hannigan) Date: Wed, 8 Feb 2012 22:02:23 -0500 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: <4F332EB1.8050000@umn.edu> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F29864F.8090603@arin.net> <4F332EB1.8050000@umn.edu> Message-ID: Why is it important that it be discussed prior to deprecating the three month rule? On Wednesday, February 8, 2012, David Farmer wrote: > I support the general concept of this proposal and would like to see it discussed in Vancouver. Furthermore, I think it is really important for this be discussed by the community before any policy to relax the current three-month window is implemented. > > On 2/1/12 12:37 CST, ARIN wrote: > >> ARIN-prop-163 Dedicated resources for initial ISP allocations >> >> Proposal Originator: Joe Maimon >> >> Proposal Version: 1.0 >> >> Date: 1 February 2012 >> >> Proposal type: New >> >> Policy term: Temporary >> >> Policy statement: >> >> Add >> >> 4.2.2.4. Resources dedicated for initial ISP allocations. >> >> Prior to any allocation or assignment that will cause ARIN's total >> available, unreserved and non-dedicated resources to fall under a total >> of a /8, ARIN will first ensure that dedicated resources equivalent to a >> /10 are available from the remainder of the available resources. These >> resources are to be used solely for initial ISP allocations that cannot >> be fulfilled from any other available ARIN resources. >> >> 4.2.2.4.1 Restrictions >> >> ARIN may require qualifying organizations to demonstrate that they were >> not created solely to receive resources from these dedicated resources. >> >> 4.2.2.4.2 Replenishment >> >> ARIN will replenish the available dedicated resources, up to the total >> of a /10 of available resources, whenever there are sufficient available >> resources, with no more than 25% of the available resources going for >> this purpose. >> >> 4.2.2.4.3 Reporting >> >> ARIN will keep numbers and statistics available as to the total size of >> the dedicated resources, allocated and unallocated and to how many >> members allocations were made, available annually. >> >> 4.2.2.4.4 Retirement >> >> ARIN will retire this section whenever two full calendar years go by >> that no allocations are made from these resources, following their >> creation. >> >> Rationale: >> >> I believe it is important to ensure access to new entities to the IPv4 >> resources ARIN maintains stewardship over. Without a policy like this >> one, they are unlikely to have any alternative other then to use PA >> space or utilize transfers that may be prohibitively burdensome. >> >> I also believe it is important to ARIN to be an essential and relevant >> entity to the process of getting these new ISP's to their footing with >> IPv4 resources. >> >> ARIN informal numbers: >> >> Total first time IPv4 allocations to ISPs approved in 2011: 318 >> Total IPv4 space approved for: 2,812 /24s >> >> Total additional IPv4 allocations to ISPs in 2011: 497 ISP accounts >> received at least one additional IPv4 allocation. >> Total IPv4 space approved for: 70,569 /24s >> >> This suggests that maintaining resources for these new ISPs can ensure a >> steady influx of new members who would otherwise have much more limited >> options, and that a /10 can provide an estimated 4 years of access to >> these resources. >> >> This same /10 would last for additional allocations less than a year. >> >> Timetable for implementation: Before ARIN has less than a /8 in >> its free pool. >> >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. > > -- > =============================================== > David Farmer Email:farmer at umn.edu > Networking & Telecommunication Services > Office of Information Technology > University of Minnesota > 2218 University Ave SE Phone: 612-626-0815 > Minneapolis, MN 55414-3029 Cell: 612-812-9952 > =============================================== > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. > -- Sent via a mobile device -------------- next part -------------- An HTML attachment was scrubbed... URL: From farmer at umn.edu Wed Feb 8 22:20:37 2012 From: farmer at umn.edu (David Farmer) Date: Wed, 08 Feb 2012 21:20:37 -0600 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F29864F.8090603@arin.net> <4F332EB1.8050000@umn.edu> Message-ID: <4F333B85.5030106@umn.edu> On 2/8/12 21:02 CST, Martin Hannigan wrote: > Why is it important that it be discussed prior to deprecating the three > month rule? I prefer "redefining the soft landing trigger" or "resetting the trigger" to "deprecate the three month rule", because as proposed the three month rule wouldn't be deprecated, but the trigger reset for a new three-month rule to kick in when the free pool is down to /8. However, if we do that before discussing this issue it is possible that the free pool could be depleted down below /8 before this policy could be reasonably implemented. If we at least start the discussion at the same PPM as we start the discussion of resetting the trigger then I'm confident we could implement it if desired before we get down to a /8 I'm not saying we have to do this for me to support resetting the trigger. However, I feel resetting the trigger before at least starting a serious discussion of this is a little disingenuous. At least that is my opinion. > On Wednesday, February 8, 2012, David Farmer > wrote: > > I support the general concept of this proposal and would like to see > it discussed in Vancouver. Furthermore, I think it is really important > for this be discussed by the community before any policy to relax the > current three-month window is implemented. > > > > On 2/1/12 12:37 CST, ARIN wrote: > > > >> ARIN-prop-163 Dedicated resources for initial ISP allocations > >> > >> Proposal Originator: Joe Maimon > >> > >> Proposal Version: 1.0 > >> > >> Date: 1 February 2012 > >> > >> Proposal type: New > >> > >> Policy term: Temporary > >> > >> Policy statement: > >> > >> Add > >> > >> 4.2.2.4. Resources dedicated for initial ISP allocations. > >> > >> Prior to any allocation or assignment that will cause ARIN's total > >> available, unreserved and non-dedicated resources to fall under a total > >> of a /8, ARIN will first ensure that dedicated resources equivalent to a > >> /10 are available from the remainder of the available resources. These > >> resources are to be used solely for initial ISP allocations that cannot > >> be fulfilled from any other available ARIN resources. > >> > >> 4.2.2.4.1 Restrictions > >> > >> ARIN may require qualifying organizations to demonstrate that they were > >> not created solely to receive resources from these dedicated resources. > >> > >> 4.2.2.4.2 Replenishment > >> > >> ARIN will replenish the available dedicated resources, up to the total > >> of a /10 of available resources, whenever there are sufficient available > >> resources, with no more than 25% of the available resources going for > >> this purpose. > >> > >> 4.2.2.4.3 Reporting > >> > >> ARIN will keep numbers and statistics available as to the total size of > >> the dedicated resources, allocated and unallocated and to how many > >> members allocations were made, available annually. > >> > >> 4.2.2.4.4 Retirement > >> > >> ARIN will retire this section whenever two full calendar years go by > >> that no allocations are made from these resources, following their > >> creation. > >> > >> Rationale: > >> > >> I believe it is important to ensure access to new entities to the IPv4 > >> resources ARIN maintains stewardship over. Without a policy like this > >> one, they are unlikely to have any alternative other then to use PA > >> space or utilize transfers that may be prohibitively burdensome. > >> > >> I also believe it is important to ARIN to be an essential and relevant > >> entity to the process of getting these new ISP's to their footing with > >> IPv4 resources. > >> > >> ARIN informal numbers: > >> > >> Total first time IPv4 allocations to ISPs approved in 2011: 318 > >> Total IPv4 space approved for: 2,812 /24s > >> > >> Total additional IPv4 allocations to ISPs in 2011: 497 ISP accounts > >> received at least one additional IPv4 allocation. > >> Total IPv4 space approved for: 70,569 /24s > >> > >> This suggests that maintaining resources for these new ISPs can ensure a > >> steady influx of new members who would otherwise have much more limited > >> options, and that a /10 can provide an estimated 4 years of access to > >> these resources. > >> > >> This same /10 would last for additional allocations less than a year. > >> > >> Timetable for implementation: Before ARIN has less than a /8 in > >> its free pool. > >> > >> _______________________________________________ > >> PPML > >> You are receiving this message because you are subscribed to > >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net > ). > >> Unsubscribe or manage your mailing list subscription at: > >> http://lists.arin.net/mailman/listinfo/arin-ppml > >> Please contact info at arin.net if you > experience any issues. > > > > -- > > =============================================== > > David Farmer Email:farmer at umn.edu > > Networking & Telecommunication Services > > Office of Information Technology > > University of Minnesota > > 2218 University Ave SE Phone: 612-626-0815 > > Minneapolis, MN 55414-3029 Cell: 612-812-9952 > > =============================================== > > _______________________________________________ > > PPML > > You are receiving this message because you are subscribed to > > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net > ). > > Unsubscribe or manage your mailing list subscription at: > > http://lists.arin.net/mailman/listinfo/arin-ppml > > Please contact info at arin.net if you experience > any issues. > > > > -- > Sent via a mobile device -- =============================================== David Farmer Email:farmer at umn.edu Networking & Telecommunication Services Office of Information Technology University of Minnesota 2218 University Ave SE Phone: 612-626-0815 Minneapolis, MN 55414-3029 Cell: 612-812-9952 =============================================== From jmaimon at chl.com Wed Feb 8 23:35:59 2012 From: jmaimon at chl.com (Joe Maimon) Date: Wed, 08 Feb 2012 23:35:59 -0500 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: <4F333B85.5030106@umn.edu> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F29864F.8090603@arin.net> <4F332EB1.8050000@umn.edu> <4F333B85.5030106@umn.edu> Message-ID: <4F334D2F.7040405@chl.com> David Farmer wrote: > > On 2/8/12 21:02 CST, Martin Hannigan wrote: >> Why is it important that it be discussed prior to deprecating the three >> month rule? > > I prefer "redefining the soft landing trigger" or "resetting the > trigger" to "deprecate the three month rule", because as proposed the > three month rule wouldn't be deprecated, but the trigger reset for a new > three-month rule to kick in when the free pool is down to /8. > > However, if we do that before discussing this issue it is possible that > the free pool could be depleted down below /8 before this policy could > be reasonably implemented. If we at least start the discussion at the > same PPM as we start the discussion of resetting the trigger then I'm > confident we could implement it if desired before we get down to a /8 > > I'm not saying we have to do this for me to support resetting the > trigger. However, I feel resetting the trigger before at least starting > a serious discussion of this is a little disingenuous. At least that is > my opinion. > David, I appreciate your support and I agree with you. Proposals to modify the three month window have direct relevance to the import and impact of this proposal. You still wont see me supporting three month window reversions. Best, Joe From hannigan at gmail.com Thu Feb 9 01:47:39 2012 From: hannigan at gmail.com (Martin Hannigan) Date: Thu, 9 Feb 2012 01:47:39 -0500 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: <4F334D2F.7040405@chl.com> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F29864F.8090603@arin.net> <4F332EB1.8050000@umn.edu> <4F333B85.5030106@umn.edu> <4F334D2F.7040405@chl.com> Message-ID: On Wed, Feb 8, 2012 at 11:35 PM, Joe Maimon wrote: > > > David Farmer wrote: >> >> >> On 2/8/12 21:02 CST, Martin Hannigan wrote: >>> >>> Why is it important that it be discussed prior to deprecating the three >>> month rule? >> >> >> I prefer "redefining the soft landing trigger" or "resetting the >> trigger" to "deprecate the three month rule", because as proposed the >> three month rule wouldn't be deprecated, but the trigger reset for a new >> three-month rule to kick in when the free pool is down to /8. >> >> However, if we do that before discussing this issue it is possible that >> the free pool could be depleted down below /8 before this policy could >> be reasonably implemented. If we at least start the discussion at the >> same PPM as we start the discussion of resetting the trigger then I'm >> confident we could implement it if desired before we get down to a /8 >> >> I'm not saying we have to do this for me to support resetting the >> trigger. However, I feel resetting the trigger before at least starting >> a serious discussion of this is a little disingenuous. At least that is >> my opinion. >> > > David, > > I appreciate your support and I agree with you. Proposals to modify the > three month window have direct relevance to the import and impact of this > proposal. > > You still wont see me supporting three month window reversions. > >From the policy perspective, you are both inaccurate with respect to linkage. One proposal is about redefining the window of need from three to twelve months. The other is for trying to provide for "new entrants". The former has considerable support, the latter doesn't. I don't see any reason to link them one way or the other, they're mutually exclusive. With regards to this proposal, it's not like there's an anti-competitive practice taking place. The reason why new entrants won't be able to get address space is because of a design fault that is the root cause of run-out. We would've, and we will, run out no matter what is put aside or reserved for anyone. There's also a legacy market to consider that at the moment is quite competitive to ARIN. The cost of ownership vs. the cost of leasing is comparable to some extent. It may be this way for as long as some set-aside lasts as well. That would boil us down to protecting people who don't have cash flow to acquire addresses. Capitalism works like that. Not everyone is equal. Best, -M< From jcurran at arin.net Thu Feb 9 02:14:26 2012 From: jcurran at arin.net (John Curran) Date: Thu, 9 Feb 2012 07:14:26 +0000 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F29864F.8090603@arin.net> <4F332EB1.8050000@umn.edu> <4F333B85.5030106@umn.edu> <4F334D2F.7040405@chl.com> Message-ID: On Feb 9, 2012, at 7:47 AM, Martin Hannigan wrote: > > With regards to this proposal, it's not like there's an > anti-competitive practice taking place. The reason why new entrants > won't be able to get address space is because of a design fault that > is the root cause of run-out. We would've, and we will, run out no > matter what is put aside or reserved for anyone. It has been noted that even in the presence of a smoothly functioning market, new entrants will face a fairly high barrier to entry as IPv6 alone will likely not suffice and that a small amount of routable IPv4 space may be required to maintain compatibility with the existing Internet. If the community does not specifically reserve address space for such entrants, it is not inherently "anti-competitive" but may raise some concerns that the established businesses in this space failed to fairly consider the requirements of the entire Internet community as compared to their own interests. We will obviously get some legal review here regarding the level of obligation that the community has to consider these requirements, and will provide it to the list as soon as it is available. Thanks! /John John Curran President and CEO ARIN From jsw at inconcepts.biz Thu Feb 9 03:39:01 2012 From: jsw at inconcepts.biz (Jeff Wheeler) Date: Thu, 9 Feb 2012 03:39:01 -0500 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F29864F.8090603@arin.net> <4F332EB1.8050000@umn.edu> <4F333B85.5030106@umn.edu> <4F334D2F.7040405@chl.com> Message-ID: On Thu, Feb 9, 2012 at 2:14 AM, John Curran wrote: > If the community does not specifically reserve address space > for such entrants, it is not inherently "anti-competitive" but > may raise some concerns that the established businesses in this > space failed to fairly consider the requirements of the entire > Internet community as compared to their own interests. I am not opposed to the creation of a reserved pool for new businesses to receive initial allocations, but if this is done, I believe they should be non-transferable. As you might imagine, a person clever enough to slip through the cracks and grab himself an initial allocation, in a post-exhaustion world, would have a potentially valuable resource that existing businesses may wish to acquire -- not for the value of the business or underlying customers, but simply for IP addresses that they cannot get otherwise, or as inexpensively. Since APNIC already has a reserved pool for new market entrants, they will no doubt have some insight into if this is actually a problem or not. -- Jeff S Wheeler Sr Network Operator? /? Innovative Network Concepts From ppml at rs.seastrom.com Thu Feb 9 08:44:55 2012 From: ppml at rs.seastrom.com (Robert E. Seastrom) Date: Thu, 09 Feb 2012 08:44:55 -0500 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: (Jeff Wheeler's message of "Thu, 9 Feb 2012 03:39:01 -0500") References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F29864F.8090603@arin.net> <4F332EB1.8050000@umn.edu> <4F333B85.5030106@umn.edu> <4F334D2F.7040405@chl.com> Message-ID: <864nv0yvc8.fsf@seastrom.com> Jeff Wheeler writes: > I am not opposed to the creation of a reserved pool for new businesses > to receive initial allocations, but if this is done, I believe they > should be non-transferable. > > As you might imagine, a person clever enough to slip through the > cracks and grab himself an initial allocation, in a post-exhaustion > world, would have a potentially valuable resource that existing > businesses may wish to acquire -- not for the value of the business or > underlying customers, but simply for IP addresses that they cannot get > otherwise, or as inexpensively. In principle, agreed. In practice, a side effect is to create an incentive to have bogus information in the RIR database. A desire to have whois move closer to reflecting reality was one of the ingredients that went into the 8.3 soup. If you have any ideas as to how to reconcile this, I'm all ears like Ross Perot. -r From bensons at queuefull.net Thu Feb 9 12:54:59 2012 From: bensons at queuefull.net (Benson Schliesser) Date: Thu, 9 Feb 2012 17:54:59 +0000 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F29864F.8090603@arin.net> <4F332EB1.8050000@umn.edu> <4F333B85.5030106@umn.edu> <4F334D2F.7040405@chl.com> Message-ID: Thanks, John. I agree with your comments and I look forward to seeing the legal review. It might also be interesting to consider the impact to non-ISP end networks. Perhaps the 'anti-competitive' issues are different, even though access to the IPv4 market might be equally available - it's not clear to me. Either way, we may want to consider what our obligations are to both groups. Cheers, -Benson --- I, Benson Schliesser, am an employee of Cisco Systems; however, opinions expressed in this email are my own views and not those of Cisco Systems or anybody else. On Thu, Feb 9, 2012 at 07:14, John Curran wrote: > On Feb 9, 2012, at 7:47 AM, Martin Hannigan wrote: > > > > With regards to this proposal, it's not like there's an > > anti-competitive practice taking place. The reason why new entrants > > won't be able to get address space is because of a design fault that > > is the root cause of run-out. We would've, and we will, run out no > > matter what is put aside or reserved for anyone. > > It has been noted that even in the presence of a smoothly > functioning market, new entrants will face a fairly high > barrier to entry as IPv6 alone will likely not suffice and > that a small amount of routable IPv4 space may be required > to maintain compatibility with the existing Internet. > > If the community does not specifically reserve address space > for such entrants, it is not inherently "anti-competitive" but > may raise some concerns that the established businesses in this > space failed to fairly consider the requirements of the entire > Internet community as compared to their own interests. > > We will obviously get some legal review here regarding the > level of obligation that the community has to consider these > requirements, and will provide it to the list as soon as it > is available. > > Thanks! > /John > > John Curran > President and CEO > ARIN > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. > -------------- next part -------------- An HTML attachment was scrubbed... URL: From narten at us.ibm.com Fri Feb 10 00:53:02 2012 From: narten at us.ibm.com (Thomas Narten) Date: Fri, 10 Feb 2012 00:53:02 -0500 Subject: [arin-ppml] Weekly posting summary for ppml@arin.net Message-ID: <201202100553.q1A5r2Ck028593@rotala.raleigh.ibm.com> Total of 13 messages in the last 7 days. script run at: Fri Feb 10 00:53:02 EST 2012 Messages | Bytes | Who --------+------+--------+----------+------------------------ 15.38% | 2 | 21.80% | 23475 | hannigan at gmail.com 15.38% | 2 | 18.91% | 20362 | farmer at umn.edu 15.38% | 2 | 11.62% | 12517 | jcurran at arin.net 7.69% | 1 | 10.01% | 10779 | bensons at queuefull.net 7.69% | 1 | 8.70% | 9366 | info at arin.net 7.69% | 1 | 6.60% | 7108 | narten at us.ibm.com 7.69% | 1 | 5.81% | 6258 | andrew.dul at quark.net 7.69% | 1 | 5.69% | 6132 | jsw at inconcepts.biz 7.69% | 1 | 5.52% | 5946 | jmaimon at chl.com 7.69% | 1 | 5.32% | 5733 | ppml at rs.seastrom.com --------+------+--------+----------+------------------------ 100.00% | 13 |100.00% | 107676 | Total From matthew at matthew.at Fri Feb 10 05:33:09 2012 From: matthew at matthew.at (Matthew Kaufman) Date: Fri, 10 Feb 2012 12:33:09 +0200 Subject: [arin-ppml] Nanog IPV4 Panel Discussion and 8.3 transfers In-Reply-To: References: <4F3042A3.5070202@quark.net> Message-ID: <4F34F265.5010509@matthew.at> On 2/7/2012 4:22 AM, John Curran wrote: > On Feb 6, 2012, at 4:14 PM, Andrew Dul wrote: > >> Vendor A sells a /16 to Vendor B. Vendor B can justify a /20 under >> current policy. ARIN's response (channeling John Curran's response to >> this question) to this transfer would be to update the WHOIS to reflect >> that Vendor B now has a /20. > To be very clear, the most likely course of events is as follows: > Vendor B puts in a transfer request to ARIN for a /16 and it is > denied because they only need a /20 under current policies. They > reapply to transfer specific /20 from vendor A (which concurs) and > that is approved and the registry is updated to reflect that the > specific /20 is now held by Vendor B. No. A more likely course of events is: Vendor B puts in a transfer request to ARIN for a /16 and it is denied because they only need a /20 under current policies. Not wanting to waste the time and money they've put in already to locate and purchase a /16, they hire a consultant who modifies their request sufficiently such that their application for transfer now appears to show a need for the full /16. The transfer of the /16 is then approved. If that fails (which it probably won't), they renegotiate the deal so that they actually control the whole /16 but only transfer the /20 for now, and transfer the rest later... in the meantime they either advertise only the /20 or they just advertise and use the /16 with Vendor A's permission. Then anyone investigating what's going on has no idea what the actual usage of the "rest" of the /16 is, and thus begins the inevitable decline in the data quality of the IPv4 whois service. Matthew Kaufman From jcurran at arin.net Fri Feb 10 06:11:29 2012 From: jcurran at arin.net (John Curran) Date: Fri, 10 Feb 2012 11:11:29 +0000 Subject: [arin-ppml] Nanog IPV4 Panel Discussion and 8.3 transfers In-Reply-To: <4F34F265.5010509@matthew.at> References: <4F3042A3.5070202@quark.net> <4F34F265.5010509@matthew.at> Message-ID: <80784260-2849-4069-91DD-6A2AAE5DC2CF@corp.arin.net> On Feb 10, 2012, at 11:33 AM, Matthew Kaufman wrote: > No. A more likely course of events is: > Vendor B puts in a transfer request to ARIN for a /16 and it is denied because they only need a /20 under current policies. Not wanting to waste the time and money they've put in already to locate and purchase a /16, they hire a consultant who modifies their request sufficiently such that their application for transfer now appears to show a need for the full /16. The transfer of the /16 is then approved. That sequence of events is certainly possible. > If that fails (which it probably won't), they renegotiate the deal so that they actually control the whole /16 but only transfer the /20 for now, and transfer the rest later... in the meantime they either advertise only the /20 or they just advertise and use the /16 with Vendor A's permission. Then anyone investigating what's going on has no idea what the actual usage of the "rest" of the /16 is, and thus begins the inevitable decline in the data quality of the IPv4 whois service. To be clear, the rest of the /16 remains registered with Vendor A, who might decide months later to use it for some other purpose, or transfer some to Party C. The Whois reflects the actual registrant, not when Vendor B has an agreement to transfer in the future under some condition, or a right of first refusal to match or beat future transfer price, or an option to exercise to obtain in the future at a certain price, or any number of other esoteric structures that parties might postulate. The point is that the actual number resources transfer when the policy is met, and don't until that time. FYI, /John John Curran President and CEO ARIN From matthew at matthew.at Fri Feb 10 08:32:43 2012 From: matthew at matthew.at (Matthew Kaufman) Date: Fri, 10 Feb 2012 15:32:43 +0200 Subject: [arin-ppml] Nanog IPV4 Panel Discussion and 8.3 transfers In-Reply-To: <80784260-2849-4069-91DD-6A2AAE5DC2CF@corp.arin.net> References: <4F3042A3.5070202@quark.net> <4F34F265.5010509@matthew.at> <80784260-2849-4069-91DD-6A2AAE5DC2CF@corp.arin.net> Message-ID: <4F351C7B.8020202@matthew.at> On 2/10/2012 1:11 PM, John Curran wrote: > The point is that the actual number resources transfer when the policy > is met, and don't until that time. If we define "transfer" as "the entry in the ARIN database is changed", then yes. If we define "transfer" as "the entity with the legal right to use or control the use of the numbers changes", not so much. We don't actually have an ARIN "transfer policy"... we have a set of rules around which fields in a registration record may be changed by whom and under what circumstances. In some of the cases, Theseus' Paradox applies. ( http://en.wikipedia.org/wiki/Ship_of_Theseus ) Matthew Kaufman From jcurran at arin.net Fri Feb 10 09:03:04 2012 From: jcurran at arin.net (John Curran) Date: Fri, 10 Feb 2012 14:03:04 +0000 Subject: [arin-ppml] Nanog IPV4 Panel Discussion and 8.3 transfers In-Reply-To: <4F351C7B.8020202@matthew.at> References: <4F3042A3.5070202@quark.net> <4F34F265.5010509@matthew.at> <80784260-2849-4069-91DD-6A2AAE5DC2CF@corp.arin.net> <4F351C7B.8020202@matthew.at> Message-ID: <2B61291C-5480-449D-859D-4B71E35187EE@arin.net> On Feb 10, 2012, at 2:32 PM, Matthew Kaufman wrote: > On 2/10/2012 1:11 PM, John Curran wrote: >> The point is that the actual number resources transfer when the policy is met, and don't until that time. > > If we define "transfer" as "the entry in the ARIN database is changed", then yes. Correct. > If we define "transfer" as "the entity with the legal right to use or control the use of the numbers changes", not so much. Incorrect. Party A retains that right until the resources are transferred to another party per policy. FYI, /John John Curran President and CEO ARIN From matthew at matthew.at Fri Feb 10 09:11:31 2012 From: matthew at matthew.at (Matthew Kaufman) Date: Fri, 10 Feb 2012 16:11:31 +0200 Subject: [arin-ppml] Nanog IPV4 Panel Discussion and 8.3 transfers In-Reply-To: <2B61291C-5480-449D-859D-4B71E35187EE@arin.net> References: <4F3042A3.5070202@quark.net> <4F34F265.5010509@matthew.at> <80784260-2849-4069-91DD-6A2AAE5DC2CF@corp.arin.net> <4F351C7B.8020202@matthew.at> <2B61291C-5480-449D-859D-4B71E35187EE@arin.net> Message-ID: <4F352593.9070009@matthew.at> On 2/10/2012 4:03 PM, John Curran wrote: > On Feb 10, 2012, at 2:32 PM, Matthew Kaufman wrote: > >> If we define "transfer" as "the entity with the legal right to use or control the use of the numbers changes", not so much. > Incorrect. Party A retains that right until the resources > are transferred to another party per policy. > We'll probably need to disagree on this. I would claim that if a contract exists in which Party A gave up those rights to another party, then it is all over save the database update. This is no different than an M&A transfer. Certainly once I own all the shares of a company I've acquired, I can direct them to do anything I want with the address space assigned to them, whether or not we've gotten around to changing the name on the whois record. If instead I purchase all the assets of a company that has address space, in practice I can run the new company that owns those assets in any way I see fit, including hiring all their employees, transferring their contracts, and continuing to route their IP address space to their equipment, again whether or not we've gotten around to changing the name on the whois record. In fact, this happens all the time, as these kinds of asset sale contracts are signed and closed *before* the ARIN paperwork is submitted, even if the transfer is assured to happen. Matthew Kaufman From jcurran at arin.net Fri Feb 10 09:17:16 2012 From: jcurran at arin.net (John Curran) Date: Fri, 10 Feb 2012 14:17:16 +0000 Subject: [arin-ppml] Nanog IPV4 Panel Discussion and 8.3 transfers In-Reply-To: <4F352593.9070009@matthew.at> References: <4F3042A3.5070202@quark.net> <4F34F265.5010509@matthew.at> <80784260-2849-4069-91DD-6A2AAE5DC2CF@corp.arin.net> <4F351C7B.8020202@matthew.at> <2B61291C-5480-449D-859D-4B71E35187EE@arin.net> <4F352593.9070009@matthew.at> Message-ID: <4B0CC674-8EE3-43B3-ADFB-5E36CCF79DC9@arin.net> On Feb 10, 2012, at 3:11 PM, Matthew Kaufman wrote: > On 2/10/2012 4:03 PM, John Curran wrote: >> On Feb 10, 2012, at 2:32 PM, Matthew Kaufman wrote: >> >>> If we define "transfer" as "the entity with the legal right to use or control the use of the numbers changes", not so much. >> Incorrect. Party A retains that right until the resources >> are transferred to another party per policy. >> > > We'll probably need to disagree on this. I would claim that if a contract exists in which Party A gave up those rights to another party, then it is all over save the database update. Yes, I expect we'd then disagree. So far, no court has ordered a database change contrary to the community developed policy (although we've had cases which were corrected when we pointed out the oversight.) > This is no different than an M&A transfer. True; we do transfer resources in accordance with 8.2 in a similar manner, ie when such requests are submitted in compliance with policy. Thanks! /John John Curran President and CEO ARIN From andrew.dul at quark.net Fri Feb 10 12:36:52 2012 From: andrew.dul at quark.net (Andrew Dul) Date: Fri, 10 Feb 2012 09:36:52 -0800 Subject: [arin-ppml] Nanog IPV4 Panel Discussion and 8.3 transfers In-Reply-To: <80784260-2849-4069-91DD-6A2AAE5DC2CF@corp.arin.net> References: <4F3042A3.5070202@quark.net> <4F34F265.5010509@matthew.at> <80784260-2849-4069-91DD-6A2AAE5DC2CF@corp.arin.net> Message-ID: <4F3555B4.4060907@quark.net> On 2/10/2012 3:11 AM, John Curran wrote: > On Feb 10, 2012, at 11:33 AM, Matthew Kaufman wrote: > > >> If that fails (which it probably won't), they renegotiate the deal so that they actually control the whole /16 but only transfer the /20 for now, and transfer the rest later... in the meantime they either advertise only the /20 or they just advertise and use the /16 with Vendor A's permission. Then anyone investigating what's going on has no idea what the actual usage of the "rest" of the /16 is, and thus begins the inevitable decline in the data quality of the IPv4 whois service. > > To be clear, the rest of the /16 remains registered with Vendor A, > who might decide months later to use it for some other purpose, or > transfer some to Party C. > > The Whois reflects the actual registrant, not when Vendor B has > an agreement to transfer in the future under some condition, or > a right of first refusal to match or beat future transfer price, > or an option to exercise to obtain in the future at a certain > price, or any number of other esoteric structures that parties > might postulate. > > The point is that the actual number resources transfer when the > policy is met, and don't until that time. > > This illustrates the point I was trying to make. The current policy is ambiguous with regard to contracts that may exist which contradict what may or may not be recorded in whois. If Vendor A sells some to Party C some of what it sold to Vendor B the first time but wasn't transferred, we now have a sales contract conflict which likely can only be resolved in court. I am not sure what the exact policy answer is to this scenario, but something seems like it needs to deal with this issue. Its possible this is a corner case which will never occur, but what exists today seems like it needs changes to reflect business and contract realities. Andrew From jmaimon at chl.com Fri Feb 10 13:04:02 2012 From: jmaimon at chl.com (Joe Maimon) Date: Fri, 10 Feb 2012 13:04:02 -0500 Subject: [arin-ppml] Nanog IPV4 Panel Discussion and 8.3 transfers In-Reply-To: <4F3555B4.4060907@quark.net> References: <4F3042A3.5070202@quark.net> <4F34F265.5010509@matthew.at> <80784260-2849-4069-91DD-6A2AAE5DC2CF@corp.arin.net> <4F3555B4.4060907@quark.net> Message-ID: <4F355C12.7000402@chl.com> Andrew Dul wrote: > On 2/10/2012 3:11 AM, John Curran wrote: >> On Feb 10, 2012, at 11:33 AM, Matthew Kaufman wrote: > > I am not sure what the exact policy answer is to this scenario, but > something seems like it needs to deal with this issue. Its possible > this is a corner case which will never occur, but what exists today > seems like it needs changes to reflect business and contract realities. > > Andrew > > Perhaps you can share the reasoning you have that causes you to believe that the courts would desire to enforce a contract between A and B on party C's property. Consider how you reasoning changes when either or both of parties A and B's behavior with regards to C is governed by contract. The contents of the ARIN database belong to ARIN, who administers the database in accordance with its governance structure - which defines and involves community led policy to control the database. The concern we should all have is that this database not lose any of its usefulness to us as a community. Best, Joe From jcurran at arin.net Fri Feb 10 13:16:09 2012 From: jcurran at arin.net (John Curran) Date: Fri, 10 Feb 2012 18:16:09 +0000 Subject: [arin-ppml] Nanog IPV4 Panel Discussion and 8.3 transfers In-Reply-To: <4F3555B4.4060907@quark.net> References: <4F3042A3.5070202@quark.net> <4F34F265.5010509@matthew.at> <80784260-2849-4069-91DD-6A2AAE5DC2CF@corp.arin.net> <4F3555B4.4060907@quark.net> Message-ID: On Feb 10, 2012, at 6:36 PM, Andrew Dul wrote: >> The point is that the actual number resources transfer when the >> policy is met, and don't until that time. > > This illustrates the point I was trying to make. The current policy is > ambiguous with regard to contracts that may exist which contradict what > may or may not be recorded in whois. If Vendor A sells some to Party C > some of what it sold to Vendor B the first time but wasn't transferred, > we now have a sales contract conflict which likely can only be resolved > in court. ARIN recommends that parties work in advance before any sale to insure that the requirements are met, and this can be at time of transaction (or in advance via the Specified Transfer Listing Service) In any case, parties need to recognize that any transfer of rights to address space only after being approved per policy. For instance, if a party A claims to 'sells their address space' to party B, but it turns out that party A actually has address space registered to them via their upstream ISP, the fact that there is a sale document does not mean that anything has been conveyed, not that Whois is incorrect (i.e. party B has likely been defrauded, and may go to court only to discover such...) > I am not sure what the exact policy answer is to this scenario, > but something seems like it needs to deal with this issue. Make sure that the contracts have appropriate language regarding effectuation; specific language recommendations are available here: www.arin.net/resources/transfers/mwe_internet_article010512.pdf FYI, /John John Curran President and CEO ARIN From andrew.dul at quark.net Fri Feb 10 13:38:39 2012 From: andrew.dul at quark.net (Andrew Dul) Date: Fri, 10 Feb 2012 10:38:39 -0800 Subject: [arin-ppml] Nanog IPV4 Panel Discussion and 8.3 transfers In-Reply-To: <4F355C12.7000402@chl.com> References: <4F3042A3.5070202@quark.net> <4F34F265.5010509@matthew.at> <80784260-2849-4069-91DD-6A2AAE5DC2CF@corp.arin.net> <4F3555B4.4060907@quark.net> <4F355C12.7000402@chl.com> Message-ID: <4F35642F.70108@quark.net> On 2/10/2012 10:04 AM, Joe Maimon wrote: > > Perhaps you can share the reasoning you have that causes you to > believe that the courts would desire to enforce a contract between A > and B on party C's property. > Contract #1: Legacy holder A sells zzz.yyy.0.0/16 to Party B for $1,000,000, agreed on 3/1/2012 ARIN registers zzz.yyy.0.0/20 to B on 4/1/2012 since B can only justify a /20 Since A still has rights to the rest of the /16 it decides to sell another block to C Contract #2: Legacy holder A sells zzz.yyy.128.0/17 to Party C for $2,000,000 agreed on 1/1/2013 ARIN registers zzz.yyy.128.0/17 to Party C on 2/1/2013 Party B sues Party A & C, ARIN etc... for breach of contract since it purchased the rights to zzz.yyy.0.0/16 on 3/1/2012 The courts decide who wins and who loses... Hope this helps explain the issues. Andrew From jcurran at arin.net Fri Feb 10 14:02:16 2012 From: jcurran at arin.net (John Curran) Date: Fri, 10 Feb 2012 19:02:16 +0000 Subject: [arin-ppml] Nanog IPV4 Panel Discussion and 8.3 transfers In-Reply-To: <4F35642F.70108@quark.net> References: <4F3042A3.5070202@quark.net> <4F34F265.5010509@matthew.at> <80784260-2849-4069-91DD-6A2AAE5DC2CF@corp.arin.net> <4F3555B4.4060907@quark.net> <4F355C12.7000402@chl.com> <4F35642F.70108@quark.net> Message-ID: <2D11FDAC-9E99-417C-96A8-EC5066B83343@corp.arin.net> On Feb 10, 2012, at 7:38 PM, Andrew Dul wrote: > On 2/10/2012 10:04 AM, Joe Maimon wrote: >> >> Perhaps you can share the reasoning you have that causes you to >> believe that the courts would desire to enforce a contract between A >> and B on party C's property. >> > > Contract #1: > Legacy holder A sells zzz.yyy.0.0/16 to Party B for $1,000,000, > agreed on 3/1/2012 > > ARIN registers zzz.yyy.0.0/20 to B on 4/1/2012 since B can only justify > a /20 > > Since A still has rights to the rest of the /16 it decides to sell > another block to C > > Contract #2: > Legacy holder A sells zzz.yyy.128.0/17 to Party C for $2,000,000 > agreed on 1/1/2013 > > ARIN registers zzz.yyy.128.0/17 to Party C on 2/1/2013 > > Party B sues Party A & C, ARIN etc... for breach of contract since it > purchased the rights to zzz.yyy.0.0/16 on 3/1/2012 > > The courts decide who wins and who loses... See my follow-on message on this regarding contract language... If Party A's contract #1 is appropriately written, then Party B only received the /20 (hopefully only paid for the same) when the contract became final. If Party A indicated otherwise to Party B and then proceeded as outlined, then indeed a court will sort the matter out without any difficulty at all. Write two contracts to sell the same automobile and you'll see the same outcome. FYI, /John John Curran President and CEO ARIN From jlewis at lewis.org Fri Feb 10 14:09:10 2012 From: jlewis at lewis.org (Jon Lewis) Date: Fri, 10 Feb 2012 14:09:10 -0500 (EST) Subject: [arin-ppml] Nanog IPV4 Panel Discussion and 8.3 transfers In-Reply-To: <2D11FDAC-9E99-417C-96A8-EC5066B83343@corp.arin.net> References: <4F3042A3.5070202@quark.net> <4F34F265.5010509@matthew.at> <80784260-2849-4069-91DD-6A2AAE5DC2CF@corp.arin.net> <4F3555B4.4060907@quark.net> <4F355C12.7000402@chl.com> <4F35642F.70108@quark.net> <2D11FDAC-9E99-417C-96A8-EC5066B83343@corp.arin.net> Message-ID: >> Contract #1: >> Legacy holder A sells zzz.yyy.0.0/16 to Party B for $1,000,000, >> agreed on 3/1/2012 >> >> ARIN registers zzz.yyy.0.0/20 to B on 4/1/2012 since B can only justify >> a /20 What if instead of selling it, A decides to use what space they have to become an LIR and rent the space out for yearly fees? IIRC, with a direct assignment, A can't do swips, but that's a minor detail/issue. ---------------------------------------------------------------------- Jon Lewis, MCP :) | I route Senior Network Engineer | therefore you are Atlantic Net | _________ http://www.lewis.org/~jlewis/pgp for PGP public key_________ From owen at delong.com Fri Feb 10 14:46:49 2012 From: owen at delong.com (Owen DeLong) Date: Fri, 10 Feb 2012 11:46:49 -0800 Subject: [arin-ppml] Nanog IPV4 Panel Discussion and 8.3 transfers In-Reply-To: <4F352593.9070009@matthew.at> References: <4F3042A3.5070202@quark.net> <4F34F265.5010509@matthew.at> <80784260-2849-4069-91DD-6A2AAE5DC2CF@corp.arin.net> <4F351C7B.8020202@matthew.at> <2B61291C-5480-449D-859D-4B71E35187EE@arin.net> <4F352593.9070009@matthew.at> Message-ID: <1109C423-B031-43C3-BD15-CFFF2F034E86@delong.com> On Feb 10, 2012, at 6:11 AM, Matthew Kaufman wrote: > On 2/10/2012 4:03 PM, John Curran wrote: >> On Feb 10, 2012, at 2:32 PM, Matthew Kaufman wrote: >> >>> If we define "transfer" as "the entity with the legal right to use or control the use of the numbers changes", not so much. >> Incorrect. Party A retains that right until the resources >> are transferred to another party per policy. >> > > We'll probably need to disagree on this. I would claim that if a contract exists in which Party A gave up those rights to another party, then it is all over save the database update. > > This is no different than an M&A transfer. > > Certainly once I own all the shares of a company I've acquired, I can direct them to do anything I want with the address space assigned to them, whether or not we've gotten around to changing the name on the whois record. > > If instead I purchase all the assets of a company that has address space, in practice I can run the new company that owns those assets in any way I see fit, including hiring all their employees, transferring their contracts, and continuing to route their IP address space to their equipment, again whether or not we've gotten around to changing the name on the whois record. In fact, this happens all the time, as these kinds of asset sale contracts are signed and closed *before* the ARIN paperwork is submitted, even if the transfer is assured to happen. > Matthew, In both of your cited examples, there is no party A remaining independent of party B and therefore no possibility of a dispute between A and B. Now, the situation that is much more of a gray area is if party A comes to agreement with party B to transfer a /16. They attempt to do this only to discover that party B only qualifies for a /20 under ARIN policy. The complete the transfer of the /20 and have some agreement regarding the remainder of the /16 being transferred at some later date or whatever. Party A then decides to dispose of the remainder of the /16 in other ways. Party B attempts to dispute this, claiming contractual rights contrary to the transfer policy. I have no idea how that scuffle would turn out. I don't think you can say with any certainty, either. Certainly it will be quite the battle between party A and party B over A's alleged breech of contract with B. Beyond that, it's unclear what would happen. Owen From info at arin.net Fri Feb 10 16:05:09 2012 From: info at arin.net (ARIN) Date: Fri, 10 Feb 2012 16:05:09 -0500 Subject: [arin-ppml] =?windows-1252?q?NRPM_2012=2E2_=96_New_Policies_Imple?= =?windows-1252?q?mented?= Message-ID: <4F358685.10109@arin.net> On 3 February 2012 the ARIN Board of Trustees adopted the following policies: ARIN-2011-11: Clarify Justified Need for Transfers ARIN-2011-12: Set Transfer Need to 24 months These policies are being implemented today. A new version of the ARIN Number Resource Policy Manual (NRPM) has been published to the ARIN website. NRPM version 2012.2 is effective 10 February 2012 and supersedes the previous version. NRPM 2012.2 contains the implementation of ARIN-2011-11 and ARIN-2011-12. Please note that the policy for Specified Transfers (NRPM 8.3) has changed. Organizations requesting address space via specified transfers can now request up to a 24-month supply. For more information, please see the Transfer Guidelines at: https://www.arin.net/resources/request/transfers.html The NRPM is available at: https://www.arin.net/policy/nrpm.html Board minutes are available at: https://www.arin.net/about_us/bot/index.html Draft policies and proposals are available at: https://www.arin.net/policy/proposals/ The ARIN Policy Development Process is available at: https://www.arin.net/policy/pdp.html Regards, Communications and Member Services American Registry for Internet Numbers (ARIN) From scottleibrand at gmail.com Fri Feb 10 17:53:08 2012 From: scottleibrand at gmail.com (Scott Leibrand) Date: Fri, 10 Feb 2012 14:53:08 -0800 Subject: [arin-ppml] ARIN-prop-157 Section 8.3 Simplification In-Reply-To: <4E7A02F2.1010702@arin.net> References: <4E7A02F2.1010702@arin.net> Message-ID: As the primary AC shepherd on this proposal, I'd like to propose modifying ARIN-prop-157 as follows: Title: ASN transfers Policy statement: In NRPM 8.3, replace "IPv4 number resources" with "IPv4 number resources and ASNs". Rationale: There are legitimate use cases for transferring ASNs, and no significant downsides (identified to date) of allowing it. In my personal opinion, that would preserve the essential feature of the policy that has shown some support on PPML, while alleviating most of the concerns. Thoughts? If you expressed support for ARIN-prop-157, do you still support the revised text? If you opposed the original draft of ARIN-prop-157, is this text any better (or worse)? Do you feel the AC should move this proposal forward to a public policy meeting? Thanks, Scott On Wed, Sep 21, 2011 at 8:29 AM, ARIN wrote: > ARIN-prop-157 Section 8.3 Simplification > > ARIN received the following policy proposal and is posting it to the > Public Policy Mailing List (PPML) in accordance with the Policy > Development Process. > > The ARIN Advisory Council (AC) will review the proposal at their next > regularly scheduled meeting (if the period before the next regularly > scheduled meeting is less than 10 days, then the period may be extended > to the subsequent regularly scheduled meeting). The AC will decide how > to utilize the proposal and announce the decision to the PPML. > > The AC invites everyone to comment on the proposal on the PPML, > particularly their support or non-support and the reasoning > behind their opinion. Such participation contributes to a thorough > vetting and provides important guidance to the AC in their deliberations. > > Draft Policies and Proposals under discussion can be found at: > https://www.arin.net/policy/proposals/index.html > > The ARIN Policy Development Process can be found at: > https://www.arin.net/policy/pdp.html > > Mailing list subscription information can be found > at: https://www.arin.net/mailing_lists/ > > Regards, > > Communications and Member Services > American Registry for Internet Numbers (ARIN) > > ## * ## > > ARIN-prop-157 Section 8.3 Simplification > > Proposal Originator: Martin Hannigan > > Proposal Version: 1.0 > > Date: 21 SEP 2011 > > Proposal type: modify > > Policy term: permanent > > Policy statement: > > Number resources within the ARIN region may be released to ARIN by an > authorized resource holder for transfer to a qualified and specified > recipient. > > Rationale: > > The original text was overly complex and imprecise. The modified language > has been reduced to be clear with respect to allowing specified transfers of > "number resources". The definition of "number resources" is any IPv4 address > or addresses, IPV6 address or addresses or a 2 byte or 4 byte ASN > individually or collectively. > > Timetable for implementation: Immediate > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From joe at oregon.uoregon.edu Fri Feb 10 17:57:01 2012 From: joe at oregon.uoregon.edu (Joe St Sauver) Date: Fri, 10 Feb 2012 14:57:01 -0800 (PST) Subject: [arin-ppml] ARIN-prop-157 Section 8.3 Simplification Message-ID: <12021014570108_4D2D5@oregon.uoregon.edu> Scott mentioned: #As the primary AC shepherd on this proposal, I'd like to propose #modifying ARIN-prop-157 as follows: # #Title: ASN transfers #Policy statement: #In NRPM 8.3, replace "IPv4 number resources" with "IPv4 number #resources and ASNs". #Rationale: #There are legitimate use cases for transferring ASNs, and no #significant downsides (identified to date) of allowing it. # #In my personal opinion, that would preserve the essential feature of #the policy that has shown some support on PPML, while alleviating most #of the concerns. # #Thoughts? In some cases ASNs are used to help map lists of IP addresses to relevant networks/network operators. (For example, you might have a list of ten thousand botted hosts, and you want to map/sort all of those to the associated origin ASN) If it is easy for the community to get a merged list of ASNs and associated ASNames or Orgnames to use for that sort of purpose, I'd be fine with the modified proposal. Alternatively, or additionally, it would be terrific if at least a list of all transferred ASNs (sorted by date of transfer) could be maintained and made available. Lacking that, my concern is that I could easily see many manually constructed and locally maintained AS number to ASName (or AS number to Orgname) mapping files gradually getting out of sync over time, which I think would be undesirable/lead to inaccuracies. Thanks for considering this feedback, Regards, Joe St Sauver (joe at oregon.uoregon.edu) http://pages.uoregon.edu/joe/ From farmer at umn.edu Fri Feb 10 20:22:49 2012 From: farmer at umn.edu (David Farmer) Date: Fri, 10 Feb 2012 19:22:49 -0600 Subject: [arin-ppml] ARIN-prop-162 In-Reply-To: <4F22BBCB.3060006@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F22BBCB.3060006@arin.net> Message-ID: <4F35C2E9.3060308@umn.edu> As AC shepherd for both ARIN-prop-161 and ARIN-prop-162, and looking at the communities comments for both proposals, I see the following issues that needed to be addressed in a revision of the text; > CJ Aronson - "this says you're changing from "request up to a 3-month supply of IP addresses." to "request up to three month supply of IP addresses." It doesn't seem to change the policy at all. What am I missing here?" To help clarify I am including the entire policy text not just the paragraph that is changing, and proposing a new title that I hope better expresses the intent of the policy. > Owen DeLong - "I would rather see this simply state when the ARIN free pool has less than one /8 of space remaining, notwithstanding reservations under NRPM 4.4 and 4.10 rather than the convoluted retroactive phrasing in the current proposal text." I believe the new text and rationale covers this; > Joe Maimon - "b) What happens if the pool grows back to over /8? " I tired to address this issue in the last sentence, and I believe the intent is to stay at 3-months once triggered, even if we go back above /8. Also, see in the rationale for a discussion of the exact amount available in the free pool after the triggering request is fulfilled. Feed back and/or suggestions please; ------------------- Title: Return to 12 Month Supply and Reset Trigger to /8 in Free Pool Policy statement: 4.2.4.4. Subscriber Members After One Year After an organization has been a subscriber member of ARIN for one year, they may choose to request up to a twelve (12) month supply of IP addresses. When the ARIN Free Pool is down to the equilivant of one /8, excluding all special reservations, the length of supply that an organization may request will be reduced. An organization may choose to request up to a three (3) month supply of IP addresses. Any request that reduces the ARIN free pool below the /8 threshold above will trigger the reduction for that and all subsequent requests by all organizations. Rationale: There has been discussion in the community that ARIN's inventory of IPv4 addresses may be excessive given the reduction in the rate of consumption which is concurrent with the reduction to a 3 month supply when ARIN received it last /8 at IANA run-out. And that such an excess inventory in the ARIN region may be damaging the transition to IPv6 by elongating the amount of time between ARIN's exhaustion and exhaustion by other RIR's, thus creating a dangerous skew across parts of Internet in the need to transition to IPv6. One solution for this issue is increase ARIN's rate of consumption by restoring the a 12 month supply of addresses. ARIN's stewardship responsibilities are of primary concern in this region. However, restoring the a 12 month supply of addresses is consistent with these stewardship responsibilities. Asking businesses to request addresses on a three month basis with such large inventory available at ARIN unnecessarily increases the cost and complexity of operating networks; repeated and slow interactions with ARIN, duplicate paperwork requirements and an inefficient use of resources by all compound the pain. The original intent of ARIN-2009-8 "Equitable IPv4 Run-Out" wasn't necessarily to slow the consumption of IPv4 but to limit the competitive disadvantage created by unequal run-out. However, when the trigger of IANA run-out was selected it wasn't anticipated that ARIN would have more that 5 /8s in inventory when IANA run-out occurred. Therefore, restoring the 12-month supply and resetting the trigger for a reduction to a 3-month supply to a locally controlled event seems consistent with the original intent of ARIN-2010-8 as well. Considering that the ARIN region has consumed significantly less than a /8 since the 3-month supply was triggered at IANA run-out a year ago; Resetting the trigger for the 3-month supply to /8 in the free pool, excluding all special reservations, seems reasonable. The special reservations to be excluded, should include all reservations made in policy, including those in sections 4.4, 4.10, any new reservations made by subsequent policies, and may also include reservations for draft policies in process at the board's discretion, such as Draft Policy ARIN-2011-5: Shared Transition Space for IPv4 Address Extension. Please Note: By triggering on any request that would drop the free pool below /8 it is possible that when there will be slightly more or slightly less than /8 available after the triggering request is fulfilled. The size of the triggering request and the exact amount above /8 available in the free pool will determine how much more or less than /8 will be available after the triggering request is fulfilled. This could be as much as 3/4 of the triggering request above /8 or as much as 1/4 of the triggering request below /8 available after fulfilling the triggering request. To help clarify how this policy proposal changes Section 4.2.4.4, the current policy text as of Feb 10, 2012 is included below; 4.2.4.4. Subscriber Members After One Year After an organization has been a subscriber member of ARIN for one year, they may choose to request up to a 12-month supply of IP addresses. When ARIN receives its last /8, by IANA implementing section 10.4.2.2, the length of supply that an organization may request will be reduced. An organization may choose to request up to a 3-month supply of IP addresses. -- =============================================== David Farmer Email:farmer at umn.edu Networking & Telecommunication Services Office of Information Technology University of Minnesota 2218 University Ave SE Phone: 612-626-0815 Minneapolis, MN 55414-3029 Cell: 612-812-9952 =============================================== From farmer at umn.edu Fri Feb 10 22:37:41 2012 From: farmer at umn.edu (David Farmer) Date: Fri, 10 Feb 2012 21:37:41 -0600 Subject: [arin-ppml] ARIN-prop-163 Dedicated resources for initial ISP allocations In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F29864F.8090603@arin.net> <4F332EB1.8050000@umn.edu> <4F333B85.5030106@umn.edu> <4F334D2F.7040405@chl.com> Message-ID: <4F35E285.10003@umn.edu> On 2/9/12 24:47 CST, Martin Hannigan wrote: > From the policy perspective, you are both inaccurate with respect to > linkage. One proposal is about redefining the window of need from > three to twelve months. The other is for trying to provide for "new > entrants". The former has considerable support, the latter doesn't. I > don't see any reason to link them one way or the other, they're > mutually exclusive. I never said they were linked from a policy perspective. In fact I think from a policy perspective there are completely independent. I support both this and returning to a 12 month supply. However, if we were to restart the 12 month supply, following the next PPM and not discuss this proposal until this fall or next spring, then it may be to late from a practical perspective to implement this policy. You seemed to express a similar concern in the following; On 2/1/12 16:12 CST, Martin Hannigan wrote: > I'm interested in this, but shy of support for now. Also, If this were > to go into the AC masher, it would be torn apart for multiple cycles > and probably be too late for any good by the time that it was able to > be useful. Less text if possible would be very helpful. I think it's > possible. So while I think these proposals are independent from a policy perspective, I wouldn't want to risk making this proposal irrelevant by delaying the start of our discussion of it. In my view the best thing is to get both 162 and 163 to Vancouver as draft policies for adoption discussion by the community. Then the AC can move one or both forward as appropriate. > With regards to this proposal, it's not like there's an > anti-competitive practice taking place. The reason why new entrants > won't be able to get address space is because of a design fault that > is the root cause of run-out. We would've, and we will, run out no > matter what is put aside or reserved for anyone. There's also a legacy > market to consider that at the moment is quite competitive to ARIN. > The cost of ownership vs. the cost of leasing is comparable to some > extent. It may be this way for as long as some set-aside lasts as > well. That would boil us down to protecting people who don't have cash > flow to acquire addresses. Capitalism works like that. Not everyone is > equal. This sound to me like you no longer support the proposal, did you change your mind since the following? On 2/1/12 23:00 CST, Martin Hannigan wrote: > Support. Needs more discussion, but shouldn't be dropped. Or do I misunderstand you? -- =============================================== David Farmer Email:farmer at umn.edu Networking & Telecommunication Services Office of Information Technology University of Minnesota 2218 University Ave SE Phone: 612-626-0815 Minneapolis, MN 55414-3029 Cell: 612-812-9952 =============================================== From farmer at umn.edu Fri Feb 10 23:23:58 2012 From: farmer at umn.edu (David Farmer) Date: Fri, 10 Feb 2012 22:23:58 -0600 Subject: [arin-ppml] ARIN-prop-157 Section 8.3 Simplification In-Reply-To: <12021014570108_4D2D5@oregon.uoregon.edu> References: <12021014570108_4D2D5@oregon.uoregon.edu> Message-ID: <4F35ED5E.2060009@umn.edu> On 2/10/12 16:57 CST, Joe St Sauver wrote: > In some cases ASNs are used to help map lists of IP addresses to relevant > networks/network operators. (For example, you might have a list of ten > thousand botted hosts, and you want to map/sort all of those to the > associated origin ASN) > > If it is easy for the community to get a merged list of ASNs and associated > ASNames or Orgnames to use for that sort of purpose, I'd be fine with the > modified proposal. See; ftp://ftp.arin.net/info/asn.txt Does this fit the bill? If not, what does needed? This seems to be built from the ARIN database daily, so when the ASN is update via the transfer I assume this file would be update on its next build. > Alternatively, or additionally, it would be terrific if > at least a list of all transferred ASNs (sorted by date of transfer) could be > maintained and made available. ARIN is currently publishing a list of IPs that have been transferred under 8.3; https://www.arin.net/knowledge/statistics/transfers_8_3.html So, I would expect they would do the same for ASN if this policy is adopted, but it wouldn't hurt to add this suggestion to the Rationale of this policy. And if it isn't provided upon implementation, submit a suggestion via the ARIN Consultation and Suggestion Process; https://www.arin.net/app/suggestion/ Why sorted by date of transfer? I'm not getting why this is important. For more details, there is an ARIN-Issued mailing list and RSS feed. However, it doesn't seem to include ASNs. Also, it is not clear if it includes transfers either. Maybe it should include both ASN and transfer activity too, I'll think about submitting a suggestion. https://www.arin.net/participate/mailing_lists/arin_issued.html -- =============================================== David Farmer Email:farmer at umn.edu Networking & Telecommunication Services Office of Information Technology University of Minnesota 2218 University Ave SE Phone: 612-626-0815 Minneapolis, MN 55414-3029 Cell: 612-812-9952 =============================================== From info at arin.net Mon Feb 13 12:48:29 2012 From: info at arin.net (ARIN) Date: Mon, 13 Feb 2012 12:48:29 -0500 Subject: [arin-ppml] Petition for Discussion of ARIN-prop-160 In-Reply-To: <4F2C29C7.6060404@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F22C09B.802@arin.net> <4F2C29C7.6060404@arin.net> Message-ID: <4F394CED.1040706@arin.net> This petition did not receive the required 10 statements of support and was therefore not successful. ARIN-prop-160 is closed. Regards, Communications and Member Services American Registry for Internet Numbers (ARIN) On 2/3/12 1:39 PM, ARIN wrote: > >> The duration of the petition is until five business days after the AC's >> draft meeting minutes are published. ARIN staff will post the result of >> the petition to PPML. > > The minutes of the AC's 20 January 2012 meeting have been published to > the ARIN website at: > https://www.arin.net/about_us/ac/index.html > > This petition will end on 10 February 2012. > > Regards, > > Communications and Member Services > American Registry for Internet Numbers (ARIN) > > > On 1/27/12 10:19 AM, ARIN wrote: >> The message below started a petition regarding the ARIN Advisory >> Council's decision to abandon ARIN-prop-160. The AC's decision was >> posted by ARIN staff to PPML on 25 January 2012. >> >> If successful, this petition will change ARIN-prop-160 into a Draft >> Policy which will be published for adoption discussion on the PPML and >> at the Public Policy Meeting in April 2012. If the petition fails, the >> proposal will be closed. >> >> For this petition to be successful, the petition needs statements of >> support from at least 10 different people from 10 different >> organizations. If you wish to support this petition, post a statement of >> support to PPML on this thread. >> >> The duration of the petition is until five business days after the AC's >> draft meeting minutes are published. ARIN staff will post the result of >> the petition to PPML. >> >> For more information on starting and participating in petitions, see PDP >> Petitions at: >> https://www.arin.net/policy/pdp_petitions.html >> >> The proposal text is below and at: >> https://www.arin.net/policy/proposals/index.html >> >> The ARIN Policy Development Process can be found at: >> https://www.arin.net/policy/pdp.html >> >> Regards, >> >> Communications and Member Services >> American Registry for Internet Numbers (ARIN) >> >> >> ##### >> >> >>> Petition for 160 please. >>> >>> >>> On Wednesday, January 25, 2012, ARIN wrote: >>>> In accordance with the ARIN Policy Development Process, the ARIN >>>> Advisory Council (AC) held a meeting on 20 January 2012 and made >>>> decisions about several draft policies and proposals. >>>> >>>> The AC recommended the following draft policies to the ARIN Board for >>>> adoption: >>>> >>>> ARIN-2011-11: Clarify Justified Need for Transfers >>>> ARIN-2011-12: Set Transfer Need to 24 months >>>> >>>> The following proposal was added to the AC's docket for development >>>> and evaluation: >>>> >>>> ARIN-prop-161 Normalize Free pool and Transfer justification periods >>>> >>>> The AC abandoned the following proposal: >>>> >>>> ARIN-prop-160 Clarification of Section 4.2.3.4.1. Utilization >>>> >>>> Regarding proposal 160, the AC stated, "This proposal represented a >>>> significant change to the justification requirements in 4.2.3.4.1 >>>> for receiving PA space. The AC did not see significant support for >>>> such a change on PPML, and felt the proposal was not justified at >>>> this time." >>>> >>>> The AC thanks the authors and the community for their continuing >>>> effort >>>> and contributions to these and all other policy considerations. >>>> >>>> The AC abandoned proposal 160. Anyone dissatisfied with this >>>> decision may initiate a petition. The petition to advance this >>>> proposal would be the "Discussion Petition." The deadline to begin a >>>> petition will be five business days after the AC's draft meeting >>>> minutes are published. For more information on starting and >>>> participating in petitions, see PDP Petitions at: >>>> https://www.arin.net/policy/pdp_petitions.html >>>> >>>> Draft Policy and Proposal texts are available at: >>>> https://www.arin.net/policy/proposals/index.html >>>> >>>> The ARIN Policy Development Process can be found at: >>>> https://www.arin.net/policy/pdp.html >>>> >>>> Regards, >>>> >>>> Communications and Member Services >>>> American Registry for Internet Numbers (ARIN) >>>> _______________________________________________ >>>> PPML >>>> You are receiving this message because you are subscribed to >>>> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >>>> Unsubscribe or manage your mailing list subscription at: >>>> http://lists.arin.net/mailman/listinfo/arin-ppml >>>> Please contact info at arin.net if you experience any issues. >>>> >>> >>> -- >>> Sent via a mobile device >> >> >> ARIN-prop-160 Clarification of Section 4.2.3.4.1. Utilization >> >> Proposal Originator: Martin Hannigan >> >> Proposal Version: 1 >> >> Date: 22 DEC 2011 >> >> Proposal type: MODIFY >> >> Policy term: PERMANENT >> >> Policy statement: >> >> Change policy statement from: >> >> 4.2.3.4.1. Utilization >> >> Reassignment information for prior allocations must show that each >> customer meets the 80% utilization criteria and must be available via >> SWIP / RWhois prior to your issuing them additional space. >> >> To: >> >> 4.2.3.4.1. Utilization >> >> Reassignment information for prior allocations made from the same >> ISP's inventory must show that each customer meets the 80% utilization >> criteria and must be available via SWIP / RWhois prior to your issuing >> them additional number resources. >> >> Rationale: >> >> Existing policy is vague. >> >> Timetable for implementation: Immediate >> >> > From info at arin.net Thu Feb 16 17:54:20 2012 From: info at arin.net (ARIN) Date: Thu, 16 Feb 2012 17:54:20 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> Message-ID: <4F3D891C.6060507@arin.net> ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers ARIN received the following policy proposal and is posting it to the Public Policy Mailing List (PPML) in accordance with the Policy Development Process. The ARIN Advisory Council (AC) will review the proposal at their next regularly scheduled meeting (if the period before the next regularly scheduled meeting is less than 10 days, then the period may be extended to the subsequent regularly scheduled meeting). The AC will decide how to utilize the proposal and announce the decision to the PPML. The AC invites everyone to comment on the proposal on the PPML, particularly their support or non-support and the reasoning behind their opinion. Such participation contributes to a thorough vetting and provides important guidance to the AC in their deliberations. Draft Policies and Proposals under discussion can be found at: https://www.arin.net/policy/proposals/index.html The ARIN Policy Development Process can be found at: https://www.arin.net/policy/pdp.html Mailing list subscription information can be found at: https://www.arin.net/mailing_lists/ Regards, Communications and Member Services American Registry for Internet Numbers (ARIN) ## * ## ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers Proposal Originator: Jeff Mehlenbacher Proposal Version: 1 Date: 16 February 16 2012 Proposal type: Modify Policy term: Permanent Policy statement: Current Policy Statement: 8.3. Transfers to Specified Recipients In addition to transfers under section 8.2, IPv4 number resources within the ARIN region may be released to ARIN by the authorized resource holder, in whole or in part, for transfer to another specified organizational recipient. Such transferred number resources may only be received under RSA by organizations that are within the ARIN region and can demonstrate the need for such resources in the amount which they can justify under current ARIN policies showing how the addresses will be utilized within 24 months. Proposed Policy Statement 8.3. Transfers to Specified Recipients In addition to transfers under section 8.2, IPv4 number resources within the ARIN region may be released to ARIN by the authorized resource holder, in whole or in part, for transfer to another specified organizational recipient. Such transferred number resources may only be received under RSA by organizations that are within the ARIN region and requires that an Officer Attestation be provided confirming the transferred number resources will be applied to enable current or planned business models. Rationale: Current policy acts as a major impediment to freeing up unused IPv4 address and constrains trade in a free market economy. If a Company receives Board approval to spend between $11.25 and $12.00 per IP, this should suggest the business case is justified for the acquiring organization. The role of ARIN should be to encourage the freeing of IPv4 addresses that will otherwise remain dormant in the hands of companies who have no incentive to transfer them. The objective of the Specified Transfer market should be to a) encourage source Companies to transfer their unused blocks thereby increasing supply of IPv4 address and b) encourage recipient Companies to acquire sufficient IPv4 addresses to support business plans rather than depleting the free pool. Current policy of demonstrating need for specified transfers, be it based on 12 months or now 24 months, does not provide sufficient incentive for organizations to acquire unused IPv4 addresses in a financial transaction. Companies recognize they must still endure the rigors of the justification process regardless of free allocation or specified transfer?making it very difficult to justify a financial transaction when specified transfers will still be assessed by exactly the same techniques and algorithms applied for approval of free resources. Eliminating needs-based justification has many benefits so long as all transactions continue to flow through ARIN for ratification: a) Buyer executive attestation will ensure the IP?s are being used for business purposes. Failure to be truthful could result in punitive measures against corporate officers, and is a risk an officer would not be likely to take b) Source Companies have an active market and financial incentive to transfer unused IPv4 blocks to Companies with need c) IPv4 number resources will not be scarce if adequate incentive exists for Buyers to acquire unused blocks through specified transfer d) Many Buyers express hesitation that confidential business plans must be disclosed through the justification process?no such disclosure would be required (under NDA or otherwise) e) Legacy blocks will come under RSA in ever increasing numbers f) Improves the accuracy, utility and value of the ARIN address registry g) Effectively kills the black or gray IPv4 transfer market guaranteeing ARIN?s custodianship over number resources h) Encourages source Companies to free up resources and recipient Companies to actively acquire available IPv4 blocks thereby eliminating speculation because supply is abundant. Only when a resource is truly scarce does capricious consumption (stockpiling) occur i) The Free resource pool is best applied to small or new ISPs while medium to large corporations with greater financial wherewithal are encouraged to participate in specified transfers to acquire larger IPv4 blocks Timetable for implementation: Immediate From kkargel at polartel.com Thu Feb 16 18:06:00 2012 From: kkargel at polartel.com (Kevin Kargel) Date: Thu, 16 Feb 2012 17:06:00 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: <4F3D891C.6060507@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> Message-ID: <8695009A81378E48879980039EEDAD28011E05E3F6@MAIL1.polartel.local> My issue with this is that it treats ARIN members unfairly. If we should eliminate needs requirements for any part of IP address allocation then we should eliminate needs requirements for *all* allocations, not just transfers for profit. All of the arguments here apply to regular allocations as much as they do to transfer allocations. This does not mean it is a good idea. I strongly oppose this proposal. Kevin Kargel > -----Original Message----- > From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On > Behalf Of ARIN > Sent: Thursday, February 16, 2012 4:54 PM > To: arin-ppml at arin.net > Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on > 8.3 Specified Transfers > > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified > Transfers > > ARIN received the following policy proposal and is posting it to the > Public Policy Mailing List (PPML) in accordance with the Policy > Development Process. > > The ARIN Advisory Council (AC) will review the proposal at their next > regularly scheduled meeting (if the period before the next regularly > scheduled meeting is less than 10 days, then the period may be extended > to the subsequent regularly scheduled meeting). The AC will decide how > to utilize the proposal and announce the decision to the PPML. > > The AC invites everyone to comment on the proposal on the PPML, > particularly their support or non-support and the reasoning > behind their opinion. Such participation contributes to a thorough > vetting and provides important guidance to the AC in their deliberations. > > Draft Policies and Proposals under discussion can be found at: > https://www.arin.net/policy/proposals/index.html > > The ARIN Policy Development Process can be found at: > https://www.arin.net/policy/pdp.html > > Mailing list subscription information can be found > at: https://www.arin.net/mailing_lists/ > > Regards, > > Communications and Member Services > American Registry for Internet Numbers (ARIN) > > > ## * ## > > > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified > Transfers > > Proposal Originator: Jeff Mehlenbacher > > Proposal Version: 1 > > Date: 16 February 16 2012 > > Proposal type: Modify > > Policy term: Permanent > > Policy statement: > > Current Policy Statement: > 8.3. Transfers to Specified Recipients > In addition to transfers under section 8.2, IPv4 number resources within > the ARIN region may be released to ARIN by the authorized resource > holder, in whole or in part, for transfer to another specified > organizational recipient. Such transferred number resources may only be > received under RSA by organizations that are within the ARIN region and > can demonstrate the need for such resources in the amount which they can > justify under current ARIN policies showing how the addresses will be > utilized within 24 months. > > Proposed Policy Statement > 8.3. Transfers to Specified Recipients > In addition to transfers under section 8.2, IPv4 number resources within > the ARIN region may be released to ARIN by the authorized resource > holder, in whole or in part, for transfer to another specified > organizational recipient. Such transferred number resources may only be > received under RSA by organizations that are within the ARIN region and > requires that an Officer Attestation be provided confirming the > transferred number resources will be applied to enable current or > planned business models. > > Rationale: > > Current policy acts as a major impediment to freeing up unused IPv4 > address and constrains trade in a free market economy. If a Company > receives Board approval to spend between $11.25 and $12.00 per IP, this > should suggest the business case is justified for the acquiring > organization. The role of ARIN should be to encourage the freeing of > IPv4 addresses that will otherwise remain dormant in the hands of > companies who have no incentive to transfer them. > > The objective of the Specified Transfer market should be to a) encourage > source Companies to transfer their unused blocks thereby increasing > supply of IPv4 address and b) encourage recipient Companies to acquire > sufficient IPv4 addresses to support business plans rather than > depleting the free pool. > > Current policy of demonstrating need for specified transfers, be it > based on 12 months or now 24 months, does not provide sufficient > incentive for organizations to acquire unused IPv4 addresses in a > financial transaction. Companies recognize they must still endure the > rigors of the justification process regardless of free allocation or > specified transfer.making it very difficult to justify a financial > transaction when specified transfers will still be assessed by exactly > the same techniques and algorithms applied for approval of free resources. > > Eliminating needs-based justification has many benefits so long as all > transactions continue to flow through ARIN for ratification: > > a) Buyer executive attestation will ensure the IP's are being used for > business purposes. Failure to be truthful could result in punitive > measures against corporate officers, and is a risk an officer would not > be likely to take > > b) Source Companies have an active market and financial incentive to > transfer unused IPv4 blocks to Companies with need > > c) IPv4 number resources will not be scarce if adequate incentive exists > for Buyers to acquire unused blocks through specified transfer > > d) Many Buyers express hesitation that confidential business plans must > be disclosed through the justification process-no such disclosure would > be required (under NDA or otherwise) > > e) Legacy blocks will come under RSA in ever increasing numbers > > f) Improves the accuracy, utility and value of the ARIN address registry > > g) Effectively kills the black or gray IPv4 transfer market guaranteeing > ARIN's custodianship over number resources > > h) Encourages source Companies to free up resources and recipient > Companies to actively acquire available IPv4 blocks thereby eliminating > speculation because supply is abundant. Only when a resource is truly > scarce does capricious consumption (stockpiling) occur > > i) The Free resource pool is best applied to small or new ISPs while > medium to large corporations with greater financial wherewithal are > encouraged to participate in specified transfers to acquire larger IPv4 > blocks > > Timetable for implementation: Immediate > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. -------------- next part -------------- A non-text attachment was scrubbed... Name: smime.p7s Type: application/x-pkcs7-signature Size: 4935 bytes Desc: not available URL: From cja at daydream.com Thu Feb 16 18:22:08 2012 From: cja at daydream.com (CJ Aronson) Date: Thu, 16 Feb 2012 16:22:08 -0700 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: <4F3D891C.6060507@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> Message-ID: I am opposed to this policy. For as long as ARIN has existed this community has been very vocal in supporting the needs basis for address allocations and assignments. I have no reason to believe that this position has changed. ----Cathy On Thu, Feb 16, 2012 at 3:54 PM, ARIN wrote: > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers > > ARIN received the following policy proposal and is posting it to the > Public Policy Mailing List (PPML) in accordance with the Policy > Development Process. > > The ARIN Advisory Council (AC) will review the proposal at their next > regularly scheduled meeting (if the period before the next regularly > scheduled meeting is less than 10 days, then the period may be extended > to the subsequent regularly scheduled meeting). The AC will decide how > to utilize the proposal and announce the decision to the PPML. > > The AC invites everyone to comment on the proposal on the PPML, > particularly their support or non-support and the reasoning > behind their opinion. Such participation contributes to a thorough > vetting and provides important guidance to the AC in their deliberations. > > Draft Policies and Proposals under discussion can be found at: > https://www.arin.net/policy/proposals/index.html > > The ARIN Policy Development Process can be found at: > https://www.arin.net/policy/pdp.html > > Mailing list subscription information can be found > at: https://www.arin.net/mailing_lists/ > > Regards, > > Communications and Member Services > American Registry for Internet Numbers (ARIN) > > > ## * ## > > > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers > > Proposal Originator: Jeff Mehlenbacher > > Proposal Version: 1 > > Date: 16 February 16 2012 > > Proposal type: Modify > > Policy term: Permanent > > Policy statement: > > Current Policy Statement: > 8.3. Transfers to Specified Recipients > In addition to transfers under section 8.2, IPv4 number resources within the > ARIN region may be released to ARIN by the authorized resource holder, in > whole or in part, for transfer to another specified organizational > recipient. Such transferred number resources may only be received under RSA > by organizations that are within the ARIN region and can demonstrate the > need for such resources in the amount which they can justify under current > ARIN policies showing how the addresses will be utilized within 24 months. > > Proposed Policy Statement > 8.3. Transfers to Specified Recipients > In addition to transfers under section 8.2, IPv4 number resources within the > ARIN region may be released to ARIN by the authorized resource holder, in > whole or in part, for transfer to another specified organizational > recipient. Such transferred number resources may only be received under RSA > by organizations that are within the ARIN region and requires that an > Officer Attestation be provided confirming the transferred number resources > will be applied to enable current or planned business models. > > Rationale: > > Current policy acts as a major impediment to freeing up unused IPv4 address > and constrains trade in a free market economy. If a Company receives Board > approval to spend between $11.25 and $12.00 per IP, this should suggest the > business case is justified for the acquiring organization. The role of ARIN > should be to encourage the freeing of IPv4 addresses that will otherwise > remain dormant in the hands of companies who have no incentive to transfer > them. > > The objective of the Specified Transfer market should be to a) encourage > source Companies to transfer their unused blocks thereby increasing supply > of IPv4 address and b) encourage recipient Companies to acquire sufficient > IPv4 addresses to support business plans rather than depleting the free > pool. > > Current policy of demonstrating need for specified transfers, be it based on > 12 months or now 24 months, does not provide sufficient incentive for > organizations to acquire unused IPv4 addresses in a financial transaction. > Companies recognize they must still endure the rigors of the justification > process regardless of free allocation or specified transfer?making it very > difficult to justify a financial transaction when specified transfers will > still be assessed by exactly the same techniques and algorithms applied for > approval of free resources. > > Eliminating needs-based justification has many benefits so long as all > transactions continue to flow through ARIN for ratification: > > a) Buyer executive attestation will ensure the IP?s are being used for > business purposes. Failure to be truthful could result in punitive measures > against corporate officers, and is a risk an officer would not be likely to > take > > b) Source Companies have an active market and financial incentive to > transfer unused IPv4 blocks to Companies with need > > c) IPv4 number resources will not be scarce if adequate incentive exists for > Buyers to acquire unused blocks through specified transfer > > d) Many Buyers express hesitation that confidential business plans must be > disclosed through the justification process?no such disclosure would be > required (under NDA or otherwise) > > e) Legacy blocks will come under RSA in ever increasing numbers > > f) Improves the accuracy, utility and value of the ARIN address registry > > g) Effectively kills the black or gray IPv4 transfer market guaranteeing > ARIN?s custodianship over number resources > > h) Encourages source Companies to free up resources and recipient Companies > to actively acquire available IPv4 blocks thereby eliminating speculation > because supply is abundant. Only when a resource is truly scarce does > capricious consumption (stockpiling) occur > > i) The Free resource pool is best applied to small or new ISPs while medium > to large corporations with greater financial wherewithal are encouraged to > participate in specified transfers to acquire larger IPv4 blocks > > Timetable for implementation: Immediate > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From farmer at umn.edu Thu Feb 16 18:23:09 2012 From: farmer at umn.edu (David Farmer) Date: Thu, 16 Feb 2012 17:23:09 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: <4F3D891C.6060507@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> Message-ID: <4F3D8FDD.8060704@umn.edu> The policy refers to "business models"; "Officer Attestation be provided confirming the transferred number resources will be applied to enable current or planned business models." Is it the author's intent that this can be any business model? Or, is this intended be to limited to a business model that requires addresses for the deployment of operational networks? I ask because; Acquiring addresses for resale or simply to corner the market on addresses are a potential business models. If the intent is to not allow these last two business models then maybe this could be an interesting way to find consensus to remove needs-basis from the current policy. But, if the intent is to include the last two business models then I'm not sure we are going to find consensus within the community for this policy and I probably oppose this policy. However, If the intent is to allow only business models that "need addresses to deploy operational networks" then; I'm not sure I support this policy yet, but it is definitely an interesting idea, and probably worthy of discussion. On 2/16/12 16:54 CST, ARIN wrote: > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified > Transfers > > Proposal Originator: Jeff Mehlenbacher > > Proposal Version: 1 > > Date: 16 February 16 2012 > > Proposal type: Modify > > Policy term: Permanent > > Policy statement: > > Current Policy Statement: > 8.3. Transfers to Specified Recipients > In addition to transfers under section 8.2, IPv4 number resources within > the ARIN region may be released to ARIN by the authorized resource > holder, in whole or in part, for transfer to another specified > organizational recipient. Such transferred number resources may only be > received under RSA by organizations that are within the ARIN region and > can demonstrate the need for such resources in the amount which they can > justify under current ARIN policies showing how the addresses will be > utilized within 24 months. > > Proposed Policy Statement > 8.3. Transfers to Specified Recipients > In addition to transfers under section 8.2, IPv4 number resources within > the ARIN region may be released to ARIN by the authorized resource > holder, in whole or in part, for transfer to another specified > organizational recipient. Such transferred number resources may only be > received under RSA by organizations that are within the ARIN region and > requires that an Officer Attestation be provided confirming the > transferred number resources will be applied to enable current or > planned business models. > > Rationale: > > Current policy acts as a major impediment to freeing up unused IPv4 > address and constrains trade in a free market economy. If a Company > receives Board approval to spend between $11.25 and $12.00 per IP, this > should suggest the business case is justified for the acquiring > organization. The role of ARIN should be to encourage the freeing of > IPv4 addresses that will otherwise remain dormant in the hands of > companies who have no incentive to transfer them. > > The objective of the Specified Transfer market should be to a) encourage > source Companies to transfer their unused blocks thereby increasing > supply of IPv4 address and b) encourage recipient Companies to acquire > sufficient IPv4 addresses to support business plans rather than > depleting the free pool. > > Current policy of demonstrating need for specified transfers, be it > based on 12 months or now 24 months, does not provide sufficient > incentive for organizations to acquire unused IPv4 addresses in a > financial transaction. Companies recognize they must still endure the > rigors of the justification process regardless of free allocation or > specified transfer?making it very difficult to justify a financial > transaction when specified transfers will still be assessed by exactly > the same techniques and algorithms applied for approval of free resources. > > Eliminating needs-based justification has many benefits so long as all > transactions continue to flow through ARIN for ratification: > > a) Buyer executive attestation will ensure the IP?s are being used for > business purposes. Failure to be truthful could result in punitive > measures against corporate officers, and is a risk an officer would not > be likely to take > > b) Source Companies have an active market and financial incentive to > transfer unused IPv4 blocks to Companies with need > > c) IPv4 number resources will not be scarce if adequate incentive exists > for Buyers to acquire unused blocks through specified transfer > > d) Many Buyers express hesitation that confidential business plans must > be disclosed through the justification process?no such disclosure would > be required (under NDA or otherwise) > > e) Legacy blocks will come under RSA in ever increasing numbers > > f) Improves the accuracy, utility and value of the ARIN address registry > > g) Effectively kills the black or gray IPv4 transfer market guaranteeing > ARIN?s custodianship over number resources > > h) Encourages source Companies to free up resources and recipient > Companies to actively acquire available IPv4 blocks thereby eliminating > speculation because supply is abundant. Only when a resource is truly > scarce does capricious consumption (stockpiling) occur > > i) The Free resource pool is best applied to small or new ISPs while > medium to large corporations with greater financial wherewithal are > encouraged to participate in specified transfers to acquire larger IPv4 > blocks > > Timetable for implementation: Immediate > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. -- =============================================== David Farmer Email:farmer at umn.edu Networking & Telecommunication Services Office of Information Technology University of Minnesota 2218 University Ave SE Phone: 612-626-0815 Minneapolis, MN 55414-3029 Cell: 612-812-9952 =============================================== From petertbui0 at gmail.com Thu Feb 16 19:37:45 2012 From: petertbui0 at gmail.com (Peter Bui) Date: Thu, 16 Feb 2012 16:37:45 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: <4F3D891C.6060507@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> Message-ID: I oppose this proposal as written. On Thu, Feb 16, 2012 at 2:54 PM, ARIN wrote: > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified > Transfers > > ARIN received the following policy proposal and is posting it to the > Public Policy Mailing List (PPML) in accordance with the Policy > Development Process. > > The ARIN Advisory Council (AC) will review the proposal at their next > regularly scheduled meeting (if the period before the next regularly > scheduled meeting is less than 10 days, then the period may be extended > to the subsequent regularly scheduled meeting). The AC will decide how > to utilize the proposal and announce the decision to the PPML. > > The AC invites everyone to comment on the proposal on the PPML, > particularly their support or non-support and the reasoning > behind their opinion. Such participation contributes to a thorough > vetting and provides important guidance to the AC in their deliberations. > > Draft Policies and Proposals under discussion can be found at: > https://www.arin.net/policy/**proposals/index.html > > The ARIN Policy Development Process can be found at: > https://www.arin.net/policy/**pdp.html > > Mailing list subscription information can be found > at: https://www.arin.net/mailing_**lists/ > > Regards, > > Communications and Member Services > American Registry for Internet Numbers (ARIN) > > > ## * ## > > > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified > Transfers > > Proposal Originator: Jeff Mehlenbacher > > Proposal Version: 1 > > Date: 16 February 16 2012 > > Proposal type: Modify > > Policy term: Permanent > > Policy statement: > > Current Policy Statement: > 8.3. Transfers to Specified Recipients > In addition to transfers under section 8.2, IPv4 number resources within > the ARIN region may be released to ARIN by the authorized resource holder, > in whole or in part, for transfer to another specified organizational > recipient. Such transferred number resources may only be received under RSA > by organizations that are within the ARIN region and can demonstrate the > need for such resources in the amount which they can justify under current > ARIN policies showing how the addresses will be utilized within 24 months. > > Proposed Policy Statement > 8.3. Transfers to Specified Recipients > In addition to transfers under section 8.2, IPv4 number resources within > the ARIN region may be released to ARIN by the authorized resource holder, > in whole or in part, for transfer to another specified organizational > recipient. Such transferred number resources may only be received under RSA > by organizations that are within the ARIN region and requires that an > Officer Attestation be provided confirming the transferred number resources > will be applied to enable current or planned business models. > > Rationale: > > Current policy acts as a major impediment to freeing up unused IPv4 > address and constrains trade in a free market economy. If a Company > receives Board approval to spend between $11.25 and $12.00 per IP, this > should suggest the business case is justified for the acquiring > organization. The role of ARIN should be to encourage the freeing of IPv4 > addresses that will otherwise remain dormant in the hands of companies who > have no incentive to transfer them. > > The objective of the Specified Transfer market should be to a) encourage > source Companies to transfer their unused blocks thereby increasing supply > of IPv4 address and b) encourage recipient Companies to acquire sufficient > IPv4 addresses to support business plans rather than depleting the free > pool. > > Current policy of demonstrating need for specified transfers, be it based > on 12 months or now 24 months, does not provide sufficient incentive for > organizations to acquire unused IPv4 addresses in a financial transaction. > Companies recognize they must still endure the rigors of the justification > process regardless of free allocation or specified transfer?making it very > difficult to justify a financial transaction when specified transfers will > still be assessed by exactly the same techniques and algorithms applied for > approval of free resources. > > Eliminating needs-based justification has many benefits so long as all > transactions continue to flow through ARIN for ratification: > > a) Buyer executive attestation will ensure the IP?s are being used for > business purposes. Failure to be truthful could result in punitive measures > against corporate officers, and is a risk an officer would not be likely to > take > > b) Source Companies have an active market and financial incentive to > transfer unused IPv4 blocks to Companies with need > > c) IPv4 number resources will not be scarce if adequate incentive exists > for Buyers to acquire unused blocks through specified transfer > > d) Many Buyers express hesitation that confidential business plans must be > disclosed through the justification process?no such disclosure would be > required (under NDA or otherwise) > > e) Legacy blocks will come under RSA in ever increasing numbers > > f) Improves the accuracy, utility and value of the ARIN address registry > > g) Effectively kills the black or gray IPv4 transfer market guaranteeing > ARIN?s custodianship over number resources > > h) Encourages source Companies to free up resources and recipient > Companies to actively acquire available IPv4 blocks thereby eliminating > speculation because supply is abundant. Only when a resource is truly > scarce does capricious consumption (stockpiling) occur > > i) The Free resource pool is best applied to small or new ISPs while > medium to large corporations with greater financial wherewithal are > encouraged to participate in specified transfers to acquire larger IPv4 > blocks > > Timetable for implementation: Immediate > ______________________________**_________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/**listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. > -------------- next part -------------- An HTML attachment was scrubbed... URL: From JOHN at egh.com Thu Feb 16 19:27:26 2012 From: JOHN at egh.com (John Santos) Date: Thu, 16 Feb 2012 19:27:26 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: Message-ID: <1120216192603.24529A-100000@Ives.egh.com> +1 Also opposed. Isn't "making lots of money by cornering the IPv4 address market" also a "business purpose"? On Thu, 16 Feb 2012, CJ Aronson wrote: > I am opposed to this policy. For as long as ARIN has existed this > community has been very vocal in supporting the needs basis for > address allocations and assignments. I have no reason to believe that > this position has changed. > > ----Cathy > > On Thu, Feb 16, 2012 at 3:54 PM, ARIN wrote: > > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers > > > > ARIN received the following policy proposal and is posting it to the > > Public Policy Mailing List (PPML) in accordance with the Policy > > Development Process. > > > > The ARIN Advisory Council (AC) will review the proposal at their next > > regularly scheduled meeting (if the period before the next regularly > > scheduled meeting is less than 10 days, then the period may be extended > > to the subsequent regularly scheduled meeting). The AC will decide how > > to utilize the proposal and announce the decision to the PPML. > > > > The AC invites everyone to comment on the proposal on the PPML, > > particularly their support or non-support and the reasoning > > behind their opinion. Such participation contributes to a thorough > > vetting and provides important guidance to the AC in their deliberations. > > > > Draft Policies and Proposals under discussion can be found at: > > https://www.arin.net/policy/proposals/index.html > > > > The ARIN Policy Development Process can be found at: > > https://www.arin.net/policy/pdp.html > > > > Mailing list subscription information can be found > > at: https://www.arin.net/mailing_lists/ > > > > Regards, > > > > Communications and Member Services > > American Registry for Internet Numbers (ARIN) > > > > > > ## * ## > > > > > > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers > > > > Proposal Originator: Jeff Mehlenbacher > > > > Proposal Version: 1 > > > > Date: 16 February 16 2012 > > > > Proposal type: Modify > > > > Policy term: Permanent > > > > Policy statement: > > > > Current Policy Statement: > > 8.3. Transfers to Specified Recipients > > In addition to transfers under section 8.2, IPv4 number resources within the > > ARIN region may be released to ARIN by the authorized resource holder, in > > whole or in part, for transfer to another specified organizational > > recipient. Such transferred number resources may only be received under RSA > > by organizations that are within the ARIN region and can demonstrate the > > need for such resources in the amount which they can justify under current > > ARIN policies showing how the addresses will be utilized within 24 months. > > > > Proposed Policy Statement > > 8.3. Transfers to Specified Recipients > > In addition to transfers under section 8.2, IPv4 number resources within the > > ARIN region may be released to ARIN by the authorized resource holder, in > > whole or in part, for transfer to another specified organizational > > recipient. Such transferred number resources may only be received under RSA > > by organizations that are within the ARIN region and requires that an > > Officer Attestation be provided confirming the transferred number resources > > will be applied to enable current or planned business models. > > > > Rationale: > > > > Current policy acts as a major impediment to freeing up unused IPv4 address > > and constrains trade in a free market economy. If a Company receives Board > > approval to spend between $11.25 and $12.00 per IP, this should suggest the > > business case is justified for the acquiring organization. The role of ARIN > > should be to encourage the freeing of IPv4 addresses that will otherwise > > remain dormant in the hands of companies who have no incentive to transfer > > them. > > > > The objective of the Specified Transfer market should be to a) encourage > > source Companies to transfer their unused blocks thereby increasing supply > > of IPv4 address and b) encourage recipient Companies to acquire sufficient > > IPv4 addresses to support business plans rather than depleting the free > > pool. > > > > Current policy of demonstrating need for specified transfers, be it based on > > 12 months or now 24 months, does not provide sufficient incentive for > > organizations to acquire unused IPv4 addresses in a financial transaction. > > Companies recognize they must still endure the rigors of the justification > > process regardless of free allocation or specified transfer making it very > > difficult to justify a financial transaction when specified transfers will > > still be assessed by exactly the same techniques and algorithms applied for > > approval of free resources. > > > > Eliminating needs-based justification has many benefits so long as all > > transactions continue to flow through ARIN for ratification: > > > > a) Buyer executive attestation will ensure the IP?s are being used for > > business purposes. Failure to be truthful could result in punitive measures > > against corporate officers, and is a risk an officer would not be likely to > > take > > > > b) Source Companies have an active market and financial incentive to > > transfer unused IPv4 blocks to Companies with need > > > > c) IPv4 number resources will not be scarce if adequate incentive exists for > > Buyers to acquire unused blocks through specified transfer > > > > d) Many Buyers express hesitation that confidential business plans must be > > disclosed through the justification process?no such disclosure would be > > required (under NDA or otherwise) > > > > e) Legacy blocks will come under RSA in ever increasing numbers > > > > f) Improves the accuracy, utility and value of the ARIN address registry > > > > g) Effectively kills the black or gray IPv4 transfer market guaranteeing > > ARIN?s custodianship over number resources > > > > h) Encourages source Companies to free up resources and recipient Companies > > to actively acquire available IPv4 blocks thereby eliminating speculation > > because supply is abundant. Only when a resource is truly scarce does > > capricious consumption (stockpiling) occur > > > > i) The Free resource pool is best applied to small or new ISPs while medium > > to large corporations with greater financial wherewithal are encouraged to > > participate in specified transfers to acquire larger IPv4 blocks > > > > Timetable for implementation: Immediate > > _______________________________________________ > > PPML > > You are receiving this message because you are subscribed to > > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > > Unsubscribe or manage your mailing list subscription at: > > http://lists.arin.net/mailman/listinfo/arin-ppml > > Please contact info at arin.net if you experience any issues. > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. > > -- John Santos Evans Griffiths & Hart, Inc. 781-861-0670 ext 539 From gary.buhrmaster at gmail.com Thu Feb 16 20:56:15 2012 From: gary.buhrmaster at gmail.com (Gary Buhrmaster) Date: Fri, 17 Feb 2012 01:56:15 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: <4F3D891C.6060507@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> Message-ID: On Thu, Feb 16, 2012 at 22:54, ARIN wrote: > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers ..... > Eliminating needs-based justification has many benefits so long as all > transactions continue to flow through ARIN for ratification: I am opposed to proposals that to do not require the recipient companies to demonstrate operational need and planned operational use of the number resources they wish to acquire. I am certainly agreeable to review the current need and planning time frame requirements to make sure they are still aligned with the real world (as other proposals are currently doing). But those do not change the basic principal of operational need as it appears that this proposal attempts to do. Note that I have no objection for independent "brokers" to exist to find buyers and sellers, should those entities choose not to avail themselves of the existing listing services. However, the recipient of the number resources in such a completed transaction should still demonstrate operational need. Opposed (as written). Gary From astrodog at gmail.com Thu Feb 16 22:32:33 2012 From: astrodog at gmail.com (Astrodog) Date: Thu, 16 Feb 2012 21:32:33 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: <1120216192603.24529A-100000@Ives.egh.com> References: <1120216192603.24529A-100000@Ives.egh.com> Message-ID: On Thu, Feb 16, 2012 at 6:27 PM, John Santos wrote: > +1 > > Also opposed. > > Isn't "making lots of money by cornering the IPv4 address market" also > a "business purpose"? Support. I believe the concern about speculation with IP addresses is fairly overblown. If an entity were to attempt such a move, it would induce more efficent usage among existing users, so that they could sell portions of their space (or avoid purchasing additional address space). This carries with it a very large risk that the addresses such an entity purchased would become nearly worthless, either due to oversupply as large address space holders sold off their space, or due to IPv6 migration and more efficent utilization due to the short term increased cost driving demand for the addresses down over longer periods of time. It is unlikely, given these concerns, that such an endevour would be attempted on a large scale or that such an attempt would have any significant impact on long term "pricing" of IPv4 addresses. The positives with such an approach are significant, though, as it greatly reduces the time and effort required on the part of both parties, as well as ARIN, to effect such a transfer, making it much easier for IP addresses to go to those entities who will use them. The situation, as things stand today, appears to involve companies deciding to arrainge such a transfer, then trying to back in to a justification under 8.3. --- Harrison > On Thu, 16 Feb 2012, CJ Aronson wrote: > >> I am opposed to this policy. ?For as long as ARIN has existed this >> community has been very vocal in supporting the needs basis for >> address allocations and assignments. ?I have no reason to believe that >> this position has changed. >> >> ----Cathy >> >> On Thu, Feb 16, 2012 at 3:54 PM, ARIN wrote: >> > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers >> > >> > ARIN received the following policy proposal and is posting it to the >> > Public Policy Mailing List (PPML) in accordance with the Policy >> > Development Process. >> > >> > The ARIN Advisory Council (AC) will review the proposal at their next >> > regularly scheduled meeting (if the period before the next regularly >> > scheduled meeting is less than 10 days, then the period may be extended >> > to the subsequent regularly scheduled meeting). The AC will decide how >> > to utilize the proposal and announce the decision to the PPML. >> > >> > The AC invites everyone to comment on the proposal on the PPML, >> > particularly their support or non-support and the reasoning >> > behind their opinion. Such participation contributes to a thorough >> > vetting and provides important guidance to the AC in their deliberations. >> > >> > Draft Policies and Proposals under discussion can be found at: >> > https://www.arin.net/policy/proposals/index.html >> > >> > The ARIN Policy Development Process can be found at: >> > https://www.arin.net/policy/pdp.html >> > >> > Mailing list subscription information can be found >> > at: https://www.arin.net/mailing_lists/ >> > >> > Regards, >> > >> > Communications and Member Services >> > American Registry for Internet Numbers (ARIN) >> > >> > >> > ## * ## >> > >> > >> > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers >> > >> > Proposal Originator: Jeff Mehlenbacher >> > >> > Proposal Version: 1 >> > >> > Date: 16 February 16 2012 >> > >> > Proposal type: Modify >> > >> > Policy term: Permanent >> > >> > Policy statement: >> > >> > Current Policy Statement: >> > 8.3. Transfers to Specified Recipients >> > In addition to transfers under section 8.2, IPv4 number resources within the >> > ARIN region may be released to ARIN by the authorized resource holder, in >> > whole or in part, for transfer to another specified organizational >> > recipient. Such transferred number resources may only be received under RSA >> > by organizations that are within the ARIN region and can demonstrate the >> > need for such resources in the amount which they can justify under current >> > ARIN policies showing how the addresses will be utilized within 24 months. >> > >> > Proposed Policy Statement >> > 8.3. Transfers to Specified Recipients >> > In addition to transfers under section 8.2, IPv4 number resources within the >> > ARIN region may be released to ARIN by the authorized resource holder, in >> > whole or in part, for transfer to another specified organizational >> > recipient. Such transferred number resources may only be received under RSA >> > by organizations that are within the ARIN region and requires that an >> > Officer Attestation be provided confirming the transferred number resources >> > will be applied to enable current or planned business models. >> > >> > Rationale: >> > >> > Current policy acts as a major impediment to freeing up unused IPv4 address >> > and constrains trade in a free market economy. If a Company receives Board >> > approval to spend between $11.25 and $12.00 per IP, this should suggest the >> > business case is justified for the acquiring organization. The role of ARIN >> > should be to encourage the freeing of IPv4 addresses that will otherwise >> > remain dormant in the hands of companies who have no incentive to transfer >> > them. >> > >> > The objective of the Specified Transfer market should be to a) encourage >> > source Companies to transfer their unused blocks thereby increasing supply >> > of IPv4 address and b) encourage recipient Companies to acquire sufficient >> > IPv4 addresses to support business plans rather than depleting the free >> > pool. >> > >> > Current policy of demonstrating need for specified transfers, be it based on >> > 12 months or now 24 months, does not provide sufficient incentive for >> > organizations to acquire unused IPv4 addresses in a financial transaction. >> > Companies recognize they must still endure the rigors of the justification >> > process regardless of free allocation or specified transfer?making it very >> > difficult to justify a financial transaction when specified transfers will >> > still be assessed by exactly the same techniques and algorithms applied for >> > approval of free resources. >> > >> > Eliminating needs-based justification has many benefits so long as all >> > transactions continue to flow through ARIN for ratification: >> > >> > a) Buyer executive attestation will ensure the IP?s are being used for >> > business purposes. Failure to be truthful could result in punitive measures >> > against corporate officers, and is a risk an officer would not be likely to >> > take >> > >> > b) Source Companies have an active market and financial incentive to >> > transfer unused IPv4 blocks to Companies with need >> > >> > c) IPv4 number resources will not be scarce if adequate incentive exists for >> > Buyers to acquire unused blocks through specified transfer >> > >> > d) Many Buyers express hesitation that confidential business plans must be >> > disclosed through the justification process?no such disclosure would be >> > required (under NDA or otherwise) >> > >> > e) Legacy blocks will come under RSA in ever increasing numbers >> > >> > f) Improves the accuracy, utility and value of the ARIN address registry >> > >> > g) Effectively kills the black or gray IPv4 transfer market guaranteeing >> > ARIN?s custodianship over number resources >> > >> > h) Encourages source Companies to free up resources and recipient Companies >> > to actively acquire available IPv4 blocks thereby eliminating speculation >> > because supply is abundant. Only when a resource is truly scarce does >> > capricious consumption (stockpiling) occur >> > >> > i) The Free resource pool is best applied to small or new ISPs while medium >> > to large corporations with greater financial wherewithal are encouraged to >> > participate in specified transfers to acquire larger IPv4 blocks >> > >> > Timetable for implementation: Immediate >> > _______________________________________________ >> > PPML >> > You are receiving this message because you are subscribed to >> > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> > Unsubscribe or manage your mailing list subscription at: >> > http://lists.arin.net/mailman/listinfo/arin-ppml >> > Please contact info at arin.net if you experience any issues. >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. >> >> > > -- > John Santos > Evans Griffiths & Hart, Inc. > 781-861-0670 ext 539 > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From dogwallah at gmail.com Fri Feb 17 00:09:03 2012 From: dogwallah at gmail.com (McTim) Date: Fri, 17 Feb 2012 05:09:03 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> Message-ID: On Friday, February 17, 2012, Peter Bui wrote: > I oppose this proposal as written. > > +1 also opposed. Regards,, McTim > On Thu, Feb 16, 2012 at 2:54 PM, ARIN 'cvml', 'info at arin.net');>> wrote: > > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified > Transfers > > ARIN received the following policy proposal and is posting it to the > Public Policy Mailing List (PPML) in accordance with the Policy > Development Process. > > The ARIN Advisory Council (AC) will review the proposal at their next > regularly scheduled meeting (if the period before the next regularly > scheduled meeting is less than 10 days, then the period may be extended > to the subsequent regularly scheduled meeting). The AC will decide how > to utilize the proposal and announce the decision to the PPML. > > The AC invites everyone to comment on the proposal on the PPML, > particularly their support or non-support and the reasoning > behind their opinion. Such participation contributes to a thorough > vetting and provides important guidance to the AC in their deliberations. > > Draft Policies and Proposals under discussion can be found at: > https://www.arin.net/policy/**proposals/index.html > > The ARIN Policy Development Process can be found at: > https://www.arin.net/policy/**pdp.html > > Mailing list subscription information can be found > at: https://www.arin.net/mailing_**lists/ > > Regards, > > Communications and Member Services > American Registry for Internet Numbers (ARIN) > > > ## * ## > > > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified > Transfers > > Proposal Originator: Jeff Mehlenbacher > > Proposal Version: 1 > > Date: 16 February 16 2012 > > Proposal type: Modify > > Policy term: Permanent > > Policy statement: > > Current Policy Statement: > 8.3. Transfers to Specified Recipients > In addition to transfers under section 8.2, IPv4 number resources within > the ARIN region may be released to ARIN by the authorized resource holder, > in whole or in part, for transfer to another specified organizational > recipient. Such transferred number resources may only be received under RSA > by organizations that are within the ARIN region and can demonstrate the > need for such resources in the amount which they can justify under current > ARIN policies showing how the addresses will be utilized within 24 months. > > Proposed Policy Statement > 8.3. Transfers to Specified Recipients > In addition to transfers under section 8.2, IPv4 number resources within > the ARIN region may be released to ARIN by the authorized resource holder, > in whole or in part, for transfer to another specified organizational > recipient. Such transferred number resources may only be received under RSA > by organizations that are within the ARIN region and requires that an > Officer Attestation be provided confirming the transferred number resources > will be applied to enable current or planned business models. > > Rationale: > > Current policy acts as a major impediment to freeing up unused IPv4 > address and constrains trade in a free market economy. If a Company > receives Board approval to spend between $11.25 and $12.00 per IP, this > should suggest the business case is justified for the acquiring > organization. The role of ARIN should be to encourage the freeing of IPv4 > addresses that will otherwise remain dormant in the hands of companies who > have no incentive to transfer them. > > The objective of the Specified Transfer market should be to a) encourage > source Companies to transfer their unused blocks thereby increasing supply > of IPv4 address and b) encourage recipient Companies to acquire sufficient > IPv4 addresses to support business plans rather than depleting the free > pool. > > Current policy of demonstrating need for specified transfers, be it based > on 12 months or now 24 months, does not provide sufficient incentive for > organizations to acquire unused IPv4 addresses in a financial transaction. > Companies recognize they must still endure the rigors of the justification > process regardless of free allocation or specified transfer?making it very > difficult to justify a financial transaction when specified transfers will > still be assessed by exactly the same techniques and algorithms applied for > approval of free resources. > > Eliminating needs-based justification has many benefits so long as all > transactions continue to flow through ARIN for ratification: > > a) Buyer executive attestation will ensure the IP?s are being used for > business purposes. Failure to be truthful could result in punitive measures > against corporate officers, and > > > -- Cheers, McTim "A name indicates what we seek. An address indicates where it is. A route indicates how we get there." Jon Postel -------------- next part -------------- An HTML attachment was scrubbed... URL: From narten at us.ibm.com Fri Feb 17 00:53:02 2012 From: narten at us.ibm.com (Thomas Narten) Date: Fri, 17 Feb 2012 00:53:02 -0500 Subject: [arin-ppml] Weekly posting summary for ppml@arin.net Message-ID: <201202170553.q1H5r2Tj024846@rotala.raleigh.ibm.com> Total of 29 messages in the last 7 days. script run at: Fri Feb 17 00:53:02 EST 2012 Messages | Bytes | Who --------+------+--------+----------+------------------------ 17.24% | 5 | 12.71% | 31448 | jcurran at arin.net 13.79% | 4 | 15.47% | 38291 | farmer at umn.edu 10.34% | 3 | 10.21% | 25265 | info at arin.net 10.34% | 3 | 7.13% | 17644 | matthew at matthew.at 6.90% | 2 | 5.55% | 13741 | andrew.dul at quark.net 3.45% | 1 | 7.76% | 19205 | petertbui0 at gmail.com 3.45% | 1 | 7.63% | 18875 | kkargel at polartel.com 3.45% | 1 | 5.75% | 14230 | astrodog at gmail.com 3.45% | 1 | 4.73% | 11708 | john at egh.com 3.45% | 1 | 4.68% | 11574 | cja at daydream.com 3.45% | 1 | 3.26% | 8077 | scottleibrand at gmail.com 3.45% | 1 | 3.14% | 7776 | owen at delong.com 3.45% | 1 | 2.68% | 6643 | narten at us.ibm.com 3.45% | 1 | 2.43% | 6004 | gary.buhrmaster at gmail.com 3.45% | 1 | 2.34% | 5793 | jlewis at lewis.org 3.45% | 1 | 2.27% | 5627 | joe at oregon.uoregon.edu 3.45% | 1 | 2.27% | 5617 | jmaimon at chl.com --------+------+--------+----------+------------------------ 100.00% | 29 |100.00% | 247518 | Total From jeffmehlenbacher at ipv4marketgroup.com Fri Feb 17 01:41:20 2012 From: jeffmehlenbacher at ipv4marketgroup.com (jeffmehlenbacher at ipv4marketgroup.com) Date: Thu, 16 Feb 2012 23:41:20 -0700 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers Message-ID: <20120216234120.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.4dac8447f5.wbe@email17.secureserver.net> An HTML attachment was scrubbed... URL: From jeffmehlenbacher at ipv4marketgroup.com Fri Feb 17 01:49:42 2012 From: jeffmehlenbacher at ipv4marketgroup.com (jeffmehlenbacher at ipv4marketgroup.com) Date: Thu, 16 Feb 2012 23:49:42 -0700 Subject: [arin-ppml] ARIN-PPML Message ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers Message-ID: <20120216234942.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.c006a75b2a.wbe@email17.secureserver.net> Yes, it is the author's desire to allow only business models that need addresses to deploy operational networks. This would certainly include ISPs, Web Hosting Companies, Cloud Computing Companies, CDNs, Software Development Companies and the like. Jeff Mehlenbacher From jeffmehlenbacher at ipv4marketgroup.com Fri Feb 17 02:17:18 2012 From: jeffmehlenbacher at ipv4marketgroup.com (jeffmehlenbacher at ipv4marketgroup.com) Date: Fri, 17 Feb 2012 00:17:18 -0700 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification Message-ID: <20120217001718.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.e0949ab319.wbe@email17.secureserver.net> I would agree that free allocations should be scrutinized closely to ensure need. For 8.3 Specified Transfers however, no purpose is served when a transfer is rejected between a Company with an unused allocation and a Company in need. The unused IPv4 block at the source Company remains unused. The rejected recipient Company must seek alternatives which may include applying to ARIN for a smaller block from the free pool. Jeff Mehlenbacher I am opposed to this policy. For as long as ARIN has existed this community has been very vocal in supporting the needs basis for address allocations and assignments. I have no reason to believe that this position has changed. ----Cathy From john.sweeting at twcable.com Fri Feb 17 08:56:36 2012 From: john.sweeting at twcable.com (Sweeting, John) Date: Fri, 17 Feb 2012 08:56:36 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: Message-ID: On 2/16/12 10:32 PM, "Astrodog" wrote: >On Thu, Feb 16, 2012 at 6:27 PM, John Santos wrote: >> +1 >> >> Also opposed. >> >> Isn't "making lots of money by cornering the IPv4 address market" also >> a "business purpose"? > >Support. > >I believe the concern about speculation with IP addresses is fairly >overblown. If an entity were to attempt such a move, it would induce >more efficent usage among existing users, so that they could sell >portions of their space (or avoid purchasing additional address >space). This carries with it a very large risk that the addresses such >an entity purchased would become nearly worthless, either due to >oversupply as large address space holders sold off their space, or due >to IPv6 migration and more efficent utilization due to the short term >increased cost driving demand for the addresses down over longer >periods of time. > >It is unlikely, given these concerns, that such an endevour would be >attempted on a large scale or that such an attempt would have any >significant impact on long term "pricing" of IPv4 addresses. > >The positives with such an approach are significant, though, as it >greatly reduces the time and effort required on the part of both >parties, as well as ARIN, to effect such a transfer, making it much >easier for IP addresses to go to those entities who will use them. So what is the harm in asking them to share how they will be using them? Is it your belief that just makes it "too hard"? > >The situation, as things stand today, appears to involve companies >deciding to arrainge such a transfer, then trying to back in to a >justification under 8.3. > >--- Harrison Just wondering, do you know of any organizations today that face that situation? > >> On Thu, 16 Feb 2012, CJ Aronson wrote: >> >>> I am opposed to this policy. For as long as ARIN has existed this >>> community has been very vocal in supporting the needs basis for >>> address allocations and assignments. I have no reason to believe that >>> this position has changed. >>> >>> ----Cathy >>> >>> On Thu, Feb 16, 2012 at 3:54 PM, ARIN wrote: >>> > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified >>>Transfers >>> > >>> > ARIN received the following policy proposal and is posting it to the >>> > Public Policy Mailing List (PPML) in accordance with the Policy >>> > Development Process. >>> > >>> > The ARIN Advisory Council (AC) will review the proposal at their next >>> > regularly scheduled meeting (if the period before the next regularly >>> > scheduled meeting is less than 10 days, then the period may be >>>extended >>> > to the subsequent regularly scheduled meeting). The AC will decide >>>how >>> > to utilize the proposal and announce the decision to the PPML. >>> > >>> > The AC invites everyone to comment on the proposal on the PPML, >>> > particularly their support or non-support and the reasoning >>> > behind their opinion. Such participation contributes to a thorough >>> > vetting and provides important guidance to the AC in their >>>deliberations. >>> > >>> > Draft Policies and Proposals under discussion can be found at: >>> > https://www.arin.net/policy/proposals/index.html >>> > >>> > The ARIN Policy Development Process can be found at: >>> > https://www.arin.net/policy/pdp.html >>> > >>> > Mailing list subscription information can be found >>> > at: https://www.arin.net/mailing_lists/ >>> > >>> > Regards, >>> > >>> > Communications and Member Services >>> > American Registry for Internet Numbers (ARIN) >>> > >>> > >>> > ## * ## >>> > >>> > >>> > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified >>>Transfers >>> > >>> > Proposal Originator: Jeff Mehlenbacher >>> > >>> > Proposal Version: 1 >>> > >>> > Date: 16 February 16 2012 >>> > >>> > Proposal type: Modify >>> > >>> > Policy term: Permanent >>> > >>> > Policy statement: >>> > >>> > Current Policy Statement: >>> > 8.3. Transfers to Specified Recipients >>> > In addition to transfers under section 8.2, IPv4 number resources >>>within the >>> > ARIN region may be released to ARIN by the authorized resource >>>holder, in >>> > whole or in part, for transfer to another specified organizational >>> > recipient. Such transferred number resources may only be received >>>under RSA >>> > by organizations that are within the ARIN region and can demonstrate >>>the >>> > need for such resources in the amount which they can justify under >>>current >>> > ARIN policies showing how the addresses will be utilized within 24 >>>months. >>> > >>> > Proposed Policy Statement >>> > 8.3. Transfers to Specified Recipients >>> > In addition to transfers under section 8.2, IPv4 number resources >>>within the >>> > ARIN region may be released to ARIN by the authorized resource >>>holder, in >>> > whole or in part, for transfer to another specified organizational >>> > recipient. Such transferred number resources may only be received >>>under RSA >>> > by organizations that are within the ARIN region and requires that an >>> > Officer Attestation be provided confirming the transferred number >>>resources >>> > will be applied to enable current or planned business models. >>> > >>> > Rationale: >>> > >>> > Current policy acts as a major impediment to freeing up unused IPv4 >>>address >>> > and constrains trade in a free market economy. If a Company receives >>>Board >>> > approval to spend between $11.25 and $12.00 per IP, this should >>>suggest the >>> > business case is justified for the acquiring organization. The role >>>of ARIN >>> > should be to encourage the freeing of IPv4 addresses that will >>>otherwise >>> > remain dormant in the hands of companies who have no incentive to >>>transfer >>> > them. >>> > >>> > The objective of the Specified Transfer market should be to a) >>>encourage >>> > source Companies to transfer their unused blocks thereby increasing >>>supply >>> > of IPv4 address and b) encourage recipient Companies to acquire >>>sufficient >>> > IPv4 addresses to support business plans rather than depleting the >>>free >>> > pool. >>> > >>> > Current policy of demonstrating need for specified transfers, be it >>>based on >>> > 12 months or now 24 months, does not provide sufficient incentive for >>> > organizations to acquire unused IPv4 addresses in a financial >>>transaction. >>> > Companies recognize they must still endure the rigors of the >>>justification >>> > process regardless of free allocation or specified transfer?making >>>it very >>> > difficult to justify a financial transaction when specified >>>transfers will >>> > still be assessed by exactly the same techniques and algorithms >>>applied for >>> > approval of free resources. >>> > >>> > Eliminating needs-based justification has many benefits so long as >>>all >>> > transactions continue to flow through ARIN for ratification: >>> > >>> > a) Buyer executive attestation will ensure the IP?s are being used >>>for >>> > business purposes. Failure to be truthful could result in punitive >>>measures >>> > against corporate officers, and is a risk an officer would not be >>>likely to >>> > take >>> > >>> > b) Source Companies have an active market and financial incentive to >>> > transfer unused IPv4 blocks to Companies with need >>> > >>> > c) IPv4 number resources will not be scarce if adequate incentive >>>exists for >>> > Buyers to acquire unused blocks through specified transfer >>> > >>> > d) Many Buyers express hesitation that confidential business plans >>>must be >>> > disclosed through the justification process?no such disclosure would >>>be >>> > required (under NDA or otherwise) >>> > >>> > e) Legacy blocks will come under RSA in ever increasing numbers >>> > >>> > f) Improves the accuracy, utility and value of the ARIN address >>>registry >>> > >>> > g) Effectively kills the black or gray IPv4 transfer market >>>guaranteeing >>> > ARIN?s custodianship over number resources >>> > >>> > h) Encourages source Companies to free up resources and recipient >>>Companies >>> > to actively acquire available IPv4 blocks thereby eliminating >>>speculation >>> > because supply is abundant. Only when a resource is truly scarce does >>> > capricious consumption (stockpiling) occur >>> > >>> > i) The Free resource pool is best applied to small or new ISPs while >>>medium >>> > to large corporations with greater financial wherewithal are >>>encouraged to >>> > participate in specified transfers to acquire larger IPv4 blocks >>> > >>> > Timetable for implementation: Immediate >>> > _______________________________________________ >>> > PPML >>> > You are receiving this message because you are subscribed to >>> > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >>> > Unsubscribe or manage your mailing list subscription at: >>> > http://lists.arin.net/mailman/listinfo/arin-ppml >>> > Please contact info at arin.net if you experience any issues. >>> _______________________________________________ >>> PPML >>> You are receiving this message because you are subscribed to >>> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >>> Unsubscribe or manage your mailing list subscription at: >>> http://lists.arin.net/mailman/listinfo/arin-ppml >>> Please contact info at arin.net if you experience any issues. >>> >>> >> >> -- >> John Santos >> Evans Griffiths & Hart, Inc. >> 781-861-0670 ext 539 >> >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. >_______________________________________________ >PPML >You are receiving this message because you are subscribed to >the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >Unsubscribe or manage your mailing list subscription at: >http://lists.arin.net/mailman/listinfo/arin-ppml >Please contact info at arin.net if you experience any issues. 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From astrodog at gmail.com Fri Feb 17 09:13:48 2012 From: astrodog at gmail.com (Astrodog) Date: Fri, 17 Feb 2012 08:13:48 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: References: Message-ID: On Fri, Feb 17, 2012 at 7:56 AM, Sweeting, John wrote: > > > On 2/16/12 10:32 PM, "Astrodog" wrote: > >>On Thu, Feb 16, 2012 at 6:27 PM, John Santos wrote: >>> +1 >>> >>> Also opposed. >>> >>> Isn't "making lots of money by cornering the IPv4 address market" also >>> a "business purpose"? >> >>Support. >> >>I believe the concern about speculation with IP addresses is fairly >>overblown. If an entity were to attempt such a move, it would induce >>more efficent usage among existing users, so that they could sell >>portions of their space (or avoid purchasing additional address >>space). This carries with it a very large risk that the addresses such >>an entity purchased would become nearly worthless, either due to >>oversupply as large address space holders sold off their space, or due >>to IPv6 migration and more efficent utilization due to the short term >>increased cost driving demand for the addresses down over longer >>periods of time. >> >>It is unlikely, given these concerns, that such an endevour would be >>attempted on a large scale or that such an attempt would have any >>significant impact on long term "pricing" of IPv4 addresses. >> >>The positives with such an approach are significant, though, as it >>greatly reduces the time and effort required on the part of both >>parties, as well as ARIN, to effect such a transfer, making it much >>easier for IP addresses to go to those entities who will use them. > > So what is the harm in asking them to share how they will be using them? > Is it your belief that just makes it "too hard"? > The problem lies more in the time and labor required to make the transfer itself happen. Needs-based justification is not an instant process, and involves arrainging for legal disclosure of whatever it is they plan to do. As a result, companies are likely to purchase, and justify larger allocations than they would otherwise, simply to avoid repeating the hassle, even if it means they end up just sitting on those addresses for quite some time. Obviously, organizations request allocations now. The existing process is not so difficult as to be unworkable. I simply believe that removing the needs-based justification will improve the utilization of addresses because it will become easier for organizations to obtain addresses quickly, when they need them, and easier for them to sell addresses to someone else when they do not. > >> >>The situation, as things stand today, appears to involve companies >>deciding to arrainge such a transfer, then trying to back in to a >>justification under 8.3. >> >>--- Harrison > > Just wondering, do you know of any organizations today that face that > situation? Most organizations I deal with work at fairly small scales as far as IP allocations go. In those organizations, the rule appears to largely be, "Request as much space as we can possibly justify. We'll come up with something to do with it later." I have not seen this applied to inter-organizational transfers, but I don't see where the distinction would be from their perspective. --- Harrison ... snip ... From paul at redbarn.org Fri Feb 17 09:18:49 2012 From: paul at redbarn.org (Paul Vixie) Date: Fri, 17 Feb 2012 14:18:49 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <20120217001718.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.e0949ab319.wbe@email17.secureserver.net> References: <20120217001718.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.e0949ab319.wbe@email17.secureserver.net> Message-ID: <4F3E61C9.4040801@redbarn.org> On 2012-02-17 7:17 AM, jeffmehlenbacher at ipv4marketgroup.com wrote: > I would agree that free allocations should be scrutinized closely to > ensure need. For 8.3 Specified Transfers however, no purpose is served > when a transfer is rejected between a Company with an unused allocation > and a Company in need. The unused IPv4 block at the source Company > remains unused. The rejected recipient Company must seek alternatives > which may include applying to ARIN for a smaller block from the free > pool. > > Jeff Mehlenbacher jeff, i'm concerned with the case where a broker actually holds address space. the current transfer system allows recipients with greater need to receive resources from those with lesser need. i do not understand the value add of putting resources into a broker's inventory. --paul From dogwallah at gmail.com Fri Feb 17 09:47:43 2012 From: dogwallah at gmail.com (McTim) Date: Fri, 17 Feb 2012 14:47:43 +0000 Subject: [arin-ppml] ARIN-PPML Message ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: <20120216234942.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.c006a75b2a.wbe@email17.secureserver.net> References: <20120216234942.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.c006a75b2a.wbe@email17.secureserver.net> Message-ID: On Friday, February 17, 2012, wrote: > Yes, it is the author's desire to allow only business models that need > addresses to deploy operational networks. Then perhaps you could express that in your policy proposal. If you do however, it seems to me to be a no-op. what am I missing? Rgds,, McTim > This would certainly include > ISPs, Web Hosting Companies, Cloud Computing Companies, CDNs, Software > Development Companies and the like. > > Jeff Mehlenbacher > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net ). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. > -- Cheers, McTim "A name indicates what we seek. An address indicates where it is. A route indicates how we get there." Jon Postel -------------- next part -------------- An HTML attachment was scrubbed... URL: From jeffmehlenbacher at ipv4marketgroup.com Fri Feb 17 10:19:01 2012 From: jeffmehlenbacher at ipv4marketgroup.com (jeffmehlenbacher at ipv4marketgroup.com) Date: Fri, 17 Feb 2012 08:19:01 -0700 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification Message-ID: <20120217081901.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.34816080d0.wbe@email17.secureserver.net> An HTML attachment was scrubbed... URL: From jeffmehlenbacher at ipv4marketgroup.com Fri Feb 17 10:22:42 2012 From: jeffmehlenbacher at ipv4marketgroup.com (jeffmehlenbacher at ipv4marketgroup.com) Date: Fri, 17 Feb 2012 08:22:42 -0700 Subject: [arin-ppml] ARIN-PPML Message ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers Message-ID: <20120217082242.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.0ce1598ba1.wbe@email17.secureserver.net> An HTML attachment was scrubbed... URL: From paul at redbarn.org Fri Feb 17 10:27:08 2012 From: paul at redbarn.org (Paul Vixie) Date: Fri, 17 Feb 2012 15:27:08 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <20120217081901.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.34816080d0.wbe@email17.secureserver.net> References: <20120217081901.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.34816080d0.wbe@email17.secureserver.net> Message-ID: <4F3E71CC.1000907@redbarn.org> On 2012-02-17 3:19 PM, jeffmehlenbacher at ipv4marketgroup.com wrote: > Paul, I cannot speak to how other brokers structure their business, > but we do not actually hold address space if I interpret you > literally. Our Sellers hold the address space. We are contracted by > companies with unused IPv4 blocks to source a company with need. Once > a potential needer is identified, we facilitate agreement on price, > timing and other conditions of a transfer then provide the necessary > legal documents and guidance to execute the transactions contingent > upon ARIN approval. The value of any broker--be it insurance, > mortgage, real estate or IPv4 transfers--is subjective but clearly if > a Seller and a Buyer prefer to use a broker, they should do so. The > Policy Proposal as written assumes there may or may not be broker > involvement in Specified Transfers. thank you jeff. it seems that you have misunderstood the current policies, which allow everything you describe, so long as the needer can demonstrate that need to ARIN. there is a place in the "transfer listing service" for brokers, too. i'm at a loss to understand what it about the current transfer policies that won't fit the model you're describing above. paul -------------- next part -------------- An HTML attachment was scrubbed... URL: From hannigan at gmail.com Fri Feb 17 10:26:49 2012 From: hannigan at gmail.com (Martin Hannigan) Date: Fri, 17 Feb 2012 10:26:49 -0500 Subject: [arin-ppml] ARIN-PPML Message ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: <20120217082242.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.0ce1598ba1.wbe@email17.secureserver.net> References: <20120217082242.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.0ce1598ba1.wbe@email17.secureserver.net> Message-ID: It already works that way. By default, you need a business model in order to run a business, no? If that business is an internet business and you need addresses, you're already covered. If you mean something else, businesss model per se is going to be extremely difficult to define. IMHO. Best, -M< On Fri, Feb 17, 2012 at 10:22 AM, wrote: > Forgive me McTim, what is a "no-op?" > > Jeff > > > -------- Original Message -------- > Subject: Re: [arin-ppml] ARIN-PPML Message ARIN-prop-165 Eliminate > Needs-Based Justification on 8.3 Specified Transfers > From: McTim > Date: Fri, February 17, 2012 9:47 am > To: "jeffmehlenbacher at ipv4marketgroup.com" > > Cc: "arin-ppml at arin.net" > > > > On Friday, February 17, 2012, wrote: >> >> Yes, it is the author's desire to allow only business models that need >> addresses to deploy operational networks. > > > > Then perhaps you could express that in your policy proposal. > > If you do however, it seems to me to be a no-op. ?what am I missing? > > Rgds,, > > McTim > > >> >> ?This would certainly include >> ISPs, Web Hosting Companies, Cloud Computing Companies, CDNs, Software >> Development Companies and the like. >> >> Jeff Mehlenbacher >> >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. > > > > -- > Cheers, > > McTim > "A name indicates what we seek. An address indicates where it is. A route > indicates how we get there."? Jon Postel > > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From jeffmehlenbacher at ipv4marketgroup.com Fri Feb 17 10:35:07 2012 From: jeffmehlenbacher at ipv4marketgroup.com (jeffmehlenbacher at ipv4marketgroup.com) Date: Fri, 17 Feb 2012 08:35:07 -0700 Subject: [arin-ppml] ARIN-PPML Message ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers Message-ID: <20120217083507.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.c8a1573bce.wbe@email17.secureserver.net> Thank you. Jeff -------- Original Message -------- Subject: Re: [arin-ppml] ARIN-PPML Message ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers From: Lee Dilkie Date: Fri, February 17, 2012 10:26 am To: jeffmehlenbacher at ipv4marketgroup.com Cc: McTim , "arin-ppml at arin.net" it's computer talk for "no operation".. believe it or not, computer processors have a "nop" instruction, ie. "do nothing". And sometimes, doing nothing is actually useful. -lee On 2/17/2012 10:22 AM, jeffmehlenbacher at ipv4marketgroup.com wrote: Forgive me McTim, what is a "no-op?" Jeff -------- Original Message -------- Subject: Re: [arin-ppml] ARIN-PPML Message ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers From: McTim Date: Fri, February 17, 2012 9:47 am To: "jeffmehlenbacher at ipv4marketgroup.com" Cc: "arin-ppml at arin.net" On Friday, February 17, 2012, wrote: Yes, it is the author's desire to allow only business models that need addresses to deploy operational networks. Then perhaps you could express that in your policy proposal. If you do however, it seems to me to be a no-op. what am I missing? Rgds,, McTim This would certainly include ISPs, Web Hosting Companies, Cloud Computing Companies, CDNs, Software Development Companies and the like. Jeff Mehlenbacher _______________________________________________ PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). Unsubscribe or manage your mailing list subscription at: http://lists.arin.net/mailman/listinfo/arin-ppml Please contact info at arin.net if you experience any issues. -- Cheers, McTim "A name indicates what we seek. An address indicates where it is. A route indicates how we get there." Jon Postel _______________________________________________PPMLYou are receiving this message because you are subscribed tothe ARIN Public Policy Mailing List (ARIN-PPML at arin.net).Unsubscribe or manage your mailing list subscription at:http://lists.arin.net/mailman/listinfo/arin-ppmlPlease contact info at arin.net if you experience any issues. From d.bucciero at wwpass.com Fri Feb 17 10:33:01 2012 From: d.bucciero at wwpass.com (David Bucciero) Date: Fri, 17 Feb 2012 10:33:01 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: <4F3D891C.6060507@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> Message-ID: <4F3E732D.6020706@wwpass.com> I am new to ARIN having received our ASN, IPv4 & IPv6 only a week or so ago. I appreciated the scrutiny for ASN & IPv4 but not for IPv6 as I feel it is too early to scrutinize IPv6. I would be opposed to this proposal as currently written. Best regards, Dave On 2/16/12 5:54 PM, ARIN wrote: > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified > Transfers > > ARIN received the following policy proposal and is posting it to the > Public Policy Mailing List (PPML) in accordance with the Policy > Development Process. > > The ARIN Advisory Council (AC) will review the proposal at their next > regularly scheduled meeting (if the period before the next regularly > scheduled meeting is less than 10 days, then the period may be extended > to the subsequent regularly scheduled meeting). The AC will decide how > to utilize the proposal and announce the decision to the PPML. > > The AC invites everyone to comment on the proposal on the PPML, > particularly their support or non-support and the reasoning > behind their opinion. Such participation contributes to a thorough > vetting and provides important guidance to the AC in their deliberations. > > Draft Policies and Proposals under discussion can be found at: > https://www.arin.net/policy/proposals/index.html > > The ARIN Policy Development Process can be found at: > https://www.arin.net/policy/pdp.html > > Mailing list subscription information can be found > at: https://www.arin.net/mailing_lists/ > > Regards, > > Communications and Member Services > American Registry for Internet Numbers (ARIN) > > > ## * ## > > > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified > Transfers > > Proposal Originator: Jeff Mehlenbacher > > Proposal Version: 1 > > Date: 16 February 16 2012 > > Proposal type: Modify > > Policy term: Permanent > > Policy statement: > > Current Policy Statement: > 8.3. Transfers to Specified Recipients > In addition to transfers under section 8.2, IPv4 number resources > within the ARIN region may be released to ARIN by the authorized > resource holder, in whole or in part, for transfer to another > specified organizational recipient. Such transferred number resources > may only be received under RSA by organizations that are within the > ARIN region and can demonstrate the need for such resources in the > amount which they can justify under current ARIN policies showing how > the addresses will be utilized within 24 months. > > Proposed Policy Statement > 8.3. Transfers to Specified Recipients > In addition to transfers under section 8.2, IPv4 number resources > within the ARIN region may be released to ARIN by the authorized > resource holder, in whole or in part, for transfer to another > specified organizational recipient. Such transferred number resources > may only be received under RSA by organizations that are within the > ARIN region and requires that an Officer Attestation be provided > confirming the transferred number resources will be applied to enable > current or planned business models. > > Rationale: > > Current policy acts as a major impediment to freeing up unused IPv4 > address and constrains trade in a free market economy. If a Company > receives Board approval to spend between $11.25 and $12.00 per IP, > this should suggest the business case is justified for the acquiring > organization. The role of ARIN should be to encourage the freeing of > IPv4 addresses that will otherwise remain dormant in the hands of > companies who have no incentive to transfer them. > > The objective of the Specified Transfer market should be to a) > encourage source Companies to transfer their unused blocks thereby > increasing supply of IPv4 address and b) encourage recipient Companies > to acquire sufficient IPv4 addresses to support business plans rather > than depleting the free pool. > > Current policy of demonstrating need for specified transfers, be it > based on 12 months or now 24 months, does not provide sufficient > incentive for organizations to acquire unused IPv4 addresses in a > financial transaction. Companies recognize they must still endure the > rigors of the justification process regardless of free allocation or > specified transfer?making it very difficult to justify a financial > transaction when specified transfers will still be assessed by exactly > the same techniques and algorithms applied for approval of free > resources. > > Eliminating needs-based justification has many benefits so long as all > transactions continue to flow through ARIN for ratification: > > a) Buyer executive attestation will ensure the IP?s are being used for > business purposes. Failure to be truthful could result in punitive > measures against corporate officers, and is a risk an officer would > not be likely to take > > b) Source Companies have an active market and financial incentive to > transfer unused IPv4 blocks to Companies with need > > c) IPv4 number resources will not be scarce if adequate incentive > exists for Buyers to acquire unused blocks through specified transfer > > d) Many Buyers express hesitation that confidential business plans > must be disclosed through the justification process?no such disclosure > would be required (under NDA or otherwise) > > e) Legacy blocks will come under RSA in ever increasing numbers > > f) Improves the accuracy, utility and value of the ARIN address registry > > g) Effectively kills the black or gray IPv4 transfer market > guaranteeing ARIN?s custodianship over number resources > > h) Encourages source Companies to free up resources and recipient > Companies to actively acquire available IPv4 blocks thereby > eliminating speculation because supply is abundant. Only when a > resource is truly scarce does capricious consumption (stockpiling) occur > > i) The Free resource pool is best applied to small or new ISPs while > medium to large corporations with greater financial wherewithal are > encouraged to participate in specified transfers to acquire larger > IPv4 blocks > > Timetable for implementation: Immediate > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. -- *David L. Bucciero* WWPass Logo *IT Director* | WWPass Corporation 5 Bedford Farms Drive, Bedford, New Hampshire 03110 1.603.782.0319 d.bucciero at wwpass.com <="" a=""> wwpass.com -------------- next part -------------- An HTML attachment was scrubbed... URL: -------------- next part -------------- A non-text attachment was scrubbed... Name: WWPass_logo.png Type: image/png Size: 1492 bytes Desc: not available URL: From jcurran at arin.net Fri Feb 17 10:41:24 2012 From: jcurran at arin.net (John Curran) Date: Fri, 17 Feb 2012 15:41:24 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <20120217001718.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.e0949ab319.wbe@email17.secureserver.net> References: <20120217001718.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.e0949ab319.wbe@email17.secureserver.net> Message-ID: <07128B62-A4CB-497F-B964-57EA298C7457@corp.arin.net> On Feb 17, 2012, at 2:17 AM, jeffmehlenbacher at ipv4marketgroup.com wrote: > I would agree that free allocations should be scrutinized closely to > ensure need. For 8.3 Specified Transfers however, no purpose is served > when a transfer is rejected between a Company with an unused allocation > and a Company in need. The unused IPv4 block at the source Company > remains unused. The rejected recipient Company must seek alternatives > which may include applying to ARIN for a smaller block from the free > pool. Jeff - Present policies require that the recipient "can demonstrate the need for such resources in the amount which they can justify under current ARIN policies showing how the addresses will be utilized within 24 months." Due to the reference to present ARIN policies, the organizations that can demonstrate the need would be service providers who need IP addresses for the network services they provide, and end-user organizations receiving assignments of IP addresses for use in its operational networks. If this constraint on recipients is what you intended in your policy proposal, then it would be best to make it explicit that transfers are permitted to organizations with an operational need for addresses to support their network deployment. I am confident that the ARIN AC can work with you to determine the appropriate wording if that is the case. Best wishes, /John John Curran President and CEO ARIN From jeffmehlenbacher at ipv4marketgroup.com Fri Feb 17 10:46:45 2012 From: jeffmehlenbacher at ipv4marketgroup.com (jeffmehlenbacher at ipv4marketgroup.com) Date: Fri, 17 Feb 2012 08:46:45 -0700 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification Message-ID: <20120217084645.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.cff46d3785.wbe@email17.secureserver.net> Yes, we are part of the Specified Transfer Listing Service and have a very good grasp on current policy governing 8.3s including the recent change to demonstrating need based on 24 months rather than 12 months. Our Policy Proposal seeks to provide the necessary incentive for Companies with unused IPs to actively put them to use through a transfer and further seeks to motivate Companies with need to use Specified Transfer though ARIN. The current practice of justifying need for Specified Transfers is a disincentive for many potential recipient organizations to participate in this market. Lack of demand directly affects the freeing of dormant supply. Jeff -------- Original Message -------- Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification From: Paul Vixie Date: Fri, February 17, 2012 10:27 am To: jeffmehlenbacher at ipv4marketgroup.com Cc: arin-ppml at arin.net On 2012-02-17 3:19 PM, jeffmehlenbacher at ipv4marketgroup.com wrote: Paul, I cannot speak to how other brokers structure their business, but we do not actually hold address space if I interpret you literally. Our Sellers hold the address space. We are contracted by companies with unused IPv4 blocks to source a company with need. Once a potential needer is identified, we facilitate agreement on price, timing and other conditions of a transfer then provide the necessary legal documents and guidance to execute the transactions contingent upon ARIN approval. The value of any broker--be it insurance, mortgage, real estate or IPv4 transfers--is subjective but clearly if a Seller and a Buyer prefer to use a broker, they should do so. The Policy Proposal as written assumes there may or may not be broker involvement in Specified Transfers. thank you jeff. it seems that you have misunderstood the current policies, which allow everything you describe, so long as the needer can demonstrate that need to ARIN. there is a place in the "transfer listing service" for brokers, too. i'm at a loss to understand what it about the current transfer policies that won't fit the model you're describing above. paul From jeffmehlenbacher at ipv4marketgroup.com Fri Feb 17 10:55:42 2012 From: jeffmehlenbacher at ipv4marketgroup.com (jeffmehlenbacher at ipv4marketgroup.com) Date: Fri, 17 Feb 2012 08:55:42 -0700 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification Message-ID: <20120217085542.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.1b40b97925.wbe@email17.secureserver.net> Thank you John. I would be pleased to work with the ARIN AC to determine appropriate wording. Jeff Mehlenbacher -------- Original Message -------- Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification From: John Curran Date: Fri, February 17, 2012 10:41 am To: "jeffmehlenbacher at ipv4marketgroup.com" Cc: "arin-ppml at arin.net" On Feb 17, 2012, at 2:17 AM, jeffmehlenbacher at ipv4marketgroup.com wrote: > I would agree that free allocations should be scrutinized closely to > ensure need. For 8.3 Specified Transfers however, no purpose is served > when a transfer is rejected between a Company with an unused allocation > and a Company in need. The unused IPv4 block at the source Company > remains unused. The rejected recipient Company must seek alternatives > which may include applying to ARIN for a smaller block from the free > pool. Jeff - Present policies require that the recipient "can demonstrate the need for such resources in the amount which they can justify under current ARIN policies showing how the addresses will be utilized within 24 months." Due to the reference to present ARIN policies, the organizations that can demonstrate the need would be service providers who need IP addresses for the network services they provide, and end-user organizations receiving assignments of IP addresses for use in its operational networks. If this constraint on recipients is what you intended in your policy proposal, then it would be best to make it explicit that transfers are permitted to organizations with an operational need for addresses to support their network deployment. I am confident that the ARIN AC can work with you to determine the appropriate wording if that is the case. Best wishes, /John John Curran President and CEO ARIN From lee at dilkie.com Fri Feb 17 10:26:05 2012 From: lee at dilkie.com (Lee Dilkie) Date: Fri, 17 Feb 2012 10:26:05 -0500 Subject: [arin-ppml] ARIN-PPML Message ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: <20120217082242.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.0ce1598ba1.wbe@email17.secureserver.net> References: <20120217082242.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.0ce1598ba1.wbe@email17.secureserver.net> Message-ID: <4F3E718D.9090702@dilkie.com> it's computer talk for "no operation".. believe it or not, computer processors have a "nop" instruction, ie. "do nothing". And sometimes, doing nothing is actually useful. -lee On 2/17/2012 10:22 AM, jeffmehlenbacher at ipv4marketgroup.com wrote: > Forgive me McTim, what is a "no-op?" > > Jeff > > > -------- Original Message -------- > Subject: Re: [arin-ppml] ARIN-PPML Message ARIN-prop-165 Eliminate > Needs-Based Justification on 8.3 Specified Transfers > From: McTim > > Date: Fri, February 17, 2012 9:47 am > To: "jeffmehlenbacher at ipv4marketgroup.com > " > > > Cc: "arin-ppml at arin.net " > > > > > > On Friday, February 17, 2012, wrote: > > Yes, it is the author's desire to allow only business models > that need > addresses to deploy operational networks. > > > > Then perhaps you could express that in your policy proposal. > > If you do however, it seems to me to be a no-op. what am I missing? > > Rgds,, > > McTim > > > > This would certainly include > ISPs, Web Hosting Companies, Cloud Computing Companies, CDNs, > Software > Development Companies and the like. > > Jeff Mehlenbacher > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net <;>). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net <;> if you experience any issues. > > > > -- > Cheers, > > McTim > "A name indicates what we seek. An address indicates where it is. > A route indicates how we get there." Jon Postel > > > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. -------------- next part -------------- An HTML attachment was scrubbed... URL: From kkargel at polartel.com Fri Feb 17 11:35:25 2012 From: kkargel at polartel.com (Kevin Kargel) Date: Fri, 17 Feb 2012 10:35:25 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <20120217084645.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.cff46d3785.wbe@email17.secureserver.net> References: <20120217084645.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.cff46d3785.wbe@email17.secureserver.net> Message-ID: <8695009A81378E48879980039EEDAD28011E05E3F8@MAIL1.polartel.local> > -----Original Message----- > From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On > Behalf Of jeffmehlenbacher at ipv4marketgroup.com > Sent: Friday, February 17, 2012 9:47 AM > To: Paul Vixie > Cc: arin-ppml at arin.net > Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification > > Yes, we are part of the Specified Transfer Listing Service and have a > very good grasp on current policy governing 8.3s including the recent > change to demonstrating need based on 24 months rather than 12 months. > Our Policy Proposal seeks to provide the necessary incentive for > Companies with unused IPs to actively put them to use through a transfer > and further seeks to motivate Companies with need to use Specified > Transfer though ARIN. The current practice of justifying need for > Specified Transfers is a disincentive for many potential recipient > organizations to participate in this market. Lack of demand directly > affects the freeing of dormant supply. > > Jeff [kjk] To my read this plainly says that the intent is to make transfer facilitation more profitable. I do not believe it is within ARIN's mission or scope to write policy with the intent of maximizing profit within an IP address market. I even more strongly opposed to this proposal. > > > > -------- Original Message -------- > Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based > Justification > From: Paul Vixie > Date: Fri, February 17, 2012 10:27 am > To: jeffmehlenbacher at ipv4marketgroup.com > Cc: arin-ppml at arin.net > > On 2012-02-17 3:19 PM, jeffmehlenbacher at ipv4marketgroup.com wrote: > Paul, I cannot speak to how other brokers structure their business, but > we do not actually hold address space if I interpret you literally. Our > Sellers hold the address space. We are contracted by companies with > unused IPv4 blocks to source a company with need. Once a potential > needer is identified, we facilitate agreement on price, timing and other > conditions of a transfer then provide the necessary legal documents and > guidance to execute the transactions contingent upon ARIN approval. The > value of any broker--be it insurance, mortgage, real estate or IPv4 > transfers--is subjective but clearly if a Seller and a Buyer prefer to > use a broker, they should do so. The Policy Proposal as written assumes > there may or may not be broker involvement in Specified Transfers. > > thank you jeff. it seems that you have misunderstood the current > policies, which allow everything you describe, so long as the needer can > demonstrate that need to ARIN. there is a place in the "transfer listing > service" for brokers, too. i'm at a loss to understand what it about the > current transfer policies that won't fit the model you're describing > above. > > paul > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. -------------- next part -------------- A non-text attachment was scrubbed... Name: smime.p7s Type: application/x-pkcs7-signature Size: 6012 bytes Desc: not available URL: From Daniel_Alexander at Cable.Comcast.com Fri Feb 17 11:42:08 2012 From: Daniel_Alexander at Cable.Comcast.com (Alexander, Daniel) Date: Fri, 17 Feb 2012 16:42:08 +0000 Subject: [arin-ppml] Prop-151: Clarifying requirements for IPv4 transfers (was "Limiting needs...") Message-ID: Hello All, The Staff and Legal review has been provided to the AC for prop-151. The review focused mainly on the 12 month needs assessment given that the Board has recently ratified 2011-12 which changed the transfer needs assessment to 24 months. This update and a few others are listed below. Another change that has been suggested is to include transfers in the 12 month restrictions on the source of a transfer. The resulting text would read as follows. "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." The intent of this change would be to limit an organization from "flipping" transferred resources. Do people feel that this should be incorporated into the text? All feedback is appreciated. Dan Alexander AC Shepherd Changes to prop-151 text: - Restored a needs requirement to the text. - Eliminated the /12 cap on resources received. - Removed the suggestions to altering the text of the RSA. - Removed the section regarding "Conditions on the IPv4 address block". - Revised the condition of space being administered by ARIN to incorporate inter-RIR transfers as a result of 2011-1. - Moved the minimum transfer size requirement down to remaining Conditions. - Separated in-region and inter-region transfers into separate sections. - Clarified the starting point of the 12 month restrictions as a result of staff feedback. - Changed the proposal title from "Limiting needs..." to "Clarifying Requirements..." as a result of feedback. - Updated needs requirement from 12 to 24 months as a result of 2011-12. Current text: Replace Section 8.3 with 8.3 Transfers between Specified Recipients within the ARIN Region. In addition to transfers under section 8.2, IPv4 numbers resources may be transferred according to the following conditions. Conditions on source of the transfer: * The source entity must be the current registered holder of the IPv4 address resources, and not be involved in any dispute as to the status of those resources. * The source entity will be ineligible to receive any further IPv4 address allocations or assignments from ARIN for a period of 12 months after a transfer approval, or until the exhaustion of ARIN's IPv4 space, whichever occurs first. * The source entity must not have received an allocation or assignment of IPv4 number resources from ARIN for the 12 months prior to the approval of a transfer request. * The minimum transfer size is a /24 Conditions on recipient of the transfer: * The recipient must demonstrate the need for up to a 24 month supply of IP address resources under current ARIN policies and sign an RSA. * The resources transferred will be subject to current ARIN policies. Add Section 8.4 Inter-RIR Transfers to Specified Recipients Inter-regional transfers may take place only via RIRs who agree to the transfer and share reciprocal, compatible, needs-based policies. Conditions on source of the transfer: * The source entity must be the current rights holder of the IPv4 address resources recognized by the RIR responsible for the resources, and not be involved in any dispute as to the status of those resources. * Source entities outside of the ARIN region must meet any requirements defined by the RIR where the source entity holds the registration. * Source entities within the ARIN region will not be eligible to receive any further IPv4 address allocations or assignments from ARIN for a period of 12 months after a transfer approval, or until the exhaustion of ARIN's IPv4 space, whichever occurs first. * Source entities within the ARIN region must not have received an allocation or assignment of IPv4 number resources from ARIN for the 12 months prior to the approval of a transfer request. * The minimum transfer size is a /24. Conditions on recipient of the transfer: * The conditions on a recipient outside of the ARIN region will be defined by the policies of the receiving RIR. * Recipients within the ARIN region will be subject to current ARIN policies and sign an RSA for the resources being received. * Recipients within the ARIN region must demonstrate the need for up to a 24 month supply of IPv4 address space. * The minimum transfer size is a /24 Rationale: The original text of this proposal attempted to simplify the requirements of an IPv4 address transfer while protecting any resources in the ARIN free pool. This revision is a result of feedback from the mailing list, and discussions with the original author. The one key point that has been removed from the original text is that a needs based review remains in place. The current text attempts to retain the original concepts of protecting any ARIN free pool, and incorporating it with the point of bringing resources under RSA. The resulting text attempts to put safeguards in place on the practice of paid transfers by creating a black out period for requests from the free pool. The text also tries to incorporate discussions regarding inter-RIR transfers and come up with language that includes the free pool protections for transfers in and out of the Region. Timetable for implementation: immediate. From mike at nationwideinc.com Fri Feb 17 11:49:57 2012 From: mike at nationwideinc.com (Mike Burns) Date: Fri, 17 Feb 2012 11:49:57 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on8.3 Specified Transfers In-Reply-To: <4F3D891C.6060507@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> Message-ID: <2EED74FD676844259E192E2C8F606115@MPC> I support this proposal and think it should be made known to this list that there is a currently a seller looking to sell a legacy /8. http://blog.internetgovernance.org/blog/_archives/2012/2/14/4998075.html I believe this group must come together to recognize the disconnect between ARIN policy and the law when it comes to legacy addresses. I have asked before and ask again, what is to happen to ARIN Whois authority when a well-bankrolled entity legally sells/buys legacy addresses with no regard to ARIN policy? It's time to inculcate a free transfer market by removing ARIN transactional impediments like needs requirements, when those requirements were designed solely to foster conservative stewardship of free pool addresses, not already allocated addresses, on a transfer market where the addresses have a monetary value. Fear of bogeymen like speculators and market-cornerers may be mitigated by the knowledge that huge blocks are available, and huge dollar amounts would be required to corner this market. Speculators. Let's wait until we at least have a whiff of their existence before we strangle a market still in it's cradle Good work Jeff. Regards, Mike Burns -----Original Message----- From: ARIN Sent: Thursday, February 16, 2012 5:54 PM To: arin-ppml at arin.net Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on8.3 Specified Transfers ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers ARIN received the following policy proposal and is posting it to the Public Policy Mailing List (PPML) in accordance with the Policy Development Process. The ARIN Advisory Council (AC) will review the proposal at their next regularly scheduled meeting (if the period before the next regularly scheduled meeting is less than 10 days, then the period may be extended to the subsequent regularly scheduled meeting). The AC will decide how to utilize the proposal and announce the decision to the PPML. The AC invites everyone to comment on the proposal on the PPML, particularly their support or non-support and the reasoning behind their opinion. Such participation contributes to a thorough vetting and provides important guidance to the AC in their deliberations. Draft Policies and Proposals under discussion can be found at: https://www.arin.net/policy/proposals/index.html The ARIN Policy Development Process can be found at: https://www.arin.net/policy/pdp.html Mailing list subscription information can be found at: https://www.arin.net/mailing_lists/ Regards, Communications and Member Services American Registry for Internet Numbers (ARIN) ## * ## ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers Proposal Originator: Jeff Mehlenbacher Proposal Version: 1 Date: 16 February 16 2012 Proposal type: Modify Policy term: Permanent Policy statement: Current Policy Statement: 8.3. Transfers to Specified Recipients In addition to transfers under section 8.2, IPv4 number resources within the ARIN region may be released to ARIN by the authorized resource holder, in whole or in part, for transfer to another specified organizational recipient. Such transferred number resources may only be received under RSA by organizations that are within the ARIN region and can demonstrate the need for such resources in the amount which they can justify under current ARIN policies showing how the addresses will be utilized within 24 months. Proposed Policy Statement 8.3. Transfers to Specified Recipients In addition to transfers under section 8.2, IPv4 number resources within the ARIN region may be released to ARIN by the authorized resource holder, in whole or in part, for transfer to another specified organizational recipient. Such transferred number resources may only be received under RSA by organizations that are within the ARIN region and requires that an Officer Attestation be provided confirming the transferred number resources will be applied to enable current or planned business models. Rationale: Current policy acts as a major impediment to freeing up unused IPv4 address and constrains trade in a free market economy. If a Company receives Board approval to spend between $11.25 and $12.00 per IP, this should suggest the business case is justified for the acquiring organization. The role of ARIN should be to encourage the freeing of IPv4 addresses that will otherwise remain dormant in the hands of companies who have no incentive to transfer them. The objective of the Specified Transfer market should be to a) encourage source Companies to transfer their unused blocks thereby increasing supply of IPv4 address and b) encourage recipient Companies to acquire sufficient IPv4 addresses to support business plans rather than depleting the free pool. Current policy of demonstrating need for specified transfers, be it based on 12 months or now 24 months, does not provide sufficient incentive for organizations to acquire unused IPv4 addresses in a financial transaction. Companies recognize they must still endure the rigors of the justification process regardless of free allocation or specified transfer?making it very difficult to justify a financial transaction when specified transfers will still be assessed by exactly the same techniques and algorithms applied for approval of free resources. Eliminating needs-based justification has many benefits so long as all transactions continue to flow through ARIN for ratification: a) Buyer executive attestation will ensure the IP?s are being used for business purposes. Failure to be truthful could result in punitive measures against corporate officers, and is a risk an officer would not be likely to take b) Source Companies have an active market and financial incentive to transfer unused IPv4 blocks to Companies with need c) IPv4 number resources will not be scarce if adequate incentive exists for Buyers to acquire unused blocks through specified transfer d) Many Buyers express hesitation that confidential business plans must be disclosed through the justification process?no such disclosure would be required (under NDA or otherwise) e) Legacy blocks will come under RSA in ever increasing numbers f) Improves the accuracy, utility and value of the ARIN address registry g) Effectively kills the black or gray IPv4 transfer market guaranteeing ARIN?s custodianship over number resources h) Encourages source Companies to free up resources and recipient Companies to actively acquire available IPv4 blocks thereby eliminating speculation because supply is abundant. Only when a resource is truly scarce does capricious consumption (stockpiling) occur i) The Free resource pool is best applied to small or new ISPs while medium to large corporations with greater financial wherewithal are encouraged to participate in specified transfers to acquire larger IPv4 blocks Timetable for implementation: Immediate _______________________________________________ PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). Unsubscribe or manage your mailing list subscription at: http://lists.arin.net/mailman/listinfo/arin-ppml Please contact info at arin.net if you experience any issues. From paul at redbarn.org Fri Feb 17 12:10:19 2012 From: paul at redbarn.org (Paul Vixie) Date: Fri, 17 Feb 2012 17:10:19 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <20120217084645.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.cff46d3785.wbe@email17.secureserver.net> References: <20120217084645.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.cff46d3785.wbe@email17.secureserver.net> Message-ID: <4F3E89FB.3000208@redbarn.org> On 2012-02-17 3:46 PM, jeffmehlenbacher at ipv4marketgroup.com wrote: > Yes, we are part of the Specified Transfer Listing Service and have a > very good grasp on current policy governing 8.3s including the recent > change to demonstrating need based on 24 months rather than 12 months. > Our Policy Proposal seeks to provide the necessary incentive for > Companies with unused IPs to actively put them to use through a transfer > and further seeks to motivate Companies with need to use Specified > Transfer though ARIN. The current practice of justifying need for > Specified Transfers is a disincentive for many potential recipient > organizations to participate in this market. Lack of demand directly > affects the freeing of dormant supply. jeff, this sounds misdirective and evasive. you have not answered my question. every incentive for sellers is present in the current transfer system. your proposal to eliminate needs-basis for recipients would not have the effect you're describing. paul From jcurran at arin.net Fri Feb 17 12:15:06 2012 From: jcurran at arin.net (John Curran) Date: Fri, 17 Feb 2012 17:15:06 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on8.3 Specified Transfers In-Reply-To: <2EED74FD676844259E192E2C8F606115@MPC> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> Message-ID: On Feb 17, 2012, at 11:49 AM, Mike Burns wrote: > I support this proposal and think it should be made known to this list that there is a currently a seller looking to sell a legacy /8. > > http://blog.internetgovernance.org/blog/_archives/2012/2/14/4998075.html > > I believe this group must come together to recognize the disconnect between ARIN policy and the law when it comes to legacy addresses. As I noted in the reply to that article, ARIN's ability to maintain the registry accordingly to community policy has not been impacted by any attempts by parties to the contrary; if there's a disconnect, it is not in the manner in which ARIN is operating. > I have asked before and ask again, what is to happen to ARIN Whois authority when a well-bankrolled entity legally sells/buys legacy addresses with no regard to ARIN policy? ARIN has no difficulty maintaining the registry appropriately; as an aside, one might consider instead what precisely is being conveyed if it supposed to be a number block which is unique with respect to others in the registry, but actually isn't complying with the rules of the registry needed to keep it unique? To follow up one point: you note that the 'disconnect' is with respect to legacy addresses, are you proposing that the elimination of needs-based justification be just for legacy addresses, or all address blocks, ARIN- issues and legacy? (While there may indeed be ARIN issued blocks which are potential for the market, these are far less likely at least initially as they were all issued over the years with tighter needs-based assessments and generally to organizations that intended to fairly quickly put them into operational networks.) FYI, /John John Curran President and CEO ARIN From jeffmehlenbacher at ipv4marketgroup.com Fri Feb 17 12:16:16 2012 From: jeffmehlenbacher at ipv4marketgroup.com (jeffmehlenbacher at ipv4marketgroup.com) Date: Fri, 17 Feb 2012 10:16:16 -0700 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification Message-ID: <20120217101616.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.0dbf6968e9.wbe@email17.secureserver.net> Thank you Kevin. The intent of our proposal is to ensure dormant supply is freed up and companies are motivated to participate in the effective reallocation and (re)use of IPv4 number resources. Further, our proposal identifies the benefits that will accrue by eliminating needs-based justification because it will encourage more participation and importantly, all transactions continue to flow through ARIN for ratification. I might also suggest the opposite outcome of what you deduce regarding making facilitation more profitable. If Sellers and Buyers alike are motivated and thus choose to participate as Lister and Needer on ARIN's Specified Transfer Listing Service, I submit Facilitators will no longer be in demand for sourcing interested parties as said parties can contact one another directly. Our services may be reduced, if requested, to transaction execution only. Jeff Mehlenbacher -------- Original Message -------- Subject: RE: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification From: Kevin Kargel Date: Fri, February 17, 2012 11:35 am To: "'jeffmehlenbacher at ipv4marketgroup.com'" , Paul Vixie Cc: "arin-ppml at arin.net" > -----Original Message----- > From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On > Behalf Of jeffmehlenbacher at ipv4marketgroup.com > Sent: Friday, February 17, 2012 9:47 AM > To: Paul Vixie > Cc: arin-ppml at arin.net > Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification > > Yes, we are part of the Specified Transfer Listing Service and have a > very good grasp on current policy governing 8.3s including the recent > change to demonstrating need based on 24 months rather than 12 months. > Our Policy Proposal seeks to provide the necessary incentive for > Companies with unused IPs to actively put them to use through a transfer > and further seeks to motivate Companies with need to use Specified > Transfer though ARIN. The current practice of justifying need for > Specified Transfers is a disincentive for many potential recipient > organizations to participate in this market. Lack of demand directly > affects the freeing of dormant supply. > > Jeff [kjk] To my read this plainly says that the intent is to make transfer facilitation more profitable. I do not believe it is within ARIN's mission or scope to write policy with the intent of maximizing profit within an IP address market. I even more strongly opposed to this proposal. > > > > -------- Original Message -------- > Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based > Justification > From: Paul Vixie > Date: Fri, February 17, 2012 10:27 am > To: jeffmehlenbacher at ipv4marketgroup.com > Cc: arin-ppml at arin.net > > On 2012-02-17 3:19 PM, jeffmehlenbacher at ipv4marketgroup.com wrote: > Paul, I cannot speak to how other brokers structure their business, but > we do not actually hold address space if I interpret you literally. Our > Sellers hold the address space. We are contracted by companies with > unused IPv4 blocks to source a company with need. Once a potential > needer is identified, we facilitate agreement on price, timing and other > conditions of a transfer then provide the necessary legal documents and > guidance to execute the transactions contingent upon ARIN approval. The > value of any broker--be it insurance, mortgage, real estate or IPv4 > transfers--is subjective but clearly if a Seller and a Buyer prefer to > use a broker, they should do so. The Policy Proposal as written assumes > there may or may not be broker involvement in Specified Transfers. > > thank you jeff. it seems that you have misunderstood the current > policies, which allow everything you describe, so long as the needer can > demonstrate that need to ARIN. there is a place in the "transfer listing > service" for brokers, too. i'm at a loss to understand what it about the > current transfer policies that won't fit the model you're describing > above. > > paul > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From gary.buhrmaster at gmail.com Fri Feb 17 12:18:48 2012 From: gary.buhrmaster at gmail.com (Gary Buhrmaster) Date: Fri, 17 Feb 2012 09:18:48 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <20120217001718.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.e0949ab319.wbe@email17.secureserver.net> References: <20120217001718.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.e0949ab319.wbe@email17.secureserver.net> Message-ID: On Thu, Feb 16, 2012 at 23:17, wrote: > I would agree that free allocations should be scrutinized closely to > ensure need. ?For 8.3 Specified Transfers however, no purpose is served > when a transfer is rejected between a Company with an unused allocation > and a Company in need. ?The unused IPv4 block at the source Company > remains unused. ?The rejected recipient Company must seek alternatives > which may include applying to ARIN for a smaller block from the free > pool. Ok, here is an alternative "thought" (it is not a proposal, and for full disclosure, I might very well "vote" against it because there are things I do not like about my proposal, but it might be a different way to frame the issue by suggesting a way that many can get a little of what they want). Proposal Thought: Legacy numbers (and only legacy numbers) may be transferred to a recipient under an RSA with the need justifications being deferred for 12 months (at which time numbers that would not be justified would return to ARIN). Adv: Allows legacy holders to monetize their underused numbers (winner legacy holder) Adv: Allows recipients to defer justifications until their business plans are more finalized (winner recipient) Adv: Move legacy numbers to RSA (winner ARIN community) Adv: Allows brokers to monetize additional facilitations (winner brokers) Dis: ARIN would have to track "deferred" justifications Dis: The numbers could end up being "tainted" while in the possession of the temporary holder (think business plan of a spammer) Dis: Requires ARIN to potentially "claw back" numbers From springer at inlandnet.com Fri Feb 17 12:22:44 2012 From: springer at inlandnet.com (John Springer) Date: Fri, 17 Feb 2012 09:22:44 -0800 (PST) Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <20120217084645.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.cff46d3785.wbe@email17.secureserver.net> References: <20120217084645.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.cff46d3785.wbe@email17.secureserver.net> Message-ID: <20120217091443.M89102@mail.inlandnet.com> I oppose this proposal. A short comment is below. On Fri, 17 Feb 2012, jeffmehlenbacher at ipv4marketgroup.com wrote: -snippety- > The current practice of justifying need for > Specified Transfers is a disincentive for many potential recipient > organizations to participate in this market. > > Jeff > -snip- I am so glad you said that. It is refreshing to hear such candor. I have always felt that this is crux of all attempts to remove the needs basis, whether from allocations, assignments or transfers. Thank you very much for making my decision so easy. John Springer From jeffmehlenbacher at ipv4marketgroup.com Fri Feb 17 12:32:46 2012 From: jeffmehlenbacher at ipv4marketgroup.com (jeffmehlenbacher at ipv4marketgroup.com) Date: Fri, 17 Feb 2012 10:32:46 -0700 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification Message-ID: <20120217103246.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.056001bac6.wbe@email17.secureserver.net> Thank you Paul. I now understand the specific intent of your question based on this posting. You are correct, similar motivation exists for the Seller based on current policy. What is missing in the market is strong demand created by an attractive alternative to free 90-day allocations based on justified need. The motivation does not exist to the extent possible for the buyers under current policy (justification based on 24 month utilization). If there is buyer demand, the sellers will more readily allocate time and resources to transfer their unused blocks--thereby increasing supply. So in this instance, our Policy Proposal seeks to encourage demand which will increase supply of currently unused IPv4 address blocks. The result should be more specified transfers and effective allocation of previously unused number resources. Jeff Mehlenbacher -------- Original Message -------- Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification From: Paul Vixie Date: Fri, February 17, 2012 12:10 pm To: jeffmehlenbacher at ipv4marketgroup.com Cc: arin-ppml at arin.net On 2012-02-17 3:46 PM, jeffmehlenbacher at ipv4marketgroup.com wrote: > Yes, we are part of the Specified Transfer Listing Service and have a > very good grasp on current policy governing 8.3s including the recent > change to demonstrating need based on 24 months rather than 12 months. > Our Policy Proposal seeks to provide the necessary incentive for > Companies with unused IPs to actively put them to use through a transfer > and further seeks to motivate Companies with need to use Specified > Transfer though ARIN. The current practice of justifying need for > Specified Transfers is a disincentive for many potential recipient > organizations to participate in this market. Lack of demand directly > affects the freeing of dormant supply. jeff, this sounds misdirective and evasive. you have not answered my question. every incentive for sellers is present in the current transfer system. your proposal to eliminate needs-basis for recipients would not have the effect you're describing. paul From mike at nationwideinc.com Fri Feb 17 12:39:05 2012 From: mike at nationwideinc.com (Mike Burns) Date: Fri, 17 Feb 2012 12:39:05 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justificationon8.3 Specified Transfers In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com><4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> Message-ID: Hi John, Answers inline. >As I noted in the reply to that article, ARIN's ability to maintain the registry accordingly to community policy has not been impacted by any attempts by parties to the contrary; if there's a disconnect, it is not in the manner in which ARIN is operating. The disconnect is ARIN's policy of not updating Whois unless a transferee of legacy space, under no contract with ARIN, voluntarily decides to jump through ARIN's hoops. Thus the danger that an actual legal transfer of address rights is effected, but ARIN's Whois still has old and irrelevant data in it. > as an aside, one might consider instead what precisely is being conveyed > if it supposed to be a number block which is unique with respect to others in the registry, but actually isn't complying with the rules of the registry needed to keep it unique? I have considered this question, my answer is that what is being conveyed are the exclusive address rights granted to the original registrant and then transferred with a legal chain of custody to the ultimate holder of the address rights. >To follow up one point: you note that the 'disconnect' is with respect to legacy addresses, are you proposing that the elimination of needs-based justification be just for legacy addresses, or all address blocks, ARIN- issues and legacy? I designed a policy proposal with the intended benefit of removing needs-based justification policies for all address holders who had held the addresses for more than a year, Prop-151, in its original incarnation. My goal was to bridge the legal divide between those with a contract with ARIN and those legacy address rights holders without one, by liberalizing transfer policies so that they were the same, effectively providing an incentive to bring legacy holders under some kind of RSA, while at the same time creating a dynamic market in IPv4 addresses which could be fueled with supply by both legacy and RSA address rights holders' stocks. This proposal also capped needs free transfers at a /12, preventing speculation and market cornering, and suggested the removal of ARIN's revokation rights for utilization from the RSA. The free pool was protected by requiring at least a 12 month holding period before addresses could be sold by those who received them from the free pool, and prevented those who sold addresses on the transfer market from dipping back into the free pool. However I would certainly support any proposal with the more limited aim of removing needs-requirements from 8.3 Transfers of Legacy Space, even though it would serve to perpetuate the "class structure" that currently divides Legacy and RSA address rights owners, and further de-incentivize the bringing of Legacy Space under RSA. Regards, Mike From mueller at syr.edu Fri Feb 17 12:41:03 2012 From: mueller at syr.edu (Milton L Mueller) Date: Fri, 17 Feb 2012 17:41:03 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <4F3E71CC.1000907@redbarn.org> References: <20120217081901.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.34816080d0.wbe@email17.secureserver.net> <4F3E71CC.1000907@redbarn.org> Message-ID: <855077AC3D7A7147A7570370CA01ECD20A19D6@SUEX10-mbx-10.ad.syr.edu> Actually, Paul, a rigid insistence on needs assessments simply gives buyers the strongest possible incentive to deal only with legacy holders and to conduct the transfers outside of the ARIN 8.3 process. In an environment in which the free pool is fully occupied and all address allocations occur through transfers from one party to another, the economic and institutional justification for needs assessments disappear. More precisely (and there is actually some economic science to be considered here, although I am sure that it will not affect you) the basis for "need" shifts from technical to economic. Given inherent uncertainty regarding a) the future value of the addresses, b) the speed with we will make the migration to IPv6 if at all, c) the arbitrary time horizon that is imposed on applicants by the needs assessment process (3 months? 6 months? 3 years?), a buyer could easily fail to qualify for "need" under traditional criteria but the socially efficient thing to do would be to let them buy them. The idea that ARIN needs to decide who is a valid recipient of IPv4 blocks is just a bump in the road that does no one any good. I guess you want to learn this the hard way. From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of Paul Vixie Sent: Friday, February 17, 2012 10:27 AM To: jeffmehlenbacher at ipv4marketgroup.com Cc: arin-ppml at arin.net Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification On 2012-02-17 3:19 PM, jeffmehlenbacher at ipv4marketgroup.com wrote: Paul, I cannot speak to how other brokers structure their business, but we do not actually hold address space if I interpret you literally. Our Sellers hold the address space. We are contracted by companies with unused IPv4 blocks to source a company with need. Once a potential needer is identified, we facilitate agreement on price, timing and other conditions of a transfer then provide the necessary legal documents and guidance to execute the transactions contingent upon ARIN approval. The value of any broker--be it insurance, mortgage, real estate or IPv4 transfers--is subjective but clearly if a Seller and a Buyer prefer to use a broker, they should do so. The Policy Proposal as written assumes there may or may not be broker involvement in Specified Transfers. thank you jeff. it seems that you have misunderstood the current policies, which allow everything you describe, so long as the needer can demonstrate that need to ARIN. there is a place in the "transfer listing service" for brokers, too. i'm at a loss to understand what it about the current transfer policies that won't fit the model you're describing above. paul -------------- next part -------------- An HTML attachment was scrubbed... URL: From owen at delong.com Fri Feb 17 12:48:36 2012 From: owen at delong.com (Owen DeLong) Date: Fri, 17 Feb 2012 09:48:36 -0800 Subject: [arin-ppml] Prop-151: Clarifying requirements for IPv4 transfers (was "Limiting needs...") In-Reply-To: References: Message-ID: <8B3800AB-040A-4B5A-8B10-E03B587BBF59@delong.com> Yes, I would like to see that change incorporated. I am very concerned about the damage to the internet that will result if we expose number policy to the same market tactics that brought about the current housing situations. Owen On Feb 17, 2012, at 8:42 AM, Alexander, Daniel wrote: > Hello All, > > The Staff and Legal review has been provided to the AC for prop-151. The > review focused mainly on the 12 month needs assessment given that the > Board has recently ratified 2011-12 which changed the transfer needs > assessment to 24 months. This update and a few others are listed below. > > Another change that has been suggested is to include transfers in the 12 > month restrictions on the source of a transfer. The resulting text would > read as follows. > > "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." > > The intent of this change would be to limit an organization from > "flipping" transferred resources. Do people feel that this should be > incorporated into the text? > > All feedback is appreciated. > > Dan Alexander > AC Shepherd > > > Changes to prop-151 text: > > - Restored a needs requirement to the text. > - Eliminated the /12 cap on resources received. > - Removed the suggestions to altering the text of the RSA. > - Removed the section regarding "Conditions on the IPv4 address block". > - Revised the condition of space being administered by ARIN to incorporate > inter-RIR transfers as a result of 2011-1. > - Moved the minimum transfer size requirement down to remaining Conditions. > - Separated in-region and inter-region transfers into separate sections. > - Clarified the starting point of the 12 month restrictions as a result of > staff feedback. > - Changed the proposal title from "Limiting needs..." to "Clarifying > Requirements..." as a result of feedback. > - Updated needs requirement from 12 to 24 months as a result of 2011-12. > > > > Current text: > > Replace Section 8.3 with > > 8.3 Transfers between Specified Recipients within the ARIN Region. > > In addition to transfers under section 8.2, IPv4 numbers resources may be > transferred according to the following conditions. > > Conditions on source of the transfer: > > * The source entity must be the current registered holder of the IPv4 > address resources, and not be involved in any dispute as to the status of > those resources. > * The source entity will be ineligible to receive any further IPv4 address > allocations or assignments from ARIN for a period of 12 months after a > transfer approval, or until the exhaustion of ARIN's IPv4 space, whichever > occurs first. > * The source entity must not have received an allocation or assignment of > IPv4 number resources from ARIN for the 12 months prior to the approval of > a transfer request. > * The minimum transfer size is a /24 > > > Conditions on recipient of the transfer: > > * The recipient must demonstrate the need for up to a 24 month supply of > IP address resources under current ARIN policies and sign an RSA. > * The resources transferred will be subject to current ARIN policies. > > > Add Section 8.4 Inter-RIR Transfers to Specified Recipients > > Inter-regional transfers may take place only via RIRs who agree to the > transfer and share reciprocal, compatible, needs-based policies. > > Conditions on source of the transfer: > > * The source entity must be the current rights holder of the IPv4 address > resources recognized by the RIR responsible for the resources, and not be > involved in any dispute as to the status of those resources. > * Source entities outside of the ARIN region must meet any requirements > defined by the RIR where the source entity holds the registration. > * Source entities within the ARIN region will not be eligible to receive > any further IPv4 address allocations or assignments from ARIN for a period > of 12 months after a transfer approval, or until the exhaustion of ARIN's > IPv4 space, whichever occurs first. > * Source entities within the ARIN region must not have received an > allocation or assignment of IPv4 number resources from ARIN for the 12 > months prior to the approval of a transfer request. > * The minimum transfer size is a /24. > > > Conditions on recipient of the transfer: > > * The conditions on a recipient outside of the ARIN region will be defined > by the policies of the receiving RIR. > * Recipients within the ARIN region will be subject to current ARIN > policies and sign an RSA for the resources being received. > * Recipients within the ARIN region must demonstrate the need for up to a > 24 month supply of IPv4 address space. > * The minimum transfer size is a /24 > > Rationale: > > The original text of this proposal attempted to simplify the requirements > of an IPv4 address transfer while protecting any resources in the ARIN > free pool. This revision is a result of feedback from the mailing list, > and discussions with the original author. The one key point that has been > removed from the original text is that a needs based review remains in > place. > > The current text attempts to retain the original concepts of protecting > any ARIN free pool, and incorporating it with the point of bringing > resources under RSA. The resulting text attempts to put safeguards in > place on the practice of paid transfers by creating a black out period for > requests from the free pool. The text also tries to incorporate > discussions regarding inter-RIR transfers and come up with language that > includes the free pool protections for transfers in and out of the Region. > > Timetable for implementation: immediate. > > > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From ikiris at gmail.com Fri Feb 17 12:52:16 2012 From: ikiris at gmail.com (Blake Dunlap) Date: Fri, 17 Feb 2012 11:52:16 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justificationon8.3 Specified Transfers In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> Message-ID: Strongly oppose. -Blake -------------- next part -------------- An HTML attachment was scrubbed... URL: From john.sweeting at twcable.com Fri Feb 17 12:55:52 2012 From: john.sweeting at twcable.com (Sweeting, John) Date: Fri, 17 Feb 2012 12:55:52 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <855077AC3D7A7147A7570370CA01ECD20A19D6@SUEX10-mbx-10.ad.syr.edu> Message-ID: Hi Milton, A few questions since I am not an expert in markets. Do you think there is a scenario where the largest and wealthiest of the world's ISP's would buy up as much address space as they could just to keep it out of the hands of their competitors? Or new start ups in their markets? There are some very wealthy companies out there that would not blink an eye at spending the money needed to run their competitors out of the market but maybe that is not possible in this particular market. Is there a way that a small but well of portion of the market could insure prices are so high that the number of competitors would be capped or even reduced? As I said I am not an expert on markets so would very much welcome your views on this. Thanks, John + From: Milton L Mueller > Date: Fri, 17 Feb 2012 12:41:03 -0500 To: 'Paul Vixie' >, "jeffmehlenbacher at ipv4marketgroup.com" > Cc: "arin-ppml at arin.net" > Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification Actually, Paul, a rigid insistence on needs assessments simply gives buyers the strongest possible incentive to deal only with legacy holders and to conduct the transfers outside of the ARIN 8.3 process. In an environment in which the free pool is fully occupied and all address allocations occur through transfers from one party to another, the economic and institutional justification for needs assessments disappear. More precisely (and there is actually some economic science to be considered here, although I am sure that it will not affect you) the basis for "need" shifts from technical to economic. Given inherent uncertainty regarding a) the future value of the addresses, b) the speed with we will make the migration to IPv6 if at all, c) the arbitrary time horizon that is imposed on applicants by the needs assessment process (3 months? 6 months? 3 years?), a buyer could easily fail to qualify for "need" under traditional criteria but the socially efficient thing to do would be to let them buy them. The idea that ARIN needs to decide who is a valid recipient of IPv4 blocks is just a bump in the road that does no one any good. I guess you want to learn this the hard way. From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of Paul Vixie Sent: Friday, February 17, 2012 10:27 AM To: jeffmehlenbacher at ipv4marketgroup.com Cc: arin-ppml at arin.net Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification On 2012-02-17 3:19 PM, jeffmehlenbacher at ipv4marketgroup.com wrote: Paul, I cannot speak to how other brokers structure their business, but we do not actually hold address space if I interpret you literally. Our Sellers hold the address space. We are contracted by companies with unused IPv4 blocks to source a company with need. Once a potential needer is identified, we facilitate agreement on price, timing and other conditions of a transfer then provide the necessary legal documents and guidance to execute the transactions contingent upon ARIN approval. The value of any broker--be it insurance, mortgage, real estate or IPv4 transfers--is subjective but clearly if a Seller and a Buyer prefer to use a broker, they should do so. The Policy Proposal as written assumes there may or may not be broker involvement in Specified Transfers. thank you jeff. it seems that you have misunderstood the current policies, which allow everything you describe, so long as the needer can demonstrate that need to ARIN. there is a place in the "transfer listing service" for brokers, too. i'm at a loss to understand what it about the current transfer policies that won't fit the model you're describing above. paul ________________________________ This E-mail and any of its attachments may contain Time Warner Cable proprietary information, which is privileged, confidential, or subject to copyright belonging to Time Warner Cable. This E-mail is intended solely for the use of the individual or entity to which it is addressed. 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From jcurran at arin.net Fri Feb 17 13:00:33 2012 From: jcurran at arin.net (John Curran) Date: Fri, 17 Feb 2012 18:00:33 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justificationon8.3 Specified Transfers In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> Message-ID: On Feb 17, 2012, at 12:39 PM, Mike Burns wrote: >> as an aside, one might consider instead what precisely is being conveyed if it supposed to > be a number block which is unique with respect to others in the registry, but > actually isn't complying with the rules of the registry needed to keep it unique? > > I have considered this question, my answer is that what is being conveyed are the exclusive address rights granted to the original registrant and then transferred with a legal chain of custody to the ultimate holder of the address rights. If that's the case, then no registration would be needed at all. For example, anyone could conduct such sales between parties privately, including dividing blocks into smaller ones sold to additional parties ad infinitum... Private property per se wouldn't imply any requirement to update a registry, absent laws specifying such. I've been told that parties who want to make a marketplace also want the results from their transactions to be in the registry and accepted by the community. Interestingly enough, the inherent conflict between wanting the community to accept the results of their 'sales' in the registry but not wanting to follow the same community's policies for changes to the registry hasn't been very well understood. FYI, /John John Curran President and CEO ARIN From owen at delong.com Fri Feb 17 13:08:07 2012 From: owen at delong.com (Owen DeLong) Date: Fri, 17 Feb 2012 10:08:07 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on8.3 Specified Transfers In-Reply-To: <2EED74FD676844259E192E2C8F606115@MPC> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> Message-ID: Given the history of Enron, the housing crisis, and even Tulips, no, the size of the market does not, IMHO, make it immune to the dangers of speculation, hoarding, and profiteering. I oppose this policy as written. We have asked this same question of the community several times over the last 5 years and each and every time, the community has expressed a clear desire to preserve needs-based justification. Continuing to ask the question over and over again expecting a different response is, IMHO, becoming somewhat tiresome. Owen On Feb 17, 2012, at 8:49 AM, Mike Burns wrote: > I support this proposal and think it should be made known to this list that there is a currently a seller looking to sell a legacy /8. > > http://blog.internetgovernance.org/blog/_archives/2012/2/14/4998075.html > > I believe this group must come together to recognize the disconnect between ARIN policy and the law when it comes to legacy addresses. > I have asked before and ask again, what is to happen to ARIN Whois authority when a well-bankrolled entity legally sells/buys legacy addresses with no regard to ARIN policy? > > It's time to inculcate a free transfer market by removing ARIN transactional impediments like needs requirements, when those requirements were designed solely to foster conservative stewardship of free pool addresses, not already allocated addresses, on a transfer market where the addresses have a monetary value. > > Fear of bogeymen like speculators and market-cornerers may be mitigated by the knowledge that huge blocks are available, and huge dollar amounts would be required to corner this market. > > Speculators. Let's wait until we at least have a whiff of their existence before we strangle a market still in it's cradle > > Good work Jeff. > > Regards, > Mike Burns > > > > > -----Original Message----- From: ARIN > Sent: Thursday, February 16, 2012 5:54 PM > To: arin-ppml at arin.net > Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on8.3 Specified Transfers > > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers > > ARIN received the following policy proposal and is posting it to the > Public Policy Mailing List (PPML) in accordance with the Policy > Development Process. > > The ARIN Advisory Council (AC) will review the proposal at their next > regularly scheduled meeting (if the period before the next regularly > scheduled meeting is less than 10 days, then the period may be extended > to the subsequent regularly scheduled meeting). The AC will decide how > to utilize the proposal and announce the decision to the PPML. > > The AC invites everyone to comment on the proposal on the PPML, > particularly their support or non-support and the reasoning > behind their opinion. Such participation contributes to a thorough > vetting and provides important guidance to the AC in their deliberations. > > Draft Policies and Proposals under discussion can be found at: > https://www.arin.net/policy/proposals/index.html > > The ARIN Policy Development Process can be found at: > https://www.arin.net/policy/pdp.html > > Mailing list subscription information can be found > at: https://www.arin.net/mailing_lists/ > > Regards, > > Communications and Member Services > American Registry for Internet Numbers (ARIN) > > > ## * ## > > > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers > > Proposal Originator: Jeff Mehlenbacher > > Proposal Version: 1 > > Date: 16 February 16 2012 > > Proposal type: Modify > > Policy term: Permanent > > Policy statement: > > Current Policy Statement: > 8.3. Transfers to Specified Recipients > In addition to transfers under section 8.2, IPv4 number resources within > the ARIN region may be released to ARIN by the authorized resource > holder, in whole or in part, for transfer to another specified > organizational recipient. Such transferred number resources may only be > received under RSA by organizations that are within the ARIN region and > can demonstrate the need for such resources in the amount which they can > justify under current ARIN policies showing how the addresses will be > utilized within 24 months. > > Proposed Policy Statement > 8.3. Transfers to Specified Recipients > In addition to transfers under section 8.2, IPv4 number resources within > the ARIN region may be released to ARIN by the authorized resource > holder, in whole or in part, for transfer to another specified > organizational recipient. Such transferred number resources may only be > received under RSA by organizations that are within the ARIN region and > requires that an Officer Attestation be provided confirming the > transferred number resources will be applied to enable current or > planned business models. > > Rationale: > > Current policy acts as a major impediment to freeing up unused IPv4 > address and constrains trade in a free market economy. If a Company > receives Board approval to spend between $11.25 and $12.00 per IP, this > should suggest the business case is justified for the acquiring > organization. The role of ARIN should be to encourage the freeing of > IPv4 addresses that will otherwise remain dormant in the hands of > companies who have no incentive to transfer them. > > The objective of the Specified Transfer market should be to a) encourage > source Companies to transfer their unused blocks thereby increasing > supply of IPv4 address and b) encourage recipient Companies to acquire > sufficient IPv4 addresses to support business plans rather than > depleting the free pool. > > Current policy of demonstrating need for specified transfers, be it > based on 12 months or now 24 months, does not provide sufficient > incentive for organizations to acquire unused IPv4 addresses in a > financial transaction. Companies recognize they must still endure the > rigors of the justification process regardless of free allocation or > specified transfer?making it very difficult to justify a financial > transaction when specified transfers will still be assessed by exactly > the same techniques and algorithms applied for approval of free resources. > > Eliminating needs-based justification has many benefits so long as all > transactions continue to flow through ARIN for ratification: > > a) Buyer executive attestation will ensure the IP?s are being used for > business purposes. Failure to be truthful could result in punitive > measures against corporate officers, and is a risk an officer would not > be likely to take > > b) Source Companies have an active market and financial incentive to > transfer unused IPv4 blocks to Companies with need > > c) IPv4 number resources will not be scarce if adequate incentive exists > for Buyers to acquire unused blocks through specified transfer > > d) Many Buyers express hesitation that confidential business plans must > be disclosed through the justification process?no such disclosure would > be required (under NDA or otherwise) > > e) Legacy blocks will come under RSA in ever increasing numbers > > f) Improves the accuracy, utility and value of the ARIN address registry > > g) Effectively kills the black or gray IPv4 transfer market guaranteeing > ARIN?s custodianship over number resources > > h) Encourages source Companies to free up resources and recipient > Companies to actively acquire available IPv4 blocks thereby eliminating > speculation because supply is abundant. Only when a resource is truly > scarce does capricious consumption (stockpiling) occur > > i) The Free resource pool is best applied to small or new ISPs while > medium to large corporations with greater financial wherewithal are > encouraged to participate in specified transfers to acquire larger IPv4 > blocks > > Timetable for implementation: Immediate > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From lsawyer at gci.com Fri Feb 17 13:14:24 2012 From: lsawyer at gci.com (Leif Sawyer) Date: Fri, 17 Feb 2012 09:14:24 -0900 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> Message-ID: <18B2C6E38A3A324986B392B2D18ABC5101D4DD6566@fnb1mbx01.gci.com> I've sat back and watched and read both sides of this. I don't see a compelling argument for eliminiation of justification. I vote AGAINST prop 165 as written and in spirit. I do not think any re-writes can provide any measurable difference. From owen at delong.com Fri Feb 17 13:20:21 2012 From: owen at delong.com (Owen DeLong) Date: Fri, 17 Feb 2012 10:20:21 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justificationon8.3 Specified Transfers In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com><4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> Message-ID: On Feb 17, 2012, at 9:39 AM, Mike Burns wrote: > Hi John, > > Answers inline. > > > >> As I noted in the reply to that article, ARIN's ability to maintain > the registry accordingly to community policy has not been impacted > by any attempts by parties to the contrary; if there's a disconnect, > it is not in the manner in which ARIN is operating. > > > The disconnect is ARIN's policy of not updating Whois unless a transferee of legacy space, under no contract with ARIN, voluntarily decides to jump through ARIN's hoops. > Thus the danger that an actual legal transfer of address rights is effected, but ARIN's Whois still has old and irrelevant data in it. > This answer presumes that your answer to the next question is actually correct. IMHO it suffers from another fundamentally flawed assumption. > >> as an aside, one might consider instead what precisely is being conveyed if it supposed to > be a number block which is unique with respect to others in the registry, but > actually isn't complying with the rules of the registry needed to keep it unique? > > I have considered this question, my answer is that what is being conveyed are the exclusive address rights granted to the original registrant and then transferred with a legal chain of custody to the ultimate holder of the address rights. > What exclusive address rights granted to the original registrant by whom and under what legal framework? IMHO, the internet operates because operators agree to route addresses according to data contained in the agreed upon registries. Even the registries clearly state that registration is not necessarily routability. This is because operators are free to configure their routers in any way they wish. The only enforcement of address rights so far has come in the form of operators refusing to accept routes they don't consider legitimate. It is hard to imagine a situation where the court would order the entire internet to route a particular prefix in a particular way (or even enjoin the entire internet from routing a prefix in a particular way) with any degree of actual efficacy. This whole talk about address rights strikes me as greatly resembling a debate among flees over which one owns the dog. Registration guarantees uniqueness among the cooperating registries and so far, ISPs generally regard the uniqueness in the registry databases as a useful and valid way to determine eligibility to control the routing of a particular prefix. If that breaks down, the results are very undefined. The courts can order the registries to make database updates (though so far, to my knowledge, they have not done so in a manner inconsistent with community developed policies). They can even order a particular ISP to route or not route a prefix in a certain way. They might even be able to convey that order to a number of ISPs. Affecting every ISP, worldwide? Unlikely. Affecting the whole internet? Virtually impossible. More likely, the court would be viewed outside of its jurisdiction as damage and routed around. So, an organization that is the recipient of a transfer of addresses outside of the policies of the registry has received only a promise that the organization that previously was using the addresses won't use them any more and very little (if anything) else in terms of actual rights. Owen From mueller at syr.edu Fri Feb 17 12:27:57 2012 From: mueller at syr.edu (Milton L Mueller) Date: Fri, 17 Feb 2012 17:27:57 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <20120217084645.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.cff46d3785.wbe@email17.secureserver.net> References: <20120217084645.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.cff46d3785.wbe@email17.secureserver.net> Message-ID: <855077AC3D7A7147A7570370CA01ECD20A19B4@SUEX10-mbx-10.ad.syr.edu> I support this policy > -----Original Message----- > From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On > Behalf Of jeffmehlenbacher at ipv4marketgroup.com > Sent: Friday, February 17, 2012 10:47 AM > To: Paul Vixie > Cc: arin-ppml at arin.net > Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification > > Yes, we are part of the Specified Transfer Listing Service and have a > very good grasp on current policy governing 8.3s including the recent > change to demonstrating need based on 24 months rather than 12 months. > Our Policy Proposal seeks to provide the necessary incentive for > Companies with unused IPs to actively put them to use through a transfer > and further seeks to motivate Companies with need to use Specified > Transfer though ARIN. The current practice of justifying need for > Specified Transfers is a disincentive for many potential recipient > organizations to participate in this market. Lack of demand directly > affects the freeing of dormant supply. > > Jeff > > > > -------- Original Message -------- > Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based > Justification > From: Paul Vixie > Date: Fri, February 17, 2012 10:27 am > To: jeffmehlenbacher at ipv4marketgroup.com > Cc: arin-ppml at arin.net > > On 2012-02-17 3:19 PM, jeffmehlenbacher at ipv4marketgroup.com wrote: > Paul, I cannot speak to how other brokers structure their business, but > we do not actually hold address space if I interpret you literally. Our > Sellers hold the address space. We are contracted by companies with > unused IPv4 blocks to source a company with need. Once a potential > needer is identified, we facilitate agreement on price, timing and other > conditions of a transfer then provide the necessary legal documents and > guidance to execute the transactions contingent upon ARIN approval. The > value of any broker--be it insurance, mortgage, real estate or IPv4 > transfers--is subjective but clearly if a Seller and a Buyer prefer to > use a broker, they should do so. The Policy Proposal as written assumes > there may or may not be broker involvement in Specified Transfers. > > thank you jeff. it seems that you have misunderstood the current > policies, which allow everything you describe, so long as the needer can > demonstrate that need to ARIN. there is a place in the "transfer listing > service" for brokers, too. i'm at a loss to understand what it about the > current transfer policies that won't fit the model you're describing > above. > > paul > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From owen at delong.com Fri Feb 17 13:25:37 2012 From: owen at delong.com (Owen DeLong) Date: Fri, 17 Feb 2012 10:25:37 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <20120217081901.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.34816080d0.wbe@email17.secureserver.net> References: <20120217081901.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.34816080d0.wbe@email17.secureserver.net> Message-ID: <9953E516-59AF-4269-91D1-4A467E2AC32C@delong.com> Jeff, If this policy is adopted, it would enable speculative brokers who wanted to to maintain inventory without showing need for the addresses. It would potentially turn IP addresses into a commodities futures market which I do not believe would serve the community well. You say that no purpose is served when a transfer is rejected between a company with an unused allocation and a company in need. Current policy does not do that. It does limit the size of the transfer to the justified need, but, it does not reject the transfer. However, no purpose is served when addresses are allowed to be purchased by organizations without need and great harm could come from allowing such transactions if they start occurring on large scale in order to engage in speculation or worse, anti-competitive practices. Owen On Feb 17, 2012, at 7:19 AM, wrote: > Paul, I cannot speak to how other brokers structure their business, but we do not actually hold address space if I interpret you literally. Our Sellers hold the address space. We are contracted by companies with unused IPv4 blocks to source a company with need. Once a potential needer is identified, we facilitate agreement on price, timing and other conditions of a transfer then provide the necessary legal documents and guidance to execute the transactions contingent upon ARIN approval. The value of any broker--be it insurance, mortgage, real estate or IPv4 transfers--is subjective but clearly if a Seller and a Buyer prefer to use a broker, they should do so. The Policy Proposal as written assumes there may or may not be broker involvement in Specified Transfers. > > Jeff Mehlenbacher > > -------- Original Message -------- > Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based > Justification > From: Paul Vixie > Date: Fri, February 17, 2012 9:18 am > To: jeffmehlenbacher at ipv4marketgroup.com > Cc: arin-ppml at arin.net > > On 2012-02-17 7:17 AM, jeffmehlenbacher at ipv4marketgroup.com wrote: > > I would agree that free allocations should be scrutinized closely to > > ensure need. For 8.3 Specified Transfers however, no purpose is served > > when a transfer is rejected between a Company with an unused allocation > > and a Company in need. The unused IPv4 block at the source Company > > remains unused. The rejected recipient Company must seek alternatives > > which may include applying to ARIN for a smaller block from the free > > pool. > > > > Jeff Mehlenbacher > > jeff, i'm concerned with the case where a broker actually holds address > space. the current transfer system allows recipients with greater need > to receive resources from those with lesser need. i do not understand > the value add of putting resources into a broker's inventory. --paul > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. -------------- next part -------------- An HTML attachment was scrubbed... URL: From joe at oregon.uoregon.edu Fri Feb 17 13:26:04 2012 From: joe at oregon.uoregon.edu (Joe St Sauver) Date: Fri, 17 Feb 2012 10:26:04 -0800 (PST) Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers Message-ID: <12021710260440_1095@oregon.uoregon.edu> Hi, Documentation of need is a long-established and proven principle that has helped ensure sound community stewardship of a critical resource, and I'm not persuaded that continuance of that requirement would be detrimental (or even pose a substantial obstacle) to legitimate resource transfers. I respectfully oppose the proposal. Regards, Joe St Sauver, Ph.D. (joe at oregon.uoregon.edu) From gene.jeffers at emp.shentel.com Fri Feb 17 13:42:03 2012 From: gene.jeffers at emp.shentel.com (Gene Jeffers) Date: Fri, 17 Feb 2012 13:42:03 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers Message-ID: <34F9FF28526C094697742849BAB2E8D403AB87D3EE@EXCHANGE7.shentel.com> Put me down as opposed to this measure. It definitely opens the door to speculation and "hoarding" of address space by companies that can afford to buy it up. I have no problem with existing "need based" regulations. Thanks, Gene Jeffers Network Engineer Shenandoah Telecommunications Company -------------- next part -------------- An HTML attachment was scrubbed... URL: From jeffrey.lyon at blacklotus.net Fri Feb 17 13:54:51 2012 From: jeffrey.lyon at blacklotus.net (Jeffrey Lyon) Date: Fri, 17 Feb 2012 13:54:51 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: <34F9FF28526C094697742849BAB2E8D403AB87D3EE@EXCHANGE7.shentel.com> References: <34F9FF28526C094697742849BAB2E8D403AB87D3EE@EXCHANGE7.shentel.com> Message-ID: On Fri, Feb 17, 2012 at 1:42 PM, Gene Jeffers wrote: > Put me down as opposed to this measure. It definitely opens the door to > speculation and ?hoarding? of address space by companies that can afford to > buy it up. I have no problem with existing ?need based? regulations. > > Thanks, > > > > Gene Jeffers > > Network Engineer > > Shenandoah Telecommunications Company > > > > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. I would be interested in seeing a small allocation carved out for the purpose of running a test, to see what would happen in a free market without needs basis. Those who have justified need could continue using existing policies to obtain space, and those without (eg. need space in a pinch, cant/dont feel like writing up justification) could purchase from the special allocation at the going market rate. -- Jeffrey Lyon, Leadership Team jeffrey.lyon at blacklotus.net | http://www.blacklotus.net Black Lotus Communications - AS32421 First and Leading in DDoS Protection Solutions From jeffrey.lyon at blacklotus.net Fri Feb 17 13:59:29 2012 From: jeffrey.lyon at blacklotus.net (Jeffrey Lyon) Date: Fri, 17 Feb 2012 13:59:29 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <9953E516-59AF-4269-91D1-4A467E2AC32C@delong.com> References: <20120217081901.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.34816080d0.wbe@email17.secureserver.net> <9953E516-59AF-4269-91D1-4A467E2AC32C@delong.com> Message-ID: On Fri, Feb 17, 2012 at 1:25 PM, Owen DeLong wrote: > Jeff, > > If this policy is adopted, it would enable speculative brokers who wanted to > to maintain inventory without showing need for the addresses. It would > potentially turn IP addresses into a commodities futures market which I do > not believe would serve the community well. > > You say that no purpose is served when a transfer is rejected between a > company with an unused allocation and a company in need. ?Current policy > does not do that. It does limit the size of the transfer to the justified > need, but, it does not reject the transfer. > > However, no purpose is served when addresses are allowed to be purchased by > organizations without need and great harm could come from allowing such > transactions if they start occurring on large scale in order to engage in > speculation or worse, anti-competitive practices. > > Owen > > On Feb 17, 2012, at 7:19 AM, > wrote: > > Paul, I cannot speak to how other brokers structure their business, but we > do not actually hold address space if I interpret you literally.? Our > Sellers hold the address space.? We are contracted by companies with unused > IPv4 blocks to source a company with need.? Once a potential needer is > identified, we facilitate agreement on price, timing and other conditions of > a transfer then provide the necessary legal documents and guidance to > execute the transactions contingent upon ARIN approval.? The value of any > broker--be it insurance, mortgage, real estate or IPv4 transfers--is > subjective but clearly if a Seller and a Buyer prefer to use a broker, they > should do so.? The Policy Proposal as written assumes there may or may not > be broker involvement in Specified Transfers. > > Jeff Mehlenbacher > > -------- Original Message -------- > Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based > Justification > From: Paul Vixie > Date: Fri, February 17, 2012 9:18 am > To: jeffmehlenbacher at ipv4marketgroup.com > Cc: arin-ppml at arin.net > > On 2012-02-17 7:17 AM, jeffmehlenbacher at ipv4marketgroup.com wrote: >> I would agree that free allocations should be scrutinized closely to >> ensure need. For 8.3 Specified Transfers however, no purpose is served >> when a transfer is rejected between a Company with an unused allocation >> and a Company in need. The unused IPv4 block at the source Company >> remains unused. The rejected recipient Company must seek alternatives >> which may include applying to ARIN for a smaller block from the free >> pool. >> >> Jeff Mehlenbacher > > jeff, i'm concerned with the case where a broker actually holds address > space. the current transfer system allows recipients with greater need > to receive resources from those with lesser need. i do not understand > the value add of putting resources into a broker's inventory. --paul > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. > > > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. Owen, As resident devils advocate, I would be remiss not to point out that anyone who stocks IP space they can't sell would soon find themselves out of business thus discouraging others from substantially engaging in the same practice, thus the "invisible hand" fixes the market. -- Jeffrey Lyon, Leadership Team jeffrey.lyon at blacklotus.net | http://www.blacklotus.net Black Lotus Communications - AS32421 First and Leading in DDoS Protection Solutions From owen at delong.com Fri Feb 17 14:12:50 2012 From: owen at delong.com (Owen DeLong) Date: Fri, 17 Feb 2012 11:12:50 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: References: <34F9FF28526C094697742849BAB2E8D403AB87D3EE@EXCHANGE7.shentel.com> Message-ID: This wouldn't test the bigger concerns about a market. The larger concerns come from market manipulation, speculative trading, and efforts to control/corner the market. There would be no incentive to do so in the test market. Owen On Feb 17, 2012, at 10:54 AM, Jeffrey Lyon wrote: > On Fri, Feb 17, 2012 at 1:42 PM, Gene Jeffers > wrote: >> Put me down as opposed to this measure. It definitely opens the door to >> speculation and ?hoarding? of address space by companies that can afford to >> buy it up. I have no problem with existing ?need based? regulations. >> >> Thanks, >> >> >> >> Gene Jeffers >> >> Network Engineer >> >> Shenandoah Telecommunications Company >> >> >> >> >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. > > I would be interested in seeing a small allocation carved out for the > purpose of running a test, to see what would happen in a free market > without needs basis. Those who have justified need could continue > using existing policies to obtain space, and those without (eg. need > space in a pinch, cant/dont feel like writing up justification) could > purchase from the special allocation at the going market rate. > > -- > Jeffrey Lyon, Leadership Team > jeffrey.lyon at blacklotus.net | http://www.blacklotus.net > Black Lotus Communications - AS32421 > First and Leading in DDoS Protection Solutions > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From jeffrey.lyon at blacklotus.net Fri Feb 17 14:17:49 2012 From: jeffrey.lyon at blacklotus.net (Jeffrey Lyon) Date: Fri, 17 Feb 2012 14:17:49 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: References: <34F9FF28526C094697742849BAB2E8D403AB87D3EE@EXCHANGE7.shentel.com> Message-ID: On Fri, Feb 17, 2012 at 2:12 PM, Owen DeLong wrote: > This wouldn't test the bigger concerns about a market. > > The larger concerns come from market manipulation, speculative trading, and efforts to control/corner the market. There would be no incentive to do so in the test market. > > Owen > > On Feb 17, 2012, at 10:54 AM, Jeffrey Lyon wrote: > >> On Fri, Feb 17, 2012 at 1:42 PM, Gene Jeffers >> wrote: >>> Put me down as opposed to this measure. It definitely opens the door to >>> speculation and ?hoarding? of address space by companies that can afford to >>> buy it up. I have no problem with existing ?need based? regulations. >>> >>> Thanks, >>> >>> >>> >>> Gene Jeffers >>> >>> Network Engineer >>> >>> Shenandoah Telecommunications Company >>> >>> >>> >>> >>> _______________________________________________ >>> PPML >>> You are receiving this message because you are subscribed to >>> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >>> Unsubscribe or manage your mailing list subscription at: >>> http://lists.arin.net/mailman/listinfo/arin-ppml >>> Please contact info at arin.net if you experience any issues. >> >> I would be interested in seeing a small allocation carved out for the >> purpose of running a test, to see what would happen in a free market >> without needs basis. Those who have justified need could continue >> using existing policies to obtain space, and those without (eg. need >> space in a pinch, cant/dont feel like writing up justification) could >> purchase from the special allocation at the going market rate. >> >> -- >> Jeffrey Lyon, Leadership Team >> jeffrey.lyon at blacklotus.net | http://www.blacklotus.net >> Black Lotus Communications - AS32421 >> First and Leading in DDoS Protection Solutions >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. Sure there would, anyone who wants to buy, sell, trade space would have to use the test market. It would function exactly the same. By your logic, even if all of ARIN dropped needs basis everyone could just go to a different RIR, and if that's the case then it ultimately doesn't matter if we have needs basis at all. -- Jeffrey Lyon, Leadership Team jeffrey.lyon at blacklotus.net | http://www.blacklotus.net Black Lotus Communications - AS32421 First and Leading in DDoS Protection Solutions From owen at delong.com Fri Feb 17 14:19:19 2012 From: owen at delong.com (Owen DeLong) Date: Fri, 17 Feb 2012 11:19:19 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217081901.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.34816080d0.wbe@email17.secureserver.net> <9953E516-59AF-4269-91D1-4A467E2AC32C@delong.com> Message-ID: On Feb 17, 2012, at 10:59 AM, Jeffrey Lyon wrote: > On Fri, Feb 17, 2012 at 1:25 PM, Owen DeLong wrote: >> Jeff, >> >> If this policy is adopted, it would enable speculative brokers who wanted to >> to maintain inventory without showing need for the addresses. It would >> potentially turn IP addresses into a commodities futures market which I do >> not believe would serve the community well. >> >> You say that no purpose is served when a transfer is rejected between a >> company with an unused allocation and a company in need. Current policy >> does not do that. It does limit the size of the transfer to the justified >> need, but, it does not reject the transfer. >> >> However, no purpose is served when addresses are allowed to be purchased by >> organizations without need and great harm could come from allowing such >> transactions if they start occurring on large scale in order to engage in >> speculation or worse, anti-competitive practices. >> >> Owen > > Owen, > > As resident devils advocate, I would be remiss not to point out that > anyone who stocks IP space they can't sell would soon find themselves > out of business thus discouraging others from substantially engaging > in the same practice, thus the "invisible hand" fixes the market. True, but, it would not be unusual to stock addresses at $10 until the market had high demand and low supply, then try to sell them for $50. The community does not benefit from that $40 spread. The community is harmed by that $40 spread. Only the speculator benefits from that spread. The invisible hand is slow to react and easily manipulated by those with resources to do so. Owen -------------- next part -------------- An HTML attachment was scrubbed... URL: From rriske at visionfinancialmarkets.com Fri Feb 17 14:12:57 2012 From: rriske at visionfinancialmarkets.com (Ryan Riske) Date: Fri, 17 Feb 2012 13:12:57 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justificationon 8.3 Specified Transfers In-Reply-To: <18B2C6E38A3A324986B392B2D18ABC5101D4DD6566@fnb1mbx01.gci.com> References: <18B2C6E38A3A324986B392B2D18ABC5101D4DD6566@fnb1mbx01.gci.com> Message-ID: <4F3EA6B9.9090806@visionfinancialmarkets.com> I also vote against prop 165 as written and in spirit. Needs-based justification keeps the field level for all players, and is important to prevent speculation, hoarding, and other anti-competitive and anti-community behaviors. From mike at nationwideinc.com Fri Feb 17 14:27:03 2012 From: mike at nationwideinc.com (Mike Burns) Date: Fri, 17 Feb 2012 14:27:03 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-BasedJustificationon8.3 Specified Transfers In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com><4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> Message-ID: >I've been told that parties who want to make a marketplace also want the results from their transactions to be in the registry and accepted by the community. Interestingly enough, the inherent conflict between wanting the community to accept the results of their 'sales' in the registry but not wanting to follow the same community's policies for changes to the registry hasn't been very well understood. FYI, /John As Owen noted, it is the routing community which holds the cards here. My guess is that if ARIN maintains it's anti-free-market tendencies, that routers will simply look at whomever is the registrant in Whois, then rely on their customer's documentation of chain of custody of the address rights from that Whois registrant up to their customer. Then they will have the customer attest to this chain of custody and route the addresses. And they will let the courts settle any discrepancies or challenges to that chain of custody. At some point, the professed desire to be registered, which you accept above, will drive the creation of a private registry for lucky legacy holders who never signed an RSA. And we will have a permanent class system for IPv4 addresses. Regards, Mike From jcurran at arin.net Fri Feb 17 14:38:48 2012 From: jcurran at arin.net (John Curran) Date: Fri, 17 Feb 2012 19:38:48 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-BasedJustificationon8.3 Specified Transfers In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> Message-ID: <5EA8DFF9-7121-4A42-936F-39F040125FE2@arin.net> On Feb 17, 2012, at 2:27 PM, Mike Burns wrote: > As Owen noted, it is the routing community which holds the cards here. > My guess is that if ARIN maintains it's anti-free-market tendencies, that routers will simply look at whomever is the registrant in Whois, then rely on their customer's documentation of chain of custody of the address rights from that Whois registrant up to their customer. "ARIN" doesn't have tendencies... ARIN does have policies which are set by the community based on the discourse on this mailing list and in the public policy meetings. If that community wants to allow transfers without policy constraints (e.g. so that someone can transfer a /30 to another party), then the policies are easy enough to change. The policies have direct impact on those who run the routers, and that appears to have been quite a bit of the resistance to these unconstrained market proposals. Thanks! /John John Curran President and CEO ARIN From astrodog at gmail.com Fri Feb 17 14:41:39 2012 From: astrodog at gmail.com (Astrodog) Date: Fri, 17 Feb 2012 13:41:39 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justificationon 8.3 Specified Transfers In-Reply-To: <4F3EA6B9.9090806@visionfinancialmarkets.com> References: <18B2C6E38A3A324986B392B2D18ABC5101D4DD6566@fnb1mbx01.gci.com> <4F3EA6B9.9090806@visionfinancialmarkets.com> Message-ID: On Fri, Feb 17, 2012 at 1:12 PM, Ryan Riske wrote: > I also vote against prop 165 as written and in spirit. ?Needs-based > justification keeps the field level for all players, and is important to > prevent speculation, hoarding, and other anti-competitive and anti-community > behaviors. > Something is being missed here that I think is significant. The current system does not keep the field level for all players. It rewards players which are better at interpreting and writing their justification to exactly what ARIN requires, or who have proposed uses more in line with what is expected. While this is easier to do with actual need, that is not actually required. A large number of organizations can meet the letter of the rules for an allocation, but have no real use for the address space currently. This results in those organizations requesting more space than they will actually use, simply to avoid fighting with it again later. If those organizations knew that there was an easy way to obtain and release address space as required, they would be inclined to sell address space they are not currently using, knowing that new space could be acquired at a later date. This would serve to keep their allocation in line with their needs. I think a big part of stewardship of the IPv4 space, as it nears exhaustion, is ensuring that organizations that have more space than they need can easily transfer that space to another organization that will use it, and has a financial incentive to do so. Otherwise, the only way to claim this space is for ARIN to audit these organizations, and do something along the lines of revoking the allocation. The needs test creates a regulatory hurdle for organizations, making them much less likely to attempt to transfer. Keep in mind that in as far as speculation goes, the value of IPv4 addresses will, over the long term, trend to 0. There would be a very real risk in cornering the market that one would instead speed the migration to IPv6, and greatly reduce the value of the address space. From jeffrey.lyon at blacklotus.net Fri Feb 17 14:43:41 2012 From: jeffrey.lyon at blacklotus.net (Jeffrey Lyon) Date: Fri, 17 Feb 2012 14:43:41 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217081901.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.34816080d0.wbe@email17.secureserver.net> <9953E516-59AF-4269-91D1-4A467E2AC32C@delong.com> Message-ID: On Fri, Feb 17, 2012 at 2:19 PM, Owen DeLong wrote: > > On Feb 17, 2012, at 10:59 AM, Jeffrey Lyon wrote: > > On Fri, Feb 17, 2012 at 1:25 PM, Owen DeLong wrote: > > Jeff, > > > If this policy is adopted, it would enable speculative brokers who wanted to > > to maintain inventory without showing need for the addresses. It would > > potentially turn IP addresses into a commodities futures market which I do > > not believe would serve the community well. > > > You say that no purpose is served when a transfer is rejected between a > > company with an unused allocation and a company in need. ?Current policy > > does not do that. It does limit the size of the transfer to the justified > > need, but, it does not reject the transfer. > > > However, no purpose is served when addresses are allowed to be purchased by > > organizations without need and great harm could come from allowing such > > transactions if they start occurring on large scale in order to engage in > > speculation or worse, anti-competitive practices. > > > Owen > > > Owen, > > As resident devils advocate, I would be remiss not to point out that > anyone who stocks IP space they can't sell would soon find themselves > out of business thus discouraging others from substantially engaging > in the same practice, thus the "invisible hand" fixes the market. > > > True, but, it would not be unusual to stock addresses at $10 until the > market had high demand and low supply, then try to sell them for $50. > > The community does not benefit from that $40 spread. The community is harmed > by that $40 spread. Only the speculator benefits from that spread. > > The invisible hand is slow to react and easily manipulated by those with > resources to do so. > > Owen > > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. Having a test market would not have any impact on the supply and demand of the free pool. The free pool would continue to exist as-is. The only spread would be in the test market, so those not participating are not impacted. -- Jeffrey Lyon, Leadership Team jeffrey.lyon at blacklotus.net | http://www.blacklotus.net Black Lotus Communications - AS32421 First and Leading in DDoS Protection Solutions From jmaimon at chl.com Fri Feb 17 14:50:02 2012 From: jmaimon at chl.com (Joe Maimon) Date: Fri, 17 Feb 2012 14:50:02 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-BasedJustificationon8.3 Specified Transfers In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com><4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> Message-ID: <4F3EAF6A.6090705@chl.com> Mike Burns wrote: > >> I've been told that parties who want to make a marketplace also want the > results from their transactions to be in the registry and accepted by the > community. Interestingly enough, the inherent conflict between wanting > the community to accept the results of their 'sales' in the registry but > not wanting to follow the same community's policies for changes to the > registry hasn't been very well understood. > > FYI, > /John > > > As Owen noted, it is the routing community which holds the cards here. > My guess is that if ARIN maintains it's anti-free-market tendencies, > that routers will simply look at whomever is the registrant in Whois, > then rely on their customer's documentation of chain of custody of the > address rights from that Whois registrant up to their customer. > > Then they will have the customer attest to this chain of custody and > route the addresses. > > And they will let the courts settle any discrepancies or challenges to > that chain of custody. > > At some point, the professed desire to be registered, which you accept > above, will drive the creation of a private registry for lucky legacy > holders who never signed an RSA. > And we will have a permanent class system for IPv4 addresses. > > Regards, > Mike > Not only do you have to make the case that this is a likely outcome, you must also make the case that the resultant negative effects are best headed off with this proposal which you support, and that any negative effects from this proposal are a worthy cost to obtain its benefits. While I share your concern about registration and routing data fragmentation, I must note that it has never been the case that industry routing decisions were based solely and predictably on registration data. However, it has always been the case that the best approach to attempting to ensure unique routability starts with unique registration, with community-wide acceptance of such. Unless that changes in a substantial fashion, ARIN and the RiR's will always have value to the community, and transfers performed without that system will not realize that value. As a small suggestion to those who agree with your concerns, or at the least, with your supported solution, chipping away in piecemeal fashion at transfers' needs requirements is likely to win wider support then appearing to do away with them completely. I will note that the more publicly known transfers did not seem to get overly hung up on needs requirements. I suspect that like all bureaucracy, familiarity breeds conformance competency or as others have said, going along to get along was the prevailing attitude. But enough about registration. Lets talk conflict, where ARIN records a transfer or allocation to a party that is contested by another party who has not obtained its claimed exclusivity rights pursuant to registry policy. How likely is that scenario to become commonplace? Whom do you project to win these kinds of confrontations? Who will be the losers? Best, Joe From jeffmehlenbacher at ipv4marketgroup.com Fri Feb 17 15:04:46 2012 From: jeffmehlenbacher at ipv4marketgroup.com (jeffmehlenbacher at ipv4marketgroup.com) Date: Fri, 17 Feb 2012 13:04:46 -0700 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification Message-ID: <20120217130446.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.cd467d4b9f.wbe@email17.secureserver.net> Owen, yes, there is much community concern over speculation, hording, greed, cornering the market. Needs-based justification on Specified Transfers is one way to discourage (but not eliminate) these acts. Our Proposed Policy seeks only to encourage a vibrant, legitimate open market between those with unused IPv4 blocks and those with stated need. Is it in the best interest of the community to maintain needs-based justification policy that may discourage legitimate participation through Specified Transfers in an attempt to corral the fringe element that would seek to speculate, horde and profit from IPv4 transfers? Jeff Mehlenbacher -------- Original Message -------- Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification From: Owen DeLong Date: Fri, February 17, 2012 2:19 pm To: Jeffrey Lyon Cc: "" , arin-ppml at arin.net On Feb 17, 2012, at 10:59 AM, Jeffrey Lyon wrote: On Fri, Feb 17, 2012 at 1:25 PM, Owen DeLong wrote: Jeff, If this policy is adopted, it would enable speculative brokers who wanted to to maintain inventory without showing need for the addresses. It would potentially turn IP addresses into a commodities futures market which I do not believe would serve the community well. You say that no purpose is served when a transfer is rejected between a company with an unused allocation and a company in need. Current policy does not do that. It does limit the size of the transfer to the justified need, but, it does not reject the transfer. However, no purpose is served when addresses are allowed to be purchased by organizations without need and great harm could come from allowing such transactions if they start occurring on large scale in order to engage in speculation or worse, anti-competitive practices. Owen Owen, As resident devils advocate, I would be remiss not to point out that anyone who stocks IP space they can't sell would soon find themselves out of business thus discouraging others from substantially engaging in the same practice, thus the "invisible hand" fixes the market. True, but, it would not be unusual to stock addresses at $10 until the market had high demand and low supply, then try to sell them for $50. The community does not benefit from that $40 spread. The community is harmed by that $40 spread. Only the speculator benefits from that spread. The invisible hand is slow to react and easily manipulated by those with resources to do so. Owen From daved at lightwave.net Fri Feb 17 15:29:57 2012 From: daved at lightwave.net (Daved Daly) Date: Fri, 17 Feb 2012 12:29:57 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <20120217130446.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.cd467d4b9f.wbe@email17.secureserver.net> References: <20120217130446.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.cd467d4b9f.wbe@email17.secureserver.net> Message-ID: On Fri, Feb 17, 2012 at 12:04 PM, wrote: > Is it in the best interest of the community to maintain needs-based > justification policy that may discourage legitimate participation > through Specified Transfers in an attempt to corral the fringe element > that would seek to speculate, horde and profit from IPv4 transfers? > I don't want to speak for them, but It seems like the obvious answer much of the community is responding with is a clear, "yes". -------------- next part -------------- An HTML attachment was scrubbed... URL: From dogwallah at gmail.com Fri Feb 17 15:58:14 2012 From: dogwallah at gmail.com (McTim) Date: Fri, 17 Feb 2012 20:58:14 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217130446.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.cd467d4b9f.wbe@email17.secureserver.net> Message-ID: On Friday, February 17, 2012, Daved Daly wrote: > On Fri, Feb 17, 2012 at 12:04 PM, > > wrote: > >> Is it in the best interest of the community to maintain needs-based >> justification policy that may discourage legitimate participation >> through Specified Transfers in an attempt to corral the fringe element >> that would seek to speculate, horde and profit from IPv4 transfers? >> > > I don't want to speak for them, but It seems like the obvious answer much > of the community is responding with is a clear, "yes". > according to MM, we are just a *small number of anti-market ideologues*. In any case, there are better reasons to maintain needs requirements besides *corralling the fringe element*, but that alone is reason enough IMO. Rgds, McTim -- Cheers, McTim "A name indicates what we seek. An address indicates where it is. A route indicates how we get there." Jon Postel -------------- next part -------------- An HTML attachment was scrubbed... URL: From jeffmehlenbacher at ipv4marketgroup.com Fri Feb 17 16:17:03 2012 From: jeffmehlenbacher at ipv4marketgroup.com (jeffmehlenbacher at ipv4marketgroup.com) Date: Fri, 17 Feb 2012 14:17:03 -0700 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification Message-ID: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> Owen, you are correct to say "Current policy does not do that. It does limit the size of the transfer to the justified need, but, it does not reject the transfer." Please understand however, that when ARIN rejects a specified transfer of, for example, a /16 under current policy and concludes, for example, that only a /20 is justified...there is little recourse for the Buyer or Seller. They have executed an Asset Purchase Agreement, funds were held in escrow for the full /16 and the deal is dead. The Seller will not carve out the unused /16 holding to a /17, a /18 a /19 and two /20s-necessitating modification to the current transaction plus 4 more transactions and all of the additional sourcing of additional Buyers and execution of legal agreements. The Buyer must seek alternatives which may include returning to ARIN for a free distribution of a /20. Again, the Seller's /16 remains unused which serves only to add to the scarcity of supply and the Buyer has consumed many months in planning for the deployment of the now rejected /16. What purpose has been served? Jeff Mehlenbacher -------- Original Message -------- Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification From: Jeffrey Lyon Date: Fri, February 17, 2012 2:43 pm To: Owen DeLong Cc: "" , arin-ppml at arin.net On Fri, Feb 17, 2012 at 2:19 PM, Owen DeLong wrote: > > On Feb 17, 2012, at 10:59 AM, Jeffrey Lyon wrote: > > On Fri, Feb 17, 2012 at 1:25 PM, Owen DeLong wrote: > > Jeff, > > > If this policy is adopted, it would enable speculative brokers who wanted to > > to maintain inventory without showing need for the addresses. It would > > potentially turn IP addresses into a commodities futures market which I do > > not believe would serve the community well. > > > You say that no purpose is served when a transfer is rejected between a > > company with an unused allocation and a company in need. Current policy > > does not do that. It does limit the size of the transfer to the justified > > need, but, it does not reject the transfer. > > > However, no purpose is served when addresses are allowed to be purchased by > > organizations without need and great harm could come from allowing such > > transactions if they start occurring on large scale in order to engage in > > speculation or worse, anti-competitive practices. > > > Owen > > > Owen, > > As resident devils advocate, I would be remiss not to point out that > anyone who stocks IP space they can't sell would soon find themselves > out of business thus discouraging others from substantially engaging > in the same practice, thus the "invisible hand" fixes the market. > > > True, but, it would not be unusual to stock addresses at $10 until the > market had high demand and low supply, then try to sell them for $50. > > The community does not benefit from that $40 spread. The community is harmed > by that $40 spread. Only the speculator benefits from that spread. > > The invisible hand is slow to react and easily manipulated by those with > resources to do so. > > Owen > > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. Having a test market would not have any impact on the supply and demand of the free pool. The free pool would continue to exist as-is. The only spread would be in the test market, so those not participating are not impacted. -- Jeffrey Lyon, Leadership Team jeffrey.lyon at blacklotus.net | http://www.blacklotus.net Black Lotus Communications - AS32421 First and Leading in DDoS Protection Solutions From owen at delong.com Fri Feb 17 16:24:46 2012 From: owen at delong.com (Owen DeLong) Date: Fri, 17 Feb 2012 13:24:46 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217081901.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.34816080d0.wbe@email17.secureserver.net> <9953E516-59AF-4269-91D1-4A467E2AC32C@delong.com> Message-ID: On Feb 17, 2012, at 11:43 AM, Jeffrey Lyon wrote: > On Fri, Feb 17, 2012 at 2:19 PM, Owen DeLong wrote: >> >> On Feb 17, 2012, at 10:59 AM, Jeffrey Lyon wrote: >> >> On Fri, Feb 17, 2012 at 1:25 PM, Owen DeLong wrote: >> >> Jeff, >> >> >> If this policy is adopted, it would enable speculative brokers who wanted to >> >> to maintain inventory without showing need for the addresses. It would >> >> potentially turn IP addresses into a commodities futures market which I do >> >> not believe would serve the community well. >> >> >> You say that no purpose is served when a transfer is rejected between a >> >> company with an unused allocation and a company in need. Current policy >> >> does not do that. It does limit the size of the transfer to the justified >> >> need, but, it does not reject the transfer. >> >> >> However, no purpose is served when addresses are allowed to be purchased by >> >> organizations without need and great harm could come from allowing such >> >> transactions if they start occurring on large scale in order to engage in >> >> speculation or worse, anti-competitive practices. >> >> >> Owen >> >> >> Owen, >> >> As resident devils advocate, I would be remiss not to point out that >> anyone who stocks IP space they can't sell would soon find themselves >> out of business thus discouraging others from substantially engaging >> in the same practice, thus the "invisible hand" fixes the market. >> >> >> True, but, it would not be unusual to stock addresses at $10 until the >> market had high demand and low supply, then try to sell them for $50. >> >> The community does not benefit from that $40 spread. The community is harmed >> by that $40 spread. Only the speculator benefits from that spread. >> >> The invisible hand is slow to react and easily manipulated by those with >> resources to do so. >> >> Owen >> >> >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. > > Having a test market would not have any impact on the supply and > demand of the free pool. The free pool would continue to exist as-is. > The only spread would be in the test market, so those not > participating are not impacted. As I said, a test market would not have the same incentives to mischief/evil as a full-blown market would because the evil benefits would be capped by the regulated market and free pool allocations. It is exactly this limited impact that makes the test invalid. OTOH, it is the damage that would be done if this is taken full scale that is my reasoning for opposing the policy on a full-scale basis regardless of the outcome of such a test if it were conducted. I'm not opposed to the test, I merely question that it has any value whatsoever. Owen From jcurran at arin.net Fri Feb 17 16:32:21 2012 From: jcurran at arin.net (John Curran) Date: Fri, 17 Feb 2012 21:32:21 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> Message-ID: <6C73E0BF-1EC6-4478-AF1E-2A776AD15014@corp.arin.net> On Feb 17, 2012, at 4:17 PM, jeffmehlenbacher at ipv4marketgroup.com wrote: > Please understand however, that when ARIN rejects a specified transfer > of, for example, a /16 under current policy and concludes, for example, > that only a /20 is justified...there is little recourse for the Buyer or > Seller. They have executed an Asset Purchase Agreement, funds were held > in escrow for the full /16 and the deal is dead. That is not always the case... We've had several cases where deals have been amended as a result of feedback during the transfer request process. FYI, /John John Curran President and CEO ARIN From ebw at abenaki.wabanaki.net Fri Feb 17 16:35:10 2012 From: ebw at abenaki.wabanaki.net (Eric Brunner-Williams) Date: Fri, 17 Feb 2012 16:35:10 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-BasedJustificationon8.3 Specified Transfers In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com><4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> Message-ID: <4F3EC80E.9090700@abenaki.wabanaki.net> On 2/17/12 2:27 PM, Mike Burns wrote: > My guess is that if ... > that routers will simply look at whomever is the registrant in Whois ... um, is that blocking for a user-space event to complete in the fast-path? if so, were you planning to propose implementation in upsidasium rather than silicon? -e From owen at delong.com Fri Feb 17 16:30:06 2012 From: owen at delong.com (Owen DeLong) Date: Fri, 17 Feb 2012 13:30:06 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> Message-ID: Why in such a circumstance would the seller not choose one of these alternatives: 1. Fragment the space, sell the /20 to the original buyer and move on to looking for additional buyers. 2. Find a buyer that does have legitimate need for a /16 (If there's value to not carving it up, isn't that defined in terms of market demand for the space as a whole?) 3. Return the /16 to ARIN so that it can be used elsewhere. Sorry, but, I just don't buy your argument that the seller would rather keep the /16 in inventory making no money than selling it in pieces or selling it to a different buyer that does have need for the full amount. It's illogical in the extreme. Owen On Feb 17, 2012, at 1:17 PM, wrote: > Owen, you are correct to say "Current policy does not do that. It does > limit the size of the transfer to the justified need, but, it does not > reject the transfer." > > Please understand however, that when ARIN rejects a specified transfer > of, for example, a /16 under current policy and concludes, for example, > that only a /20 is justified...there is little recourse for the Buyer or > Seller. They have executed an Asset Purchase Agreement, funds were held > in escrow for the full /16 and the deal is dead. The Seller will not > carve out the unused /16 holding to a /17, a /18 a /19 and two > /20s-necessitating modification to the current transaction plus 4 more > transactions and all of the additional sourcing of additional Buyers and > execution of legal agreements. The Buyer must seek alternatives which > may include returning to ARIN for a free distribution of a /20. > > Again, the Seller's /16 remains unused which serves only to add to the > scarcity of supply and the Buyer has consumed many months in planning > for the deployment of the now rejected /16. What purpose has been > served? > > Jeff Mehlenbacher > > -------- Original Message -------- > Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based > Justification > From: Jeffrey Lyon > Date: Fri, February 17, 2012 2:43 pm > To: Owen DeLong > Cc: "" > , arin-ppml at arin.net > > On Fri, Feb 17, 2012 at 2:19 PM, Owen DeLong wrote: >> >> On Feb 17, 2012, at 10:59 AM, Jeffrey Lyon wrote: >> >> On Fri, Feb 17, 2012 at 1:25 PM, Owen DeLong wrote: >> >> Jeff, >> >> >> If this policy is adopted, it would enable speculative brokers who wanted to >> >> to maintain inventory without showing need for the addresses. It would >> >> potentially turn IP addresses into a commodities futures market which I do >> >> not believe would serve the community well. >> >> >> You say that no purpose is served when a transfer is rejected between a >> >> company with an unused allocation and a company in need. Current policy >> >> does not do that. It does limit the size of the transfer to the justified >> >> need, but, it does not reject the transfer. >> >> >> However, no purpose is served when addresses are allowed to be purchased by >> >> organizations without need and great harm could come from allowing such >> >> transactions if they start occurring on large scale in order to engage in >> >> speculation or worse, anti-competitive practices. >> >> >> Owen >> >> >> Owen, >> >> As resident devils advocate, I would be remiss not to point out that >> anyone who stocks IP space they can't sell would soon find themselves >> out of business thus discouraging others from substantially engaging >> in the same practice, thus the "invisible hand" fixes the market. >> >> >> True, but, it would not be unusual to stock addresses at $10 until the >> market had high demand and low supply, then try to sell them for $50. >> >> The community does not benefit from that $40 spread. The community is harmed >> by that $40 spread. Only the speculator benefits from that spread. >> >> The invisible hand is slow to react and easily manipulated by those with >> resources to do so. >> >> Owen >> >> >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. > > Having a test market would not have any impact on the supply and > demand of the free pool. The free pool would continue to exist as-is. > The only spread would be in the test market, so those not > participating are not impacted. > > -- > Jeffrey Lyon, Leadership Team > jeffrey.lyon at blacklotus.net | http://www.blacklotus.net > Black Lotus Communications - AS32421 > First and Leading in DDoS Protection Solutions > From kkargel at polartel.com Fri Feb 17 16:38:32 2012 From: kkargel at polartel.com (Kevin Kargel) Date: Fri, 17 Feb 2012 15:38:32 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <6C73E0BF-1EC6-4478-AF1E-2A776AD15014@corp.arin.net> References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> <6C73E0BF-1EC6-4478-AF1E-2A776AD15014@corp.arin.net> Message-ID: <8695009A81378E48879980039EEDAD28011E05E3FA@MAIL1.polartel.local> If we are going to eliminate needs basis can I call "DIBS" on all the addresses that are left right now? :) Sorry list, I couldn't resist.. Kevin -------------- next part -------------- A non-text attachment was scrubbed... Name: smime.p7s Type: application/x-pkcs7-signature Size: 4935 bytes Desc: not available URL: From jeffrey.lyon at blacklotus.net Fri Feb 17 16:46:00 2012 From: jeffrey.lyon at blacklotus.net (Jeffrey Lyon) Date: Fri, 17 Feb 2012 16:46:00 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217081901.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.34816080d0.wbe@email17.secureserver.net> <9953E516-59AF-4269-91D1-4A467E2AC32C@delong.com> Message-ID: On Fri, Feb 17, 2012 at 4:24 PM, Owen DeLong wrote: > > On Feb 17, 2012, at 11:43 AM, Jeffrey Lyon wrote: > >> On Fri, Feb 17, 2012 at 2:19 PM, Owen DeLong wrote: >>> >>> On Feb 17, 2012, at 10:59 AM, Jeffrey Lyon wrote: >>> >>> On Fri, Feb 17, 2012 at 1:25 PM, Owen DeLong wrote: >>> >>> Jeff, >>> >>> >>> If this policy is adopted, it would enable speculative brokers who wanted to >>> >>> to maintain inventory without showing need for the addresses. It would >>> >>> potentially turn IP addresses into a commodities futures market which I do >>> >>> not believe would serve the community well. >>> >>> >>> You say that no purpose is served when a transfer is rejected between a >>> >>> company with an unused allocation and a company in need. ?Current policy >>> >>> does not do that. It does limit the size of the transfer to the justified >>> >>> need, but, it does not reject the transfer. >>> >>> >>> However, no purpose is served when addresses are allowed to be purchased by >>> >>> organizations without need and great harm could come from allowing such >>> >>> transactions if they start occurring on large scale in order to engage in >>> >>> speculation or worse, anti-competitive practices. >>> >>> >>> Owen >>> >>> >>> Owen, >>> >>> As resident devils advocate, I would be remiss not to point out that >>> anyone who stocks IP space they can't sell would soon find themselves >>> out of business thus discouraging others from substantially engaging >>> in the same practice, thus the "invisible hand" fixes the market. >>> >>> >>> True, but, it would not be unusual to stock addresses at $10 until the >>> market had high demand and low supply, then try to sell them for $50. >>> >>> The community does not benefit from that $40 spread. The community is harmed >>> by that $40 spread. Only the speculator benefits from that spread. >>> >>> The invisible hand is slow to react and easily manipulated by those with >>> resources to do so. >>> >>> Owen >>> >>> >>> _______________________________________________ >>> PPML >>> You are receiving this message because you are subscribed to >>> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >>> Unsubscribe or manage your mailing list subscription at: >>> http://lists.arin.net/mailman/listinfo/arin-ppml >>> Please contact info at arin.net if you experience any issues. >> >> Having a test market would not have any impact on the supply and >> demand of the free pool. The free pool would continue to exist as-is. >> The only spread would be in the test market, so those not >> participating are not impacted. > > > As I said, a test market would not have the same incentives to mischief/evil as a full-blown market would because the evil benefits would be capped by the regulated market and free pool allocations. > > It is exactly this limited impact that makes the test invalid. OTOH, it is the damage that would be done if this is taken full scale that is my reasoning for opposing the policy on a full-scale basis regardless of the outcome of such a test if it were conducted. > > I'm not opposed to the test, I merely question that it has any value whatsoever. > > Owen > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. The test itself could be more of a solution to the debate. It would create a limited pool of space without needs basis for those who wish to pay higher rates to bypass ARIN review, while allowing the community at large to continue doing business under the status quo. If the alleged detrimental effects of a free market would not fully surface in a test run, then that makes it even more beneficial for this purpose. I would stipulate that the participants themselves must be pre-approved to participate, in order to prevent IP space contamination (eg. spam gangs). -- Jeffrey Lyon, Leadership Team jeffrey.lyon at blacklotus.net | http://www.blacklotus.net Black Lotus Communications - AS32421 First and Leading in DDoS Protection Solutions From astrodog at gmail.com Fri Feb 17 16:59:35 2012 From: astrodog at gmail.com (Astrodog) Date: Fri, 17 Feb 2012 15:59:35 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> Message-ID: On Fri, Feb 17, 2012 at 3:30 PM, Owen DeLong wrote: > Why in such a circumstance would the seller not choose one of these alternatives: > > 1. ? ? ?Fragment the space, sell the /20 to the original buyer and move on to looking for > ? ? ? ?additional buyers. Any sale will have administrative overhead. The value realized from a /20 may not cover the costs incurred to get it sold. As the space is fragmented, it requires more and more administrative overhead to sell. This makes attempting to sell the space less attractive in the first place, given the risk that the transfer may not be approved. > > 2. ? ? ?Find a buyer that does have legitimate need for a /16 (If there's value to not carving it up, > ? ? ? ?isn't that defined in terms of market demand for the space as a whole?) The seller is not ARIN. Presumably in the hypothetical, they believed that their original buyer had a legitimate need and ARIN disagreed. The seller has no way to be sure of which way such a determination would go, and incurs all of the administrative cost of attempting a sale again, while still having the risk that the transfer would be rejected. > 3. ? ? ?Return the /16 to ARIN so that it can be used elsewhere. While I believe that this is the "right" thing to do in this case, it is unlikely that most organizations would choose this path. It offers no return, and still has administrative overhead, both in returning the space, and in ensuring that they really do not use any of the space. It also precludes them from attempting to use the space in the future, and does not offer them any direct return. > Sorry, but, I just don't buy your argument that the seller would rather keep the /16 in inventory making no money than selling it in pieces or selling it to a different buyer that does have need for the full amount. It's illogical in the extreme. Because the sale requires spending money to work out terms and potentially, significant quantities of time to locate the buyer and wait for them to go through the need test, there is a point at which selling the addresses in pieces is no longer economical and the seller is left with oddly fragmented space based on which transfers were approved by ARIN. --- Harrison From gary.buhrmaster at gmail.com Fri Feb 17 17:10:22 2012 From: gary.buhrmaster at gmail.com (Gary Buhrmaster) Date: Fri, 17 Feb 2012 22:10:22 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> Message-ID: On Fri, Feb 17, 2012 at 21:59, Astrodog wrote: .... >> 2. ? ? ?Find a buyer that does have legitimate need for a /16 (If there's value to not carving it up, >> ? ? ? ?isn't that defined in terms of market demand for the space as a whole?) > > The seller is not ARIN. Presumably in the hypothetical, they believed > that their original buyer had a legitimate need and ARIN disagreed. > The seller has no way to be sure of which way such a determination > would go, and incurs all of the administrative cost of attempting a > sale again, while still having the risk that the transfer would be > rejected. A seller can always require buyers to show ARIN "pre-approval" for need before initiating negotiations. Gary From farmer at umn.edu Fri Feb 17 17:13:24 2012 From: farmer at umn.edu (David Farmer) Date: Fri, 17 Feb 2012 16:13:24 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> Message-ID: <4F3ED104.6040108@umn.edu> On 2/17/12 16:10 CST, Gary Buhrmaster wrote: > On Fri, Feb 17, 2012 at 21:59, Astrodog wrote: > .... >>> 2. Find a buyer that does have legitimate need for a /16 (If there's value to not carving it up, >>> isn't that defined in terms of market demand for the space as a whole?) >> >> The seller is not ARIN. Presumably in the hypothetical, they believed >> that their original buyer had a legitimate need and ARIN disagreed. >> The seller has no way to be sure of which way such a determination >> would go, and incurs all of the administrative cost of attempting a >> sale again, while still having the risk that the transfer would be >> rejected. > > A seller can always require buyers to show ARIN > "pre-approval" for need before initiating negotiations. Exactly, and this is one of the purposes of the ARIN STLS. -- =============================================== David Farmer Email:farmer at umn.edu Networking & Telecommunication Services Office of Information Technology University of Minnesota 2218 University Ave SE Phone: 612-626-0815 Minneapolis, MN 55414-3029 Cell: 612-812-9952 =============================================== From jeffrey.lyon at blacklotus.net Fri Feb 17 17:15:57 2012 From: jeffrey.lyon at blacklotus.net (Jeffrey Lyon) Date: Fri, 17 Feb 2012 17:15:57 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <4F3ED104.6040108@umn.edu> References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> <4F3ED104.6040108@umn.edu> Message-ID: On Fri, Feb 17, 2012 at 5:13 PM, David Farmer wrote: > > > On 2/17/12 16:10 CST, Gary Buhrmaster wrote: >> >> On Fri, Feb 17, 2012 at 21:59, Astrodog ?wrote: >> .... >>>> >>>> 2. ? ? ?Find a buyer that does have legitimate need for a /16 (If >>>> there's value to not carving it up, >>>> ? ? ? ?isn't that defined in terms of market demand for the space as a >>>> whole?) >>> >>> >>> The seller is not ARIN. Presumably in the hypothetical, they believed >>> that their original buyer had a legitimate need and ARIN disagreed. >>> The seller has no way to be sure of which way such a determination >>> would go, and incurs all of the administrative cost of attempting a >>> sale again, while still having the risk that the transfer would be >>> rejected. >> >> >> A seller can always require buyers to show ARIN >> "pre-approval" for need before initiating negotiations. > > > Exactly, and this is one of the purposes of the ARIN STLS. > > -- > =============================================== > David Farmer ? ? ? ? ? ? ? Email:farmer at umn.edu > Networking & Telecommunication Services > Office of Information Technology > University of Minnesota > 2218 University Ave SE ? ? ?Phone: 612-626-0815 > Minneapolis, MN 55414-3029 ? Cell: 612-812-9952 > =============================================== > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. STLS still has needs basis. My common re: preapproval was just to make sure the participant themselves arent bad actors. -- Jeffrey Lyon, Leadership Team jeffrey.lyon at blacklotus.net | http://www.blacklotus.net Black Lotus Communications - AS32421 First and Leading in DDoS Protection Solutions From farmer at umn.edu Fri Feb 17 17:23:22 2012 From: farmer at umn.edu (David Farmer) Date: Fri, 17 Feb 2012 16:23:22 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> <4F3ED104.6040108@umn.edu> Message-ID: <4F3ED35A.8010904@umn.edu> On 2/17/12 16:15 CST, Jeffrey Lyon wrote: > On Fri, Feb 17, 2012 at 5:13 PM, David Farmer wrote: >> >> Exactly, and this is one of the purposes of the ARIN STLS. >> > > STLS still has needs basis. My common re: preapproval was just to make > sure the participant themselves arent bad actors. > So, how does ARIN know they are not bad actors or a good actor turned bad without evaluating a request against some kind of criteria? I'm not saying this is impossible, I've just not see a solution to the problem. -- =============================================== David Farmer Email:farmer at umn.edu Networking & Telecommunication Services Office of Information Technology University of Minnesota 2218 University Ave SE Phone: 612-626-0815 Minneapolis, MN 55414-3029 Cell: 612-812-9952 =============================================== From hannigan at gmail.com Fri Feb 17 17:23:27 2012 From: hannigan at gmail.com (Martin Hannigan) Date: Fri, 17 Feb 2012 17:23:27 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> Message-ID: You want it the other way around. Prior to entry on stls. On Friday, February 17, 2012, Gary Buhrmaster wrote: > On Fri, Feb 17, 2012 at 21:59, Astrodog > > wrote: > .... > >> 2. Find a buyer that does have legitimate need for a /16 (If > there's value to not carving it up, > >> isn't that defined in terms of market demand for the space as a > whole?) > > > > The seller is not ARIN. Presumably in the hypothetical, they believed > > that their original buyer had a legitimate need and ARIN disagreed. > > The seller has no way to be sure of which way such a determination > > would go, and incurs all of the administrative cost of attempting a > > sale again, while still having the risk that the transfer would be > > rejected. > > A seller can always require buyers to show ARIN > "pre-approval" for need before initiating negotiations. > > Gary > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net ). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. > -- Sent via a mobile device -------------- next part -------------- An HTML attachment was scrubbed... URL: From astrodog at gmail.com Fri Feb 17 17:29:12 2012 From: astrodog at gmail.com (Astrodog) Date: Fri, 17 Feb 2012 16:29:12 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <4F3ED104.6040108@umn.edu> References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> <4F3ED104.6040108@umn.edu> Message-ID: On Fri, Feb 17, 2012 at 4:13 PM, David Farmer wrote: > > > On 2/17/12 16:10 CST, Gary Buhrmaster wrote: >> >> On Fri, Feb 17, 2012 at 21:59, Astrodog ?wrote: >> .... >>>> >>>> 2. ? ? ?Find a buyer that does have legitimate need for a /16 (If >>>> there's value to not carving it up, >>>> ? ? ? ?isn't that defined in terms of market demand for the space as a >>>> whole?) >>> >>> >>> The seller is not ARIN. Presumably in the hypothetical, they believed >>> that their original buyer had a legitimate need and ARIN disagreed. >>> The seller has no way to be sure of which way such a determination >>> would go, and incurs all of the administrative cost of attempting a >>> sale again, while still having the risk that the transfer would be >>> rejected. >> >> >> A seller can always require buyers to show ARIN >> "pre-approval" for need before initiating negotiations. > > > Exactly, and this is one of the purposes of the ARIN STLS. > Presumably, the needs basis for listing on STLS is not indefinite. At some point, an organization may abandon its original plan for address space and no longer be eligible for the transfer under its STLS listing. While this makes it less likely that a seller will have an aborted sale due to ARIN denial, the risk would still exist. Also, I am not sure if STLS listing exempts an organization from the needs test under 8.3 (as they a test was already performed to get on the list in the first place) or if a needs test is performed for the transfer in addition to the test performed for listing on STLS? Perhaps someone here can offer some clarification? --- Harrison From mike at nationwideinc.com Fri Feb 17 17:46:38 2012 From: mike at nationwideinc.com (Mike Burns) Date: Fri, 17 Feb 2012 17:46:38 -0500 Subject: [arin-ppml] ARIN-prop-165 EliminateNeeds-BasedJustificationon8.3 Specified Transfers In-Reply-To: <4F3EC80E.9090700@abenaki.wabanaki.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com><4F3D891C.6060507@arin.net><2EED74FD676844259E192E2C8F606115@MPC> <4F3EC80E.9090700@abenaki.wabanaki.net> Message-ID: <22B132EB2DE349229BFC94F4C6659868@MPC> Routers are people too, Eric. As in the people who control the routers. The router engineers will look at Whois, see the registrant doesn't match their customer, then solicit documentary chain of custody from the registrant to the customer. -----Original Message----- From: Eric Brunner-Williams Sent: Friday, February 17, 2012 4:35 PM To: arin-ppml at arin.net Subject: Re: [arin-ppml] ARIN-prop-165 EliminateNeeds-BasedJustificationon8.3 Specified Transfers On 2/17/12 2:27 PM, Mike Burns wrote: > My guess is that if ... > that routers will simply look at whomever is the registrant in Whois ... um, is that blocking for a user-space event to complete in the fast-path? if so, were you planning to propose implementation in upsidasium rather than silicon? -e _______________________________________________ PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). Unsubscribe or manage your mailing list subscription at: http://lists.arin.net/mailman/listinfo/arin-ppml Please contact info at arin.net if you experience any issues. From springer at inlandnet.com Fri Feb 17 17:49:34 2012 From: springer at inlandnet.com (John Springer) Date: Fri, 17 Feb 2012 14:49:34 -0800 (PST) Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217130446.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.cd467d4b9f.wbe@email17.secureserver.net> Message-ID: <20120217144757.L60214@mail.inlandnet.com> On Fri, 17 Feb 2012, McTim wrote: > On Friday, February 17, 2012, Daved Daly wrote: >> On Fri, Feb 17, 2012 at 12:04 PM, >>> wrote: >> >>> Is it in the best interest of the community to maintain needs-based >>> justification policy that may discourage legitimate participation >>> through Specified Transfers in an attempt to corral the fringe element >>> that would seek to speculate, horde and profit from IPv4 transfers? >>> >> >> I don't want to speak for them, but It seems like the obvious answer much >> of the community is responding with is a clear, "yes". >> > > > according to MM, we are just a *small number of anti-market ideologues*. > > In any case, there are better reasons to maintain needs requirements > besides *corralling the fringe element*, but that alone is reason enough > IMO. > > Rgds, > > McTim > > > -- > Cheers, > > McTim > "A name indicates what we seek. An address indicates where it is. A route > indicates how we get there." Jon Postel > +1 John "Head in the Sand" Springer From jcurran at arin.net Fri Feb 17 19:52:12 2012 From: jcurran at arin.net (John Curran) Date: Sat, 18 Feb 2012 00:52:12 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> <4F3ED104.6040108@umn.edu> Message-ID: On Feb 17, 2012, at 5:29 PM, Astrodog wrote: > Also, I am not sure if STLS listing exempts an organization from the > needs test under 8.3 (as they a test was already performed to get on > the list in the first place) or if a needs test is performed for the > transfer in addition to the test performed for listing on STLS? > Perhaps someone here can offer some clarification? A recipient goes through the needs-assessment as part of the listing process. They do not have to undergo a second assessment when submitting a subsequent transfer request as long as it is for an address block no larger than their qualification. In this manner, a seller can have confidence that an appropriately sized transfer to the recipient will be promptly completed. Note - Use of the specified transfer listing service is completely optional, and doesn't change policy requirements. It simply allows for completing some parts of the process in advance. FYI, /John John Curran President and CEO ARIN From astrodog at gmail.com Fri Feb 17 19:55:28 2012 From: astrodog at gmail.com (Astrodog) Date: Fri, 17 Feb 2012 18:55:28 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> <4F3ED104.6040108@umn.edu> Message-ID: On Fri, Feb 17, 2012 at 6:52 PM, John Curran wrote: > On Feb 17, 2012, at 5:29 PM, Astrodog wrote: > >> Also, I am not sure if STLS listing exempts an organization from the >> needs test under 8.3 (as they a test was already performed to get on >> the list in the first place) or if a needs test is performed for the >> transfer in addition to the test performed for listing on STLS? >> Perhaps someone here can offer some clarification? > > A recipient goes through the needs-assessment as part of the listing > process. They do not have to undergo a second assessment when submitting > a subsequent transfer request as long as it is for an address block no > larger than their qualification. ?In this manner, a seller can have > confidence that an appropriately sized transfer to the recipient will > be promptly completed. > > Note - Use of the specified transfer listing service is completely > optional, and doesn't change policy requirements. ?It simply allows > for completing some parts of the process in advance. > Is there an... expiration date of sorts on the STLS listing? I dug around some without any luck. Thanks for the information, --- Harrison From jcurran at arin.net Fri Feb 17 20:05:14 2012 From: jcurran at arin.net (John Curran) Date: Sat, 18 Feb 2012 01:05:14 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> <4F3ED104.6040108@umn.edu> Message-ID: <584B2717-70E7-4D5A-A590-34877F81BBE4@arin.net> On Feb 17, 2012, at 7:55 PM, Astrodog wrote: > Is there an... expiration date of sorts on the STLS listing? I dug > around some without any luck. Any assignment, allocation, or transfer of resources to a party will invalidate their listing as a qualified recipient, but otherwise no. FYI, /John John Curran President and CEO ARIN From owen at delong.com Fri Feb 17 20:31:22 2012 From: owen at delong.com (Owen DeLong) Date: Fri, 17 Feb 2012 17:31:22 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> Message-ID: <716B4FC5-ED6C-485D-82CB-55973C8EB55B@delong.com> On Feb 17, 2012, at 1:59 PM, Astrodog wrote: > On Fri, Feb 17, 2012 at 3:30 PM, Owen DeLong wrote: >> Why in such a circumstance would the seller not choose one of these alternatives: >> >> 1. Fragment the space, sell the /20 to the original buyer and move on to looking for >> additional buyers. > > Any sale will have administrative overhead. The value realized from a > /20 may not cover the costs incurred to get it sold. As the space is > fragmented, it requires more and more administrative overhead to sell. > This makes attempting to sell the space less attractive in the first > place, given the risk that the transfer may not be approved. > At $10+/address, if you're willing to give up even a /24, it pretty well covers any likely administrative overhead, so, I have trouble believing the increasing COGS argument. >> >> 2. Find a buyer that does have legitimate need for a /16 (If there's value to not carving it up, >> isn't that defined in terms of market demand for the space as a whole?) > > The seller is not ARIN. Presumably in the hypothetical, they believed > that their original buyer had a legitimate need and ARIN disagreed. > The seller has no way to be sure of which way such a determination > would go, and incurs all of the administrative cost of attempting a > sale again, while still having the risk that the transfer would be > rejected. STLS provides an ability for organizations to get ARIN pre-approved for block sizes, so, this statement is not true. Sellers can choose to work with buyers that have pre-approval for the size they need. > >> 3. Return the /16 to ARIN so that it can be used elsewhere. > > While I believe that this is the "right" thing to do in this case, it > is unlikely that most organizations would choose this path. It offers > no return, and still has administrative overhead, both in returning > the space, and in ensuring that they really do not use any of the > space. It also precludes them from attempting to use the space in the > future, and does not offer them any direct return. > Agreed, but, I felt the list would be incomplete without this option. >> Sorry, but, I just don't buy your argument that the seller would rather keep the /16 in inventory making no money than selling it in pieces or selling it to a different buyer that does have need for the full amount. It's illogical in the extreme. > > Because the sale requires spending money to work out terms and > potentially, significant quantities of time to locate the buyer and > wait for them to go through the need test, there is a point at which > selling the addresses in pieces is no longer economical and the seller > is left with oddly fragmented space based on which transfers were > approved by ARIN. Again, the option here is to work with pre-approved buyers and that is one of the benefits provided by STLS. Owen From gbonser at seven.com Fri Feb 17 21:41:20 2012 From: gbonser at seven.com (George Bonser) Date: Sat, 18 Feb 2012 02:41:20 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: <4F3D891C.6060507@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> Message-ID: <596B74B410EE6B4CA8A30C3AF1A155EA09CD215F@RWC-MBX1.corp.seven.com> > -----Original Message----- > From: arin-ppml-bounces at arin.net > Sent: Thursday, February 16, 2012 2:54 PM > To: arin-ppml at arin.net > Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification > on 8.3 Specified Transfers > > ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified > Transfers Oppose. From mueller at syr.edu Fri Feb 17 22:47:24 2012 From: mueller at syr.edu (Milton L Mueller) Date: Sat, 18 Feb 2012 03:47:24 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: References: <34F9FF28526C094697742849BAB2E8D403AB87D3EE@EXCHANGE7.shentel.com> Message-ID: <855077AC3D7A7147A7570370CA01ECD20A1CCC@SUEX10-mbx-10.ad.syr.edu> > > I would be interested in seeing a small allocation carved out for the > purpose of running a test, to see what would happen in a free market > without needs basis. Those who have justified need could continue using > existing policies to obtain space, and those without (eg. need space in > a pinch, cant/dont feel like writing up justification) could purchase > from the special allocation at the going market rate. > [Milton L Mueller] We already have this. It's called the legacy blocks. From mueller at syr.edu Fri Feb 17 22:49:55 2012 From: mueller at syr.edu (Milton L Mueller) Date: Sat, 18 Feb 2012 03:49:55 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <9953E516-59AF-4269-91D1-4A467E2AC32C@delong.com> References: <20120217081901.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.34816080d0.wbe@email17.secureserver.net> <9953E516-59AF-4269-91D1-4A467E2AC32C@delong.com> Message-ID: <855077AC3D7A7147A7570370CA01ECD20A1CDD@SUEX10-mbx-10.ad.syr.edu> Hey, great idea, let's abolish futures markets for cotton, oil, wheat and soybeans as well. That'll "serve the community." Shortages are actually good for you. If this policy is adopted, it would enable speculative brokers who wanted to to maintain inventory without showing need for the addresses. It would potentially turn IP addresses into a commodities futures market which I do not believe would serve the community well. -------------- next part -------------- An HTML attachment was scrubbed... URL: From mueller at syr.edu Fri Feb 17 23:07:23 2012 From: mueller at syr.edu (Milton L Mueller) Date: Sat, 18 Feb 2012 04:07:23 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justificationon 8.3 Specified Transfers In-Reply-To: References: <18B2C6E38A3A324986B392B2D18ABC5101D4DD6566@fnb1mbx01.gci.com> <4F3EA6B9.9090806@visionfinancialmarkets.com> Message-ID: <855077AC3D7A7147A7570370CA01ECD20A1D25@SUEX10-mbx-10.ad.syr.edu> Astrodog: You have to realize that statements like Riske's are religious incantations, not arguments. That most of the people on this list keep repeating these incantations, even when confronted with the fact that 40%+ of the v4 address space is legacy and not under contract to ARIN - and thus can ALREADY be re-allocated through the market REGARDLESS of ARIN needs assessments - should make it clear that the dialogue is fundamentally disconnected from reality. This is about faith, not reason; about a shrinking community bonding with each other, not about policy making. Anyway, a tip of the hat to the proponents of ARIN-prop-165 for their effort; you showed a touching faith in the RIR policy making process. This has been tried several times before, the result is always the same: the sheep start bleating "needs assessment good, markets bad" and, as in Orwell's Animal Farm, the discussion ends. Ciao. > -----Original Message----- > From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On > Behalf Of Astrodog > > On Fri, Feb 17, 2012 at 1:12 PM, Ryan Riske > wrote: > > I also vote against prop 165 as written and in spirit. ?Needs-based > > justification keeps the field level for all players, and is important > > to prevent speculation, hoarding, and other anti-competitive and > > anti-community behaviors. > > > > Something is being missed here that I think is significant. The current > system does not keep the field level for all players. It rewards players > which are better at interpreting and writing their justification to > exactly what ARIN requires, or who have proposed uses more in line with > what is expected. While this is easier to do with actual need, that is > not actually required. A large number of organizations can meet the > letter of the rules for an allocation, but have no real use for the > address space currently. This results in those organizations requesting > more space than they will actually use, simply to avoid fighting with it > again later. If those organizations knew that there was an easy way to > obtain and release address space as required, they would be inclined to > sell address space they are not currently using, knowing that new space > could be acquired at a later date. This would serve to keep their > allocation in line with their needs. > > I think a big part of stewardship of the IPv4 space, as it nears > exhaustion, is ensuring that organizations that have more space than > they need can easily transfer that space to another organization that > will use it, and has a financial incentive to do so. Otherwise, the only > way to claim this space is for ARIN to audit these organizations, and do > something along the lines of revoking the allocation. The needs test > creates a regulatory hurdle for organizations, making them much less > likely to attempt to transfer. > > Keep in mind that in as far as speculation goes, the value of IPv4 > addresses will, over the long term, trend to 0. There would be a very > real risk in cornering the market that one would instead speed the > migration to IPv6, and greatly reduce the value of the address space. > _______________________________________________ > PPML > You are receiving this message because you are subscribed to the ARIN > Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From owen at delong.com Sat Feb 18 00:07:55 2012 From: owen at delong.com (Owen DeLong) Date: Fri, 17 Feb 2012 21:07:55 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <855077AC3D7A7147A7570370CA01ECD20A1CDD@SUEX10-mbx-10.ad.syr.edu> References: <20120217081901.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.34816080d0.wbe@email17.secureserver.net> <9953E516-59AF-4269-91D1-4A467E2AC32C@delong.com> <855077AC3D7A7147A7570370CA01ECD20A1CDD@SUEX10-mbx-10.ad.syr.edu> Message-ID: <6996443A-F297-44B7-A785-92926D5FD33C@delong.com> On Feb 17, 2012, at 7:49 PM, Milton L Mueller wrote: > Hey, great idea, let?s abolish futures markets for cotton, oil, wheat and soybeans as well. That?ll ?serve the community.? Shortages are actually good for you. > > > If this policy is adopted, it would enable speculative brokers who wanted to to maintain inventory without showing need for the addresses. It would potentially turn IP addresses into a commodities futures market which I do not believe would serve the community well. Futures markets in products which are produced are very different from futures markets in items of finite quantity. While oil has a theoretically finite quantity, in reality, advancements of technology have consistently created an effect that is roughly equivalent to production in market terms. All of your other examples are literally products which are produced. The presence of a futures market in IPv4 addresses would do nothing to prevent or reduce the coming shortage. It would merely increase cost. Owen -------------- next part -------------- An HTML attachment was scrubbed... URL: From owen at delong.com Sat Feb 18 00:09:37 2012 From: owen at delong.com (Owen DeLong) Date: Fri, 17 Feb 2012 21:09:37 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: <855077AC3D7A7147A7570370CA01ECD20A1CCC@SUEX10-mbx-10.ad.syr.edu> References: <34F9FF28526C094697742849BAB2E8D403AB87D3EE@EXCHANGE7.shentel.com> <855077AC3D7A7147A7570370CA01ECD20A1CCC@SUEX10-mbx-10.ad.syr.edu> Message-ID: <34AB7AED-D12B-437D-A61F-114E15BD717D@delong.com> On Feb 17, 2012, at 7:47 PM, Milton L Mueller wrote: >> >> I would be interested in seeing a small allocation carved out for the >> purpose of running a test, to see what would happen in a free market >> without needs basis. Those who have justified need could continue using >> existing policies to obtain space, and those without (eg. need space in >> a pinch, cant/dont feel like writing up justification) could purchase >> from the special allocation at the going market rate. >> > [Milton L Mueller] We already have this. It's called the legacy blocks. 1. Legacy blocks are not what I would call a small allocation. 2. Legacy blocks are not transferable in the ARIN registry without compliance with ARIN policy. In fact, legacy blocks once transferred under 8.3 generally stop being legacy blocks. Owen From paul at redbarn.org Sat Feb 18 01:20:00 2012 From: paul at redbarn.org (paul vixie) Date: Sat, 18 Feb 2012 06:20:00 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: <855077AC3D7A7147A7570370CA01ECD20A1CCC@SUEX10-mbx-10.ad.syr.edu> References: <34F9FF28526C094697742849BAB2E8D403AB87D3EE@EXCHANGE7.shentel.com> <855077AC3D7A7147A7570370CA01ECD20A1CCC@SUEX10-mbx-10.ad.syr.edu> Message-ID: <4F3F4310.3060500@redbarn.org> On 2/18/2012 3:47 AM, Milton L Mueller wrote: >> I would be interested in seeing a small allocation carved out for the >> purpose of running a test, to see what would happen in a free market >> without needs basis. Those who have justified need could continue using >> existing policies to obtain space, and those without (eg. need space in >> a pinch, cant/dont feel like writing up justification) could purchase >> from the special allocation at the going market rate. >> > [Milton L Mueller] We already have this. It's called the legacy blocks. milton, vigorous reassertion is not considered proof in this forum. --paul From jcurran at arin.net Sat Feb 18 06:41:11 2012 From: jcurran at arin.net (John Curran) Date: Sat, 18 Feb 2012 11:41:11 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justificationon 8.3 Specified Transfers In-Reply-To: <855077AC3D7A7147A7570370CA01ECD20A1D25@SUEX10-mbx-10.ad.syr.edu> References: <18B2C6E38A3A324986B392B2D18ABC5101D4DD6566@fnb1mbx01.gci.com> <4F3EA6B9.9090806@visionfinancialmarkets.com> <855077AC3D7A7147A7570370CA01ECD20A1D25@SUEX10-mbx-10.ad.syr.edu> Message-ID: On Feb 17, 2012, at 11:07 PM, Milton L Mueller wrote: > Anyway, a tip of the hat to the proponents of ARIN-prop-165 for their effort; you showed a touching faith in the RIR policy making process. This has been tried several times before, the result is always the same: the sheep start bleating "needs assessment good, markets bad" Milton - The community response to these proposals for an unconstrained market is more reasoned that your summary would suggest. There already is a limited market mechanism through the existing policy for specified transfers; this alone is recognition that markets are not inherently "bad" but do serve as a viable mechanism for getting limited resources to the folks who have need for them. Markets have an added benefit that the pricing incentive works on resources that are already distributed, whereas the historic approach to distribution from a centrally managed available pool provides no meaningful incentive for getting resources that are underutilized back into productive use. If the community were solely concerned with the requirement of improving the utilization of the fixed size pool of numbers in order to maximize availability, then it is fairly clear that a unconstrained market would suffice for this task. There are some interesting questions that arise from the market approach (see John Sweetings questions to you of 17 Feb 17 12:55:52 PM) which remain unanswered about how such an unconstrained market would remain fair, but I'm told those are type of questions that economists deal with all of time and presumably can be addressed. However, the inherent questions of how and when markets work is _not_ the only concern that is being expressed in the discussion, and that is likely because there specific requirements being met by the present system which have not been answered by the various market advocates, specifically how markets would protect the "fair distribution of globally unique Internet address space according to the operational needs of the end-users and ISPs operating networks using this address space" and the "distribution of globally unique Internet addresses in a hierarchical manner" so as to encourage address aggregation to the extent possible (refer to the first page of IETF BCP12, aka RFC 2050, for this statement of goals.) As the present specified transfer policy requires need assessment in the same manner as allocation/assignment from the available pool, transfers automatically inherent certain mechanisms that serve to protect these underlying goals of the Internet number registry system: - Address transfers are indirectly limited in size by "need", which protects fair access by all to number resources in the presence of extremely large players (i.e. Mr. Sweeting's earlier query) - Address transfers must be of a minimum size, which serves to prevent deaggregation which could otherwise occur in markets as resources are packaged into sizes to maximize $$$ return. Presuming that a policy proposal emerges for a less constrained market mechanism, it would be useful to hear how it addresses the above goals. This is the discussion that many are trying to have on the list; it would helpful if you would help raise it above reporting on bleating and waiving of invisible hands. It is incumbent upon those who advocate change to argue the merits of their case, but we have yet to hear how elimination of the needs-based assessment for an unconstrained market will still satisfy the goals of the Internet number registry system. Thanks! /John John Curran President and CEO ARIN From ebw at abenaki.wabanaki.net Sat Feb 18 08:31:36 2012 From: ebw at abenaki.wabanaki.net (Eric Brunner-Williams) Date: Sat, 18 Feb 2012 08:31:36 -0500 Subject: [arin-ppml] ARIN-prop-165 EliminateNeeds-BasedJustificationon8.3 Specified Transfers In-Reply-To: <22B132EB2DE349229BFC94F4C6659868@MPC> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com><4F3D891C.6060507@arin.net><2EED74FD676844259E192E2C8F606115@MPC> <4F3EC80E.9090700@abenaki.wabanaki.net> <22B132EB2DE349229BFC94F4C6659868@MPC> Message-ID: <4F3FA838.8010607@abenaki.wabanaki.net> > Routers are people too, Eric. > As in the people who control the routers. > The router engineers will look at Whois, see the registrant doesn't match their customer, then solicit documentary chain of custody from the registrant to the customer. utility not evident. necessity not evident. -e From astrodog at gmail.com Sat Feb 18 12:48:23 2012 From: astrodog at gmail.com (Astrodog) Date: Sat, 18 Feb 2012 11:48:23 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <716B4FC5-ED6C-485D-82CB-55973C8EB55B@delong.com> References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> <716B4FC5-ED6C-485D-82CB-55973C8EB55B@delong.com> Message-ID: On Fri, Feb 17, 2012 at 7:31 PM, Owen DeLong wrote: > > On Feb 17, 2012, at 1:59 PM, Astrodog wrote: > >> On Fri, Feb 17, 2012 at 3:30 PM, Owen DeLong wrote: >>> Why in such a circumstance would the seller not choose one of these alternatives: >>> >>> 1. ? ? ?Fragment the space, sell the /20 to the original buyer and move on to looking for >>> ? ? ? ?additional buyers. >> >> Any sale will have administrative overhead. The value realized from a >> /20 may not cover the costs incurred to get it sold. As the space is >> fragmented, it requires more and more administrative overhead to sell. >> This makes attempting to sell the space less attractive in the first >> place, given the risk that the transfer may not be approved. >> > > At $10+/address, if you're willing to give up even a /24, it pretty well > covers any likely administrative overhead, so, I have trouble believing > the increasing COGS argument. > Just looking at the legal side of things, at many organizations, they'd be looking at spending a few thousand dollars to work out a sale. Plus whatever time is involved with the rest of their staff to make it happen. (Making sure they really don't use any of the space, finding someone to sell it to, etc, etc.) >>> >>> 2. ? ? ?Find a buyer that does have legitimate need for a /16 (If there's value to not carving it up, >>> ? ? ? ?isn't that defined in terms of market demand for the space as a whole?) >> >> The seller is not ARIN. Presumably in the hypothetical, they believed >> that their original buyer had a legitimate need and ARIN disagreed. >> The seller has no way to be sure of which way such a determination >> would go, and incurs all of the administrative cost of attempting a >> sale again, while still having the risk that the transfer would be >> rejected. > > STLS provides an ability for organizations to get ARIN pre-approved for block > sizes, so, this statement is not true. Sellers can choose to work with buyers > that have pre-approval for the size they need. STLS does appear to address some of the concerns with buyers. I do have a couple of concerns with how it works, though. Primarily that an STLS approval does not appear to expire and that any transfer to an organization on STLS regardless of size will require another assessment. That's a whole other discussion, though, so, for the purposes of this one, lets stick with STLS addresses a big part of my concern. > >> >>> 3. ? ? ?Return the /16 to ARIN so that it can be used elsewhere. >> >> While I believe that this is the "right" thing to do in this case, it >> is unlikely that most organizations would choose this path. It offers >> no return, and still has administrative overhead, both in returning >> the space, and in ensuring that they really do not use any of the >> space. It also precludes them from attempting to use the space in the >> future, and does not offer them any direct return. >> > > Agreed, but, I felt the list would be incomplete without this option. > Given how well this option actually solves the problem, it's unfortunate that I'm guessing almost no one does it. >>> Sorry, but, I just don't buy your argument that the seller would rather keep the /16 in inventory making no money than selling it in pieces or selling it to a different buyer that does have need for the full amount. It's illogical in the extreme. >> >> Because the sale requires spending money to work out terms and >> potentially, significant quantities of time to locate the buyer and >> wait for them to go through the need test, there is a point at which >> selling the addresses in pieces is no longer economical and the seller >> is left with oddly fragmented space based on which transfers were >> approved by ARIN. > > Again, the option here is to work with pre-approved buyers and that is > one of the benefits provided by STLS. > > Owen > STLS, as implemented, does address some of my concerns with buyers. --- Harrison From astrodog at gmail.com Sat Feb 18 13:16:22 2012 From: astrodog at gmail.com (Astrodog) Date: Sat, 18 Feb 2012 12:16:22 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justificationon 8.3 Specified Transfers In-Reply-To: References: <18B2C6E38A3A324986B392B2D18ABC5101D4DD6566@fnb1mbx01.gci.com> <4F3EA6B9.9090806@visionfinancialmarkets.com> <855077AC3D7A7147A7570370CA01ECD20A1D25@SUEX10-mbx-10.ad.syr.edu> Message-ID: On Sat, Feb 18, 2012 at 5:41 AM, John Curran wrote: > On Feb 17, 2012, at 11:07 PM, Milton L Mueller wrote: > >> Anyway, a tip of the hat to the proponents of ARIN-prop-165 for their effort; you showed a touching faith in the RIR policy making process. This has been tried several times before, the result is always the same: the sheep start bleating "needs assessment good, markets bad" > > Milton - > > The community response to these proposals for an unconstrained > market is more reasoned that your summary would suggest. There > already is a limited market mechanism through the existing policy > for specified transfers; this alone is recognition that markets > are not inherently "bad" but do serve as a viable mechanism for > getting limited resources to the folks who have need for them. > Markets have an added benefit that the pricing incentive works > on resources that are already distributed, whereas the historic > approach to distribution from a centrally managed available pool > provides no meaningful incentive for getting resources that are > underutilized back into productive use. > > If the community were solely concerned with the requirement of > improving the utilization of the fixed size pool of numbers in > order to maximize availability, then it is fairly clear that a > unconstrained market would suffice for this task. ?There are > some interesting questions that arise from the market approach > (see John Sweetings questions to you of 17 Feb 17 12:55:52 PM) > which remain unanswered about how such an unconstrained market > would remain fair, but I'm told those are type of questions that > economists deal with all of time and presumably can be addressed. > > However, the inherent questions of how and when markets work is > _not_ the only concern that is being expressed in the discussion, > and that is likely because there specific requirements being met > by the present system which have not been answered by the various > market advocates, specifically how markets would protect the "fair > distribution of globally unique Internet address space according to > the operational needs of the end-users and ISPs operating networks > using this address space" and the "distribution of globally unique > Internet addresses in a hierarchical manner" so as to encourage > address aggregation to the extent possible (refer to the first > page of IETF BCP12, aka RFC 2050, for this statement of goals.) > > As the present specified transfer policy requires need assessment > in the same manner as allocation/assignment from the available pool, > transfers automatically inherent certain mechanisms that serve to > protect these underlying goals of the Internet number registry system: > > - Address transfers are indirectly limited in size by "need", which > ?protects fair access by all to number resources in the presence > ?of extremely large players (i.e. Mr. Sweeting's earlier query) > > - Address transfers must be of a minimum size, which serves to > ?prevent deaggregation which could otherwise occur in markets > ?as resources are packaged into sizes to maximize $$$ return. > > Presuming that a policy proposal emerges for a less constrained market > mechanism, it would be useful to hear how it addresses the above goals. > This is the discussion that many are trying to have on the list; it > would helpful if you would help raise it above reporting on bleating > and waiving of invisible hands. ?It is incumbent upon those who advocate > change to argue the merits of their case, but we have yet to hear how > elimination of the needs-based assessment for an unconstrained market > will still satisfy the goals of the Internet number registry system. Given the concerns of the community and after watching this discussion play out, I think it may be more useful for those of us who support the removal of needs-based assessments to provide a more comprehensive document explaining why we believe that it serves those goals better than the existing system. Something I've been curious about, as this conversation has gone on, are there cases you are aware of at ARIN where, in retrospect, you believe a needs based asseessment provided an allocation in error? (the requesting organization didn't use the resources, etc.) For obvious reasons, I don't expect to hear about specific cases, but I am curious as to how often this comes up. --- Harrison From jcurran at arin.net Sat Feb 18 13:41:13 2012 From: jcurran at arin.net (John Curran) Date: Sat, 18 Feb 2012 18:41:13 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justificationon 8.3 Specified Transfers In-Reply-To: References: <18B2C6E38A3A324986B392B2D18ABC5101D4DD6566@fnb1mbx01.gci.com> <4F3EA6B9.9090806@visionfinancialmarkets.com> <855077AC3D7A7147A7570370CA01ECD20A1D25@SUEX10-mbx-10.ad.syr.edu> Message-ID: <00E29A9E-8A7F-4625-958B-9CA4D61ECF76@arin.net> On Feb 18, 2012, at 1:16 PM, Astrodog wrote: > Given the concerns of the community and after watching this discussion > play out, I think it may be more useful for those of us who support > the removal of needs-based assessments to provide a more comprehensive > document explaining why we believe that it serves those goals better > than the existing system. > > Something I've been curious about, as this conversation has gone on, > are there cases you are aware of at ARIN where, in retrospect, you > believe a needs based asseessment provided an allocation in error? > (the requesting organization didn't use the resources, etc.) For > obvious reasons, I don't expect to hear about specific cases, but I am > curious as to how often this comes up. Very rarely. Per the number resource policy manual section 12, ARIN may initiate review of resource registration if we believe they were completed in error. I do not have statistics offhand, but we only have a handful of reviews underway at any given moment. For example, if a party indicated that they were going to use the number resources to be received in order to expand their hosting business, and then promptly upon receipt instead sought to transfer them, we would have the ability to initiate a review to see if they originally received them by fraudulent representations, and could take corrective action. The various registration service agreements provide for binding arbitration should there be a disputed matter. I hope this addresses your question. /John John Curran President and CEO ARIN From astrodog at gmail.com Sat Feb 18 13:50:07 2012 From: astrodog at gmail.com (Astrodog) Date: Sat, 18 Feb 2012 12:50:07 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justificationon 8.3 Specified Transfers In-Reply-To: <00E29A9E-8A7F-4625-958B-9CA4D61ECF76@arin.net> References: <18B2C6E38A3A324986B392B2D18ABC5101D4DD6566@fnb1mbx01.gci.com> <4F3EA6B9.9090806@visionfinancialmarkets.com> <855077AC3D7A7147A7570370CA01ECD20A1D25@SUEX10-mbx-10.ad.syr.edu> <00E29A9E-8A7F-4625-958B-9CA4D61ECF76@arin.net> Message-ID: On Sat, Feb 18, 2012 at 12:41 PM, John Curran wrote: > On Feb 18, 2012, at 1:16 PM, Astrodog wrote: > >> Given the concerns of the community and after watching this discussion >> play out, I think it may be more useful for those of us who support >> the removal of needs-based assessments to provide a more comprehensive >> document explaining why we believe that it serves those goals better >> than the existing system. >> >> Something I've been curious about, as this conversation has gone on, >> are there cases you are aware of at ARIN where, in retrospect, you >> believe a needs based asseessment provided an allocation in error? >> (the requesting organization didn't use the resources, etc.) For >> obvious reasons, I don't expect to hear about specific cases, but I am >> curious as to how often this comes up. > > Very rarely. ?Per the number resource policy manual section 12, > ARIN may initiate > review of resource registration if we believe they were completed > in error. I do not have statistics offhand, but we only have a > handful of reviews underway at any given moment. > > For example, if a party indicated that they were going to use the > number resources to be received in order to expand their hosting > business, and then promptly upon receipt instead sought to transfer > them, we would have the ability to initiate a review to see if they > originally received them by fraudulent representations, and could > take corrective action. The various registration service agreements > provide for binding arbitration should there be a disputed matter. > Got it. Thanks again for the information, it has been very useful. I'll probably kick off a new thread with a set of ideas I've had out of this one. As things stand today, I don't believe there is anything even approaching significant support, let alone community consensus for prop-165, and a more measured, incremental approach is probably the best way to move forward. --- Harrison From michael+ppml at burnttofu.net Sat Feb 18 19:21:56 2012 From: michael+ppml at burnttofu.net (Michael Sinatra) Date: Sat, 18 Feb 2012 16:21:56 -0800 Subject: [arin-ppml] what about 36 months? Message-ID: <4F4040A4.9030703@burnttofu.net> If the goal of the eliminate-needs-policy is to allow the market do efficiently allocate number resources while preventing predatory behavior, what kind of effect do we think moving to a 36 month window for 8.3 transfers would have? It might make it easy to justify need. It seems like someone with legitimate use for IPv4 resources could easily justify whatever then can afford, if the window size is 36 months. On the other hand, it should be pretty easy to sniff out a speculator--someone who has zero customers, zero internet products and 5 employees and wants to buy a /14, claiming their business will radically change in the next 3 years. I don't know how quickly we want to move to 36 months, given that we just went to 24. And I am not advocating any particular policy at this point, just asking a question of the community. thanks, michael From scottleibrand at gmail.com Sat Feb 18 19:39:53 2012 From: scottleibrand at gmail.com (Scott Leibrand) Date: Sat, 18 Feb 2012 16:39:53 -0800 Subject: [arin-ppml] what about 36 months? In-Reply-To: <4F4040A4.9030703@burnttofu.net> References: <4F4040A4.9030703@burnttofu.net> Message-ID: We did hear part of the community advocating for 36 months when we were discussing the change to 24. I think most of us (including myself personally) wanted to change things incrementally and see what effect it had. I would expect that the policy cycle leading up to the fall public policy meeting would be our first good opportunity to revisit whether 24 months is working, or whether we need to adjust it. A policy proposal submitted any time in the next 5 months or so would likely be up for discussion in Dallas in October. In the mean time, if anyone has any data or experiences they can share that might shed light on the appropriate timeframe, or if anyone has any other limitations other than timeframe they think should be adjusted, I'd love to hear them. It's also worth noting that we'll likely have ARIN-prop-162 up for discussion this policy cycle, which will examine the related issue of whether anything needs to change with the current 3 month window for free pool allocations now that we've changed the transfer need window to 24 months. -Scott On Sat, Feb 18, 2012 at 4:21 PM, Michael Sinatra wrote: > If the goal of the eliminate-needs-policy is to allow the market do > efficiently allocate number resources while preventing predatory behavior, > what kind of effect do we think moving to a 36 month window for 8.3 > transfers would have? > > It might make it easy to justify need. ?It seems like someone with > legitimate use for IPv4 resources could easily justify whatever then can > afford, if the window size is 36 months. ?On the other hand, it should be > pretty easy to sniff out a speculator--someone who has zero customers, zero > internet products and 5 employees and wants to buy a /14, claiming their > business will radically change in the next 3 years. > > I don't know how quickly we want to move to 36 months, given that we just > went to 24. ?And I am not advocating any particular policy at this point, > just asking a question of the community. > > thanks, > michael > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From gbonser at seven.com Sun Feb 19 18:59:01 2012 From: gbonser at seven.com (George Bonser) Date: Sun, 19 Feb 2012 23:59:01 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on8.3 Specified Transfers In-Reply-To: <2EED74FD676844259E192E2C8F606115@MPC> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> Message-ID: <596B74B410EE6B4CA8A30C3AF1A155EA09CD61A9@RWC-MBX1.corp.seven.com> > It's time to inculcate a free transfer market by removing ARIN > transactional impediments like needs requirements, when those > requirements were designed solely to foster conservative stewardship of > free pool addresses, not already allocated addresses, on a transfer > market where the addresses have a monetary value. They have monetary value only to the extent that they may be transferred. One must exist to create the other. These are not property. Resource allocations are a finite global resource and people have been designated a certain amount of that resource according to need. I believe it is also the desire that unused resources be returned for re-allocation or transferred also according to need. While I am an ardent support of free markets, this is one of the exceptional cases where a free market in the resource would do harm to a larger free market (operations on the internet in general). It would allow an exceptionally deep-pocketed individual or organization to hoard address space and drive up market values or engage in malicious depriving of the market of address resources. Unlike gold or any other commodity, these addresses can not be added to by mining or improvements in production, etc. The pie is of a fixed size and can not change in size. This is at the same time the demands on those resources are increasing. This is a very short-sighted notion if looked at in the context of stewardship of the overall internet. One might make a short term killing on IP address space yet do a huge amount of harm to the Internet as a whole. > Fear of bogeymen like speculators and market-cornerers may be mitigated > by the knowledge that huge blocks are available, and huge dollar > amounts would be required to corner this market. And there are plenty of people around with huge piles of idle cash. The Warren Buffets of the world come to mind but even state actors could get into the fun. A government could, through innumerable third parties, accumulate huge amounts of address space if the desire is to simply do harm to the economies that are more reliant on such space than theirs. > Speculators. Let's wait until we at least have a whiff of their > existence before we strangle a market still in it's cradle This is one place where a "free market" is not desirable, in my opinion. From owen at delong.com Sun Feb 19 18:58:45 2012 From: owen at delong.com (Owen DeLong) Date: Sun, 19 Feb 2012 15:58:45 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> <716B4FC5-ED6C-485D-82CB-55973C8EB55B@delong.com> Message-ID: On Feb 18, 2012, at 9:48 AM, Astrodog wrote: > On Fri, Feb 17, 2012 at 7:31 PM, Owen DeLong wrote: >> >> On Feb 17, 2012, at 1:59 PM, Astrodog wrote: >> >>> On Fri, Feb 17, 2012 at 3:30 PM, Owen DeLong wrote: >>>> Why in such a circumstance would the seller not choose one of these alternatives: >>>> >>>> 1. Fragment the space, sell the /20 to the original buyer and move on to looking for >>>> additional buyers. >>> >>> Any sale will have administrative overhead. The value realized from a >>> /20 may not cover the costs incurred to get it sold. As the space is >>> fragmented, it requires more and more administrative overhead to sell. >>> This makes attempting to sell the space less attractive in the first >>> place, given the risk that the transfer may not be approved. >>> >> >> At $10+/address, if you're willing to give up even a /24, it pretty well >> covers any likely administrative overhead, so, I have trouble believing >> the increasing COGS argument. >> > > Just looking at the legal side of things, at many organizations, > they'd be looking at spending a few thousand dollars to work out a > sale. Plus whatever time is involved with the rest of their staff to > make it happen. (Making sure they really don't use any of the space, > finding someone to sell it to, etc, etc.) > Yes, but, most of that expense only has to happen once even if their first attempt at a sale doesn't go through exactly as planned. The incremental cost of the redux for a different sale isn't so high. >>>> >>>> 2. Find a buyer that does have legitimate need for a /16 (If there's value to not carving it up, >>>> isn't that defined in terms of market demand for the space as a whole?) >>> >>> The seller is not ARIN. Presumably in the hypothetical, they believed >>> that their original buyer had a legitimate need and ARIN disagreed. >>> The seller has no way to be sure of which way such a determination >>> would go, and incurs all of the administrative cost of attempting a >>> sale again, while still having the risk that the transfer would be >>> rejected. >> >> STLS provides an ability for organizations to get ARIN pre-approved for block >> sizes, so, this statement is not true. Sellers can choose to work with buyers >> that have pre-approval for the size they need. > > STLS does appear to address some of the concerns with buyers. I do > have a couple of concerns with how it works, though. Primarily that an > STLS approval does not appear to expire and that any transfer to an > organization on STLS regardless of size will require another > assessment. That's a whole other discussion, though, so, for the > purposes of this one, lets stick with STLS addresses a big part of my > concern. > Yes, that's exactly how it works. I agree that an expiration on STLS entries would be a good thing. The re-qual. is an important safeguard as far as I am concerned. It discourages partial fills and excessive fragmentation due to multiple partial fills. Glad to hear that STLS mostly addresses your concern. Hopefully that means we can abandon 165 soon. >> >>> >>>> 3. Return the /16 to ARIN so that it can be used elsewhere. >>> >>> While I believe that this is the "right" thing to do in this case, it >>> is unlikely that most organizations would choose this path. It offers >>> no return, and still has administrative overhead, both in returning >>> the space, and in ensuring that they really do not use any of the >>> space. It also precludes them from attempting to use the space in the >>> future, and does not offer them any direct return. >>> >> >> Agreed, but, I felt the list would be incomplete without this option. >> > > Given how well this option actually solves the problem, it's > unfortunate that I'm guessing almost no one does it. > Actually, ARIN does get more space back than I would have guessed, but, yes, it is an option that is not used nearly as often as it should be. Owen From gbonser at seven.com Sun Feb 19 19:04:05 2012 From: gbonser at seven.com (George Bonser) Date: Mon, 20 Feb 2012 00:04:05 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217001718.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.e0949ab319.wbe@email17.secureserver.net> Message-ID: <596B74B410EE6B4CA8A30C3AF1A155EA09CD61ED@RWC-MBX1.corp.seven.com> > On > Behalf Of Gary Buhrmaster > Ok, here is an alternative "thought" (it is not a proposal, and for > full disclosure, I might very well "vote" against it because there are > things I do not like about my proposal, but it might be a different way > to frame the issue by suggesting a way that many can get a little of > what they want). > > > Proposal Thought: > Legacy numbers (and only legacy numbers) may be transferred to a > recipient under an RSA with the need justifications being deferred for > 12 months (at which time numbers that would not be justified would > return to ARIN). What this "smells" like to me is: Legacy numbers may be transferred to a broker on consignment for 12 months where they can be resold to the highest bidder. At the end of 12 months, any unsold space is returned to the original legacy holder and anyone who bought portions of that space is then on the hook to justify their need for the address. The only thing remaining with the broker is the cash in their pocket. From gbonser at seven.com Sun Feb 19 20:18:44 2012 From: gbonser at seven.com (George Bonser) Date: Mon, 20 Feb 2012 01:18:44 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <596B74B410EE6B4CA8A30C3AF1A155EA09CD61ED@RWC-MBX1.corp.seven.com> References: <20120217001718.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.e0949ab319.wbe@email17.secureserver.net> <596B74B410EE6B4CA8A30C3AF1A155EA09CD61ED@RWC-MBX1.corp.seven.com> Message-ID: <596B74B410EE6B4CA8A30C3AF1A155EA09CD628E@RWC-MBX1.corp.seven.com> > What this "smells" like to me is: Legacy numbers may be transferred to > a broker on consignment for 12 months where they can be resold to the > highest bidder. At the end of 12 months, any unsold space is returned > to the original legacy holder and anyone who bought portions of that > space is then on the hook to justify their need for the address. The > only thing remaining with the broker is the cash in their pocket. Upon further consideration, I would have no problems eliminating all "needs" based assignment of IPv4 resources effective January 1, 2017 and ending all services (whois, etc) for IPv4 effective January 1, 2022. From jsahala at gmail.com Sun Feb 19 20:44:04 2012 From: jsahala at gmail.com (joshua sahala) Date: Sun, 19 Feb 2012 18:44:04 -0700 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-BasedJustificationon8.3 Specified Transfers In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> Message-ID: On Fri, Feb 17, 2012 at 12:27 PM, Mike Burns wrote: > [cut] > My guess is that if ARIN maintains it's anti-free-market tendencies this is a laughable assertion given that arin (yes, technically by way of policy proposals) is already facilitating (and in many ways condoning) this 'free market capitalistic' speculation^Wbrokerage. instead of auditing legacy holders and reclaiming unjustifiable allocations, policy and position have been moving in this direction for years...and now we have a speculator submitting a proposal to make it easier for him, and others like him, to profit off the scarcity of this resource. this proposal does not benefit the community; it benefits those with the money to buy up and hoard space, and it benefits the speculators^Wbrokers in the middle, 'facilitating' the transactions. if you truly believe that ip addresses are a commodity to be traded in the pits like pork bellies, then by all means, support this. as for me, i am strongly opposed /joshua -- A common mistake that people make when trying to design something completely foolproof is to underestimate the ingenuity of complete fools. ? ? ? ? - Douglas Adams - From astrodog at gmail.com Sun Feb 19 23:56:26 2012 From: astrodog at gmail.com (Astrodog) Date: Sun, 19 Feb 2012 22:56:26 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on8.3 Specified Transfers In-Reply-To: <596B74B410EE6B4CA8A30C3AF1A155EA09CD61A9@RWC-MBX1.corp.seven.com> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> <596B74B410EE6B4CA8A30C3AF1A155EA09CD61A9@RWC-MBX1.corp.seven.com> Message-ID: On Sun, Feb 19, 2012 at 5:59 PM, George Bonser wrote: >> It's time to inculcate a free transfer market by removing ARIN >> transactional impediments like needs requirements, when those >> requirements were designed solely to foster conservative stewardship of >> free pool addresses, not already allocated addresses, on a transfer >> market where the addresses have a monetary value. > > They have monetary value only to the extent that they may be transferred. ?One must exist to create the other. ?These are not property. ?Resource allocations are a finite global resource and people have been designated a certain amount of that resource according to need. ?I believe it is also the desire that unused resources be returned for re-allocation or transferred also according to need. ?While I am an ardent support of free markets, this is one of the exceptional cases where a free market in the resource would do harm to a larger free market (operations on the internet in general). ?It would allow an exceptionally deep-pocketed individual or organization to hoard address space and drive up market values or engage in malicious depriving of the market of address resources. Unfortunately, regardless of the policies involved, IP addresses *are* an asset for those who already hold them. Even if, hypothetically, ARIN provided no mechanism to transfer address space from one organization to another, it is easy enough for one organization to route some portion of it's IP space to another, and at some point, financial incentives would exist to make this sort of arraingement. A malicious actor can operate along these lines, regardless of ARIN's transfer policy. In as far as driving up the price of address space goes, through speculation or hording, this can only occur while the entity in question is actively purchasing address space. Once they stop, the prices return to whatever the organizations trading the space agree to. Further, as IPv6 deployment moves forward, IPv4 address lose value, meaning that such an actor would not be inclined to hold the space for any length of time, as driving up prices pushes deployments to IPv6, and further weakens demand for the asset they're holding. > > Unlike gold or any other commodity, these addresses can not be added to by mining or improvements in production, etc. ?The pie is of a fixed size and can not change in size. ?This is at the same time the demands on those resources are increasing. Commodities have generally predictable production rates. Over the near term, demand for IPv4 space is increasing, however the long term trend will be IPv6 migration, as the price of IPv4 space becomes prohibitive. As move organizations migrate to IPv6, the demand for IPv4 space becomes limited to legacy applications where IPv6 is not feasable. > > This is a very short-sighted notion if looked at in the context of stewardship of the overall internet. ?One might make a short term killing on IP address space yet do a huge amount of harm to the Internet as a whole. > I do not see how short-term speculation can do a huge amount of harm to the internet as a whole. Exhaustion is already a problem that organizations are facing. The difference with needs-based allocation is that as things stand today, ARIN determines how much address space an organization is approved for, instead of the organization itself. This promotes organizations overestimating need in discussions with ARIN, and attempting to obtain the largest possible allocation. >> Fear of bogeymen like speculators and market-cornerers may be mitigated >> by the knowledge that huge blocks are available, and huge dollar >> amounts would be required to corner this market. > > And there are plenty of people around with huge piles of idle cash. ?The Warren Buffets of the world come to mind but even state actors could get into the fun. ?A government could, through innumerable third parties, accumulate huge amounts of address space if the desire is to simply do harm to the economies that are more reliant on such space than theirs. This is the same argument as before with malicious actors. ARIN's policies do not prohibit this behavior anyway. > >> Speculators. Let's wait until we at least have a whiff of their >> existence before we strangle a market still in it's cradle > > This is one place where a "free market" is not desirable, in my opinion. > The problem is that it already exists. There's just a layer of paperwork on top of it now, that rewards who can play "ARIN Policy"-opoly. Instead of resources going to who is willing to pay the most for them, they will go to who has the best I.T. Legal department. I don't see how this is more "fair" than the existing system, given that organizations with long-standing interactions will be much better at this than newcomers. --- Harrison From astrodog at gmail.com Mon Feb 20 00:09:08 2012 From: astrodog at gmail.com (Astrodog) Date: Sun, 19 Feb 2012 23:09:08 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> <716B4FC5-ED6C-485D-82CB-55973C8EB55B@delong.com> Message-ID: On Sun, Feb 19, 2012 at 5:58 PM, Owen DeLong wrote: > > On Feb 18, 2012, at 9:48 AM, Astrodog wrote: > >> On Fri, Feb 17, 2012 at 7:31 PM, Owen DeLong wrote: >>> >>> On Feb 17, 2012, at 1:59 PM, Astrodog wrote: >>> >>>> On Fri, Feb 17, 2012 at 3:30 PM, Owen DeLong wrote: >>>>> Why in such a circumstance would the seller not choose one of these alternatives: >>>>> >>>>> 1. ? ? ?Fragment the space, sell the /20 to the original buyer and move on to looking for >>>>> ? ? ? ?additional buyers. >>>> >>>> Any sale will have administrative overhead. The value realized from a >>>> /20 may not cover the costs incurred to get it sold. As the space is >>>> fragmented, it requires more and more administrative overhead to sell. >>>> This makes attempting to sell the space less attractive in the first >>>> place, given the risk that the transfer may not be approved. >>>> >>> >>> At $10+/address, if you're willing to give up even a /24, it pretty well >>> covers any likely administrative overhead, so, I have trouble believing >>> the increasing COGS argument. >>> >> >> Just looking at the legal side of things, at many organizations, >> they'd be looking at spending a few thousand dollars to work out a >> sale. Plus whatever time is involved with the rest of their staff to >> make it happen. (Making sure they really don't use any of the space, >> finding someone to sell it to, etc, etc.) >> > > Yes, but, most of that expense only has to happen once even if their first attempt at a sale doesn't go through exactly as planned. The incremental cost of the redux for a different sale isn't so high. > It isn't as high, but it certainly still exists. The legal costs working out the sale will pretty much be fixed per transaction. An organization is much less likely to attempt the transfer in the first place if there is a significant risk that they will lose money the first time around, and will be even less likely to attempt a second transfer after being bitten trying the first. >>>>> >>>>> 2. ? ? ?Find a buyer that does have legitimate need for a /16 (If there's value to not carving it up, >>>>> ? ? ? ?isn't that defined in terms of market demand for the space as a whole?) >>>> >>>> The seller is not ARIN. Presumably in the hypothetical, they believed >>>> that their original buyer had a legitimate need and ARIN disagreed. >>>> The seller has no way to be sure of which way such a determination >>>> would go, and incurs all of the administrative cost of attempting a >>>> sale again, while still having the risk that the transfer would be >>>> rejected. >>> >>> STLS provides an ability for organizations to get ARIN pre-approved for block >>> sizes, so, this statement is not true. Sellers can choose to work with buyers >>> that have pre-approval for the size they need. >> >> STLS does appear to address some of the concerns with buyers. I do >> have a couple of concerns with how it works, though. Primarily that an >> STLS approval does not appear to expire and that any transfer to an >> organization on STLS regardless of size will require another >> assessment. That's a whole other discussion, though, so, for the >> purposes of this one, lets stick with STLS addresses a big part of my >> concern. >> > > Yes, that's exactly how it works. I agree that an expiration on STLS entries would be a good thing. > > The re-qual. is an important safeguard as far as I am concerned. It discourages partial fills and excessive fragmentation due to multiple partial fills. > > Glad to hear that STLS mostly addresses your concern. Hopefully that means we can abandon 165 soon. > STLS certainly smoothes things over for sellers. I do agree that fragmentation is undesirable, but if the suggestion here is that transfers are all need based, the quantity of space an entity needs does not decrease simply because a partially filled transaction occurred. If one *needs* a /18, and instead gets a /19, the remaining /19 is still "needed". If the intent of the community is to drive transfers based on need, then an approval for an /18 is also an approval for 2 /19s, 4 /20s, etc. If an organization is approved for an /18, and gets a /19 instead... and is subsequently denied for another /19, then it sounds like the original approval for an /18 was incorrect. >>> >>>> >>>>> 3. ? ? ?Return the /16 to ARIN so that it can be used elsewhere. >>>> >>>> While I believe that this is the "right" thing to do in this case, it >>>> is unlikely that most organizations would choose this path. It offers >>>> no return, and still has administrative overhead, both in returning >>>> the space, and in ensuring that they really do not use any of the >>>> space. It also precludes them from attempting to use the space in the >>>> future, and does not offer them any direct return. >>>> >>> >>> Agreed, but, I felt the list would be incomplete without this option. >>> >> >> Given how well this option actually solves ?the problem, it's >> unfortunate that I'm guessing almost no one does it. >> > > Actually, ARIN does get more space back than I would have guessed, but, yes, it is an option that is not used nearly as often as it should be. I think the fundamental problem here is that IP addresses, for better or worse, have become an "asset" to those organizations that control them. ARIN may be able to rectify this problem through audits, but this may be a legal rabbithole that no one actually wants to explore. If the community has decided that IP space *is* an asset, then the needs-based allocation doesn't make much sense. If IP space is not an asset, then I don't understand why 8.3 transfers would be permitted in the first place. (It becomes something akin to trading food stamps for cash.) > > Owen > --- Harrison From gbonser at seven.com Mon Feb 20 00:45:04 2012 From: gbonser at seven.com (George Bonser) Date: Mon, 20 Feb 2012 05:45:04 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on8.3 Specified Transfers In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> <596B74B410EE6B4CA8A30C3AF1A155EA09CD61A9@RWC-MBX1.corp.seven.com> Message-ID: <596B74B410EE6B4CA8A30C3AF1A155EA09CD6408@RWC-MBX1.corp.seven.com> > Unfortunately, regardless of the policies involved, IP addresses *are* > an asset for those who already hold them. Not if they are not being used, they aren't. They are an asset just like the 50 extra staplers in the supply closet are an "asset". > Even if, hypothetically, ARIN > provided no mechanism to transfer address space from one organization > to another, it is easy enough for one organization to route some > portion of it's IP space to another, and at some point, financial > incentives would exist to make this sort of arraingement. Not really. Real soon now nobody is really going to give a rat's pair of hips about IPv4 addresses. They will be a "hot" commodity for a year or two and then suddenly they will be nearly useless. Once the majority of the major players are operating native v6 and once there are enough v6 only players, nobody is really going to want v4 addresses anymore. > A malicious > actor can operate along these lines, regardless of ARIN's transfer > policy. Possibly, but it would be orders of magnitude more difficult. > In as far as driving up the price of address space goes, > through speculation or hording, this can only occur while the entity in > question is actively purchasing address space. Once they stop, the > prices return to whatever the organizations trading the space agree to. Not really. Once all the easily available (cheap) address space is obtained it would take more money to get the rest to get up off of theirs. But on second thought, it would simply speed the migration to v6 and actually accelerate the demise of that "market". The collapse of a v4 address market would probably occur very quickly, possibly before anyone could react to it. Market "prices" for v4 address space will plummet practically (maybe even literally) overnight once it dawns on people that nobody really wants them anymore. > Further, as IPv6 deployment moves forward, IPv4 address lose value, > meaning that such an actor would not be inclined to hold the space for > any length of time, as driving up prices pushes deployments to IPv6, > and further weakens demand for the asset they're holding. True. But now is not the time to allow this. Maybe in 5 years when the market is basically worthless anyway, we can remove need restrictions and people can purchase address space through brokers. I'm not particularly interested in creating a windfall market for some people during the transition period. From astrodog at gmail.com Mon Feb 20 01:47:45 2012 From: astrodog at gmail.com (Astrodog) Date: Mon, 20 Feb 2012 00:47:45 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on8.3 Specified Transfers In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> <596B74B410EE6B4CA8A30C3AF1A155EA09CD61A9@RWC-MBX1.corp.seven.com> <596B74B410EE6B4CA8A30C3AF1A155EA09CD6408@RWC-MBX1.corp.seven.com> Message-ID: On Sun, Feb 19, 2012 at 11:45 PM, George Bonser wrote: >> Unfortunately, regardless of the policies involved, IP addresses *are* >> an asset for those who already hold them. > > Not if they are not being used, they aren't. ?They are an asset just like the 50 extra staplers in the supply closet are an "asset". Right. That's just like any other hard asset an organization might have. Something they can sell to someone else (or, that they can sell the use of to someone else). The fact that they don't utilize the asset doesn't change the fact that if they decide they want the money, they can sell the staplers, IP addresses, etc. > > >> Even if, hypothetically, ARIN >> provided no mechanism to transfer address space from one organization >> to another, it is easy enough for one organization to route some >> portion of it's IP space to another, and at some point, financial >> incentives would exist to make this sort of arraingement. > > Not really. ?Real soon now nobody is really going to give a rat's pair of hips about IPv4 addresses. ?They will be a "hot" commodity for a year or two and then suddenly they will be nearly useless. ?Once the majority of the major players are operating native v6 and once there are enough v6 only players, nobody is really going to want v4 addresses anymore. > This is a strong argument against anyone attempting to "corner" the IPv4 market. Particularly while ARIN still has free blocks to allocate. (A spike in prices can be squashed simply by releasing more IPs) > >> A malicious >> actor can operate along these lines, regardless of ARIN's transfer >> policy. > > Possibly, but it would ?be orders of magnitude more difficult. How so? The legal framework and overhead aren't that different, if an organization is willing to give up some direct control. (Something a legitimate purchaser is less likely to do, but that makes very little difference to the seller) > >> In as far as driving up the price of address space goes, >> through speculation or hording, this can only occur while the entity in >> question is actively purchasing address space. Once they stop, the >> prices return to whatever the organizations trading the space agree to. > > Not really. ?Once all the easily available (cheap) address space is obtained it would take more money to get the rest to get up off of theirs. ?But on second thought, it would simply speed the migration to v6 and actually accelerate the demise of that "market". ?The collapse of a v4 address market would probably occur very quickly, possibly before anyone could react to it. ?Market "prices" for v4 address space will plummet practically (maybe even literally) overnight once it dawns on people that nobody really wants them anymore. That risk is why significant speculation is unlikely. Why would anyone accept that risk? > >> Further, as IPv6 deployment moves forward, IPv4 address lose value, >> meaning that such an actor would not be inclined to hold the space for >> any length of time, as driving up prices pushes deployments to IPv6, >> and further weakens demand for the asset they're holding. > > True. ?But now is not the time to allow this. ?Maybe in 5 years when the market is basically worthless anyway, we can remove need restrictions and people can purchase address space through brokers. ?I'm not particularly interested in creating a windfall market for some people during the transition period. > I think the largest "winners" in this scenario are organizations that lack internal legal resources familiar with ARIN. Brokers and the like gain by having a more difficult market, as organizations are less likely to attempt to go for it alone. The current environment does not match up with direct need. At best, it limits allocation hording to large organizations that are familiar with ARIN's policies and exactly how things can be worded. I don't believe the intention of needs testing is simply to slightly improve the position of existing players at the expense of new entrants. --- Harrison -- "A human being should be able to change a diaper, plan an invasion, butcher a hog, conn a ship, design a building, write a sonnet, balance accounts, build a wall, set a bone, comfort the dying, take orders, give orders, cooperate, act alone, solve equations, analyze a new problem, pitch manure, program a computer, cook a tasty meal, fight efficiently, die gallantly. Specialization is for insects." --- Robert A. Heinlein From owen at delong.com Mon Feb 20 04:53:37 2012 From: owen at delong.com (Owen DeLong) Date: Mon, 20 Feb 2012 01:53:37 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> <716B4FC5-ED6C-485D-82CB-55973C8EB55B@delong.com> Message-ID: <4C60BC19-5586-4123-B5D4-9625CE0D1E8C@delong.com> >>>>>> >>>>>> 2. Find a buyer that does have legitimate need for a /16 (If there's value to not carving it up, >>>>>> isn't that defined in terms of market demand for the space as a whole?) >>>>> >>>>> The seller is not ARIN. Presumably in the hypothetical, they believed >>>>> that their original buyer had a legitimate need and ARIN disagreed. >>>>> The seller has no way to be sure of which way such a determination >>>>> would go, and incurs all of the administrative cost of attempting a >>>>> sale again, while still having the risk that the transfer would be >>>>> rejected. >>>> >>>> STLS provides an ability for organizations to get ARIN pre-approved for block >>>> sizes, so, this statement is not true. Sellers can choose to work with buyers >>>> that have pre-approval for the size they need. >>> >>> STLS does appear to address some of the concerns with buyers. I do >>> have a couple of concerns with how it works, though. Primarily that an >>> STLS approval does not appear to expire and that any transfer to an >>> organization on STLS regardless of size will require another >>> assessment. That's a whole other discussion, though, so, for the >>> purposes of this one, lets stick with STLS addresses a big part of my >>> concern. >>> >> >> Yes, that's exactly how it works. I agree that an expiration on STLS entries would be a good thing. >> >> The re-qual. is an important safeguard as far as I am concerned. It discourages partial fills and excessive fragmentation due to multiple partial fills. >> >> Glad to hear that STLS mostly addresses your concern. Hopefully that means we can abandon 165 soon. >> > > STLS certainly smoothes things over for sellers. I do agree that > fragmentation is undesirable, but if the suggestion here is that > transfers are all need based, the quantity of space an entity needs > does not decrease simply because a partially filled transaction > occurred. If one *needs* a /18, and instead gets a /19, the remaining > /19 is still "needed". > Yes... The intent of this provision is to discourage people from using partial fills instead of seeking larger (potentially more expensive) contiguous blocks. If you do a partial fill, then, you have to start the process all over to get the next part, so, you're better off getting what you actually need. > If the intent of the community is to drive transfers based on need, > then an approval for an /18 is also an approval for 2 /19s, 4 /20s, > etc. If an organization is approved for an /18, and gets a /19 > instead... and is subsequently denied for another /19, then it sounds > like the original approval for an /18 was incorrect. > No... That provision is there specifically to avoid that for of incentive to fragmentation. >>>> >>>>> >>>>>> 3. Return the /16 to ARIN so that it can be used elsewhere. >>>>> >>>>> While I believe that this is the "right" thing to do in this case, it >>>>> is unlikely that most organizations would choose this path. It offers >>>>> no return, and still has administrative overhead, both in returning >>>>> the space, and in ensuring that they really do not use any of the >>>>> space. It also precludes them from attempting to use the space in the >>>>> future, and does not offer them any direct return. >>>>> >>>> >>>> Agreed, but, I felt the list would be incomplete without this option. >>>> >>> >>> Given how well this option actually solves the problem, it's >>> unfortunate that I'm guessing almost no one does it. >>> >> >> Actually, ARIN does get more space back than I would have guessed, but, yes, it is an option that is not used nearly as often as it should be. > > I think the fundamental problem here is that IP addresses, for better > or worse, have become an "asset" to those organizations that control > them. ARIN may be able to rectify this problem through audits, but > this may be a legal rabbithole that no one actually wants to explore. > If the community has decided that IP space *is* an asset, then the > needs-based allocation doesn't make much sense. If IP space is not an > asset, then I don't understand why 8.3 transfers would be permitted in > the first place. (It becomes something akin to trading food stamps for > cash.) > I'm not sure what you mean by controlling an IP address. I've never seen an integer with a knob on it. IP addresses are not owned and are not property. Specifically, what is being allocated/issued are unique registrations among cooperating parties. The only guarantee on an ARIN registration is that it won't conflict with another ARIN registration or a registration from another cooperating RIR (currently LACNIC, APNIC, AfriNIC, and RIPE-NCC). This says nothing about whether or not anyone will route it or whether or not some other party who has no registration from an RIR will attempt to use the block on the internet. As such, I think that there is a large disconnect between the paradigm under which you are considering this and what the paradigm which I believe applies to the situation. Owen From astrodog at gmail.com Mon Feb 20 05:28:23 2012 From: astrodog at gmail.com (Astrodog) Date: Mon, 20 Feb 2012 04:28:23 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <4C60BC19-5586-4123-B5D4-9625CE0D1E8C@delong.com> References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> <716B4FC5-ED6C-485D-82CB-55973C8EB55B@delong.com> <4C60BC19-5586-4123-B5D4-9625CE0D1E8C@delong.com> Message-ID: On Mon, Feb 20, 2012 at 3:53 AM, Owen DeLong wrote: >>>>>>> >>>>>>> 2. ? ? ?Find a buyer that does have legitimate need for a /16 (If there's value to not carving it up, >>>>>>> ? ? ? ?isn't that defined in terms of market demand for the space as a whole?) >>>>>> >>>>>> The seller is not ARIN. Presumably in the hypothetical, they believed >>>>>> that their original buyer had a legitimate need and ARIN disagreed. >>>>>> The seller has no way to be sure of which way such a determination >>>>>> would go, and incurs all of the administrative cost of attempting a >>>>>> sale again, while still having the risk that the transfer would be >>>>>> rejected. >>>>> >>>>> STLS provides an ability for organizations to get ARIN pre-approved for block >>>>> sizes, so, this statement is not true. Sellers can choose to work with buyers >>>>> that have pre-approval for the size they need. >>>> >>>> STLS does appear to address some of the concerns with buyers. I do >>>> have a couple of concerns with how it works, though. Primarily that an >>>> STLS approval does not appear to expire and that any transfer to an >>>> organization on STLS regardless of size will require another >>>> assessment. That's a whole other discussion, though, so, for the >>>> purposes of this one, lets stick with STLS addresses a big part of my >>>> concern. >>>> >>> >>> Yes, that's exactly how it works. I agree that an expiration on STLS entries would be a good thing. >>> >>> The re-qual. is an important safeguard as far as I am concerned. It discourages partial fills and excessive fragmentation due to multiple partial fills. >>> >>> Glad to hear that STLS mostly addresses your concern. Hopefully that means we can abandon 165 soon. >>> >> >> STLS certainly smoothes things over for sellers. I do agree that >> fragmentation is undesirable, but if the suggestion here is that >> transfers are all need based, the quantity of space an entity needs >> does not decrease simply because a partially filled transaction >> occurred. If one *needs* a /18, and instead gets a /19, the remaining >> /19 is still "needed". >> > > Yes... The intent of this provision is to discourage people from using > partial fills instead of seeking larger (potentially more expensive) > contiguous blocks. > > If you do a partial fill, then, you have to start the process all over to > get the next part, so, you're better off getting what you actually need. > >> If the intent of the community is to drive transfers based on need, >> then an approval for an /18 is also an approval for 2 /19s, 4 /20s, >> etc. If an organization is approved for an /18, and gets a /19 >> instead... and is subsequently denied for another /19, then it sounds >> like the original approval for an /18 was incorrect. >> > > No... That provision is there specifically to avoid that for of incentive > to fragmentation. > >>>>> >>>>>> >>>>>>> 3. ? ? ?Return the /16 to ARIN so that it can be used elsewhere. >>>>>> >>>>>> While I believe that this is the "right" thing to do in this case, it >>>>>> is unlikely that most organizations would choose this path. It offers >>>>>> no return, and still has administrative overhead, both in returning >>>>>> the space, and in ensuring that they really do not use any of the >>>>>> space. It also precludes them from attempting to use the space in the >>>>>> future, and does not offer them any direct return. >>>>>> >>>>> >>>>> Agreed, but, I felt the list would be incomplete without this option. >>>>> >>>> >>>> Given how well this option actually solves ?the problem, it's >>>> unfortunate that I'm guessing almost no one does it. >>>> >>> >>> Actually, ARIN does get more space back than I would have guessed, but, yes, it is an option that is not used nearly as often as it should be. >> >> I think the fundamental problem here is that IP addresses, for better >> or worse, have become an "asset" to those organizations that control >> them. ARIN may be able to rectify this problem through audits, but >> this may be a legal rabbithole that no one actually wants to explore. >> If the community has decided that IP space *is* an asset, then the >> needs-based allocation doesn't make much sense. If IP space is not an >> asset, then I don't understand why 8.3 transfers would be permitted in >> the first place. (It becomes something akin to trading food stamps for >> cash.) >> > > I'm not sure what you mean by controlling an IP address. I've never seen > an integer with a knob on it. > > IP addresses are not owned and are not property. Specifically, what is > being allocated/issued are unique registrations among cooperating parties. > The only guarantee on an ARIN registration is that it won't conflict with another > ARIN registration or a registration from another cooperating RIR (currently > LACNIC, APNIC, AfriNIC, and RIPE-NCC). This says nothing about whether > or not anyone will route it or whether or not some other party who has no > registration from an RIR will attempt to use the block on the internet. > > As such, I think that there is a large disconnect between the paradigm > under which you are considering this and what the paradigm which I > believe applies to the situation. Personally, I agree with this assessment. However, it isn't how most registrants view things. If the assertion is that IPs are *not* an asset, it seems like ARIN should be reclaiming the space. If someone doesn't need the space anymore (and, thus, starts looking for a buyer under 8.3), this would seem like prima facae evidence that they no longer meet the need requirements anyway. Is there community support for the elimination of 8.3 transfers entirely, to be replaced with a more aggressive audit system for need testing, post-registration, so that the space may be reclaimed? --- Harrison From jcurran at arin.net Mon Feb 20 07:12:04 2012 From: jcurran at arin.net (John Curran) Date: Mon, 20 Feb 2012 12:12:04 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> <716B4FC5-ED6C-485D-82CB-55973C8EB55B@delong.com> <4C60BC19-5586-4123-B5D4-9625CE0D1E8C@delong.com> Message-ID: <91D6AB7E-B948-417D-A9C7-ED07C92214B8@corp.arin.net> On Feb 20, 2012, at 5:28 AM, Astrodog wrote: > Personally, I agree with this assessment. However, it isn't how most > registrants view things. > > If the assertion is that IPs are *not* an asset, it seems like ARIN > should be reclaiming the space. If someone doesn't need the space > anymore (and, thus, starts looking for a buyer under 8.3), this would > seem like prima facae evidence that they no longer meet the need > requirements anyway. "IPs" are an ambiguous reference. If the question is whether Internet numbers are freely held personal property, then ARIN's answer is "no". Address holders do have certain rights (such as exclusive right to be the registrant of the address space within the ARIN registry database, as well as the exclusive right to transfer the registration of the space), but those rights intersect other rights (e.g. the community's right of visibility to the public portion) with respect to the same registrations. The policies adopted in the region are the basis by which we will manage the registry and hence the intersection of these rights. Rights can be often be considered an asset of an estate but that does not mean that the underlying item is a form of "free and clear" property, only that something (often limited in nature) has been transferred. > Is there community support for the elimination of 8.3 transfers > entirely, to be replaced with a more aggressive audit system for need > testing, post-registration, so that the space may be reclaimed? This has been considered over the years, but does not fit well with ARIN's formation, wherein ARIN indicated that the existing registrations at the time would be maintained per the status quo. Now, it's recognized that you can't both form an organization for the management of number resources in the region via community developed policy, and simultaneously not ever change policy for existing registrations, but we'll actually done a reasonable job of striking exactly that balance. Changes which affect the entire registry (e.g. establishment of policies governing visibility and fields within registrations) have been adopted without significant issue. Policies which add new functions (such as the specified transfer policy) have also been adopted and effectively expand on the options available to all resource holders. We have worked hard not to create policy of undue burden, but will and do change existing policy for all number resources holders when it becomes important to do so in further of the mission (e.g. addition of abuse POC, POC validation etc.) The community could consider a policy for audit and reclamation of resource holders, however, it would not been in keeping with the expectations set for existing resources holders when ARIN was formed, and protection against reclamation for lack of utilization was put in the legacy RSA specifically to recognize this fact. Recently, in recognition that a functional market provides adequate incentive for getting underutilized resources back into use, this same language which precludes reclamation due to lack of utilization was put into the standard RSA (thus leaving very few actual differences between the terms of the agreements.) You indicate that "this isn't how most registrants view things", but I would disagree; we've seen significant use of the specified transfer policy to date (particularly as ARIN still has available IPv4 number resources to issue) and nearly every service provider in the region has contractually agreed to the number resource policies developed by the community. I am aware that some parties who haven't been receiving new number resources over the proceeding years (and hence aren't necessarily under an ARIN RSA of any form) are unhappy with the limitations for monetization of their underutilized resources under the present specified transfer policy; I universally direct them to this forum (the Public Policy Mailing List) to raise their concerns. FYI, /John John Curran President and CEO ARIN From astrodog at gmail.com Mon Feb 20 07:45:21 2012 From: astrodog at gmail.com (Astrodog) Date: Mon, 20 Feb 2012 06:45:21 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <91D6AB7E-B948-417D-A9C7-ED07C92214B8@corp.arin.net> References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> <716B4FC5-ED6C-485D-82CB-55973C8EB55B@delong.com> <4C60BC19-5586-4123-B5D4-9625CE0D1E8C@delong.com> <91D6AB7E-B948-417D-A9C7-ED07C92214B8@corp.arin.net> Message-ID: On Mon, Feb 20, 2012 at 6:12 AM, John Curran wrote: > On Feb 20, 2012, at 5:28 AM, Astrodog wrote: > >> Personally, I agree with this assessment. However, it isn't how most >> registrants view things. >> >> If the assertion is that IPs are *not* an asset, it seems like ARIN >> should be reclaiming the space. If someone doesn't need the space >> anymore (and, thus, starts looking for a buyer under 8.3), this would >> seem like prima facae evidence that they no longer meet the need >> requirements anyway. > > "IPs" are an ambiguous reference. ?If the question is whether Internet > numbers are freely held personal property, then ARIN's answer is "no". > Address holders do have certain rights (such as exclusive right to be > the registrant of the address space within the ARIN registry database, > as well as the exclusive right to transfer the registration of the space), > but those rights intersect other rights (e.g. the community's right of > visibility to the public portion) with respect to the same registrations. > The policies adopted in the region are the basis by which we will manage > the registry and hence the intersection of these rights. > > Rights can be often be considered an asset of an estate but that does not > mean that the underlying item is a form of "free and clear" property, only > that something (often limited in nature) has been transferred. > >> Is there community support for the elimination of 8.3 transfers >> entirely, to be replaced with a more aggressive audit system for need >> testing, post-registration, so that the space may be reclaimed? > > This has been considered over the years, but does not fit well with ARIN's > formation, wherein ARIN indicated that the existing registrations at the time > would be maintained per the status quo. Now, it's recognized that you can't > both form an organization for the management of number resources in the region > via community developed policy, and simultaneously not ever change policy for > existing registrations, but we'll actually done a reasonable job of striking > exactly that balance. > > Changes which affect the entire registry (e.g. establishment of policies > governing visibility and fields within registrations) have been adopted > without significant issue. ?Policies which add new functions (such as the > specified transfer policy) have also been adopted and effectively expand > on the options available to all resource holders. ?We have worked hard not > to create policy of undue burden, but will and do change existing policy > for all number resources holders when it becomes important to do so in > further of the mission (e.g. addition of abuse POC, POC validation etc.) > > The community could consider a policy for audit and reclamation of resource > holders, however, it would not been in keeping with the expectations set > for existing resources holders when ARIN was formed, and protection against > reclamation for lack of utilization was put in the legacy RSA specifically > to recognize this fact. ?Recently, in recognition that a functional market > provides adequate incentive for getting underutilized resources back into use, > this same language which precludes reclamation due to lack of utilization was > put into the standard RSA (thus leaving very few actual differences between > the terms of the agreements.) > > You indicate that "this isn't how most registrants view things", but I would > disagree; we've seen significant use of the specified transfer policy to date > (particularly as ARIN still has available IPv4 number resources to issue) and > nearly every service provider in the region has contractually agreed to the > number resource policies developed by the community. ?I am aware that some > parties who haven't been receiving new number resources over the proceeding > years (and hence aren't necessarily under an ARIN RSA of any form) are unhappy > with the limitations for monetization of their underutilized resources under > the present specified transfer policy; I universally direct them to this forum > (the Public Policy Mailing List) to raise their concerns. I think I may have been unclear. I was referring to registrants viewing the allocation as an asset, not simply listing in a registry. (Though, that is what they actually have) More fundamentally, I believe that needs testing 8.3 transfers, while having specific language in the RSAs that preclude reclaimation of unused resources is not consistent. If allocation really is meant to be driven by need, then reclaimation of unused resources seems to be a fundamental piece. As it stands now, the combination of policies rewards a combination of I.T. / Legal savvy, and requesting as much in the way of resources as one can possibly get away with, regardless of how those resources will be actually be allocated within an organization. As IPv4 nears exhaustion, I believe the community is going to be faced with a difficult choice regarding needs-based allocation. "New" organizations will have a more difficult time post-exhaustion than their competitors who may have entirely unutilized assignments, merely because their competitors recieved an allocation for an entirely unrelated, and for the purposes of this hypothetical eventually non-viable, use. I don't see the purpose in adding yet another disadvantage for those entities. If the community consensus is to allocate based on need, then I believe policy for reclaimation should be adopted. If the community consensus is to treat IP allocations as an asset, then needs testing seems to be an undue and potentially anti-competitive burden on those seeking allocations and something that will result in less utilization. I'm not opposed to either set of policies, but the current mix seems to strongly favor existing users of space. I think the fundamental question is "Are internet number allocations an asset?". Sorry for beating what is, I suspect, a very dead horse, --- Harrison From jcurran at arin.net Mon Feb 20 08:28:45 2012 From: jcurran at arin.net (John Curran) Date: Mon, 20 Feb 2012 13:28:45 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> <716B4FC5-ED6C-485D-82CB-55973C8EB55B@delong.com> <4C60BC19-5586-4123-B5D4-9625CE0D1E8C@delong.com> <91D6AB7E-B948-417D-A9C7-ED07C92214B8@corp.arin.net> Message-ID: <95903313-28DF-49C6-9E27-D0CA41D59CAD@corp.arin.net> On Feb 20, 2012, at 7:45 AM, Astrodog wrote: > "New" organizations will have a more difficult time post-exhaustion > than their competitors who may have entirely unutilized assignments, ... There have policy proposals to specifically reserve space for new entrants (which might help offset any advantage that existing registrants may have post-depletion) FYI, /John John Curran President and CEO ARIN From jmaimon at chl.com Mon Feb 20 09:23:20 2012 From: jmaimon at chl.com (Joe Maimon) Date: Mon, 20 Feb 2012 09:23:20 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on8.3 Specified Transfers In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> <596B74B410EE6B4CA8A30C3AF1A155EA09CD61A9@RWC-MBX1.corp.seven.com> <596B74B410EE6B4CA8A30C3AF1A155EA09CD6408@RWC-MBX1.corp.seven.com> Message-ID: <4F425758.7050509@chl.com> Astrodog wrote: > This is a strong argument against anyone attempting to "corner" the > IPv4 market. Particularly while ARIN still has free blocks to > allocate. (A spike in prices can be squashed simply by releasing more > IPs) > This is one of the reasons I consider it important for ARIN to maintain the ability to continue allocating to new entrants for longer then its free pool is expected to last. Joe From mpetach at netflight.com Mon Feb 20 13:33:26 2012 From: mpetach at netflight.com (Matthew Petach) Date: Mon, 20 Feb 2012 10:33:26 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on8.3 Specified Transfers In-Reply-To: <596B74B410EE6B4CA8A30C3AF1A155EA09CD61A9@RWC-MBX1.corp.seven.com> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> <596B74B410EE6B4CA8A30C3AF1A155EA09CD61A9@RWC-MBX1.corp.seven.com> Message-ID: On Sun, Feb 19, 2012 at 3:59 PM, George Bonser wrote: >> It's time to inculcate a free transfer market by removing ARIN >> transactional impediments like needs requirements, when those >> requirements were designed solely to foster conservative stewardship of >> free pool addresses, not already allocated addresses, on a transfer >> market where the addresses have a monetary value. > > They have monetary value only to the extent that they may be transferred. > One must exist to create the other. ?These are not property. Hm. The Adrex presentation at NANOG 54 seemed to indicate the courts have ruled otherwise, that IPv4 addresses are indeed real property that have value and can be purchased and sold to settle debts in bankruptcy proceedings. Are perhaps seeing a disconnect between what ARIN community members think IP addresses are, and what the US court system considers them to be? And if so, perhaps we need to bring the two systems back in alignment, before we get into a position of pushing policies that contravene legal precedents? Or would you consider ARIN policy support to be a form of civil disobedience? ^_^; Thanks! Matt PS--oddly enough, I support this proposal. I think Geoff Huston had it right. From jcurran at arin.net Mon Feb 20 14:13:41 2012 From: jcurran at arin.net (John Curran) Date: Mon, 20 Feb 2012 19:13:41 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on8.3 Specified Transfers In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> <596B74B410EE6B4CA8A30C3AF1A155EA09CD61A9@RWC-MBX1.corp.seven.com> Message-ID: On Feb 20, 2012, at 1:33 PM, Matthew Petach wrote: > Hm. The Adrex presentation at NANOG 54 seemed to indicate the > courts have ruled otherwise, that IPv4 addresses are indeed real > property that have value and can be purchased and sold to settle > debts in bankruptcy proceedings. To date, courts have held that parties rights and interests in address blocks may be an asset of an estate, not that the numbers themselves are property. (This is despite several parties efforts to assert otherwise...) The fact that a holder has rights to an address block does not mean that the community does not also have certain rights to the same address block. In the referenced transaction, the recipient submitted a transfer request to ARIN, ARIN found it acceptable, and indicated to the court that the sale was acceptable. If you want to see the actual documents that were revised to reflect reality, refer to this posting and the ARIN references in the approved court documents: http://lists.arin.net/pipermail/arin-ppml/2011-December/023849.html Thanks! /John John Curran President and CEO ARIN From jcurran at arin.net Mon Feb 20 14:35:04 2012 From: jcurran at arin.net (John Curran) Date: Mon, 20 Feb 2012 19:35:04 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on8.3 Specified Transfers In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> <596B74B410EE6B4CA8A30C3AF1A155EA09CD61A9@RWC-MBX1.corp.seven.com> Message-ID: On Feb 20, 2012, at 2:13 PM, John Curran wrote: > To date, courts have held that parties rights and interests in address > blocks may be an asset of an estate, not that the numbers themselves are > property. (This is despite several parties efforts to assert otherwise...) > The fact that a holder has rights to an address block does not mean that > the community does not also have certain rights to the same address block. > > In the referenced transaction, the recipient submitted a transfer request > to ARIN, ARIN found it acceptable, and indicated to the court that the sale > was acceptable. If you want to see the actual documents that were revised > to reflect reality, refer to this posting and the ARIN references in the > approved court documents: > > http://lists.arin.net/pipermail/arin-ppml/2011-December/023849.html Matt - We also have many other cases of bankruptcy court transfer of number resources in accordance with ARIN NRPM 8.3; Border's case referenced below is good example of typical language found in the various sale agreements: ARIN has neither agreed nor had to make any changes to the registry which not in accordance with community developed policy; we have occasionally received orders which suggest otherwise (e.g. transfer a single /32 to another party, or transfer without recipient submitting satisfactory transfer request), but have been able to get these corrected without exception. Thanks! /John John Curran President and CEO ARIN From owen at delong.com Tue Feb 21 04:39:46 2012 From: owen at delong.com (Owen DeLong) Date: Tue, 21 Feb 2012 01:39:46 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> <716B4FC5-ED6C-485D-82CB-55973C8EB55B@delong.com> <4C60BC19-5586-4123-B5D4-9625CE0D1E8C@delong.com> <91D6AB7E-B948-417D-A9C7-ED07C92214B8@corp.arin.net> Message-ID: <0FC27C01-CEB8-49D1-A84F-B948A2243404@delong.com> > I think I may have been unclear. I was referring to registrants > viewing the allocation as an asset, not simply listing in a registry. > (Though, that is what they actually have) > What is an allocation other than a listing in a registry? I do not understand what you are saying here. > More fundamentally, I believe that needs testing 8.3 transfers, while > having specific language in the RSAs that preclude reclaimation of > unused resources is not consistent. If allocation really is meant to > be driven by need, then reclaimation of unused resources seems to be a > fundamental piece. As it stands now, the combination of policies > rewards a combination of I.T. / Legal savvy, and requesting as much in > the way of resources as one can possibly get away with, regardless of > how those resources will be actually be allocated within an > organization. As IPv4 nears exhaustion, I believe the community is > going to be faced with a difficult choice regarding needs-based > allocation. > Agreed. I would rather see the reclamation language restored except in the case of LRSA. In the case of the LRSA, that protection represents the community giving up certain of its rights in order to provide a small inducement to said legacy holders to join the community with full citizenship rather than continue to operate on the edges of the community with vague and ill-defined applicability of community policy. > If the community consensus is to allocate based on need, then I > believe policy for reclaimation should be adopted. If the community > consensus is to treat IP allocations as an asset, then needs testing > seems to be an undue and potentially anti-competitive burden on those > seeking allocations and something that will result in less > utilization. > I agree with you and section 12 was, in part, an attempt to do so. Unfortunately, fear of litigation and lack of political will seem to have overwhelmed the intent of section 12. > I'm not opposed to either set of policies, but the current mix seems > to strongly favor existing users of space. I think the fundamental > question is "Are internet number allocations an asset?". Fundamentally, no. They are not. Unfortunately, there are many people with a vested interest in trying to convert them into an asset, so, those people will continue to attempt to cloud the issue in various ways and do whatever can be done to make them seem like an asset. Fundamentally, an IP allocation is a line-item in a database. The database is maintained according to a set of rules established by the community. IP allocations are not any form of exclusive right to use or guarantee of usefulness or property or any of the other things one would normally require to define something as an asset. The whole system works because the people who run routers (ISPs) tend to do so according to the data contained in the database on a cooperative basis. That cooperation is voluntary and any individual ISP can change their mind about cooperating at any time. Likely, if it's just one, they will get depeered and become irrelevant to the rest of the internet. However, if it is a critical mass, you might see interesting segmentation of the IPv4 internet developing. This may, in fact, be one of the scenarios that leads to a rapidly accelerated deployment of IPv6. Owen > > Sorry for beating what is, I suspect, a very dead horse, > > --- Harrison > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From cgrundemann at gmail.com Tue Feb 21 15:04:32 2012 From: cgrundemann at gmail.com (Chris Grundemann) Date: Tue, 21 Feb 2012 13:04:32 -0700 Subject: [arin-ppml] Prop-151: Clarifying requirements for IPv4 transfers (was "Limiting needs...") In-Reply-To: References: Message-ID: On Fri, Feb 17, 2012 at 09:42, Alexander, Daniel wrote: > Hello All, > > The Staff and Legal review has been provided to the AC for prop-151. The > review focused mainly on the 12 month needs assessment given that the > Board has recently ratified 2011-12 which changed the transfer needs > assessment to 24 months. This update and a few others are listed below. > > Another change that has been suggested is to include transfers in the 12 > month restrictions on the source of a transfer. The resulting text would > read as follows. > > "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." > > The intent of this change would be to limit an organization from > "flipping" transferred resources. Do people feel that this should be > incorporated into the text? This inclusion is absolutely mandatory to maintaining a needs-based system. As such, the question should be reversed: "Is there any reason to exclude transfers, when allocations and assignments are counted?" Cheer, ~Chris > All feedback is appreciated. > > Dan Alexander > AC Shepherd > > > Changes to prop-151 text: > > - Restored a needs requirement to the text. > - Eliminated the /12 cap on resources received. > - Removed the suggestions to altering the text of the RSA. > - Removed the section regarding "Conditions on the IPv4 address block". > - Revised the condition of space being administered by ARIN to incorporate > inter-RIR transfers as a result of 2011-1. > - Moved the minimum transfer size requirement down to remaining Conditions. > - Separated in-region and inter-region transfers into separate sections. > - Clarified the starting point of the 12 month restrictions as a result of > staff feedback. > - Changed the proposal title from "Limiting needs..." to "Clarifying > Requirements..." as a result of feedback. > - Updated needs requirement from 12 to 24 months as a result of 2011-12. > > > > Current text: > > Replace Section 8.3 with > > 8.3 Transfers between Specified Recipients within the ARIN Region. > > In addition to transfers under section 8.2, IPv4 numbers resources may be > transferred according to the following conditions. > > Conditions on source of the transfer: > > * The source entity must be the current registered holder of the IPv4 > address resources, and not be involved in any dispute as to the status of > those resources. > * The source entity will be ineligible to receive any further IPv4 address > allocations or assignments from ARIN for a period of 12 months after a > transfer approval, or until the exhaustion of ARIN's IPv4 space, whichever > occurs first. > * The source entity must not have received an allocation or assignment of > IPv4 number resources from ARIN for the 12 months prior to the approval of > a transfer request. > * The minimum transfer size is a /24 > > > Conditions on recipient of the transfer: > > * The recipient must demonstrate the need for up to a 24 month supply of > IP address resources under current ARIN policies and sign an RSA. > * The resources transferred will be subject to current ARIN policies. > > > Add Section 8.4 Inter-RIR Transfers to Specified Recipients > > Inter-regional transfers may take place only via RIRs who agree to the > transfer and share reciprocal, compatible, needs-based policies. > > Conditions on source of the transfer: > > * The source entity must be the current rights holder of the IPv4 address > resources recognized by the RIR responsible for the resources, and not be > involved in any dispute as to the status of those resources. > * Source entities outside of the ARIN region must meet any requirements > defined by the RIR where the source entity holds the registration. > * Source entities within the ARIN region will not be eligible to receive > any further IPv4 address allocations or assignments from ARIN for a period > of 12 months after a transfer approval, or until the exhaustion of ARIN's > IPv4 space, whichever occurs first. > * Source entities within the ARIN region must not have received an > allocation or assignment of IPv4 number resources from ARIN for the 12 > months prior to the approval of a transfer request. > * The minimum transfer size is a /24. > > > Conditions on recipient of the transfer: > > * The conditions on a recipient outside of the ARIN region will be defined > by the policies of the receiving RIR. > * Recipients within the ARIN region will be subject to current ARIN > policies and sign an RSA for the resources being received. > * Recipients within the ARIN region must demonstrate the need for up to a > 24 month supply of IPv4 address space. > * The minimum transfer size is a /24 > > Rationale: > > The original text of this proposal attempted to simplify the requirements > of an IPv4 address transfer while protecting any resources in the ARIN > free pool. This revision is a result of feedback from the mailing list, > and discussions with the original author. The one key point that has been > removed from the original text is that a needs based review remains in > place. > > The current text attempts to retain the original concepts of protecting > any ARIN free pool, and incorporating it with the point of bringing > resources under RSA. The resulting text attempts to put safeguards in > place on the practice of paid transfers by creating a black out period for > requests from the free pool. The text also tries to incorporate > discussions regarding inter-RIR transfers and come up with language that > includes the free pool protections for transfers in and out of the Region. > > Timetable for implementation: immediate. > > > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. -- @ChrisGrundemann http://chrisgrundemann.com From jeffrey.lyon at blacklotus.net Tue Feb 21 15:10:18 2012 From: jeffrey.lyon at blacklotus.net (Jeffrey Lyon) Date: Tue, 21 Feb 2012 15:10:18 -0500 Subject: [arin-ppml] Prop-151: Clarifying requirements for IPv4 transfers (was "Limiting needs...") In-Reply-To: References: Message-ID: On Tue, Feb 21, 2012 at 3:04 PM, Chris Grundemann wrote: > On Fri, Feb 17, 2012 at 09:42, Alexander, Daniel > wrote: >> Hello All, >> >> The Staff and Legal review has been provided to the AC for prop-151. The >> review focused mainly on the 12 month needs assessment given that the >> Board has recently ratified 2011-12 which changed the transfer needs >> assessment to 24 months. This update and a few others are listed below. >> >> Another change that has been suggested is to include transfers in the 12 >> month restrictions on the source of a transfer. The resulting text would >> read as follows. >> >> "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." >> >> The intent of this change would be to limit an organization from >> "flipping" transferred resources. Do people feel that this should be >> incorporated into the text? > > This inclusion is absolutely mandatory to maintaining a needs-based > system. As such, the question should be reversed: "Is there any reason > to exclude transfers, when allocations and assignments are counted?" > > Cheer, > ~Chris > >> All feedback is appreciated. >> >> Dan Alexander >> AC Shepherd >> >> >> Changes to prop-151 text: >> >> - Restored a needs requirement to the text. >> - Eliminated the /12 cap on resources received. >> - Removed the suggestions to altering the text of the RSA. >> - Removed the section regarding "Conditions on the IPv4 address block". >> - Revised the condition of space being administered by ARIN to incorporate >> inter-RIR transfers as a result of 2011-1. >> - Moved the minimum transfer size requirement down to remaining Conditions. >> - Separated in-region and inter-region transfers into separate sections. >> - Clarified the starting point of the 12 month restrictions as a result of >> staff feedback. >> - Changed the proposal title from "Limiting needs..." to "Clarifying >> Requirements..." as a result of feedback. >> - Updated needs requirement from 12 to 24 months as a result of 2011-12. >> >> >> >> Current text: >> >> Replace Section 8.3 with >> >> 8.3 Transfers between Specified Recipients within the ARIN Region. >> >> In addition to transfers under section 8.2, IPv4 numbers resources may be >> transferred according to the following conditions. >> >> Conditions on source of the transfer: >> >> * The source entity must be the current registered holder of the IPv4 >> address resources, and not be involved in any dispute as to the status of >> those resources. >> * The source entity will be ineligible to receive any further IPv4 address >> allocations or assignments from ARIN for a period of 12 months after a >> transfer approval, or until the exhaustion of ARIN's IPv4 space, whichever >> occurs first. >> * The source entity must not have received an allocation or assignment of >> IPv4 number resources from ARIN for the 12 months prior to the approval of >> a transfer request. >> * The minimum transfer size is a /24 >> >> >> Conditions on recipient of the transfer: >> >> * The recipient must demonstrate the need for up to a 24 month supply of >> IP address resources under current ARIN policies and sign an RSA. >> * The resources transferred will be subject to current ARIN policies. >> >> >> Add Section 8.4 Inter-RIR Transfers to Specified Recipients >> >> Inter-regional transfers may take place only via RIRs who agree to the >> transfer and share reciprocal, compatible, needs-based policies. >> >> Conditions on source of the transfer: >> >> * The source entity must be the current rights holder of the IPv4 address >> resources recognized by the RIR responsible for the resources, and not be >> involved in any dispute as to the status of those resources. >> * Source entities outside of the ARIN region must meet any requirements >> defined by the RIR where the source entity holds the registration. >> * Source entities within the ARIN region will not be eligible to receive >> any further IPv4 address allocations or assignments from ARIN for a period >> of 12 months after a transfer approval, or until the exhaustion of ARIN's >> IPv4 space, whichever occurs first. >> * Source entities within the ARIN region must not have received an >> allocation or assignment of IPv4 number resources from ARIN for the 12 >> months prior to the approval of a transfer request. >> * The minimum transfer size is a /24. >> >> >> Conditions on recipient of the transfer: >> >> * The conditions on a recipient outside of the ARIN region will be defined >> by the policies of the receiving RIR. >> * Recipients within the ARIN region will be subject to current ARIN >> policies and sign an RSA for the resources being received. >> * Recipients within the ARIN region must demonstrate the need for up to a >> 24 month supply of IPv4 address space. >> * The minimum transfer size is a /24 >> >> Rationale: >> >> The original text of this proposal attempted to simplify the requirements >> of an IPv4 address transfer while protecting any resources in the ARIN >> free pool. This revision is a result of feedback from the mailing list, >> and discussions with the original author. The one key point that has been >> removed from the original text is that a needs based review remains in >> place. >> >> The current text attempts to retain the original concepts of protecting >> any ARIN free pool, and incorporating it with the point of bringing >> resources under RSA. The resulting text attempts to put safeguards in >> place on the practice of paid transfers by creating a black out period for >> requests from the free pool. The text also tries to incorporate >> discussions regarding inter-RIR transfers and come up with language that >> includes the free pool protections for transfers in and out of the Region. >> >> Timetable for implementation: immediate. >> >> >> >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. > > > > -- > @ChrisGrundemann > http://chrisgrundemann.com > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. That inclusion also permits organizations that require additional space from obtaining it, which I would oppose. Jeff -- Jeffrey Lyon, Leadership Team jeffrey.lyon at blacklotus.net | http://www.blacklotus.net Black Lotus Communications - AS32421 First and Leading in DDoS Protection Solutions From cgrundemann at gmail.com Tue Feb 21 15:17:45 2012 From: cgrundemann at gmail.com (Chris Grundemann) Date: Tue, 21 Feb 2012 13:17:45 -0700 Subject: [arin-ppml] Prop-151: Clarifying requirements for IPv4 transfers (was "Limiting needs...") In-Reply-To: References: Message-ID: On Tue, Feb 21, 2012 at 13:10, Jeffrey Lyon wrote: > On Tue, Feb 21, 2012 at 3:04 PM, Chris Grundemann wrote: >> On Fri, Feb 17, 2012 at 09:42, Alexander, Daniel >> wrote: >>> Another change that has been suggested is to include transfers in the 12 >>> month restrictions on the source of a transfer. The resulting text would >>> read as follows. >>> >>> "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." >>> >>> The intent of this change would be to limit an organization from >>> "flipping" transferred resources. Do people feel that this should be >>> incorporated into the text? >> >> This inclusion is absolutely mandatory to maintaining a needs-based >> system. As such, the question should be reversed: "Is there any reason >> to exclude transfers, when allocations and assignments are counted?" > That inclusion also permits organizations that require additional > space from obtaining it, which I would oppose. Hi Jeff, I think there may be some confusion. The restriction we are discussing here is on the _source_ of transfers, not the recipient. What this requirement actually does is to restrict organizations from "selling" space which they recently (within the previous 12 months) obtained. It does NOT stop organizations from receiving more space if they have need. HTH, ~Chris > Jeff > > -- > Jeffrey Lyon, Leadership Team > jeffrey.lyon at blacklotus.net | http://www.blacklotus.net > Black Lotus Communications - AS32421 > First and Leading in DDoS Protection Solutions -- @ChrisGrundemann http://chrisgrundemann.com From jeffrey.lyon at blacklotus.net Tue Feb 21 15:23:56 2012 From: jeffrey.lyon at blacklotus.net (Jeffrey Lyon) Date: Tue, 21 Feb 2012 15:23:56 -0500 Subject: [arin-ppml] Prop-151: Clarifying requirements for IPv4 transfers (was "Limiting needs...") In-Reply-To: References: Message-ID: On Tue, Feb 21, 2012 at 3:17 PM, Chris Grundemann wrote: > On Tue, Feb 21, 2012 at 13:10, Jeffrey Lyon wrote: >> On Tue, Feb 21, 2012 at 3:04 PM, Chris Grundemann wrote: >>> On Fri, Feb 17, 2012 at 09:42, Alexander, Daniel >>> wrote: > >>>> Another change that has been suggested is to include transfers in the 12 >>>> month restrictions on the source of a transfer. The resulting text would >>>> read as follows. >>>> >>>> "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." >>>> >>>> The intent of this change would be to limit an organization from >>>> "flipping" transferred resources. Do people feel that this should be >>>> incorporated into the text? >>> >>> This inclusion is absolutely mandatory to maintaining a needs-based >>> system. As such, the question should be reversed: "Is there any reason >>> to exclude transfers, when allocations and assignments are counted?" > >> That inclusion also permits organizations that require additional >> space from obtaining it, which I would oppose. > > Hi Jeff, > > I think there may be some confusion. The restriction we are discussing > here is on the _source_ of transfers, not the recipient. What this > requirement actually does is to restrict organizations from "selling" > space which they recently (within the previous 12 months) obtained. It > does NOT stop organizations from receiving more space if they have > need. > > HTH, > ~Chris > > >> Jeff >> >> -- >> Jeffrey Lyon, Leadership Team >> jeffrey.lyon at blacklotus.net | http://www.blacklotus.net >> Black Lotus Communications - AS32421 >> First and Leading in DDoS Protection Solutions > > > > -- > @ChrisGrundemann > http://chrisgrundemann.com Chris, Duly noted, I missed the "source" part. -- Jeffrey Lyon, Leadership Team jeffrey.lyon at blacklotus.net | http://www.blacklotus.net Black Lotus Communications - AS32421 First and Leading in DDoS Protection Solutions From mpetach at netflight.com Tue Feb 21 16:35:16 2012 From: mpetach at netflight.com (Matthew Petach) Date: Tue, 21 Feb 2012 13:35:16 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on8.3 Specified Transfers In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> <596B74B410EE6B4CA8A30C3AF1A155EA09CD61A9@RWC-MBX1.corp.seven.com> Message-ID: On Mon, Feb 20, 2012 at 11:13 AM, John Curran wrote: > On Feb 20, 2012, at 1:33 PM, Matthew Petach wrote: > >> Hm. ?The Adrex presentation at NANOG 54 seemed to indicate the >> courts have ruled otherwise, that IPv4 addresses are indeed real >> property that have value and can be purchased and sold to settle >> debts in bankruptcy proceedings. > > To date, courts have held that parties rights and interests in address > blocks may be an asset of an estate, not that the numbers themselves are > property. (This is despite several parties efforts to assert otherwise...) > The fact that a holder has rights to an address block does not mean that > the community does not also have certain rights to the same address block. John, Thank you for the clarification (somewhat) on this. Not being a lawyer at heart, I often find the more I read, the less and less clear I actually am. ^_^;; Can you explain how multiple parties can share rights to the same address block? IE, how can a seller sell rights to a block and yet have the community *also* own rights to the same block? Is there an order of operations, or a set of precedence rules that establish when the purchaser's rights are paramount, and when they are subjugated to the rights of the community? Or is this just a legalese way of saying "as long as you follow the rules, you have rights to this block; but if you don't follow the rules, the community rights supersede your rights to the block?" Thanks! Matt From jcurran at arin.net Tue Feb 21 16:47:10 2012 From: jcurran at arin.net (John Curran) Date: Tue, 21 Feb 2012 21:47:10 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on8.3 Specified Transfers In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F3D891C.6060507@arin.net> <2EED74FD676844259E192E2C8F606115@MPC> <596B74B410EE6B4CA8A30C3AF1A155EA09CD61A9@RWC-MBX1.corp.seven.com> Message-ID: <3738FD35-007B-4A21-82AE-70FF630FAF81@arin.net> On Feb 21, 2012, at 4:35 PM, Matthew Petach wrote: > Can you explain how multiple parties can share rights to the same > address block? IE, how can a seller sell rights to a block and yet > have the community *also* own rights to the same block? Certainly: recognize that they are different rights... The address holder has the right to be the exclusive registrant, to transfer in accordance with policy, etc. The community has other rights, such as visibility into the public portions of these registrations. We've tried to be much more explicit in the latest registration services agreements to specify the rights involved. Note that this is not much different that various rights that one may have to a piece of software; the right to use it and have it registered to you does not imply ownership of the underlying software, even if you can transfer your rights to another party for money. > Is there an order of operations, or a set of precedence rules that > establish when the purchaser's rights are paramount, and when they > are subjugated to the rights of the community? The community developed policies govern how these rights interact; ARIN operates the registry and related services in accordance with these policies. Hope this helps, /John John Curran President and CEO ARIN From Daniel_Alexander at Cable.Comcast.com Tue Feb 21 17:38:29 2012 From: Daniel_Alexander at Cable.Comcast.com (Alexander, Daniel) Date: Tue, 21 Feb 2012 22:38:29 +0000 Subject: [arin-ppml] Prop-151: Clarifying requirements for IPv4 transfers (was "Limiting needs...") In-Reply-To: Message-ID: Chris, There is a valid point in trying to prevent the "flipping" of IP blocks that are obtained through transfer, but you would have to add more words to specify that it is that particular block that was obtained through transfer that you could not be a source on in the next 12 months. The current wording places the restriction on any resources held by the source entity, not the block in question. There are valid use cases where a provider may need to obtain a block for some need, but would want to transfer off another, unrelated block, to service a customer. I would prefer giving ARIN staff the flexibility to consider these things during the review. Someone may get away with it once, if they chose to take this approach, but I don't see them being approved by ARIN staff as a recipient after that since they obviously didn't need the last one. Let's also consider that the block you are concerned about being flipped has been received under RSA and you now have a question regarding the conditions by which they have obtained the registration. Dan Alexander Speaking only as myself On 2/21/12 3:04 PM, "Chris Grundemann" wrote: >On Fri, Feb 17, 2012 at 09:42, Alexander, Daniel > wrote: >> Hello All, >> >> The Staff and Legal review has been provided to the AC for prop-151. The >> review focused mainly on the 12 month needs assessment given that the >> Board has recently ratified 2011-12 which changed the transfer needs >> assessment to 24 months. This update and a few others are listed below. >> >> Another change that has been suggested is to include transfers in the 12 >> month restrictions on the source of a transfer. The resulting text would >> read as follows. >> >> "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." >> >> The intent of this change would be to limit an organization from >> "flipping" transferred resources. Do people feel that this should be >> incorporated into the text? > >This inclusion is absolutely mandatory to maintaining a needs-based >system. As such, the question should be reversed: "Is there any reason >to exclude transfers, when allocations and assignments are counted?" > >Cheer, >~Chris > >> All feedback is appreciated. >> >> Dan Alexander >> AC Shepherd >> >> >> Changes to prop-151 text: >> >> - Restored a needs requirement to the text. >> - Eliminated the /12 cap on resources received. >> - Removed the suggestions to altering the text of the RSA. >> - Removed the section regarding "Conditions on the IPv4 address block". >> - Revised the condition of space being administered by ARIN to >>incorporate >> inter-RIR transfers as a result of 2011-1. >> - Moved the minimum transfer size requirement down to remaining >>Conditions. >> - Separated in-region and inter-region transfers into separate sections. >> - Clarified the starting point of the 12 month restrictions as a result >>of >> staff feedback. >> - Changed the proposal title from "Limiting needs..." to "Clarifying >> Requirements..." as a result of feedback. >> - Updated needs requirement from 12 to 24 months as a result of 2011-12. >> >> >> >> Current text: >> >> Replace Section 8.3 with >> >> 8.3 Transfers between Specified Recipients within the ARIN Region. >> >> In addition to transfers under section 8.2, IPv4 numbers resources may >>be >> transferred according to the following conditions. >> >> Conditions on source of the transfer: >> >> * The source entity must be the current registered holder of the IPv4 >> address resources, and not be involved in any dispute as to the status >>of >> those resources. >> * The source entity will be ineligible to receive any further IPv4 >>address >> allocations or assignments from ARIN for a period of 12 months after a >> transfer approval, or until the exhaustion of ARIN's IPv4 space, >>whichever >> occurs first. >> * The source entity must not have received an allocation or assignment >>of >> IPv4 number resources from ARIN for the 12 months prior to the approval >>of >> a transfer request. >> * The minimum transfer size is a /24 >> >> >> Conditions on recipient of the transfer: >> >> * The recipient must demonstrate the need for up to a 24 month supply of >> IP address resources under current ARIN policies and sign an RSA. >> * The resources transferred will be subject to current ARIN policies. >> >> >> Add Section 8.4 Inter-RIR Transfers to Specified Recipients >> >> Inter-regional transfers may take place only via RIRs who agree to the >> transfer and share reciprocal, compatible, needs-based policies. >> >> Conditions on source of the transfer: >> >> * The source entity must be the current rights holder of the IPv4 >>address >> resources recognized by the RIR responsible for the resources, and not >>be >> involved in any dispute as to the status of those resources. >> * Source entities outside of the ARIN region must meet any requirements >> defined by the RIR where the source entity holds the registration. >> * Source entities within the ARIN region will not be eligible to receive >> any further IPv4 address allocations or assignments from ARIN for a >>period >> of 12 months after a transfer approval, or until the exhaustion of >>ARIN's >> IPv4 space, whichever occurs first. >> * Source entities within the ARIN region must not have received an >> allocation or assignment of IPv4 number resources from ARIN for the 12 >> months prior to the approval of a transfer request. >> * The minimum transfer size is a /24. >> >> >> Conditions on recipient of the transfer: >> >> * The conditions on a recipient outside of the ARIN region will be >>defined >> by the policies of the receiving RIR. >> * Recipients within the ARIN region will be subject to current ARIN >> policies and sign an RSA for the resources being received. >> * Recipients within the ARIN region must demonstrate the need for up to >>a >> 24 month supply of IPv4 address space. >> * The minimum transfer size is a /24 >> >> Rationale: >> >> The original text of this proposal attempted to simplify the >>requirements >> of an IPv4 address transfer while protecting any resources in the ARIN >> free pool. This revision is a result of feedback from the mailing list, >> and discussions with the original author. The one key point that has >>been >> removed from the original text is that a needs based review remains in >> place. >> >> The current text attempts to retain the original concepts of protecting >> any ARIN free pool, and incorporating it with the point of bringing >> resources under RSA. The resulting text attempts to put safeguards in >> place on the practice of paid transfers by creating a black out period >>for >> requests from the free pool. The text also tries to incorporate >> discussions regarding inter-RIR transfers and come up with language that >> includes the free pool protections for transfers in and out of the >>Region. >> >> Timetable for implementation: immediate. >> >> >> >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. > > > >-- >@ChrisGrundemann >http://chrisgrundemann.com From cgrundemann at gmail.com Tue Feb 21 17:58:04 2012 From: cgrundemann at gmail.com (Chris Grundemann) Date: Tue, 21 Feb 2012 15:58:04 -0700 Subject: [arin-ppml] Prop-151: Clarifying requirements for IPv4 transfers (was "Limiting needs...") In-Reply-To: References: Message-ID: On Tue, Feb 21, 2012 at 15:38, Alexander, Daniel wrote: > Chris, > > There is a valid point in trying to prevent the "flipping" of IP blocks > that are obtained through transfer, but you would have to add more words > to specify that it is that particular block that was obtained through > transfer that you could not be a source on in the next 12 months. The > current wording places the restriction on any resources held by the source > entity, not the block in question. > > There are valid use cases where a provider may need to obtain a block for > some need, but would want to transfer off another, unrelated block, to > service a customer. > > I would prefer giving ARIN staff the flexibility to consider these things > during the review. Someone may get away with it once, if they chose to > take this approach, but I don't see them being approved by ARIN staff as a > recipient after that since they obviously didn't need the last one. > > Let's also consider that the block you are concerned about being flipped > has been received under RSA and you now have a question regarding the > conditions by which they have obtained the registration. I do not disagree. My point is that all of what you say above applies equally to allocations, assignments, and transfers. If you feel that the restriction is not needed, then it is not needed for any of them. If you feel that the restriction is needed - then we need it for all three. The part I don't understand is how why it should be applied selectively to two of the three address acquisition methods? Cheers, ~Chris > Dan Alexander > Speaking only as myself > > > On 2/21/12 3:04 PM, "Chris Grundemann" wrote: > >>On Fri, Feb 17, 2012 at 09:42, Alexander, Daniel >> wrote: >>> Hello All, >>> >>> The Staff and Legal review has been provided to the AC for prop-151. The >>> review focused mainly on the 12 month needs assessment given that the >>> Board has recently ratified 2011-12 which changed the transfer needs >>> assessment to 24 months. This update and a few others are listed below. >>> >>> Another change that has been suggested is to include transfers in the 12 >>> month restrictions on the source of a transfer. The resulting text would >>> read as follows. >>> >>> "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." >>> >>> The intent of this change would be to limit an organization from >>> "flipping" transferred resources. Do people feel that this should be >>> incorporated into the text? >> >>This inclusion is absolutely mandatory to maintaining a needs-based >>system. As such, the question should be reversed: "Is there any reason >>to exclude transfers, when allocations and assignments are counted?" >> >>Cheer, >>~Chris >> >>> All feedback is appreciated. >>> >>> Dan Alexander >>> AC Shepherd >>> >>> >>> Changes to prop-151 text: >>> >>> - Restored a needs requirement to the text. >>> - Eliminated the /12 cap on resources received. >>> - Removed the suggestions to altering the text of the RSA. >>> - Removed the section regarding "Conditions on the IPv4 address block". >>> - Revised the condition of space being administered by ARIN to >>>incorporate >>> inter-RIR transfers as a result of 2011-1. >>> - Moved the minimum transfer size requirement down to remaining >>>Conditions. >>> - Separated in-region and inter-region transfers into separate sections. >>> - Clarified the starting point of the 12 month restrictions as a result >>>of >>> staff feedback. >>> - Changed the proposal title from "Limiting needs..." to "Clarifying >>> Requirements..." as a result of feedback. >>> - Updated needs requirement from 12 to 24 months as a result of 2011-12. >>> >>> >>> >>> Current text: >>> >>> Replace Section 8.3 with >>> >>> 8.3 Transfers between Specified Recipients within the ARIN Region. >>> >>> In addition to transfers under section 8.2, IPv4 numbers resources may >>>be >>> transferred according to the following conditions. >>> >>> Conditions on source of the transfer: >>> >>> * The source entity must be the current registered holder of the IPv4 >>> address resources, and not be involved in any dispute as to the status >>>of >>> those resources. >>> * The source entity will be ineligible to receive any further IPv4 >>>address >>> allocations or assignments from ARIN for a period of 12 months after a >>> transfer approval, or until the exhaustion of ARIN's IPv4 space, >>>whichever >>> occurs first. >>> * The source entity must not have received an allocation or assignment >>>of >>> IPv4 number resources from ARIN for the 12 months prior to the approval >>>of >>> a transfer request. >>> * The minimum transfer size is a /24 >>> >>> >>> Conditions on recipient of the transfer: >>> >>> * The recipient must demonstrate the need for up to a 24 month supply of >>> IP address resources under current ARIN policies and sign an RSA. >>> * The resources transferred will be subject to current ARIN policies. >>> >>> >>> Add Section 8.4 Inter-RIR Transfers to Specified Recipients >>> >>> Inter-regional transfers may take place only via RIRs who agree to the >>> transfer and share reciprocal, compatible, needs-based policies. >>> >>> Conditions on source of the transfer: >>> >>> * The source entity must be the current rights holder of the IPv4 >>>address >>> resources recognized by the RIR responsible for the resources, and not >>>be >>> involved in any dispute as to the status of those resources. >>> * Source entities outside of the ARIN region must meet any requirements >>> defined by the RIR where the source entity holds the registration. >>> * Source entities within the ARIN region will not be eligible to receive >>> any further IPv4 address allocations or assignments from ARIN for a >>>period >>> of 12 months after a transfer approval, or until the exhaustion of >>>ARIN's >>> IPv4 space, whichever occurs first. >>> * Source entities within the ARIN region must not have received an >>> allocation or assignment of IPv4 number resources from ARIN for the 12 >>> months prior to the approval of a transfer request. >>> * The minimum transfer size is a /24. >>> >>> >>> Conditions on recipient of the transfer: >>> >>> * The conditions on a recipient outside of the ARIN region will be >>>defined >>> by the policies of the receiving RIR. >>> * Recipients within the ARIN region will be subject to current ARIN >>> policies and sign an RSA for the resources being received. >>> * Recipients within the ARIN region must demonstrate the need for up to >>>a >>> 24 month supply of IPv4 address space. >>> * The minimum transfer size is a /24 >>> >>> Rationale: >>> >>> The original text of this proposal attempted to simplify the >>>requirements >>> of an IPv4 address transfer while protecting any resources in the ARIN >>> free pool. This revision is a result of feedback from the mailing list, >>> and discussions with the original author. The one key point that has >>>been >>> removed from the original text is that a needs based review remains in >>> place. >>> >>> The current text attempts to retain the original concepts of protecting >>> any ARIN free pool, and incorporating it with the point of bringing >>> resources under RSA. The resulting text attempts to put safeguards in >>> place on the practice of paid transfers by creating a black out period >>>for >>> requests from the free pool. The text also tries to incorporate >>> discussions regarding inter-RIR transfers and come up with language that >>> includes the free pool protections for transfers in and out of the >>>Region. >>> >>> Timetable for implementation: immediate. >>> >>> >>> >>> _______________________________________________ >>> PPML >>> You are receiving this message because you are subscribed to >>> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >>> Unsubscribe or manage your mailing list subscription at: >>> http://lists.arin.net/mailman/listinfo/arin-ppml >>> Please contact info at arin.net if you experience any issues. >> >> >> >>-- >>@ChrisGrundemann >>http://chrisgrundemann.com > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. -- @ChrisGrundemann http://chrisgrundemann.com From Daniel_Alexander at Cable.Comcast.com Tue Feb 21 18:28:12 2012 From: Daniel_Alexander at Cable.Comcast.com (Alexander, Daniel) Date: Tue, 21 Feb 2012 23:28:12 +0000 Subject: [arin-ppml] Prop-151: Clarifying requirements for IPv4 transfers (was "Limiting needs...") In-Reply-To: Message-ID: The intent of the condition is to limit ARIN's free pool from being a source of revenue. One should not be able to double dip by profiting on the transfer of resources while they are obtaining resources from ARIN, essentially for free. It is not intended to prevent the flipping of any particular resource. If we want to prevent flipping it should be a separate condition, but my thought was to leave that to the RSA and recipient review. -Dan On 2/21/12 5:58 PM, "Chris Grundemann" wrote: >On Tue, Feb 21, 2012 at 15:38, Alexander, Daniel > wrote: >> Chris, >> >> There is a valid point in trying to prevent the "flipping" of IP blocks >> that are obtained through transfer, but you would have to add more words >> to specify that it is that particular block that was obtained through >> transfer that you could not be a source on in the next 12 months. The >> current wording places the restriction on any resources held by the >>source >> entity, not the block in question. >> >> There are valid use cases where a provider may need to obtain a block >>for >> some need, but would want to transfer off another, unrelated block, to >> service a customer. >> >> I would prefer giving ARIN staff the flexibility to consider these >>things >> during the review. Someone may get away with it once, if they chose to >> take this approach, but I don't see them being approved by ARIN staff >>as a >> recipient after that since they obviously didn't need the last one. >> >> Let's also consider that the block you are concerned about being flipped >> has been received under RSA and you now have a question regarding the >> conditions by which they have obtained the registration. > >I do not disagree. My point is that all of what you say above applies >equally to allocations, assignments, and transfers. If you feel that >the restriction is not needed, then it is not needed for any of them. >If you feel that the restriction is needed - then we need it for all >three. The part I don't understand is how why it should be applied >selectively to two of the three address acquisition methods? > >Cheers, >~Chris > >> Dan Alexander >> Speaking only as myself >> >> >> On 2/21/12 3:04 PM, "Chris Grundemann" wrote: >> >>>On Fri, Feb 17, 2012 at 09:42, Alexander, Daniel >>> wrote: >>>> Hello All, >>>> >>>> The Staff and Legal review has been provided to the AC for prop-151. >>>>The >>>> review focused mainly on the 12 month needs assessment given that the >>>> Board has recently ratified 2011-12 which changed the transfer needs >>>> assessment to 24 months. This update and a few others are listed >>>>below. >>>> >>>> Another change that has been suggested is to include transfers in the >>>>12 >>>> month restrictions on the source of a transfer. The resulting text >>>>would >>>> read as follows. >>>> >>>> "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." >>>> >>>> The intent of this change would be to limit an organization from >>>> "flipping" transferred resources. Do people feel that this should be >>>> incorporated into the text? >>> >>>This inclusion is absolutely mandatory to maintaining a needs-based >>>system. As such, the question should be reversed: "Is there any reason >>>to exclude transfers, when allocations and assignments are counted?" >>> >>>Cheer, >>>~Chris >>> >>>> All feedback is appreciated. >>>> >>>> Dan Alexander >>>> AC Shepherd >>>> >>>> >>>> Changes to prop-151 text: >>>> >>>> - Restored a needs requirement to the text. >>>> - Eliminated the /12 cap on resources received. >>>> - Removed the suggestions to altering the text of the RSA. >>>> - Removed the section regarding "Conditions on the IPv4 address >>>>block". >>>> - Revised the condition of space being administered by ARIN to >>>>incorporate >>>> inter-RIR transfers as a result of 2011-1. >>>> - Moved the minimum transfer size requirement down to remaining >>>>Conditions. >>>> - Separated in-region and inter-region transfers into separate >>>>sections. >>>> - Clarified the starting point of the 12 month restrictions as a >>>>result >>>>of >>>> staff feedback. >>>> - Changed the proposal title from "Limiting needs..." to "Clarifying >>>> Requirements..." as a result of feedback. >>>> - Updated needs requirement from 12 to 24 months as a result of >>>>2011-12. >>>> >>>> >>>> >>>> Current text: >>>> >>>> Replace Section 8.3 with >>>> >>>> 8.3 Transfers between Specified Recipients within the ARIN Region. >>>> >>>> In addition to transfers under section 8.2, IPv4 numbers resources may >>>>be >>>> transferred according to the following conditions. >>>> >>>> Conditions on source of the transfer: >>>> >>>> * The source entity must be the current registered holder of the IPv4 >>>> address resources, and not be involved in any dispute as to the status >>>>of >>>> those resources. >>>> * The source entity will be ineligible to receive any further IPv4 >>>>address >>>> allocations or assignments from ARIN for a period of 12 months after a >>>> transfer approval, or until the exhaustion of ARIN's IPv4 space, >>>>whichever >>>> occurs first. >>>> * The source entity must not have received an allocation or assignment >>>>of >>>> IPv4 number resources from ARIN for the 12 months prior to the >>>>approval >>>>of >>>> a transfer request. >>>> * The minimum transfer size is a /24 >>>> >>>> >>>> Conditions on recipient of the transfer: >>>> >>>> * The recipient must demonstrate the need for up to a 24 month supply >>>>of >>>> IP address resources under current ARIN policies and sign an RSA. >>>> * The resources transferred will be subject to current ARIN policies. >>>> >>>> >>>> Add Section 8.4 Inter-RIR Transfers to Specified Recipients >>>> >>>> Inter-regional transfers may take place only via RIRs who agree to the >>>> transfer and share reciprocal, compatible, needs-based policies. >>>> >>>> Conditions on source of the transfer: >>>> >>>> * The source entity must be the current rights holder of the IPv4 >>>>address >>>> resources recognized by the RIR responsible for the resources, and not >>>>be >>>> involved in any dispute as to the status of those resources. >>>> * Source entities outside of the ARIN region must meet any >>>>requirements >>>> defined by the RIR where the source entity holds the registration. >>>> * Source entities within the ARIN region will not be eligible to >>>>receive >>>> any further IPv4 address allocations or assignments from ARIN for a >>>>period >>>> of 12 months after a transfer approval, or until the exhaustion of >>>>ARIN's >>>> IPv4 space, whichever occurs first. >>>> * Source entities within the ARIN region must not have received an >>>> allocation or assignment of IPv4 number resources from ARIN for the 12 >>>> months prior to the approval of a transfer request. >>>> * The minimum transfer size is a /24. >>>> >>>> >>>> Conditions on recipient of the transfer: >>>> >>>> * The conditions on a recipient outside of the ARIN region will be >>>>defined >>>> by the policies of the receiving RIR. >>>> * Recipients within the ARIN region will be subject to current ARIN >>>> policies and sign an RSA for the resources being received. >>>> * Recipients within the ARIN region must demonstrate the need for up >>>>to >>>>a >>>> 24 month supply of IPv4 address space. >>>> * The minimum transfer size is a /24 >>>> >>>> Rationale: >>>> >>>> The original text of this proposal attempted to simplify the >>>>requirements >>>> of an IPv4 address transfer while protecting any resources in the ARIN >>>> free pool. This revision is a result of feedback from the mailing >>>>list, >>>> and discussions with the original author. The one key point that has >>>>been >>>> removed from the original text is that a needs based review remains in >>>> place. >>>> >>>> The current text attempts to retain the original concepts of >>>>protecting >>>> any ARIN free pool, and incorporating it with the point of bringing >>>> resources under RSA. The resulting text attempts to put safeguards in >>>> place on the practice of paid transfers by creating a black out period >>>>for >>>> requests from the free pool. The text also tries to incorporate >>>> discussions regarding inter-RIR transfers and come up with language >>>>that >>>> includes the free pool protections for transfers in and out of the >>>>Region. >>>> >>>> Timetable for implementation: immediate. >>>> >>>> >>>> >>>> _______________________________________________ >>>> PPML >>>> You are receiving this message because you are subscribed to >>>> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >>>> Unsubscribe or manage your mailing list subscription at: >>>> http://lists.arin.net/mailman/listinfo/arin-ppml >>>> Please contact info at arin.net if you experience any issues. >>> >>> >>> >>>-- >>>@ChrisGrundemann >>>http://chrisgrundemann.com >> >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. > > > >-- >@ChrisGrundemann >http://chrisgrundemann.com From cgrundemann at gmail.com Tue Feb 21 19:01:47 2012 From: cgrundemann at gmail.com (Chris Grundemann) Date: Tue, 21 Feb 2012 17:01:47 -0700 Subject: [arin-ppml] Prop-151: Clarifying requirements for IPv4 transfers (was "Limiting needs...") In-Reply-To: References: Message-ID: On Tue, Feb 21, 2012 at 16:28, Alexander, Daniel wrote: > > The intent of the condition is to limit ARIN's free pool from being a > source of revenue. One should not be able to double dip by profiting on > the transfer of resources while they are obtaining resources from ARIN, > essentially for free. It is not intended to prevent the flipping of any > particular resource. Thanks for the clarification. I still choose to place profiting from the improper acquisition of ARIN managed resources in a single bucket however. I believe that ARIN should act as steward for all number resources within the region, not just those that have not been previously handed out. > If we want to prevent flipping it should be a separate condition, but my > thought was to leave that to the RSA and recipient review. If the RSA and recipient review can control "flipping" why can they not prevent "profiting"? Cheers, ~Chris > -Dan > > On 2/21/12 5:58 PM, "Chris Grundemann" wrote: > >>On Tue, Feb 21, 2012 at 15:38, Alexander, Daniel >> wrote: >>> Chris, >>> >>> There is a valid point in trying to prevent the "flipping" of IP blocks >>> that are obtained through transfer, but you would have to add more words >>> to specify that it is that particular block that was obtained through >>> transfer that you could not be a source on in the next 12 months. The >>> current wording places the restriction on any resources held by the >>>source >>> entity, not the block in question. >>> >>> There are valid use cases where a provider may need to obtain a block >>>for >>> some need, but would want to transfer off another, unrelated block, to >>> service a customer. >>> >>> I would prefer giving ARIN staff the flexibility to consider these >>>things >>> during the review. Someone may get away with it once, if they chose to >>> take this approach, but I don't see them being approved by ARIN staff >>>as a >>> recipient after that since they obviously didn't need the last one. >>> >>> Let's also consider that the block you are concerned about being flipped >>> has been received under RSA and you now have a question regarding the >>> conditions by which they have obtained the registration. >> >>I do not disagree. My point is that all of what you say above applies >>equally to allocations, assignments, and transfers. If you feel that >>the restriction is not needed, then it is not needed for any of them. >>If you feel that the restriction is needed - then we need it for all >>three. The part I don't understand is how why it should be applied >>selectively to two of the three address acquisition methods? >> >>Cheers, >>~Chris >> >>> Dan Alexander >>> Speaking only as myself >>> >>> >>> On 2/21/12 3:04 PM, "Chris Grundemann" wrote: >>> >>>>On Fri, Feb 17, 2012 at 09:42, Alexander, Daniel >>>> wrote: >>>>> Hello All, >>>>> >>>>> The Staff and Legal review has been provided to the AC for prop-151. >>>>>The >>>>> review focused mainly on the 12 month needs assessment given that the >>>>> Board has recently ratified 2011-12 which changed the transfer needs >>>>> assessment to 24 months. This update and a few others are listed >>>>>below. >>>>> >>>>> Another change that has been suggested is to include transfers in the >>>>>12 >>>>> month restrictions on the source of a transfer. The resulting text >>>>>would >>>>> read as follows. >>>>> >>>>> "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." >>>>> >>>>> The intent of this change would be to limit an organization from >>>>> "flipping" transferred resources. Do people feel that this should be >>>>> incorporated into the text? >>>> >>>>This inclusion is absolutely mandatory to maintaining a needs-based >>>>system. As such, the question should be reversed: "Is there any reason >>>>to exclude transfers, when allocations and assignments are counted?" >>>> >>>>Cheer, >>>>~Chris >>>> >>>>> All feedback is appreciated. >>>>> >>>>> Dan Alexander >>>>> AC Shepherd >>>>> >>>>> >>>>> Changes to prop-151 text: >>>>> >>>>> - Restored a needs requirement to the text. >>>>> - Eliminated the /12 cap on resources received. >>>>> - Removed the suggestions to altering the text of the RSA. >>>>> - Removed the section regarding "Conditions on the IPv4 address >>>>>block". >>>>> - Revised the condition of space being administered by ARIN to >>>>>incorporate >>>>> inter-RIR transfers as a result of 2011-1. >>>>> - Moved the minimum transfer size requirement down to remaining >>>>>Conditions. >>>>> - Separated in-region and inter-region transfers into separate >>>>>sections. >>>>> - Clarified the starting point of the 12 month restrictions as a >>>>>result >>>>>of >>>>> staff feedback. >>>>> - Changed the proposal title from "Limiting needs..." to "Clarifying >>>>> Requirements..." as a result of feedback. >>>>> - Updated needs requirement from 12 to 24 months as a result of >>>>>2011-12. >>>>> >>>>> >>>>> >>>>> Current text: >>>>> >>>>> Replace Section 8.3 with >>>>> >>>>> 8.3 Transfers between Specified Recipients within the ARIN Region. >>>>> >>>>> In addition to transfers under section 8.2, IPv4 numbers resources may >>>>>be >>>>> transferred according to the following conditions. >>>>> >>>>> Conditions on source of the transfer: >>>>> >>>>> * The source entity must be the current registered holder of the IPv4 >>>>> address resources, and not be involved in any dispute as to the status >>>>>of >>>>> those resources. >>>>> * The source entity will be ineligible to receive any further IPv4 >>>>>address >>>>> allocations or assignments from ARIN for a period of 12 months after a >>>>> transfer approval, or until the exhaustion of ARIN's IPv4 space, >>>>>whichever >>>>> occurs first. >>>>> * The source entity must not have received an allocation or assignment >>>>>of >>>>> IPv4 number resources from ARIN for the 12 months prior to the >>>>>approval >>>>>of >>>>> a transfer request. >>>>> * The minimum transfer size is a /24 >>>>> >>>>> >>>>> Conditions on recipient of the transfer: >>>>> >>>>> * The recipient must demonstrate the need for up to a 24 month supply >>>>>of >>>>> IP address resources under current ARIN policies and sign an RSA. >>>>> * The resources transferred will be subject to current ARIN policies. >>>>> >>>>> >>>>> Add Section 8.4 Inter-RIR Transfers to Specified Recipients >>>>> >>>>> Inter-regional transfers may take place only via RIRs who agree to the >>>>> transfer and share reciprocal, compatible, needs-based policies. >>>>> >>>>> Conditions on source of the transfer: >>>>> >>>>> * The source entity must be the current rights holder of the IPv4 >>>>>address >>>>> resources recognized by the RIR responsible for the resources, and not >>>>>be >>>>> involved in any dispute as to the status of those resources. >>>>> * Source entities outside of the ARIN region must meet any >>>>>requirements >>>>> defined by the RIR where the source entity holds the registration. >>>>> * Source entities within the ARIN region will not be eligible to >>>>>receive >>>>> any further IPv4 address allocations or assignments from ARIN for a >>>>>period >>>>> of 12 months after a transfer approval, or until the exhaustion of >>>>>ARIN's >>>>> IPv4 space, whichever occurs first. >>>>> * Source entities within the ARIN region must not have received an >>>>> allocation or assignment of IPv4 number resources from ARIN for the 12 >>>>> months prior to the approval of a transfer request. >>>>> * The minimum transfer size is a /24. >>>>> >>>>> >>>>> Conditions on recipient of the transfer: >>>>> >>>>> * The conditions on a recipient outside of the ARIN region will be >>>>>defined >>>>> by the policies of the receiving RIR. >>>>> * Recipients within the ARIN region will be subject to current ARIN >>>>> policies and sign an RSA for the resources being received. >>>>> * Recipients within the ARIN region must demonstrate the need for up >>>>>to >>>>>a >>>>> 24 month supply of IPv4 address space. >>>>> * The minimum transfer size is a /24 >>>>> >>>>> Rationale: >>>>> >>>>> The original text of this proposal attempted to simplify the >>>>>requirements >>>>> of an IPv4 address transfer while protecting any resources in the ARIN >>>>> free pool. This revision is a result of feedback from the mailing >>>>>list, >>>>> and discussions with the original author. The one key point that has >>>>>been >>>>> removed from the original text is that a needs based review remains in >>>>> place. >>>>> >>>>> The current text attempts to retain the original concepts of >>>>>protecting >>>>> any ARIN free pool, and incorporating it with the point of bringing >>>>> resources under RSA. The resulting text attempts to put safeguards in >>>>> place on the practice of paid transfers by creating a black out period >>>>>for >>>>> requests from the free pool. The text also tries to incorporate >>>>> discussions regarding inter-RIR transfers and come up with language >>>>>that >>>>> includes the free pool protections for transfers in and out of the >>>>>Region. >>>>> >>>>> Timetable for implementation: immediate. >>>>> >>>>> >>>>> >>>>> _______________________________________________ >>>>> PPML >>>>> You are receiving this message because you are subscribed to >>>>> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >>>>> Unsubscribe or manage your mailing list subscription at: >>>>> http://lists.arin.net/mailman/listinfo/arin-ppml >>>>> Please contact info at arin.net if you experience any issues. >>>> >>>> >>>> >>>>-- >>>>@ChrisGrundemann >>>>http://chrisgrundemann.com >>> >>> _______________________________________________ >>> PPML >>> You are receiving this message because you are subscribed to >>> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >>> Unsubscribe or manage your mailing list subscription at: >>> http://lists.arin.net/mailman/listinfo/arin-ppml >>> Please contact info at arin.net if you experience any issues. >> >> >> >>-- >>@ChrisGrundemann >>http://chrisgrundemann.com > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. -- @ChrisGrundemann http://chrisgrundemann.com From owen at delong.com Wed Feb 22 01:01:05 2012 From: owen at delong.com (Owen DeLong) Date: Tue, 21 Feb 2012 22:01:05 -0800 Subject: [arin-ppml] Prop-151: Clarifying requirements for IPv4 transfers (was "Limiting needs...") In-Reply-To: References: Message-ID: <250ED98D-1D9C-4F59-BB31-724B5B0975CE@delong.com> On Feb 21, 2012, at 2:38 PM, Alexander, Daniel wrote: > Chris, > > There is a valid point in trying to prevent the "flipping" of IP blocks > that are obtained through transfer, but you would have to add more words > to specify that it is that particular block that was obtained through > transfer that you could not be a source on in the next 12 months. The > current wording places the restriction on any resources held by the source > entity, not the block in question. > I disagree. I hate it when the government plays these games and I see no reason to enable them in IP address transfers. Whether you get resource A and immediately sell resource B instead of using resource B to fill the need for which you got A, or, get resource A and sell it, it's still effectively flipping. Just like when the government allocates lottery money to the schools in order to get the ballot measure passed, then decreases other funding for schools by the amount the lottery brings in. If you receive addresses through any mechanism, you should not be able to transfer excess addresses out for 12 months. ARIN should not be in the business of providing free revenue to organizations from their existing address resources. > There are valid use cases where a provider may need to obtain a block for > some need, but would want to transfer off another, unrelated block, to > service a customer. > I think these are corner cases. I think that the flipping scenario is far more likely as it has strong monetary incentives. > I would prefer giving ARIN staff the flexibility to consider these things > during the review. Someone may get away with it once, if they chose to > take this approach, but I don't see them being approved by ARIN staff as a > recipient after that since they obviously didn't need the last one. > If the policy doesn't prohibit it, then, ARIN staff can't really use that as a basis to reject them as a recipient. > Let's also consider that the block you are concerned about being flipped > has been received under RSA and you now have a question regarding the > conditions by which they have obtained the registration. Yeah, but, we put safe harbor all over the transfer stuff, so, the fact that they are transferring it kind of makes them mostly immune to that. Owen > > Dan Alexander > Speaking only as myself > > > On 2/21/12 3:04 PM, "Chris Grundemann" wrote: > >> On Fri, Feb 17, 2012 at 09:42, Alexander, Daniel >> wrote: >>> Hello All, >>> >>> The Staff and Legal review has been provided to the AC for prop-151. The >>> review focused mainly on the 12 month needs assessment given that the >>> Board has recently ratified 2011-12 which changed the transfer needs >>> assessment to 24 months. This update and a few others are listed below. >>> >>> Another change that has been suggested is to include transfers in the 12 >>> month restrictions on the source of a transfer. The resulting text would >>> read as follows. >>> >>> "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." >>> >>> The intent of this change would be to limit an organization from >>> "flipping" transferred resources. Do people feel that this should be >>> incorporated into the text? >> >> This inclusion is absolutely mandatory to maintaining a needs-based >> system. As such, the question should be reversed: "Is there any reason >> to exclude transfers, when allocations and assignments are counted?" >> >> Cheer, >> ~Chris >> >>> All feedback is appreciated. >>> >>> Dan Alexander >>> AC Shepherd >>> >>> >>> Changes to prop-151 text: >>> >>> - Restored a needs requirement to the text. >>> - Eliminated the /12 cap on resources received. >>> - Removed the suggestions to altering the text of the RSA. >>> - Removed the section regarding "Conditions on the IPv4 address block". >>> - Revised the condition of space being administered by ARIN to >>> incorporate >>> inter-RIR transfers as a result of 2011-1. >>> - Moved the minimum transfer size requirement down to remaining >>> Conditions. >>> - Separated in-region and inter-region transfers into separate sections. >>> - Clarified the starting point of the 12 month restrictions as a result >>> of >>> staff feedback. >>> - Changed the proposal title from "Limiting needs..." to "Clarifying >>> Requirements..." as a result of feedback. >>> - Updated needs requirement from 12 to 24 months as a result of 2011-12. >>> >>> >>> >>> Current text: >>> >>> Replace Section 8.3 with >>> >>> 8.3 Transfers between Specified Recipients within the ARIN Region. >>> >>> In addition to transfers under section 8.2, IPv4 numbers resources may >>> be >>> transferred according to the following conditions. >>> >>> Conditions on source of the transfer: >>> >>> * The source entity must be the current registered holder of the IPv4 >>> address resources, and not be involved in any dispute as to the status >>> of >>> those resources. >>> * The source entity will be ineligible to receive any further IPv4 >>> address >>> allocations or assignments from ARIN for a period of 12 months after a >>> transfer approval, or until the exhaustion of ARIN's IPv4 space, >>> whichever >>> occurs first. >>> * The source entity must not have received an allocation or assignment >>> of >>> IPv4 number resources from ARIN for the 12 months prior to the approval >>> of >>> a transfer request. >>> * The minimum transfer size is a /24 >>> >>> >>> Conditions on recipient of the transfer: >>> >>> * The recipient must demonstrate the need for up to a 24 month supply of >>> IP address resources under current ARIN policies and sign an RSA. >>> * The resources transferred will be subject to current ARIN policies. >>> >>> >>> Add Section 8.4 Inter-RIR Transfers to Specified Recipients >>> >>> Inter-regional transfers may take place only via RIRs who agree to the >>> transfer and share reciprocal, compatible, needs-based policies. >>> >>> Conditions on source of the transfer: >>> >>> * The source entity must be the current rights holder of the IPv4 >>> address >>> resources recognized by the RIR responsible for the resources, and not >>> be >>> involved in any dispute as to the status of those resources. >>> * Source entities outside of the ARIN region must meet any requirements >>> defined by the RIR where the source entity holds the registration. >>> * Source entities within the ARIN region will not be eligible to receive >>> any further IPv4 address allocations or assignments from ARIN for a >>> period >>> of 12 months after a transfer approval, or until the exhaustion of >>> ARIN's >>> IPv4 space, whichever occurs first. >>> * Source entities within the ARIN region must not have received an >>> allocation or assignment of IPv4 number resources from ARIN for the 12 >>> months prior to the approval of a transfer request. >>> * The minimum transfer size is a /24. >>> >>> >>> Conditions on recipient of the transfer: >>> >>> * The conditions on a recipient outside of the ARIN region will be >>> defined >>> by the policies of the receiving RIR. >>> * Recipients within the ARIN region will be subject to current ARIN >>> policies and sign an RSA for the resources being received. >>> * Recipients within the ARIN region must demonstrate the need for up to >>> a >>> 24 month supply of IPv4 address space. >>> * The minimum transfer size is a /24 >>> >>> Rationale: >>> >>> The original text of this proposal attempted to simplify the >>> requirements >>> of an IPv4 address transfer while protecting any resources in the ARIN >>> free pool. This revision is a result of feedback from the mailing list, >>> and discussions with the original author. The one key point that has >>> been >>> removed from the original text is that a needs based review remains in >>> place. >>> >>> The current text attempts to retain the original concepts of protecting >>> any ARIN free pool, and incorporating it with the point of bringing >>> resources under RSA. The resulting text attempts to put safeguards in >>> place on the practice of paid transfers by creating a black out period >>> for >>> requests from the free pool. The text also tries to incorporate >>> discussions regarding inter-RIR transfers and come up with language that >>> includes the free pool protections for transfers in and out of the >>> Region. >>> >>> Timetable for implementation: immediate. >>> >>> >>> >>> _______________________________________________ >>> PPML >>> You are receiving this message because you are subscribed to >>> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >>> Unsubscribe or manage your mailing list subscription at: >>> http://lists.arin.net/mailman/listinfo/arin-ppml >>> Please contact info at arin.net if you experience any issues. >> >> >> >> -- >> @ChrisGrundemann >> http://chrisgrundemann.com > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From info at arin.net Wed Feb 22 17:51:36 2012 From: info at arin.net (ARIN) Date: Wed, 22 Feb 2012 17:51:36 -0500 Subject: [arin-ppml] Draft Policy ARIN-2011-7: Compliance Requirement - revised Message-ID: <4F457178.7040805@arin.net> Draft Policy ARIN-2011-7 Compliance Requirement ARIN-2011-7 has been revised. This draft policy is open for discussion on this mailing list and will be on the agenda at the upcoming ARIN Public Policy Meeting in Vancouver. ARIN-2011-7 is below and can be found at: https://www.arin.net/policy/proposals/2011_7.html Following the text is an ARIN staff assessment. Regards, Communications and Member Services American Registry for Internet Numbers (ARIN) ## * ## Draft Policy ARIN-2011-7 Compliance Requirement Version: 5 Date: 22 February 2012 Policy statement: In section 12.4, replace: Organizations found by ARIN to be materially out of compliance with current ARIN policy shall be requested or required to return resources as needed to bring them into (or reasonably close to) compliance. With: Organizations found by ARIN to be out of compliance with current ARIN policy shall be required to update reassignment information or return resources as needed to bring them into (or reasonably close to) compliance. (Leave paragraph 12.4.a. and 12.4.b. unchanged) Replace section 12.5 with: Except in cases of fraud when immediate action can be taken, an organization shall be given thirty (30) days to respond. If an organization fails to respond within thirty (30) days, ARIN may cease providing reverse DNS services to that organization. If progress of resource returns or record corrections has not occurred within sixty (60) days after ARIN initiated contact, ARIN shall cease providing reverse DNS services for the resources in question. ARIN shall negotiate a longer term with the organization if ARIN believes the organization is working in good faith to restore compliance and has a valid need for additional time. Replace section 12.6 with: At any time ninety (90) days after initial ARIN contact, ARIN may initiate the revocation of any resources issued by ARIN as required to bring the organization into overall compliance. Except in cases of fraud, or violations of policy, an organization shall be given a minimum of six months to effect a return. ARIN shall negotiate a longer term with the organization if ARIN believes the organization is working in good faith to restore compliance and has a valid need for additional time to renumber out of the affected blocks. ARIN shall follow the same guidelines for revocation that are required for voluntary return in paragraph 12.4.b. above. Rationale: Version 5 further addresses PPML and AC feedback since the last PPM. Version 4 addresses all feedback received at the ARIN PPM in Philadelphia. Mostly small textual changes - does re-introduce the 6 month window for resource revocations (it now remains in section 12.6). Version 3 addresses remaining legal concerns with specific wording. Version 2 addresses several staff and legal concerns with the original text of this policy by clarifying the language and making it more concrete. To date the community has not documented or firmly established use of an effective enforcement mechanism. This policy will support current policy and compel those who are allocated ARIN resources to maintain the proper WHOIS records in accordance with ARIN NRPM. While it is recognized this is not an absolute solution to ensure compliance, it is the best method under current ARIN policies. Timetable for implementation: Immediate ##### ARIN STAFF & LEGAL ASSESSMENT Draft Policy: 2011-7 Compliance Requirement Date of Assessment: 15 Feb 2012 1. Proposal Summary (Staff Understanding) This proposal requires ARIN staff to identify customers who are out of compliance with policy, and to eventually withhold services for those who fail to come into compliance within a designated time. Staff is to contact customers who are out of compliance with policy and give them 30 days to respond to our contact and to demonstrate they've begun to take corrective measures within 60 days. If either of these criteria is not met, the policy instructs staff to cease providing reverse DNS services to the customer or to begin reclamation efforts after 90 days. 2. Comments A. ARIN Staff Comments ? The term ?out of compliance? is not well defined anywhere within this policy. Without additional criteria, staff will continue to interpret this term somewhat liberally, and to apply it at our discretion using our best judgment and consideration of existing factors. Only those organizations that we deem to be significantly in violation of existing policy will be flagged for further review and audit. ? Removing an organization?s reverse DNS and/or reclaiming their IP number resources will be likely to have a negative impact on their ability to conduct business. B. ARIN General Counsel ? This policy has significant legal implications, as it requires ARIN to withdraw services that may impact innocent and bona fide third parties utilizing the resources. Any revocation made pursuant to this revised policy could result in litigation. 3. Resource Impact This policy would have moderate resource impact from an implementation aspect. It is estimated that implementation could occur within 6 ? 9 months after ratification by the ARIN Board of Trustees. The implementation of this policy will require new software tools to track these newly defined deadlines. Additionally, there will likely be a significant increase in time and workload for the RS team as the potential for a significant increase in resource audits due to non-compliance with IPv6 reassignment requirements is great. This may even require additional personnel, although it is too early to tell right now. The following would be needed in order to implement: ? Updated guidelines and website documentation ? Staff training ? Software tools would need to be developed to track the 30 and 60-day deadlines. 4. Proposal Text Draft Policy ARIN-2011-7 Compliance Requirement Policy statement: In section 12.4, replace: Organizations found by ARIN to be materially out of compliance with current ARIN policy shall be requested or required to return resources as needed to bring them into (or reasonably close to) compliance. With: Organizations found by ARIN to be out of compliance with current ARIN policy shall be required to update reassignment information or return resources as needed to bring them into (or reasonably close to) compliance. (Leave paragraph 12.4.a. and 12.4.b. unchanged) Replace section 12.5 with: Except in cases of fraud when immediate action can be taken, an organization shall be given thirty (30) days to respond. If an organization fails to respond within thirty (30) days, ARIN may cease providing reverse DNS services to that organization. If progress of resource returns or record corrections has not occurred within sixty (60) days after ARIN initiated contact, ARIN shall cease providing reverse DNS services for the resources in question. ARIN shall negotiate a longer term with the organization if ARIN believes the organization is working in good faith to restore compliance and has a valid need for additional time. Replace section 12.6 with: At any time ninety (90) days after initial ARIN contact, ARIN may initiate the revocation of any resources issued by ARIN as required to bring the organization into overall compliance. Except in cases of fraud, or violations of policy, an organization shall be given a minimum of six months to effect a return. ARIN shall negotiate a longer term with the organization if ARIN believes the organization is working in good faith to restore compliance and has a valid need for additional time to renumber out of the affected blocks. ARIN shall follow the same guidelines for revocation that are required for voluntary return in paragraph 12.4.b. above. From info at arin.net Wed Feb 22 17:52:38 2012 From: info at arin.net (ARIN) Date: Wed, 22 Feb 2012 17:52:38 -0500 Subject: [arin-ppml] Advisory Council Meeting Results - February 2012 Message-ID: <4F4571B6.90504@arin.net> In accordance with the ARIN Policy Development Process, the ARIN Advisory Council (AC) held a meeting on 16 February 2012 and made decisions about several proposals. The AC selected the following proposals as draft policies for adoption discussion online and at the ARIN XXIX Public Policy Meeting in Vancouver in April. The draft policies will be posted shortly to the PPML. ARIN-prop-151 Limiting needs requirements for IPv4 Transfers ARIN-prop-159 IPv6 Subsequent Allocations Utilization Requirement The AC abandoned the following proposals: ARIN-prop-161 Normalize Free pool and Transfer justification periods ARIN-prop-163 Dedicated resources for initial ISP allocations ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion The AC stated the following about proposal 161, "Based on similarities between proposals 161 and 162 combined with the greater support of 162 on PPML, the AC decided to abandon 161 and focus on development of 162." Regarding proposal 163, the AC stated, "Based on a lack of significant support or extenuating circumstances that would require the creation of a specially designated class of v4 address space within the ARIN region, the AC chose to abandon proposal 163. Without a compelling inequity present, it's difficult to make a case for carve-outs of any kind other than for critical infrastructure. The community has underscored this with significant expressions of support for fewer v4 initiatives and more focus on transition." And regarding proposal 164, the AC said, "Due to a lack of support and strong opposition among the community on PPML, the AC abandoned proposal 164." The AC thanks the authors and the community for their continuing effort and contributions to these and all other policy considerations. The AC abandoned proposals 161, 163 and 164. The AC is advancing draft policy text for proposals 151 and 159 that differs from the original proposal texts. Anyone dissatisfied with these decisions may initiate a petition. The petition to advance these proposals is the "Discussion Petition." The deadline to begin a petition will be five business days after the AC's draft meeting minutes are published. For more information on starting and participating in petitions, see PDP Petitions at: https://www.arin.net/policy/pdp_petitions.html Draft Policy and Proposal texts are available at: https://www.arin.net/policy/proposals/index.html The ARIN Policy Development Process can be found at: https://www.arin.net/policy/pdp.html Regards, Communications and Member Services American Registry for Internet Numbers (ARIN) From info at arin.net Wed Feb 22 17:54:52 2012 From: info at arin.net (ARIN) Date: Wed, 22 Feb 2012 17:54:52 -0500 Subject: [arin-ppml] Draft Policy 2012-1 Clarifying requirements for IPv4 transfers (was Re: Prop-151: Clarifying requirements for IPv4 transfers) Message-ID: <4F45723C.6010300@arin.net> Draft Policy ARIN-2012-1 Clarifying requirements for IPv4 transfers On 16 February 2012 the ARIN Advisory Council (AC) selected "Clarifying requirements for IPv4 transfers" as a draft policy for adoption discussion on the PPML and at the Public Policy Meeting in Vancouver in April. The draft was developed by the AC from policy proposal "ARIN-prop-151 Limiting needs requirements for IPv4 Transfers." Per the Policy Development Process the AC submitted text to ARIN for a staff and legal assessment prior to its selection as a draft policy. Below the draft policy is the ARIN staff and legal assessment, followed by the text that was submitted by the AC. Note that the AC revised the draft policy text after they received the assessment from staff. Draft Policy ARIN-2012-1 is below and can be found at: https://www.arin.net/policy/proposals/2012_1.html You are encouraged to discuss Draft Policy 2012-1 on the PPML prior to the April Public Policy Meeting. Both the discussion on the list and at the meeting will be used by the ARIN Advisory Council to determine the community consensus for adopting this as policy. The ARIN Policy Development Process 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, Member Services American Registry for Internet Numbers (ARIN) ## * ## Draft Policy ARIN-2012-1 Clarifying requirements for IPv4 transfers Date: 22 February 2012 Policy statement: Current text: Replace Section 8.3 with 8.3 Transfers between Specified Recipients within the ARIN Region. In addition to transfers under section 8.2, IPv4 numbers resources may be transferred according to the following conditions. Conditions on source of the transfer: * The source entity must be the current registered holder of the IPv4 address resources, and not be involved in any dispute as to the status of those resources. * The source entity will be ineligible to receive any further IPv4 address allocations or assignments from ARIN for a period of 12 months after a transfer approval, or until the exhaustion of ARIN's IPv4 space, whichever occurs first. * The source entity must not have received an allocation or assignment of IPv4 number resources from ARIN for the 12 months prior to the approval of a transfer request. * The minimum transfer size is a /24 Conditions on recipient of the transfer: * The recipient must demonstrate the need for up to a 24 month supply of IP address resources under current ARIN policies and sign an RSA. * The resources transferred will be subject to current ARIN policies. Add Section 8.4 Inter-RIR Transfers to Specified Recipients Inter-regional transfers may take place only via RIRs who agree to the transfer and share reciprocal, compatible, needs-based policies. Conditions on source of the transfer: * The source entity must be the current rights holder of the IPv4 address resources recognized by the RIR responsible for the resources, and not be involved in any dispute as to the status of those resources. * Source entities outside of the ARIN region must meet any requirements defined by the RIR where the source entity holds the registration. * Source entities within the ARIN region will not be eligible to receive any further IPv4 address allocations or assignments from ARIN for a period of 12 months after a transfer approval, or until the exhaustion of ARIN's IPv4 space, whichever occurs first. * Source entities within the ARIN region must not have received an allocation or assignment of IPv4 number resources from ARIN for the 12 months prior to the approval of a transfer request. * The minimum transfer size is a /24. Conditions on recipient of the transfer: * The conditions on a recipient outside of the ARIN region will be defined by the policies of the receiving RIR. * Recipients within the ARIN region will be subject to current ARIN policies and sign an RSA for the resources being received. * Recipients within the ARIN region must demonstrate the need for up to a 24 month supply of IPv4 address space. * The minimum transfer size is a /24 Rationale: The original text of this proposal attempted to simplify the requirements of an IPv4 address transfer while protecting any resources in the ARIN free pool. This revision is a result of feedback from the mailing list, and discussions with the original author. The one key point that has been removed from the original text is that a needs based review remains in place. The current text attempts to retain the original concepts of protecting any ARIN free pool, and incorporating it with the point of bringing resources under RSA. The resulting text attempts to put safeguards in place on the practice of paid transfers by creating a black out period for requests from the free pool. The text also tries to incorporate discussions regarding inter-RIR transfers and come up with language that includes the free pool protections for transfers in and out of the Region. Timetable for implementation: immediate. ########## ARIN STAFF ASSESSMENT Proposal: ARIN-prop-151 Limiting needs requirements for IPv4 Transfers Date of Assessment: Feb 15, 2012 1. Proposal Summary (Staff Understanding) This proposal would modify the 8.3 transfer policy and implement an inter-RIR transfer policy (both for IPv4 addresses only). For 8.3 transfers, recipients would be limited to 12 months need, versus the 24 month need currently in place, and the organization releasing the resources can't have received additional IPv4 addresses from ARIN in the previous 12 months and will be ineligible to receive additional IPv4 addresses for 12 months after the transfer. For transfers from ARIN to another RIR, the releasing org must be the authorized holder, can't have received additional IPv4 addresses from ARIN in the previous 12 months, and will be unable to obtain additional IPv4 addresses from ARIN for 12 months following the transfer, and the recipient org must qualify to receive the resources under the other RIR's policies. For transfers to ARIN from another RIR, the other RIR must verify the releasing org is the authorized resource holder, and the recipient may request up to a 12 month supply of IPv4 addresses. 2. Comments A. ARIN Staff Comments ? The timer for when the 12?month period before the transfer begins is undefined. When would staff start the timer? From the day the transfer request is submitted to ARIN? Or on the future approval date of the proposed transfer? Staff believes it would be logical to count back 12 months from the date of the transfer approval. ? This proposal imposes a 12-??month waiting period on organizations wishing to transfer IPv4 address space from ARIN to another region on either side of the transfer (both pre?xfer and post?xfer). This would be a good deterrent to organizations intending to ?flip? IPv4 address space via an 8.3 transfer. ? Should this same limitation be imposed on organizations wishing to transfer IPv4 space from another region into the ARIN region such that the releasing org cannot have received IPv4 address space from their RIR within the 12-month period prior to the transfer? This again would deter flipping IPv4 addresses via an 8.3 transfer and bring parity to the policy for transfer both to and from the ARIN region. ? The concise language in the phrase, "reciprocal, compatible, needs?based policies" is a very good improvement to this policy text and makes it very clear. It ensures that both RIRs have reciprocal inter-RIR policies, inter?RIR policies which are compatible with one another, and general number resource policies which are needs?based. ? Numerous sentences in this policy are not compatible with the current NRPM 8.3, which now allows for a 24-??month need to be met. If this policy proposal is being passed, the community should very carefully compare and contrast the current NRPM 8.3 with this text to ensure the changes being proposed are acceptable to the community. B. ARIN General Counsel This proposal would reverse a policy just approved days ago that allows transfers of up to 24 months? need under 8.3, and move it back to the prior policy of 12 months. Counsel had previously recommended to the Board, AC and community that the 24 month policy was better for ARIN?s legal needs. Adopting the reversal back to 12 months will make it much harder for those who are willing to complete transfers in bankruptcy in accordance with ARIN?s policies to do so. I also do not believe reversing policy in this way is good on any subject. The electronic ink is not dry on the change form 12 to 24 months. This proposed change would substantially increase legal fees and legal risks for ARIN, and therefore I would recommend to the Board that it not ratify the reversal from 24 months to 12 months. If this problem is resolved there are no legal concerns regarding the policy except for some logical suggestions counsel has made to the policy text regarding inter region transfers Other changes in the policy appear to have solved other legal concerns expressed in previous comments on earlier versions of this policy. 3. Resource Impact This policy would have major resource impact from an implementation aspect. It is estimated that implementation would occur within 12 months after ratification by the ARIN Board of Trustees. The following would be needed in order to implement: ? Careful coordination between the RIRs on DNS issues and updates for the inter-rir transfers ? Potential issues include: o Zone fragmentation o DNS synchronization problems o Potential administrative and operational issues in coordinating reverse addressing ? RPKI implications ? Updated guidelines ? Staff training 4. Proposal Text Replace Section 8.3 with 8.3 Transfers between Specified Recipients within the ARIN Region. In addition to transfers under section 8.2, IPv4 numbers resources may be transferred according to the following conditions. Conditions on source of the transfer: * The source entity must be the current registered holder of the IPv4 address resources, and not be involved in any dispute as to the status of those resources. * The source entity will be ineligible to receive any further IPv4 address allocations or assignments from ARIN for a period of 12 months after the transfer, or until the exhaustion of ARIN's IPv4 space, whichever occurs first. * The source entity must not have received an allocation or assignment of IPv4 number resources from ARIN for the 12 months prior to the transfer. * The minimum transfer size is a /24 Conditions on recipient of the transfer: * The recipient must demonstrate the need for up to a 12 month supply of IP address resources under current ARIN policies and sign an RSA. * The resources transferred will be subject to current ARIN policies. Add Section 8.4 Inter-??RIR Transfers to Specified Recipients Inter-regional transfers may take place only via RIRs who agree to the transfer and share reciprocal, compatible, needs-??based policies. Conditions on source of the transfer: * The source entity must be the current rights holder of the IPv4 address resources recognized by the RIR responsible for the resources, and not be involved in any dispute as to the status of those resources. * Source entities outside of the ARIN region must meet any requirements defined by the RIR where the source entity holds the registration. * Source entities within the ARIN region will not be eligible to receive any further IPv4 address allocations or assignments from ARIN for a period of 12 months after the transfer, or until the exhaustion of ARIN's IPv4 space, whichever occurs first. * Source entities within the ARIN region must not have received an allocation or assignment of IPv4 number resources from ARIN for the 12 months prior to the transfer. * The minimum transfer size is a /24 Conditions on recipient of the transfer: * The conditions on a recipient outside of the ARIN region will be defined by the policies of the receiving RIR. * Recipients within the ARIN region will be subject to current ARIN policies and sign an RSA for the resources being received. * Recipients within the ARIN region must demonstrate the need for up to a 12 month supply of IPv4 address space. * The minimum transfer size is a /24 Rationale: The original text of this proposal attempted to impose few constraints on the transfer or on the parties involved other than than allowing the registry to record transactions where IPv4 addresses are transfered between ARIN account holders. This revision is a result of feedback from the mailing list, and discussions with the original author. The one key point that has been removed from the original text is that a needs based review remains in place. The current text attempts to retain the original concepts of protecting any ARIN free pool, and incorporating it with the point of bringing resources under RSA. The resulting text attempts to put safeguards in place on the practice of paid transfers by creating a black out period for requests from the free pool. The text also tries to incorporate discussions regarding inter-??RIR transfers and come up with language that includes the free pool protections for transfers in and out of the Region. From info at arin.net Wed Feb 22 17:55:54 2012 From: info at arin.net (ARIN) Date: Wed, 22 Feb 2012 17:55:54 -0500 Subject: [arin-ppml] Draft Policy 2012-2: IPv6 Subsequent Allocations Utilization Requirement Message-ID: <4F45727A.3040007@arin.net> Draft Policy ARIN-2012-2 IPv6 Subsequent Allocations Utilization Requirement On 16 February 2012 the ARIN Advisory Council (AC) selected "Clarifying requirements for IPv4 transfers" as a draft policy for adoption discussion on the PPML and at the Public Policy Meeting in Vancouver in April. The draft was developed by the AC from policy proposal "ARIN-prop-151 Limiting needs requirements for IPv4 Transfers." Per the Policy Development Process the AC submitted text to ARIN for a staff and legal assessment prior to its selection as a draft policy. Below the draft policy is the ARIN staff and legal assessment, followed by the text that was submitted by the AC. Draft Policy ARIN-2012-2 is below and can be found at: https://www.arin.net/policy/proposals/2012_2.html You are encouraged to discuss Draft Policy 2012-2 on the PPML prior to the April Public Policy Meeting. Both the discussion on the list and at the meeting will be used by the ARIN Advisory Council to determine the community consensus for adopting this as policy. The ARIN Policy Development Process 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, Member Services American Registry for Internet Numbers (ARIN) ## * ## Draft Policy ARIN-2012-2 IPv6 Subsequent Allocations Utilization Requirement Date: 22 February 2012 Policy statement: NRPM section 2.16 Utilized (IPv6) Add: 3. Tie down blocks shall be considered fully utilized, for the purpose of subsequent allocations, when the first reassignment is made from the tie down pool. (e.g. a /36 tie down for customer /48s will be considered utilized for subsequent allocations once the first /48 is assigned from the /36). Rationale: If you are executing to a long term plan, you should be able to continue to execute on your approved allocation and assignment plan regardless of the number of regions/groupings you originally planned for. We want to promote tie downs on nibbles and long term planning. Timetable for implementation: Immediately ########## ARIN Staff and Legal Assessment Draft Policy: PP 159 ?IPv6 Subsequent Allocations Utilization Requirement? Date of Assessment: 15 Feb 2012 1. Proposal Summary (Staff Understanding) The intent of this proposal is to allow an additional way for ISP's that have already begun using their IPv6 space but who may not have sufficiently planned for longer term growth, to receive an additional allocation. This policy would allow an organization to qualify for an additional IPv6 allocation if they can show that 75% of their IPv6 address space as a whole is subnetted, provided that each subnet has at least 1 customer or infrastructure assignment/allocation. 2. Staff Comments: A. ARIN Staff Comments: If this policy were to be implemented exactly as written, ARIN staff would approve an additional IPv6 allocation as long as a network had subnetted at least 75% of their IPv6 allocation, with at least one customer or internal assignment/allocation in each subnet. ARIN would not evaluate subnet size; as long as any portion of a subnet is used, then that subnet would be considered to be fully used, regardless of its size. Effectively, this allows an operator to qualify for IPv6 addresses any time they want, because it's trivial to subnet out 75% of an allocation(s) and use at least a tiny portion of each, and may not encourage conservation of IPv6 address space. If the author's intent is to allow operators to make reasonable decisions about their IPv6 deployment, another option would be to simplify the IPv6 additional allocation policy to allow an operator to qualify for more IPv6 addresses when they can show a need for them. Alternatively, if the author's intent is to have ARIN staff evaluate whether those decisions are reasonable, then specific criteria needs to be laid out to give staff guidance as to how we do that (e.g. block size, timeframes, etc.). The author's original proposal rationale stated that the expectation would be for ARIN to use its discretion to weed out such requests, but there is no policy basis for doing so. Nothing in this text gives staff any basis for rejecting any subnet size, regardless of how reasonable we think it is. If the author wants ARIN to review requests to determine if technically reasonable, than some criteria or guidance must be provided within the policy text. B. ARIN General Counsel ? This policy does not create significant legal issues. 3. Resource Impact This policy would have minimal resource impact from an implementation aspect. It is estimated that implementation could occur within 3 months after ratification by the ARIN Board of Trustees. The following would be needed in order to implement: Guidelines and procedures need to be updated Staff training Proposal text: Modify 6.5.3.b as follows: An LIR may request a subsequent allocation when they can show utilization of: 75% or more of their total address space or more than 90% of any serving site or when 75% of the aggregate has been subnetted, and each subnet contains at least 1* customer or infrastructure allocation or assignment ( *1 can be replaced here with any reasonable number) Original Rationale: If you are executing to a long term plan, you should be able to continue to execute on your approved allocation and assignment plan regardless of the number of regions/groupings you originally planned for. We want to promote tie downs on nibbles and long term planning. From jmaimon at chl.com Wed Feb 22 23:47:17 2012 From: jmaimon at chl.com (Joe Maimon) Date: Wed, 22 Feb 2012 23:47:17 -0500 Subject: [arin-ppml] Advisory Council Meeting Results - February 2012 In-Reply-To: <4F4571B6.90504@arin.net> References: <4F4571B6.90504@arin.net> Message-ID: <4F45C4D5.5090401@chl.com> ARIN wrote: > > > Regarding proposal 163, the AC stated, "Based on a lack of significant > support or extenuating circumstances that would require the creation of > a specially designated class of v4 address space within the ARIN region, > the AC chose to abandon proposal 163. Without a compelling inequity > present, it's difficult to make a case for carve-outs of any kind other > than for critical infrastructure. The community has underscored this > with significant expressions of support for fewer v4 initiatives and > more focus on transition." To the drafter of this language, and to those who affirmed it. To the AC as the unified body we have been told to consider it as. You have outstripped your mandate, again. Your reasoning and conclusions are convoluted, arbitrary and fabricated, biased in support of your own opinions, desires and agendas. You are ignoring the existence of THREE "specially designated class of v4 addresses", current and pending, lobbied hard for by members AC. You have arbitrarily moved the bar of community support, which you have grudgingly acknowledged exists even while dismissing it as not "significant" enough. You have arbitrarily decided that the community is not interested in "v4 initiatives", unless of course, its a policy advanced by a member of the in club - or a policy designed to deplete IPv4 quicker. It was not that long ago that your first disgraceful attempt at dictating to the community what policies would be acceptable was made. You have arbitrarily decided upon what set of circumstances you would be convinced that this policy merits community wide consideration and you have arbitrarily pronounced (mis)judgement on those circumstances, in the teeth of simple and stark numbers and facts. What have you left over for the community you claim to represent? You no longer speak for the larger community. You have been seduced into redefining the community to encompass only yourselves and those who agree with you. You have successfully and repetitively acted in a manner that stifles debate and frustrates participants. I do not consider your behavior congruent with your job description. > And regarding proposal 164, the AC said, "Due to a lack of support and > strong opposition among the community on PPML, the AC abandoned proposal > 164." Yes there was lack of stated support. However there can still be interest in wider discussion. Which is part of the AC's job to determine. Where are they now, the community members who want transition to be as quick and as painful as possible? Who claim that the unpredictability of exhaustion and the continue availability of IPv4 hampers IPv6 uptake? Who advocate liaises-fair or worse, expressing the opinion that the faster IPv4 is dead by way of RiR exhaustion, the better? Can you not stand behind your own ideals and objectives when it is laid out in black and white, in a policy proposal? I wish for you to have the opportunity to speak now or (hopefully) remain silent until after transition. I will appeal both these decisions, petitioning any and all members of the community (and that includes AC members too) for their support. Whether you believe either of these proposals are worthy of consideration in their own merit, or whether you believe the AC has not acted in the manner you want to hold them to, I request and welcome your support for petition of these abandonment decisions. Best, Joe From mike at willitsonline.com Wed Feb 22 23:44:17 2012 From: mike at willitsonline.com (mike) Date: Wed, 22 Feb 2012 20:44:17 -0800 Subject: [arin-ppml] ARIN as a public interest business Message-ID: <4F45C421.7000802@willitsonline.com> Hello, I am a small ISP and a small business that has 4 employees and under $1m/yr revenue. I depend on my ARIN as/ip assignments because my business model demands the technical features that only being an AS with PI IPv4 space can provide. I am very unhappy however with the price I pay yearly to ARIN, which operates apparently in a vacuum and in complete ignorance of fiscal responsibility, witness the squandering of it's funds which then have to come out of my pocket. I work my tail off for every dollar I make and every time I send a check to ARIN it makes my blood boil knowing how you spend it. I can do without: The 'team arin' comics - https://www.arin.net/knowledge/comic.html The personal phone calls from ARIN staffers regarding elections I don't care about that I get every year. The refrigerator magnet advising same. The hand signed paper mail letters about same. ... and on and on and on.... I would love to know, if ARIN was forced to operate like a business, how cheaply could ip resource assignments be made? Do you think some of these 'expenses' could be trimmed so that my next bill due is smaller than the year before? And how could customer service at ARIN improve if under a business model where customer satisfaction was actually a stated goal, instead of just an accidental by-product that nobody currently is responsible for providing, and people could actually get fired for being mouthy and rude unlike today's academic institution/tenured professor immunity to consequences attitude that exists now? Please don't hate me. I am a business and just think you should be, too. Mike- From jmaimon at chl.com Wed Feb 22 23:47:12 2012 From: jmaimon at chl.com (Joe Maimon) Date: Wed, 22 Feb 2012 23:47:12 -0500 Subject: [arin-ppml] Petition for advancement of Policy Proposal #164 Predictable ARIN IPv4 Resource exhaustion, to Draft Policy status Message-ID: <4F45C4D0.1020200@chl.com> All, I am unsatisfied with the AC's abandonment of Policy Proposal #164 Predictable ARIN IPv4 Resource exhaustion. I formally petition you, the members of this regional community, for your support in advancing to draft policy status the proposal and for it to be discussed at an upcoming ARIN Public Policy meeting. I ask you for statements in support of this petition. The full policy proposal text is available at http://lists.arin.net/pipermail/arin-ppml/2012-February/024055.html Best and my thanks, Joe From jmaimon at chl.com Wed Feb 22 23:47:10 2012 From: jmaimon at chl.com (Joe Maimon) Date: Wed, 22 Feb 2012 23:47:10 -0500 Subject: [arin-ppml] Petition for advancement of Policy Proposal #163 Dedicated resources for initial ISP allocations, to Draft Policy status Message-ID: <4F45C4CE.2030302@chl.com> All, I am unsatisfied with the AC's abandonment of Policy Proposal #163 Dedicated resources for initial ISP allocations. I formally petition you, the members of this regional community, for your support in advancing to draft policy status the proposal and for it to be discussed at an upcoming ARIN Public Policy meeting. I ask you for statements in support of this petition. The full policy proposal text is available at http://lists.arin.net/pipermail/arin-ppml/2012-February/024054.html Best and my thanks, Joe From woody at pch.net Thu Feb 23 00:38:29 2012 From: woody at pch.net (Bill Woodcock) Date: Wed, 22 Feb 2012 21:38:29 -0800 Subject: [arin-ppml] ARIN as a public interest business In-Reply-To: <4F45C421.7000802@willitsonline.com> References: <4F45C421.7000802@willitsonline.com> Message-ID: -----BEGIN PGP SIGNED MESSAGE----- Hash: SHA256 On Feb 22, 2012, at 8:44 PM, mike wrote: > I am very unhappy with the price I pay yearly to ARIN. Mr. Ireton: Thank you for bringing this up. I'm sure someone will chime in to the effect that, because fees are a matter of budget rather than policy, the PPML is not the appropriate place for this conversation. I hope that if and when they do, they refer us to a venue where we can continue the conversation. In the mean time, I'd be very interested to hear more people's thoughts on the matter. In general, what I've heard in the past can be grossly summarized as: small providers prefer lower fees and fewer services, while large providers prefer the status-quo or higher fees and more services. Recalling that different sizes of providers essentially pay at different rates, do people feel that that means that small providers are collectively paying too great a share of ARIN's costs, while large providers are paying too little? Do large providers still prefer the status-quo or higher fees, even in the current economic climate? Anyone care to suggest other things they feel are superfluous to ARIN's mission? Thanks, -Bill Woodcock, ARIN board member, speaking individually. -----BEGIN PGP SIGNATURE----- Version: GnuPG/MacGPG2 v2.0.17 (Darwin) Comment: GPGTools - http://gpgtools.org iQIbBAEBCAAGBQJPRdDWAAoJEG+kcEsoi3+HHU4P+KnFMwAY8rbNZAm02AVnzJyQ K0eU8u8UgZogDkIZ6oiwfZPdV9WeHsIBP87jOO56pzZJrA9tU6ftr6FMRheic9DP MGBfT7AEWMNHjdSs6XZbReokeNZhcN4yPIm4i1sg043cuL3nCDThb2fR5fAQn8/n j2pAuVmbYv86bNdha+33vtS2rfY8+a8yF5cc4RMMksPo7kP/6qHWBjtEk55BoI4U lFSyvu9tlbsTyln/kqEvCO8euEFJ6+Z8NURULd+I1tlrY6Xh6JGdGnVtSbiFXOzj 4FZS5bxKv8fCPjcoARLC285Rg/QPK5WeQOhKkAnfL4Gb9naggisCcVGTgZUJBpdh jH2RG7DQmB5KJVLQ883mF87Uy2afv64tL+Tt30bs/s4oPuGlgMx54YkJTijbKDum UF7FWa4i5HINjUtv1W5ajXXlnAaIKmXcqx5GacW5wr3kG+tk5z8tmE1v+Jv8xguT 6r4pBQLacGk4PjtH9fsHZO9j0GCGtqN0YztvoTvfscDUYXnsJnbAuItRXDX4A36B Qls7pnMd0dW2Yvp+ko0iA/pSfy/BfulSSkE2c0YENYQ0dBhEMeI2JRFzcGbeLicb 9vPFrgVb4yjLZo4ZQbFnnY9MmwJLQpNSnELJrxtF8ducyeCBZEwth3byeyv+CPsu uHnxavQLAS6riHC9L0I= =1kVv -----END PGP SIGNATURE----- From farmer at umn.edu Thu Feb 23 01:51:40 2012 From: farmer at umn.edu (David Farmer) Date: Thu, 23 Feb 2012 00:51:40 -0600 Subject: [arin-ppml] Petition for advancement of Policy Proposal #163 Dedicated resources for initial ISP allocations, to Draft Policy status In-Reply-To: <4F45C4CE.2030302@chl.com> References: <4F45C4CE.2030302@chl.com> Message-ID: <4F45E1FC.6070308@umn.edu> I support the petition of this proposal to Draft Policy status for adoption discussion at the Vancouver Public Policy Meeting. While I support the policy proposal and this petition, as an AC Member I did vote to Abandon this proposal, precisely to allow the community to petition to get this policy proposal to the Vancouver meeting. I believe even if the AC had accepted this proposal on its docket that it would not likely have made it to the Vancouver meeting anyway. The AC is running up on the deadlines for the Vancouver meeting and there were other proposals with clearly more community support that required the limited resources that the AC had available before the deadline. If you support this issue please join in support of this petition. I also encourage the author and the community to work on the text of this proposal prior to to text freeze before the meeting. On 2/22/12 22:47 CST, Joe Maimon wrote: > All, > > I am unsatisfied with the AC's abandonment of Policy Proposal #163 > Dedicated resources for initial ISP allocations. > > I formally petition you, the members of this regional community, for > your support in advancing to draft policy status the proposal and for it > to be discussed at an upcoming ARIN Public Policy meeting. > > I ask you for statements in support of this petition. > > The full policy proposal text is available at > > http://lists.arin.net/pipermail/arin-ppml/2012-February/024054.html > > Best and my thanks, > > Joe > > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. -- =============================================== David Farmer Email:farmer at umn.edu Networking & Telecommunication Services Office of Information Technology University of Minnesota 2218 University Ave SE Phone: 612-626-0815 Minneapolis, MN 55414-3029 Cell: 612-812-9952 =============================================== From jcurran at arin.net Thu Feb 23 06:13:56 2012 From: jcurran at arin.net (John Curran) Date: Thu, 23 Feb 2012 11:13:56 +0000 Subject: [arin-ppml] ARIN as a public interest business In-Reply-To: <4F45C421.7000802@willitsonline.com> References: <4F45C421.7000802@willitsonline.com> Message-ID: <90C81EBC-B168-40CF-87A1-67BA6415FFEC@corp.arin.net> On Feb 22, 2012, at 11:44 PM, mike wrote: > Hello, > > I am a small ISP and a small business that has 4 employees and under $1m/yr revenue. I depend on my ARIN as/ip assignments because my business model demands the technical features that only being an AS with PI IPv4 space can provide. I am very unhappy however with the price I pay yearly to ARIN, which operates apparently in a vacuum and in complete ignorance of fiscal responsibility, witness the squandering of it's funds which then have to come out of my pocket. I work my tail off for every dollar I make and every time I send a check to ARIN it makes my blood boil knowing how you spend it. Mike - Thank you for your message; it's actually quite helpful to hear such focused feedback. As was noted earlier, we have an arin-discuss at arin.net mailing list for discussion of member matters such as fees, but I will provide some brief responses here and would encourage further discussion on that list. > I can do without: > > The 'team arin' comics - https://www.arin.net/knowledge/comic.html Myself as well - I "killed" the Team ARIN comic series several years ago. These were particularly effective at communicating background about IP addresses to audiences such as elected officials and press, but quickly reached diminishing returns and hence were cut from our program budget. > The personal phone calls from ARIN staffers regarding elections I don't care about that I get every year. > > The refrigerator magnet advising same. > > The hand signed paper mail letters about same. > > ... and on and on and on.... Yes, we do spend a small amount of money each year in contacting members via reminder cards about the upcoming elections, as well as have the staff dedicate several days to calling members with reminders about the election. The direct costs are low (~$20K each year) and the imputed staff costs are modest (about $40K). The benefits of the member outreach is a higher election participation rate (e.g. 14% of the total eligible organizations cast ballots in the 2011 Trustee elections) as well as several organizations each year update their contact information as a result of the election member outreach. You indicate that you don't care about elections, and I would ask that you at least consider voting for ARIN Board of Trustee candidates. The Trustees oversee the development of ARIN's budget and fees, and therefore electing candidates who hold the same beliefs as yourself regarding ARIN's budget and fees is the most certain way of directing the organization. You can determine the views of the various candidates from the questionnaires that candidates answer and are available online during the election process. > I would love to know, if ARIN was forced to operate like a business, how cheaply could ip resource assignments be made? Do you think some of these 'expenses' could be trimmed so that my next bill due is smaller than the year before? We actually operate very much like a business, and the Board actively considers the right balance of ARIN's budget and fees (based on guidance received from the members both on these mailing lists and the members meetings.) There are two aspects to the fees: how ARIN distributes costs among the members via fees, and what are the total costs of the operation. Mr. Woodcock raised some questions about cost distribution in his email on fees (and we would welcome your feedback there) and I will deal with the total cost containment issue. At the request of the Board, we have just completed introducing program-based cost accounting (as opposed to functional or "department" measurements) so that we can better understand ARIN's costs of various programs and make sure that we're being cost-effective in delivering on mission goals and services. I presented the most recent numbers at the recent Philadelphia ARIN Members Meeting, and will summarize below: From: Expenses through August 2011 - Program Area Program Exp. (% of Total) ------------ ------------ ---------- Registry Service $ 2,946,836 (31.69 %) Registry Development $ 4,641,148 (49.91 %) ARIN Organization $ 602,854 ( 6.48 %) Internet Governance $ 1,108,217 (11.92 %) Approximately half of ARIN's ongoing expenses related to "Registry Development", and this includes the costs of running the policy development process, the portion of the public policy meetings which support policy development, the development activities for ARIN Online in support of policy changes, etc. One of the most significant questions in ARIN's future is whether the amount of IPv4 policy development activity will drop in the near-term future, as this would allow ARIN to reduce the rate of ARIN Online changes and consider options to make policy development efforts more cost-effective. It is also true that ARIN has considerable expenditures in Internet Governance, and this is the result of increasing activities within ICANN, the IGF (Internet Governance Forum) and international bodies such as the ITU, where issues about Internet number resources and policy are increasingly being discussed. Again, to the extent that we can achieve more stability in this area, we can work to reduce this amount either by participating in less activities or gaining the ability coordinate participation through related organizations such as the NRO or the Internet Society. It is reasonable to think that ARIN should be able to lower its cost structure significantly over the coming years if there is more stability in the policy and Internet governance areas, and this should result in fee reductions even absent any structural changes in the fee distribution among members... Note - ARIN has consistently lowered fees over the years as soon as cost efficiencies have allowed (and this has resulted in 4 fee reductions since we started operations.) > And how could customer service at ARIN improve if under a business model where customer satisfaction was actually a stated goal, instead of just an accidental by-product that nobody currently is responsible for providing, and people could actually get fired for being mouthy and rude unlike today's academic institution/tenured professor immunity to consequences attitude that exists now? If any member of the staff has been anything other than professional and respectful during your dealings with ARIN, please feel free to contact me directly (jcurran at arin.net, cell + 1 617 512 8095) at any time. While we cannot commit to approving all your requests, you are entitled to have professional and respectful communications at all times and you may hold me directly accountable on this matter. I apologize for this lengthy response, but wanted you to know that your feedback is important and appreciated. Feel free to contact me directly if you want to follow-up further in any manner. Sincerely, /John John Curran President and CEO ARIN From dave at goflashpoint.com Thu Feb 23 07:47:18 2012 From: dave at goflashpoint.com (David Gibbons) Date: Thu, 23 Feb 2012 07:47:18 -0500 Subject: [arin-ppml] ARIN as a public interest business In-Reply-To: <4F45C421.7000802@willitsonline.com> References: <4F45C421.7000802@willitsonline.com> Message-ID: On Wed, Feb 22, 2012 at 11:44 PM, mike wrote: > I am a small ISP and a small business that has 4 employees and > under $1m/yr revenue. I depend on my ARIN as/ip assignments because my > business model demands the technical features that only being an AS with PI > IPv4 space can provide. I am very unhappy however with the price I pay > yearly to ARIN, which operates apparently in a vacuum and in complete > ignorance of fiscal responsibility, witness the squandering of it's funds > which then have to come out of my pocket. I work my tail off for every > dollar I make and every time I send a check to ARIN it makes my blood boil > knowing how you spend it. > I couldn't agree more about the refrigerator magnets, paper mail, etc. I was literally speechless when we received the package from ARIN that probably cost $10 to mail containing stamped pens, etc. They're a total waste. However -- are you really complaining about the roughly $2k a year that your (apparently only) /20 costs you? Maybe $1k more for an ASN? My company is about the same size as yours and in the same type of industry. The ARIN fees are extremely reasonable. This line item is so small -- even in the budget of a small business -- that this discussion has probably cost us all more in collective time than a yearly allocation fee. Give me a break. You make some valid points, I just don't think the fees justify the discussion. Cheers, Dave -- David Gibbons -------------- next part -------------- An HTML attachment was scrubbed... URL: From john.sweeting at twcable.com Thu Feb 23 08:59:43 2012 From: john.sweeting at twcable.com (Sweeting, John) Date: Thu, 23 Feb 2012 08:59:43 -0500 Subject: [arin-ppml] Petition for advancement of Policy Proposal #163 Dedicated resources for initial ISP allocations, to Draft Policy status In-Reply-To: <4F45E1FC.6070308@umn.edu> Message-ID: On 2/23/12 1:51 AM, "David Farmer" wrote: >I support the petition of this proposal to Draft Policy status for >adoption discussion at the Vancouver Public Policy Meeting. Which is every AC member's right > >While I support the policy proposal and this petition, as an AC Member I >did vote to Abandon this proposal, precisely to allow the community to >petition to get this policy proposal to the Vancouver meeting. I David, as you well know the AC does everything it can to ensure all proposals on the docket make it to the PPM. At this time we have 3 draft policies approved and 2 proposals undergoing Staff & Legal review so we can move them to draft policies on March 8th. We moved this meeting up from March 15th just to ensure that we could meet the timeline to move them forward. If the majority of the AC had felt that PP 163, or any other proposal, should be placed on the docket and presented in Vancouver then we would have made it happen. Thanks to ARIN staff for being very flexible in providing Staff & Legal reviews to us. > >believe even if the AC had accepted this proposal on its docket that it >would not likely have made it to the Vancouver meeting anyway. The AC >is running up on the deadlines for the Vancouver meeting and there were >other proposals with clearly more community support that required the >limited resources that the AC had available before the deadline. This proposal could definitely have made it to Vancouver if the majority of the AC felt that it should have been accepted on the docket and moved forward to Draft Policy status. It can also make it there as a Petition IAW the PDP. > >If you support this issue please join in support of this petition. I >also encourage the author and the community to work on the text of this >proposal prior to to text freeze before the meeting. > >On 2/22/12 22:47 CST, Joe Maimon wrote: >> All, >> >> I am unsatisfied with the AC's abandonment of Policy Proposal #163 >> Dedicated resources for initial ISP allocations. >> >> I formally petition you, the members of this regional community, for >> your support in advancing to draft policy status the proposal and for it >> to be discussed at an upcoming ARIN Public Policy meeting. >> >> I ask you for statements in support of this petition. >> >> The full policy proposal text is available at >> >> http://lists.arin.net/pipermail/arin-ppml/2012-February/024054.html >> >> Best and my thanks, >> >> Joe >> >> >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. > >-- >=============================================== >David Farmer Email:farmer at umn.edu >Networking & Telecommunication Services >Office of Information Technology >University of Minnesota >2218 University Ave SE Phone: 612-626-0815 >Minneapolis, MN 55414-3029 Cell: 612-812-9952 >=============================================== >_______________________________________________ >PPML >You are receiving this message because you are subscribed to >the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >Unsubscribe or manage your mailing list subscription at: >http://lists.arin.net/mailman/listinfo/arin-ppml >Please contact info at arin.net if you experience any issues. This E-mail and any of its attachments may contain Time Warner Cable proprietary information, which is privileged, confidential, or subject to copyright belonging to Time Warner Cable. This E-mail is intended solely for the use of the individual or entity to which it is addressed. If you are not the intended recipient of this E-mail, you are hereby notified that any dissemination, distribution, copying, or action taken in relation to the contents of and attachments to this E-mail is strictly prohibited and may be unlawful. If you have received this E-mail in error, please notify the sender immediately and permanently delete the original and any copy of this E-mail and any printout. From hannigan at gmail.com Thu Feb 23 09:05:36 2012 From: hannigan at gmail.com (Martin Hannigan) Date: Thu, 23 Feb 2012 09:05:36 -0500 Subject: [arin-ppml] Advisory Council Meeting Results - February 2012 In-Reply-To: <4F45C4D5.5090401@chl.com> References: <4F4571B6.90504@arin.net> <4F45C4D5.5090401@chl.com> Message-ID: On Wed, Feb 22, 2012 at 11:47 PM, Joe Maimon wrote: > > > ARIN wrote: >> >> >> >> Regarding proposal 163, the AC stated, "Based on a lack of significant >> support or extenuating circumstances that would require the creation of >> a specially designated class of v4 address space within the ARIN region, >> the AC chose to abandon proposal 163. Without a compelling inequity >> present, it's difficult to make a case for carve-outs of any kind other >> than for critical infrastructure. The community has underscored this >> with significant expressions of support for fewer v4 initiatives and >> more focus on transition." > > > To the drafter of this language, and to those who affirmed it. I was the primary author, the AC participated in its editing and then voted on it. > > To the AC as the unified body we have been told to consider it as. > > You have outstripped your mandate, again. Your reasoning and conclusions are > convoluted, arbitrary and fabricated, biased in support of your own > opinions, desires and agendas. > > You are ignoring the existence of THREE "specially designated class of v4 > addresses", current and pending, lobbied hard for by members AC. Not. I agree, the /10 for cable operators should have never been set aside so you can't really lump everyone into that fur ball. I wrote the carve out for CI and that's temporary. Because we are failing to transition, we still need to be able to move the traffic to the benefit of all. Compelling. The carve out you proposed is effectively an infrastructure subsidy that would only further drag transition. Not compelling. [ clip ] > You have arbitrarily decided that the community is not interested in "v4 > initiatives", unless of course, its a policy advanced by a member of the in > club - or a policy designed to deplete IPv4 quicker. > There was a table topic at the PHL meeting about this and it was unanimous that ARIN should not be working on v4 policy or as little as practical. I've also heard that consistently at the mic and on the list. I think that's right. [ clip ] Best, -M< From hannigan at gmail.com Thu Feb 23 09:06:43 2012 From: hannigan at gmail.com (Martin Hannigan) Date: Thu, 23 Feb 2012 09:06:43 -0500 Subject: [arin-ppml] Advisory Council Meeting Results - February 2012 In-Reply-To: References: <4F4571B6.90504@arin.net> <4F45C4D5.5090401@chl.com> Message-ID: On Thu, Feb 23, 2012 at 9:05 AM, Martin Hannigan wrote: > On Wed, Feb 22, 2012 at 11:47 PM, Joe Maimon wrote: >> >> >> ARIN wrote: >>> >>> >>> >>> Regarding proposal 163, the AC stated, "Based on a lack of significant >>> support or extenuating circumstances that would require the creation of >>> a specially designated class of v4 address space within the ARIN region, >>> the AC chose to abandon proposal 163. Without a compelling inequity >>> present, it's difficult to make a case for carve-outs of any kind other >>> than for critical infrastructure. The community has underscored this >>> with significant expressions of support for fewer v4 initiatives and >>> more focus on transition." >> >> >> To the drafter of this language, and to those who affirmed it. > > I was the primary author, the AC participated in its editing and then > voted on it. > Clarification, no vote, just AC participation for the text. The proposal itself was voted. Sorry for the confusion. Best, -M< From john.sweeting at twcable.com Thu Feb 23 09:13:58 2012 From: john.sweeting at twcable.com (Sweeting, John) Date: Thu, 23 Feb 2012 09:13:58 -0500 Subject: [arin-ppml] Advisory Council Meeting Results - February 2012 In-Reply-To: Message-ID: On 2/23/12 9:06 AM, "Martin Hannigan" wrote: >On Thu, Feb 23, 2012 at 9:05 AM, Martin Hannigan >wrote: >> On Wed, Feb 22, 2012 at 11:47 PM, Joe Maimon wrote: >>> >>> >>> ARIN wrote: >>>> >>>> >>>> >>>> Regarding proposal 163, the AC stated, "Based on a lack of significant >>>> support or extenuating circumstances that would require the creation >>>>of >>>> a specially designated class of v4 address space within the ARIN >>>>region, >>>> the AC chose to abandon proposal 163. Without a compelling inequity >>>> present, it's difficult to make a case for carve-outs of any kind >>>>other >>>> than for critical infrastructure. The community has underscored this >>>> with significant expressions of support for fewer v4 initiatives and >>>> more focus on transition." >>> >>> >>> To the drafter of this language, and to those who affirmed it. >> >> I was the primary author, the AC participated in its editing and then >> voted on it. >> > >Clarification, no vote, just AC participation for the text. The >proposal itself was voted. Sorry for the confusion. Joe, the minutes will be posted soon and you will be able to better understand the voting based on the shepherd's report. Thanks. > >Best, > >-M< >_______________________________________________ >PPML >You are receiving this message because you are subscribed to >the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >Unsubscribe or manage your mailing list subscription at: >http://lists.arin.net/mailman/listinfo/arin-ppml >Please contact info at arin.net if you experience any issues. This E-mail and any of its attachments may contain Time Warner Cable proprietary information, which is privileged, confidential, or subject to copyright belonging to Time Warner Cable. This E-mail is intended solely for the use of the individual or entity to which it is addressed. If you are not the intended recipient of this E-mail, you are hereby notified that any dissemination, distribution, copying, or action taken in relation to the contents of and attachments to this E-mail is strictly prohibited and may be unlawful. If you have received this E-mail in error, please notify the sender immediately and permanently delete the original and any copy of this E-mail and any printout. From john.sweeting at twcable.com Thu Feb 23 09:28:27 2012 From: john.sweeting at twcable.com (Sweeting, John) Date: Thu, 23 Feb 2012 09:28:27 -0500 Subject: [arin-ppml] Advisory Council Meeting Results - February 2012 In-Reply-To: Message-ID: On 2/23/12 9:05 AM, "Martin Hannigan" wrote: >On Wed, Feb 22, 2012 at 11:47 PM, Joe Maimon wrote: >> >> >> ARIN wrote: >>> >>> >>> >>> Regarding proposal 163, the AC stated, "Based on a lack of significant >>> support or extenuating circumstances that would require the creation of >>> a specially designated class of v4 address space within the ARIN >>>region, >>> the AC chose to abandon proposal 163. Without a compelling inequity >>> present, it's difficult to make a case for carve-outs of any kind other >>> than for critical infrastructure. The community has underscored this >>> with significant expressions of support for fewer v4 initiatives and >>> more focus on transition." >> >> >> To the drafter of this language, and to those who affirmed it. > >I was the primary author, the AC participated in its editing and then >voted on it. Just a point of clarification as the Chair of the AC: We normally ask the Primary Shepherd to draft the wording to explain why we take certain actions, since the Primary Shepherd is the one with the intimate knowledge of the proposal and normally is the one that recommends what actions we take. In this case as Marty has indicated he was the Primary Shepherd and had that responsibility. There were 2 AC members that voiced displeasure to me with the wording but in keeping with the openness the AC would like to maintain I allowed the wording suggested by Marty, with some tweaks from Chris Grundeman incorporated to be used. As the Chair I do have veto power over the wording but very seldom use it as I think it is important for the shepherd's to be able to make that communication to the community as well as the originator. Also we normally try to let the originator know ahead of the formal announcement but that is not always possible. > >> >> To the AC as the unified body we have been told to consider it as. >> >> You have outstripped your mandate, again. Your reasoning and >>conclusions are >> convoluted, arbitrary and fabricated, biased in support of your own >> opinions, desires and agendas. >> >> You are ignoring the existence of THREE "specially designated class of >>v4 >> addresses", current and pending, lobbied hard for by members AC. > >Not. I agree, the /10 for cable operators should have never been set >aside so you can't really lump everyone into that fur ball. I wrote >the carve out for CI and that's temporary. Because we are failing to >transition, we still need to be able to move the traffic to the >benefit of all. Compelling. The carve out you proposed is effectively >an infrastructure subsidy that would only further drag transition. Not >compelling. > > >[ clip ] > >> You have arbitrarily decided that the community is not interested in "v4 >> initiatives", unless of course, its a policy advanced by a member of >>the in >> club - or a policy designed to deplete IPv4 quicker. >> > >There was a table topic at the PHL meeting about this and it was >unanimous that ARIN should not be working on v4 policy or as little as >practical. I've also heard that consistently at the mic and on the >list. I think that's right. > >[ clip ] > > >Best, > >-M< >_______________________________________________ >PPML >You are receiving this message because you are subscribed to >the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >Unsubscribe or manage your mailing list subscription at: >http://lists.arin.net/mailman/listinfo/arin-ppml >Please contact info at arin.net if you experience any issues. This E-mail and any of its attachments may contain Time Warner Cable proprietary information, which is privileged, confidential, or subject to copyright belonging to Time Warner Cable. This E-mail is intended solely for the use of the individual or entity to which it is addressed. If you are not the intended recipient of this E-mail, you are hereby notified that any dissemination, distribution, copying, or action taken in relation to the contents of and attachments to this E-mail is strictly prohibited and may be unlawful. If you have received this E-mail in error, please notify the sender immediately and permanently delete the original and any copy of this E-mail and any printout. From owen at delong.com Thu Feb 23 09:31:19 2012 From: owen at delong.com (Owen DeLong) Date: Thu, 23 Feb 2012 06:31:19 -0800 Subject: [arin-ppml] Advisory Council Meeting Results - February 2012 In-Reply-To: References: <4F4571B6.90504@arin.net> <4F45C4D5.5090401@chl.com> Message-ID: <57E436EA-DE6E-4A20-B025-630155F8B685@delong.com> > Not. I agree, the /10 for cable operators should have never been set > aside so you can't really lump everyone into that fur ball. I wrote I presume by "the /10 for cable operators" you refer to the /10 for transitional technologies. I will note that while this effort was spearheaded by folks from Cable Labs, the Broadband forum is also behind it and so are many DSL and PON-based ISPs. I would say it is more of a carve-out for residential ISPs than a carve out for cable operators, but, even beyond residential ISPs there may well be application(s) for that space. Primarily it is a carve out of private address space to support an intermediate layer of NAT in a NAT444 environment, but, it can also be used for several other transition-related purposes. Owen From cja at daydream.com Thu Feb 23 10:18:31 2012 From: cja at daydream.com (CJ Aronson) Date: Thu, 23 Feb 2012 08:18:31 -0700 Subject: [arin-ppml] Petition for advancement of Policy Proposal #163 Dedicated resources for initial ISP allocations, to Draft Policy status In-Reply-To: <4F45E1FC.6070308@umn.edu> References: <4F45C4CE.2030302@chl.com> <4F45E1FC.6070308@umn.edu> Message-ID: I voted to put this proposal on the docket because I felt that it was worthy of discussion at the upcoming meeting in Vancouver. There was plenty of time to get it onto the agenda at the PPM and we (the AC) moved our March call up so that we could advance some proposals to the PPM within the appropriate amount of time. I do not participate in the petition process because although I may not always agree with the decisions that the AC makes that's all part of being on an elected body such as the AC. The AC vote was clearly in favor of abandoning this proposal and if the rest of the community feels otherwise than all it takes is for 10 of you to speak up. If you feel that there should be a block set aside such as in this proposal please speak up so that we can have a lively discussion at the upcoming ARIN meeting. Thanks ----Cathy On Wed, Feb 22, 2012 at 11:51 PM, David Farmer wrote: > I support the petition of this proposal to Draft Policy status for adoption > discussion at the Vancouver Public Policy Meeting. > > While I support the policy proposal and this petition, as an AC Member I did > vote to Abandon this proposal, precisely to allow the community to petition > to get this policy proposal to the Vancouver meeting. ?I believe even if the > AC had accepted this proposal on its docket that it would not likely have > made it to the Vancouver meeting anyway. ?The AC is running up on the > deadlines for the Vancouver meeting and there were other proposals with > clearly more community support that required the limited resources that the > AC had available before the deadline. > > If you support this issue please join in support of this petition. ?I also > encourage the author and the community to work on the text of this proposal > prior to to text freeze before the meeting. > > > On 2/22/12 22:47 CST, Joe Maimon wrote: >> >> All, >> >> I am unsatisfied with the AC's abandonment of Policy Proposal #163 >> Dedicated resources for initial ISP allocations. >> >> I formally petition you, the members of this regional community, for >> your support in advancing to draft policy status the proposal and for it >> to be discussed at an upcoming ARIN Public Policy meeting. >> >> I ask you for statements in support of this petition. >> >> The full policy proposal text is available at >> >> http://lists.arin.net/pipermail/arin-ppml/2012-February/024054.html >> >> Best and my thanks, >> >> Joe >> >> >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. > > > -- > =============================================== > David Farmer ? ? ? ? ? ? ? Email:farmer at umn.edu > Networking & Telecommunication Services > Office of Information Technology > University of Minnesota > 2218 University Ave SE ? ? ?Phone: 612-626-0815 > Minneapolis, MN 55414-3029 ? Cell: 612-812-9952 > =============================================== > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From hannigan at gmail.com Thu Feb 23 10:35:02 2012 From: hannigan at gmail.com (Martin Hannigan) Date: Thu, 23 Feb 2012 10:35:02 -0500 Subject: [arin-ppml] Advisory Council Meeting Results - February 2012 In-Reply-To: References: Message-ID: On Thu, Feb 23, 2012 at 9:28 AM, Sweeting, John wrote: > > > On 2/23/12 9:05 AM, "Martin Hannigan" wrote: > >>On Wed, Feb 22, 2012 at 11:47 PM, Joe Maimon wrote: >>> >>> >>> ARIN wrote: >>>> >>>> >>>> >>>> Regarding proposal 163, the AC stated, "Based on a lack of significant >>>> support or extenuating circumstances that would require the creation of >>>> a specially designated class of v4 address space within the ARIN >>>>region, >>>> the AC chose to abandon proposal 163. Without a compelling inequity >>>> present, it's difficult to make a case for carve-outs of any kind other >>>> than for critical infrastructure. The community has underscored this >>>> with significant expressions of support for fewer v4 initiatives and >>>> more focus on transition." >>> >>> >>> To the drafter of this language, and to those who affirmed it. >> >>I was the primary author, the AC participated in its editing and then >>voted on it. > > > Just a point of clarification as the Chair of the AC: We normally ask the > Primary Shepherd to draft the wording to explain why we take certain > actions, since the Primary Shepherd is the one with the intimate knowledge > of the proposal and normally is the one that recommends what actions we That "intimate knowledge" is then extolled upon the entire AC during it's call. There are opportunities for the AC to ask questions and make comments as is demonstrated in the pending post of the AC minutes. > take. In this case as Marty has indicated he was the Primary Shepherd and > had that responsibility. There were 2 AC members that voiced displeasure > to me with the wording but in keeping with the openness the AC would like > to maintain I allowed the wording suggested by Marty, Who were the two AC members who opted to raise a concern with wording of the AC's public statement? Why didn't you make that statement to the AC om their behalf if they weren't willing to do it themselves? [ clip ] > As the Chair I do have veto > power over the wording but very seldom use it as I think it is important > for the shepherd's to be able to make that communication to the community > as well as the originator. Also we normally try to let the originator know > ahead of the formal announcement but that is not always possible. John, are you licensed to drive that bus? :-) Best, -M< From john.sweeting at twcable.com Thu Feb 23 11:17:50 2012 From: john.sweeting at twcable.com (Sweeting, John) Date: Thu, 23 Feb 2012 11:17:50 -0500 Subject: [arin-ppml] Advisory Council Meeting Results - February 2012 In-Reply-To: Message-ID: On 2/23/12 10:35 AM, "Martin Hannigan" wrote: >On Thu, Feb 23, 2012 at 9:28 AM, Sweeting, John > wrote: >> >> >> On 2/23/12 9:05 AM, "Martin Hannigan" wrote: >> >>>On Wed, Feb 22, 2012 at 11:47 PM, Joe Maimon wrote: >>>> >>>> >>>> ARIN wrote: >>>>> >>>>> >>>>> >>>>> Regarding proposal 163, the AC stated, "Based on a lack of >>>>>significant >>>>> support or extenuating circumstances that would require the creation >>>>>of >>>>> a specially designated class of v4 address space within the ARIN >>>>>region, >>>>> the AC chose to abandon proposal 163. Without a compelling inequity >>>>> present, it's difficult to make a case for carve-outs of any kind >>>>>other >>>>> than for critical infrastructure. The community has underscored this >>>>> with significant expressions of support for fewer v4 initiatives and >>>>> more focus on transition." >>>> >>>> >>>> To the drafter of this language, and to those who affirmed it. >>> >>>I was the primary author, the AC participated in its editing and then >>>voted on it. >> >> >> Just a point of clarification as the Chair of the AC: We normally ask >>the >> Primary Shepherd to draft the wording to explain why we take certain >> actions, since the Primary Shepherd is the one with the intimate >>knowledge >> of the proposal and normally is the one that recommends what actions we > >That "intimate knowledge" is then extolled upon the entire AC during >it's call. There are opportunities for the AC to ask questions and >make comments as is demonstrated in the pending post of the AC >minutes. To some extent that is true but normally that information is shared via email prior to the call and is also discussed at length with the Secondary Shepherd to ensure that the right information is shared and that the motion made is agreed on by the shepherds. The AC puts faith into the 2 assigned shepherds doing their part in evaluating and reporting on their assigned proposals/draft policies. This process is discussed at length during the AC annual workshop. > >> take. In this case as Marty has indicated he was the Primary Shepherd >>and >> had that responsibility. There were 2 AC members that voiced displeasure >> to me with the wording but in keeping with the openness the AC would >>like >> to maintain I allowed the wording suggested by Marty, > >Who were the two AC members who opted to raise a concern with wording >of the AC's public statement? Why didn't you make that statement to >the AC om their behalf if they weren't willing to do it themselves? I will leave that up to them if they care to share. > > >[ clip ] > > >> As the Chair I do have veto >> power over the wording but very seldom use it as I think it is important >> for the shepherd's to be able to make that communication to the >>community >> as well as the originator. Also we normally try to let the originator >>know >> ahead of the formal announcement but that is not always possible. > >John, are you licensed to drive that bus? :-) Marty, you have to show up for the annual workshop to get the answer to that question! ;-) > > >Best, > >-M< This E-mail and any of its attachments may contain Time Warner Cable proprietary information, which is privileged, confidential, or subject to copyright belonging to Time Warner Cable. This E-mail is intended solely for the use of the individual or entity to which it is addressed. If you are not the intended recipient of this E-mail, you are hereby notified that any dissemination, distribution, copying, or action taken in relation to the contents of and attachments to this E-mail is strictly prohibited and may be unlawful. If you have received this E-mail in error, please notify the sender immediately and permanently delete the original and any copy of this E-mail and any printout. From hannigan at gmail.com Thu Feb 23 11:29:12 2012 From: hannigan at gmail.com (Martin Hannigan) Date: Thu, 23 Feb 2012 11:29:12 -0500 Subject: [arin-ppml] Advisory Council Meeting Results - February 2012 In-Reply-To: References: Message-ID: On Thu, Feb 23, 2012 at 11:17 AM, Sweeting, John wrote: > > > On 2/23/12 10:35 AM, "Martin Hannigan" wrote: > >>On Thu, Feb 23, 2012 at 9:28 AM, Sweeting, John >> wrote: >>> >>> >>> On 2/23/12 9:05 AM, "Martin Hannigan" wrote: >>> >>>>On Wed, Feb 22, 2012 at 11:47 PM, Joe Maimon wrote: >>>>> >>>>> >>>>> ARIN wrote: >>>>>> >>>>>> >>>>>> >>>>>> Regarding proposal 163, the AC stated, "Based on a lack of >>>>>>significant >>>>>> support or extenuating circumstances that would require the creation >>>>>>of >>>>>> a specially designated class of v4 address space within the ARIN >>>>>>region, >>>>>> the AC chose to abandon proposal 163. Without a compelling inequity >>>>>> present, it's difficult to make a case for carve-outs of any kind >>>>>>other >>>>>> than for critical infrastructure. The community has underscored this >>>>>> with significant expressions of support for fewer v4 initiatives and >>>>>> more focus on transition." >>>>> >>>>> >>>>> To the drafter of this language, and to those who affirmed it. >>>> >>>>I was the primary author, the AC participated in its editing and then >>>>voted on it. >>> >>> >>> Just a point of clarification as the Chair of the AC: We normally ask >>>the >>> Primary Shepherd to draft the wording to explain why we take certain >>> actions, since the Primary Shepherd is the one with the intimate >>>knowledge >>> of the proposal and normally is the one that recommends what actions we >> >>That "intimate knowledge" is then extolled upon the entire AC during >>it's call. There are opportunities for the AC to ask questions and >>make comments as is demonstrated in the pending post of the AC >>minutes. > > To some extent that is true but normally that information is shared via It's entirely true. > email prior to the call and is also discussed at length with the Secondary > Shepherd to ensure that the right information is shared and that the > motion made is agreed on by the shepherds. The AC puts faith into the 2 Inaccurate. See below. > assigned shepherds doing their part in evaluating and reporting on their > assigned proposals/draft policies. This process is discussed at length > during the AC annual workshop. I've reviewed the AC email archives to try and find supporting data points for your statement. I'm not able to find anything conclusive except that all shepherds do it differently and there is no standard. [ clip ] >>Who were the two AC members who opted to raise a concern with wording >>of the AC's public statement? Why didn't you make that statement to >>the AC om their behalf if they weren't willing to do it themselves? > > > I will leave that up to them if they care to share. Do you care to answer why you did not then act on their behalf? >>[ clip ] >> >> >>> As the Chair I do have veto >>> power over the wording but very seldom use it as I think it is important >>> for the shepherd's to be able to make that communication to the >>>community >>> as well as the originator. Also we normally try to let the originator >>>know >>> ahead of the formal announcement but that is not always possible. >> >>John, are you licensed to drive that bus? :-) > > Marty, you have to show up for the annual workshop to get the answer to > that question! ;-) [which, I did attend via telecon for almost the entire session ] I didn't happen to hear any mention of your bus license. That might explain why the wheels are falling off. Best, -M< From john.sweeting at twcable.com Thu Feb 23 11:43:46 2012 From: john.sweeting at twcable.com (Sweeting, John) Date: Thu, 23 Feb 2012 11:43:46 -0500 Subject: [arin-ppml] Advisory Council Meeting Results - February 2012 In-Reply-To: Message-ID: My apologies to the PPML list for this OT thread. If anyone would like answers to the questions below then please reach out to me individually. On 2/23/12 11:29 AM, "Martin Hannigan" wrote: >On Thu, Feb 23, 2012 at 11:17 AM, Sweeting, John > wrote: >> >> >> On 2/23/12 10:35 AM, "Martin Hannigan" wrote: >> >>>On Thu, Feb 23, 2012 at 9:28 AM, Sweeting, John >>> wrote: >>>> >>>> >>>> On 2/23/12 9:05 AM, "Martin Hannigan" wrote: >>>> >>>>>On Wed, Feb 22, 2012 at 11:47 PM, Joe Maimon wrote: >>>>>> >>>>>> >>>>>> ARIN wrote: >>>>>>> >>>>>>> >>>>>>> >>>>>>> Regarding proposal 163, the AC stated, "Based on a lack of >>>>>>>significant >>>>>>> support or extenuating circumstances that would require the >>>>>>>creation >>>>>>>of >>>>>>> a specially designated class of v4 address space within the ARIN >>>>>>>region, >>>>>>> the AC chose to abandon proposal 163. Without a compelling inequity >>>>>>> present, it's difficult to make a case for carve-outs of any kind >>>>>>>other >>>>>>> than for critical infrastructure. The community has underscored >>>>>>>this >>>>>>> with significant expressions of support for fewer v4 initiatives >>>>>>>and >>>>>>> more focus on transition." >>>>>> >>>>>> >>>>>> To the drafter of this language, and to those who affirmed it. >>>>> >>>>>I was the primary author, the AC participated in its editing and then >>>>>voted on it. >>>> >>>> >>>> Just a point of clarification as the Chair of the AC: We normally ask >>>>the >>>> Primary Shepherd to draft the wording to explain why we take certain >>>> actions, since the Primary Shepherd is the one with the intimate >>>>knowledge >>>> of the proposal and normally is the one that recommends what actions >>>>we >>> >>>That "intimate knowledge" is then extolled upon the entire AC during >>>it's call. There are opportunities for the AC to ask questions and >>>make comments as is demonstrated in the pending post of the AC >>>minutes. >> >> To some extent that is true but normally that information is shared via > >It's entirely true. > >> email prior to the call and is also discussed at length with the >>Secondary >> Shepherd to ensure that the right information is shared and that the >> motion made is agreed on by the shepherds. The AC puts faith into the 2 > >Inaccurate. See below. > >> assigned shepherds doing their part in evaluating and reporting on their >> assigned proposals/draft policies. This process is discussed at length >> during the AC annual workshop. > >I've reviewed the AC email archives to try and find supporting data >points for your statement. I'm not able to find anything conclusive >except that all shepherds do it differently and there is no standard. > > >[ clip ] > >>>Who were the two AC members who opted to raise a concern with wording >>>of the AC's public statement? Why didn't you make that statement to >>>the AC om their behalf if they weren't willing to do it themselves? >> >> >> I will leave that up to them if they care to share. > >Do you care to answer why you did not then act on their behalf? > > >>>[ clip ] >>> >>> >>>> As the Chair I do have veto >>>> power over the wording but very seldom use it as I think it is >>>>important >>>> for the shepherd's to be able to make that communication to the >>>>community >>>> as well as the originator. Also we normally try to let the originator >>>>know >>>> ahead of the formal announcement but that is not always possible. >>> >>>John, are you licensed to drive that bus? :-) >> >> Marty, you have to show up for the annual workshop to get the answer to >> that question! ;-) > >[which, I did attend via telecon for almost the entire session ] > >I didn't happen to hear any mention of your bus license. That might >explain why the wheels are falling off. > >Best, > >-M< This E-mail and any of its attachments may contain Time Warner Cable proprietary information, which is privileged, confidential, or subject to copyright belonging to Time Warner Cable. This E-mail is intended solely for the use of the individual or entity to which it is addressed. If you are not the intended recipient of this E-mail, you are hereby notified that any dissemination, distribution, copying, or action taken in relation to the contents of and attachments to this E-mail is strictly prohibited and may be unlawful. If you have received this E-mail in error, please notify the sender immediately and permanently delete the original and any copy of this E-mail and any printout. From farmer at umn.edu Thu Feb 23 11:53:46 2012 From: farmer at umn.edu (David Farmer) Date: Thu, 23 Feb 2012 10:53:46 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <20120217141703.a9ea43ae5a3fe419ce3b8d7ea1f8bec0.fe5cdb252e.wbe@email17.secureserver.net> <716B4FC5-ED6C-485D-82CB-55973C8EB55B@delong.com> Message-ID: <4F466F1A.1080703@umn.edu> On 2/19/12 23:09 CST, Astrodog wrote: > On Sun, Feb 19, 2012 at 5:58 PM, Owen DeLong wrote: >> >> Yes, that's exactly how it works. I agree that an expiration on STLS entries would be a good thing. >> >> The re-qual. is an important safeguard as far as I am concerned. It discourages partial fills and excessive fragmentation due to multiple partial fills. >> >> Glad to hear that STLS mostly addresses your concern. Hopefully that means we can abandon 165 soon. >> > > STLS certainly smoothes things over for sellers. I do agree that > fragmentation is undesirable, but if the suggestion here is that > transfers are all need based, the quantity of space an entity needs > does not decrease simply because a partially filled transaction > occurred. If one *needs* a /18, and instead gets a /19, the remaining > /19 is still "needed". > > If the intent of the community is to drive transfers based on need, > then an approval for an /18 is also an approval for 2 /19s, 4 /20s, > etc. If an organization is approved for an /18, and gets a /19 > instead... and is subsequently denied for another /19, then it sounds > like the original approval for an /18 was incorrect. The single block requirement has been removed, so it is possible to fulfill a /18 demand with 2 /19s or 4 /20s from a single seller in a single transfer transaction. There is still an issue with multiple transactions from different sellers that I believe would require a new justification, between each transaction. This is mostly to be consistent with the unmet request/waiting list provisions of sections 4.1.8. I believe the idea is you can simultaneously be put on to the waiting list and STLS once the free pool is exhausted. if STLS were completely independent then allowing multiple transfers until your need was fulfilled would probably work, and probably work better than the current process. But allow you to sit on the free-pool waiting list until your need is completely fulfilled doesn't seem fair. So once you accept an allocation, either by executing a transfer or from the free-pool, probably usually smaller than your need, then you are dropped from the waiting list and you need to re-justify and go to the back of the line for free-pool waiting list. I suppose we could have done it all differently, but transfers will not be the exclusive source of addresses, there are and will be some, probably small, amounts of address space returned or otherwise reclaimed even after free-pool exhaustion, and we need a system to allow fair distribution of this returned/reclaimed address space too. And I think a linkage between the waiting list and transfers is necessary, I don't think it is fair to keep your place on the waiting list if you also executed a transfer. Maybe there is a different way to handle this, but there are a number of different parts than need to fit together and some times you can't individually optimize all of the pieces, and still have them fit together. My personal recommendation to those interested in eliminating need-based justification, is that you change your tactics and not attack the concept of need-based justification, but look at ways to redefine the processes and evaluation criteria for need. Note that there has always been a needs basis for assignment or allocation of number resources, that is being that you need them to build operational networks and that is why an organization receives them. However, around the time of the creation of the RIR system the current processes and criteria for the evaluation of need based on slow-start and your historical allocations were created and were a significant change from the then current processes and criteria. I believe it should be possible to create a new regime that ensures that there is operational need for the assignment of resources that is more market friendly than the current slow-start with historical allocations as the criteria to ensure operational need. Also note that I believe the current process and criteria have a dependency on a unrestricted free-pool in order to accurately determine an organizations actual need over time. And as the free-pool is exhausted, this process will no longer accurately determine an organization's actual need but skew toward measuring an organizations ability to pay for resources, year over year, rather than an abstract measure of need. Therefore, I think it will be necessary to find a more market compatible processes and criteria for ensuring that an organization has operational need. That said, I don't see the idea of completely throwing out the concept of needs basis finding consensus within the community. However, a radical redefinition of the processes and criteria for the evaluation of need may be possible, if it respects and protects the concept that operational need is a necessary component of making an assignment or allocation. Early in the discussion of this proposal I asked about the author's intent regarding the "Officer Attestation" and if that was intended to be attesting to operational need by the organization. While I'm not sure this is sufficient protection, I think this is the kind of creative redefinition of the processes and criteria for the evaluation of operational need that we should be discussing and I encourage those that support loosening the policy constraints on the market to move the discussion toward these kinds of solutions. Thanks -- =============================================== David Farmer Email:farmer at umn.edu Networking & Telecommunication Services Office of Information Technology University of Minnesota 2218 University Ave SE Phone: 612-626-0815 Minneapolis, MN 55414-3029 Cell: 612-812-9952 =============================================== From farmer at umn.edu Thu Feb 23 12:08:33 2012 From: farmer at umn.edu (David Farmer) Date: Thu, 23 Feb 2012 11:08:33 -0600 Subject: [arin-ppml] Prop-151: Clarifying requirements for IPv4 transfers (was "Limiting needs...") In-Reply-To: References: Message-ID: <4F467291.8080500@umn.edu> I just had a though; While I doubt this would happen that much, I'm not sure it is in the communities interest to prevent such a scenario either. So, would this language prevent an organizations from swapping address space to prevent the fragmentation and disaggregation of a larger block. In other words, an organization has a /16 and only needs a /20 could the receive the transfer of a /20 and then transfer the whole /16. In this case the organizations desire to maximize it financial return by transferring a larger block also facilitates the communities desire to reduce fragmentation and increase aggregation. And this scenario would require transfers in multiple directions that I think the language being discussed is intended to prevent. On 2/21/12 18:01 CST, Chris Grundemann wrote: > On Tue, Feb 21, 2012 at 16:28, Alexander, Daniel > wrote: >> >> The intent of the condition is to limit ARIN's free pool from being a >> source of revenue. One should not be able to double dip by profiting on >> the transfer of resources while they are obtaining resources from ARIN, >> essentially for free. It is not intended to prevent the flipping of any >> particular resource. > > Thanks for the clarification. I still choose to place profiting from > the improper acquisition of ARIN managed resources in a single bucket > however. I believe that ARIN should act as steward for all number > resources within the region, not just those that have not been > previously handed out. > >> If we want to prevent flipping it should be a separate condition, but my >> thought was to leave that to the RSA and recipient review. > > If the RSA and recipient review can control "flipping" why can they > not prevent "profiting"? > > Cheers, > ~Chris > >> -Dan -- =============================================== David Farmer Email:farmer at umn.edu Networking & Telecommunication Services Office of Information Technology University of Minnesota 2218 University Ave SE Phone: 612-626-0815 Minneapolis, MN 55414-3029 Cell: 612-812-9952 =============================================== From owen at delong.com Thu Feb 23 14:33:26 2012 From: owen at delong.com (Owen DeLong) Date: Thu, 23 Feb 2012 13:33:26 -0600 Subject: [arin-ppml] Prop-151: Clarifying requirements for IPv4 transfers (was "Limiting needs...") In-Reply-To: <4F467291.8080500@umn.edu> References: <4F467291.8080500@umn.edu> Message-ID: <01DD963D-3CEF-4E72-83A3-9DDDFF00ADC8@delong.com> I would not oppose addressing this corner case with language to the effect of "ARIN staff may make exceptions to these limits in cases where they determine that the combined transfers are in the community interest." Owen Sent from my iPhone On Feb 23, 2012, at 11:08, David Farmer wrote: > I just had a though; While I doubt this would happen that much, I'm not sure it is in the communities interest to prevent such a scenario either. > > So, would this language prevent an organizations from swapping address space to prevent the fragmentation and disaggregation of a larger block. > > In other words, an organization has a /16 and only needs a /20 could the receive the transfer of a /20 and then transfer the whole /16. In this case the organizations desire to maximize it financial return by transferring a larger block also facilitates the communities desire to reduce fragmentation and increase aggregation. > > And this scenario would require transfers in multiple directions that I think the language being discussed is intended to prevent. > > On 2/21/12 18:01 CST, Chris Grundemann wrote: >> On Tue, Feb 21, 2012 at 16:28, Alexander, Daniel >> wrote: >>> >>> The intent of the condition is to limit ARIN's free pool from being a >>> source of revenue. One should not be able to double dip by profiting on >>> the transfer of resources while they are obtaining resources from ARIN, >>> essentially for free. It is not intended to prevent the flipping of any >>> particular resource. >> >> Thanks for the clarification. I still choose to place profiting from >> the improper acquisition of ARIN managed resources in a single bucket >> however. I believe that ARIN should act as steward for all number >> resources within the region, not just those that have not been >> previously handed out. >> >>> If we want to prevent flipping it should be a separate condition, but my >>> thought was to leave that to the RSA and recipient review. >> >> If the RSA and recipient review can control "flipping" why can they >> not prevent "profiting"? >> >> Cheers, >> ~Chris >> >>> -Dan > > > -- > =============================================== > David Farmer Email:farmer at umn.edu > Networking & Telecommunication Services > Office of Information Technology > University of Minnesota > 2218 University Ave SE Phone: 612-626-0815 > Minneapolis, MN 55414-3029 Cell: 612-812-9952 > =============================================== > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From info at arin.net Thu Feb 23 16:13:28 2012 From: info at arin.net (ARIN) Date: Thu, 23 Feb 2012 16:13:28 -0500 Subject: [arin-ppml] Petition for Discussion of ARIN-prop-164 In-Reply-To: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> Message-ID: <4F46ABF8.80206@arin.net> The message below started a petition regarding the ARIN Advisory Council's decision to abandon ARIN-prop-164. The AC's decision was posted by ARIN staff to PPML on 22 February 2012. If successful, this petition will change ARIN-prop-164 into a Draft Policy which will be published for adoption discussion on the PPML and at the Public Policy Meeting in April 2012. If the petition fails, the proposal will be closed. For this petition to be successful, the petition needs statements of support from at least 10 different people from 10 different organizations. If you wish to support this petition, post a statement of support to PPML on this thread. The duration of the petition is until five business days after the AC's draft meeting minutes are published. ARIN staff will post the result of the petition to PPML. For more information on starting and participating in petitions, see PDP Petitions at: https://www.arin.net/policy/pdp_petitions.html The proposal text is below and at: https://www.arin.net/policy/proposals/index.html The ARIN Policy Development Process can be found at: https://www.arin.net/policy/pdp.html Regards, Communications and Member Services American Registry for Internet Numbers (ARIN) ##### > -----Original Message----- > From: Joe Maimon > Date: Wed, 22 Feb 2012 23:47:12 -0500 > To: "ppml >> \"ppml at arin.net\"" > Subject: [arin-ppml] Petition for advancement of Policy Proposal #164 Predictable ARIN IPv4 Resource exhaustion, to Draft Policy status > > All, > > I am unsatisfied with the AC's abandonment of Policy Proposal #164 > Predictable ARIN IPv4 Resource exhaustion. > > I formally petition you, the members of this regional community, for > your support in advancing to draft policy status the proposal and for it > to be discussed at an upcoming ARIN Public Policy meeting. > > I ask you for statements in support of this petition. > > The full policy proposal text is available at > > http://lists.arin.net/pipermail/arin-ppml/2012-February/024055.html > > Best and my thanks, > > Joe > > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion Proposal Originator: Joe Maimon Proposal Version: 1.0 Date: 1 February 2012 Proposal type: New Policy term: Temporary Policy statement: Add a section to 4 Upon the last calendar date of the year that this proposal is adopted, ARIN will disburse all of its available IPv4 resources to its existing members, in proportion to their fee schedule, with the smallest allocation of size /24, to be effective immediately. Rationale: Many people feel that ARIN has too much available resources. Many people also believe that the uncertainty as to when ARIN will run out of these resources is not good. This proposal seeks to resolve both of these concerns. Timetable for implementation: Immediate From info at arin.net Thu Feb 23 16:15:35 2012 From: info at arin.net (ARIN) Date: Thu, 23 Feb 2012 16:15:35 -0500 Subject: [arin-ppml] Petition for Discussion of ARIN-prop-163 In-Reply-To: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> Message-ID: <4F46AC77.8060206@arin.net> The message below started a petition regarding the ARIN Advisory Council's decision to abandon ARIN-prop-163. The AC's decision was posted by ARIN staff to PPML on 22 February 2012. If successful, this petition will change ARIN-prop-163 into a Draft Policy which will be published for adoption discussion on the PPML and at the Public Policy Meeting in April 2012. If the petition fails, the proposal will be closed. For this petition to be successful, the petition needs statements of support from at least 10 different people from 10 different organizations. If you wish to support this petition, post a statement of support to PPML on this thread. The duration of the petition is until five business days after the AC's draft meeting minutes are published. ARIN staff will post the result of the petition to PPML. For more information on starting and participating in petitions, see PDP Petitions at: https://www.arin.net/policy/pdp_petitions.html The proposal text is below and at: https://www.arin.net/policy/proposals/index.html The ARIN Policy Development Process can be found at: https://www.arin.net/policy/pdp.html Regards, Communications and Member Services American Registry for Internet Numbers (ARIN) ##### > -----Original Message----- > From: Joe Maimon > Date: Wed, 22 Feb 2012 23:47:10 -0500 > To: "ppml >> \"ppml at arin.net\"" > Subject: [arin-ppml] Petition for advancement of Policy Proposal #163 Dedicated resources for initial ISP allocations, to Draft Policy status > > All, > > I am unsatisfied with the AC's abandonment of Policy Proposal #163 > Dedicated resources for initial ISP allocations. > > I formally petition you, the members of this regional community, for > your support in advancing to draft policy status the proposal and for it > to be discussed at an upcoming ARIN Public Policy meeting. > > I ask you for statements in support of this petition. > > The full policy proposal text is available at > > http://lists.arin.net/pipermail/arin-ppml/2012-February/024054.html > > Best and my thanks, > > Joe > > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. ARIN-prop-163 Dedicated resources for initial ISP allocations Proposal Originator: Joe Maimon Proposal Version: 1.0 Date: 1 February 2012 Proposal type: New Policy term: Temporary Policy statement: Add 4.2.2.4. Resources dedicated for initial ISP allocations. Prior to any allocation or assignment that will cause ARIN's total available, unreserved and non-dedicated resources to fall under a total of a /8, ARIN will first ensure that dedicated resources equivalent to a /10 are available from the remainder of the available resources. These resources are to be used solely for initial ISP allocations that cannot be fulfilled from any other available ARIN resources. 4.2.2.4.1 Restrictions ARIN may require qualifying organizations to demonstrate that they were not created solely to receive resources from these dedicated resources. 4.2.2.4.2 Replenishment ARIN will replenish the available dedicated resources, up to the total of a /10 of available resources, whenever there are sufficient available resources, with no more than 25% of the available resources going for this purpose. 4.2.2.4.3 Reporting ARIN will keep numbers and statistics available as to the total size of the dedicated resources, allocated and unallocated and to how many members allocations were made, available annually. 4.2.2.4.4 Retirement ARIN will retire this section whenever two full calendar years go by that no allocations are made from these resources, following their creation. Rationale: I believe it is important to ensure access to new entities to the IPv4 resources ARIN maintains stewardship over. Without a policy like this one, they are unlikely to have any alternative other then to use PA space or utilize transfers that may be prohibitively burdensome. I also believe it is important to ARIN to be an essential and relevant entity to the process of getting these new ISP's to their footing with IPv4 resources. ARIN informal numbers: Total first time IPv4 allocations to ISPs approved in 2011: 318 Total IPv4 space approved for: 2,812 /24s Total additional IPv4 allocations to ISPs in 2011: 497 ISP accounts received at least one additional IPv4 allocation. Total IPv4 space approved for: 70,569 /24s This suggests that maintaining resources for these new ISPs can ensure a steady influx of new members who would otherwise have much more limited options, and that a /10 can provide an estimated 4 years of access to these resources. This same /10 would last for additional allocations less than a year. Timetable for implementation: Before ARIN has less than a /8 in its free pool. From mueller at syr.edu Thu Feb 23 16:47:41 2012 From: mueller at syr.edu (Milton L Mueller) Date: Thu, 23 Feb 2012 21:47:41 +0000 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: <34AB7AED-D12B-437D-A61F-114E15BD717D@delong.com> References: <34F9FF28526C094697742849BAB2E8D403AB87D3EE@EXCHANGE7.shentel.com> <855077AC3D7A7147A7570370CA01ECD20A1CCC@SUEX10-mbx-10.ad.syr.edu> <34AB7AED-D12B-437D-A61F-114E15BD717D@delong.com> Message-ID: <855077AC3D7A7147A7570370CA01ECD20A3CD8@SUEX10-mbx-10.ad.syr.edu> Vixie: > vigorous reassertion is not considered proof in this forum. De Long: > 2. Legacy blocks are not transferable in the ARIN registry without > compliance with ARIN policy. [Milton L Mueller] Where is Vixie when we need him? From jcurran at arin.net Thu Feb 23 16:59:35 2012 From: jcurran at arin.net (John Curran) Date: Thu, 23 Feb 2012 21:59:35 +0000 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification References: Message-ID: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> Milton - Is there an fairly straightforward economic explanation that addresses the questions that John Sweeting raised? If so, could you outline it? Thanks! /John John Curran President and CEO ARIN Begin forwarded message: From: "Sweeting, John" > Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification Date: February 17, 2012 12:55:52 PM EST To: Milton L Mueller >, 'Paul Vixie' >, "jeffmehlenbacher at ipv4marketgroup.com" > Cc: "arin-ppml at arin.net" > Hi Milton, A few questions since I am not an expert in markets. Do you think there is a scenario where the largest and wealthiest of the world's ISP's would buy up as much address space as they could just to keep it out of the hands of their competitors? Or new start ups in their markets? There are some very wealthy companies out there that would not blink an eye at spending the money needed to run their competitors out of the market but maybe that is not possible in this particular market. Is there a way that a small but well of portion of the market could insure prices are so high that the number of competitors would be capped or even reduced? As I said I am not an expert on markets so would very much welcome your views on this. Thanks, John ... -------------- next part -------------- An HTML attachment was scrubbed... URL: From cgrundemann at gmail.com Thu Feb 23 17:04:33 2012 From: cgrundemann at gmail.com (Chris Grundemann) Date: Thu, 23 Feb 2012 15:04:33 -0700 Subject: [arin-ppml] Advisory Council Meeting Results - February 2012 In-Reply-To: <4F45C4D5.5090401@chl.com> References: <4F4571B6.90504@arin.net> <4F45C4D5.5090401@chl.com> Message-ID: On Wed, Feb 22, 2012 at 21:47, Joe Maimon wrote: >> And regarding proposal 164, the AC said, "Due to a lack of support and >> strong opposition among the community on PPML, the AC abandoned proposal >> 164." > > Yes there was lack of stated support. However there can still be interest in > wider discussion. Which is part of the AC's job to determine. Seven people posted to PPML regarding this proposal. Six of them stated flat opposition. The other one was you. I did not see anything that indicated an "interest in wider discussion." Perhaps I missed something? Cheers, ~Chris > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. -- @ChrisGrundemann http://chrisgrundemann.com From jmaimon at chl.com Thu Feb 23 17:54:51 2012 From: jmaimon at chl.com (Joe Maimon) Date: Thu, 23 Feb 2012 17:54:51 -0500 Subject: [arin-ppml] Advisory Council Meeting Results - February 2012 In-Reply-To: References: <4F4571B6.90504@arin.net> <4F45C4D5.5090401@chl.com> Message-ID: <4F46C3BB.6060602@chl.com> Chris, The list traffic pattern being what it is, any policy that generates feedback has something going for it already. Thanks for your response. Best, Joe Chris Grundemann wrote: > On Wed, Feb 22, 2012 at 21:47, Joe Maimon wrote: > >>> And regarding proposal 164, the AC said, "Due to a lack of support and >>> strong opposition among the community on PPML, the AC abandoned proposal >>> 164." >> Yes there was lack of stated support. However there can still be interest in >> wider discussion. Which is part of the AC's job to determine. > Seven people posted to PPML regarding this proposal. Six of them > stated flat opposition. The other one was you. I did not see anything > that indicated an "interest in wider discussion." Perhaps I missed > something? > > Cheers, > ~Chris > >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. From owen at delong.com Thu Feb 23 19:43:46 2012 From: owen at delong.com (Owen DeLong) Date: Thu, 23 Feb 2012 16:43:46 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers In-Reply-To: <855077AC3D7A7147A7570370CA01ECD20A3CD8@SUEX10-mbx-10.ad.syr.edu> References: <34F9FF28526C094697742849BAB2E8D403AB87D3EE@EXCHANGE7.shentel.com> <855077AC3D7A7147A7570370CA01ECD20A1CCC@SUEX10-mbx-10.ad.syr.edu> <34AB7AED-D12B-437D-A61F-114E15BD717D@delong.com> <855077AC3D7A7147A7570370CA01ECD20A3CD8@SUEX10-mbx-10.ad.syr.edu> Message-ID: <655A6BA0-3CDC-47A6-BC5A-BC991D435A61@delong.com> On Feb 23, 2012, at 1:47 PM, Milton L Mueller wrote: > Vixie: >> vigorous reassertion is not considered proof in this forum. > > De Long: > >> 2. Legacy blocks are not transferable in the ARIN registry without >> compliance with ARIN policy. > > [Milton L Mueller] Where is Vixie when we need him? > > First, Milton, the name is DeLong, not De Long. Second, can you cite a single instance, event, or occurrence which contradicts my statement? Note that I specifically limited the scope to transfers recorded in the ARIN registry. Alleged transfers not involving the ARIN registry are out of scope of the discussion and YMMV whether such transfers actually have the intended effect or not. To the best of my knowledge, ARIN will not record a transfer that does not comply with ARIN policy. The CEO has stated such on this list many times. If you know of circumstances where ARIN staff has performed a transfer in contradiction to ARIN policy, I would certainly like to know about it and ask Mr. Curran to explain the situation. Owen From tvest at eyeconomics.com Thu Feb 23 20:31:09 2012 From: tvest at eyeconomics.com (Tom Vest) Date: Thu, 23 Feb 2012 20:31:09 -0500 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> Message-ID: Consider how other de facto non-duplicable "bottleneck" inputs that are critical to entering some market tend to be priced (absent regulatory intervention) when the only source(s) for those inputs are incumbent market participants. There is a straightforward explanation for this behavior, but it seems to get very little attention, straightforward or otherwise, in conventional economics. In fact, the nearest thing to a straightforward answer that comes to my mind was written all the way back in 1979 by the staunchly pro-market industry guru George Gilder, in a critical Forbes Magazine review of a recently-published book by liberal economist JK Galbraith: The truth, perceived by Galbraith perhaps better than by most of his adversaries, is that the very essence of capitalism is the competitive pursuit of transitory positions of monopoly. This pursuit is not guided by any invisible hand. It is governed by the quite visible and aggressive hand of management and entrepreneurship. Businesses continually differentiate their products, marketing techniques, advertising and retailing strategies, in order to find some unique niche in the system from which they can reap, as long as possible, monopoly profits. Without the aid of government, protecting patents or otherwise excluding competitors, these monopoly positions tend to be short-lived. But they are the goal of business activity, the focus of creative entrepreneurship, the motivation of research and development. The monopoly positions, moreover, are not at all unlimited, because they are always held -- unless government intercedes to enforce them -- under the threat of potential competitors and substitutes at home or abroad. The monopoly can be maintained only as long as the price is kept low enough to exclude others. In this sense, monopolies are good. The more dynamic and inventive an economy the more monopolies it will engender. The ideal of perfect competition, like the ideal of an economy without monopolies, is also an economy without innovations.* Of course, for Gilder and most orthodox libertarian/Austrian economic thinkers more generally, the observation that a private monopoly has persisted for generations, or all of human history to date, would be perfectly consistent with the belief that it's only a matter of time before the market produces a better outcome. Private monopolies are "transient" by definition. TV *Happy to share the full text of the review with anyone who's interested. The complete reference is: George Gilder, "Galbraithian Truth and Fallacy," Forbes (November 12, 1979). On Feb 23, 2012, at 4:59 PM, John Curran wrote: > Milton - > > Is there an fairly straightforward economic explanation that addresses > the questions that John Sweeting raised? If so, could you outline it? > > Thanks! > /John > > John Curran > President and CEO > ARIN > > Begin forwarded message: > >> From: "Sweeting, John" >> Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification >> Date: February 17, 2012 12:55:52 PM EST >> To: Milton L Mueller , 'Paul Vixie' , "jeffmehlenbacher at ipv4marketgroup.com" >> Cc: "arin-ppml at arin.net" >> >> Hi Milton, >> >> A few questions since I am not an expert in markets. Do you think there is a scenario where the largest and wealthiest of the world's ISP's would buy up as much address space as they could just to keep it out of the hands of their competitors? Or new start ups in their markets? There are some very wealthy companies out there that would not blink an eye at spending the money needed to run their competitors out of the market but maybe that is not possible in this particular market. Is there a way that a small but well of portion of the market could insure prices are so high that the number of competitors would be capped or even reduced? As I said I am not an expert on markets so would very much welcome your views on this. >> >> Thanks, >> John >> ... > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From jeffrey.lyon at blacklotus.net Thu Feb 23 21:11:13 2012 From: jeffrey.lyon at blacklotus.net (Jeffrey Lyon) Date: Thu, 23 Feb 2012 21:11:13 -0500 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> Message-ID: On Thu, Feb 23, 2012 at 8:31 PM, Tom Vest wrote: > Consider how other de facto non-duplicable "bottleneck" inputs that are critical to entering some market tend to be priced (absent regulatory intervention) when the only source(s) for those inputs are incumbent market participants. > > There is a straightforward explanation for this behavior, but it seems to get very little attention, straightforward or otherwise, in conventional economics. > > In fact, the nearest thing to a straightforward answer that comes to my mind was written all the way back in 1979 by the staunchly pro-market industry guru George Gilder, in a critical Forbes Magazine review of a recently-published book by liberal economist JK Galbraith: > > The truth, perceived by Galbraith perhaps better than by most of his adversaries, is that the very essence of capitalism is the competitive pursuit of transitory positions of monopoly. This pursuit is not guided by any invisible hand. It is governed by the quite visible and aggressive hand of management and entrepreneurship. Businesses continually differentiate their products, marketing techniques, advertising and retailing strategies, in order to find some unique niche in the system from which they can reap, as long as possible, monopoly profits. Without the aid of government, protecting patents or otherwise excluding competitors, these monopoly positions tend to be short-lived. But they are the goal of business activity, the focus of creative entrepreneurship, the motivation of research and development. The monopoly positions, moreover, are not at all unlimited, because they are always held -- unless government intercedes to enforce them -- under the threat of poten > ?tial competitors and substitutes at home or abroad. The monopoly can be maintained only as long as the price is kept low enough to exclude others. In this sense, monopolies are good. The more dynamic and inventive an economy the more monopolies it will engender. The ideal of perfect competition, like the ideal of an economy without monopolies, is also an economy without innovations.* > > Of course, for Gilder and most orthodox libertarian/Austrian economic thinkers more generally, the observation that a private monopoly has persisted for generations, or all of human history to date, would be perfectly consistent with the belief that it's only a matter of time before the market produces a better outcome. Private monopolies are "transient" by definition. > > TV > > *Happy to share the full text of the review with anyone who's interested. The complete reference is: > > George Gilder, "Galbraithian Truth and Fallacy," Forbes (November 12, 1979). > > > On Feb 23, 2012, at 4:59 PM, John Curran wrote: > >> Milton - >> >> ? ?Is there an fairly straightforward economic explanation that addresses >> ? ?the questions that John Sweeting raised? ?If so, could you outline it? >> >> Thanks! >> /John >> >> John Curran >> President and CEO >> ARIN >> >> Begin forwarded message: >> >>> From: "Sweeting, John" >>> Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification >>> Date: February 17, 2012 12:55:52 PM EST >>> To: Milton L Mueller , 'Paul Vixie' , "jeffmehlenbacher at ipv4marketgroup.com" >>> Cc: "arin-ppml at arin.net" >>> >>> Hi Milton, >>> >>> A few questions since I am not an expert in markets. ?Do you think there is a scenario where the largest and wealthiest of the world's ISP's would buy up as much address space as they could just to keep it out of the hands of their competitors? Or new start ups in their markets? ?There are some very wealthy companies out there that would not blink an eye at spending the money needed to run their competitors out of the market but maybe that is not possible in this particular market. Is there a way that a small but well of portion of the market could insure prices are so high that the number of competitors would be capped or even reduced? As I said I am not an expert on markets so would very much welcome your views on this. >>> >>> Thanks, >>> John >>> ... >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. http://www.youtube.com/watch?v=GTQnarzmTOc -- Jeffrey Lyon, Leadership Team jeffrey.lyon at blacklotus.net | http://www.blacklotus.net Black Lotus Communications - AS32421 First and Leading in DDoS Protection Solutions From narten at us.ibm.com Fri Feb 24 00:53:03 2012 From: narten at us.ibm.com (Thomas Narten) Date: Fri, 24 Feb 2012 00:53:03 -0500 Subject: [arin-ppml] Weekly posting summary for ppml@arin.net Message-ID: <201202240553.q1O5r3Jm025677@rotala.raleigh.ibm.com> Total of 155 messages in the last 7 days. script run at: Fri Feb 24 00:53:03 EST 2012 Messages | Bytes | Who --------+------+--------+----------+------------------------ 11.61% | 18 | 13.25% | 175388 | owen at delong.com 10.32% | 16 | 8.81% | 116627 | jcurran at arin.net 8.39% | 13 | 9.10% | 120424 | astrodog at gmail.com 7.74% | 12 | 6.16% | 81465 | jeffmehlenbacher at ipv4marketgroup.com 5.81% | 9 | 6.21% | 82173 | jeffrey.lyon at blacklotus.net 4.52% | 7 | 5.23% | 69269 | john.sweeting at twcable.com 3.87% | 6 | 4.81% | 63612 | info at arin.net 3.87% | 6 | 4.20% | 55572 | mueller at syr.edu 3.23% | 5 | 4.19% | 55475 | cgrundemann at gmail.com 3.87% | 6 | 3.54% | 46917 | hannigan at gmail.com 3.87% | 6 | 2.77% | 36661 | jmaimon at chl.com 3.23% | 5 | 3.16% | 41878 | farmer at umn.edu 3.23% | 5 | 2.34% | 30933 | gbonser at seven.com 2.58% | 4 | 2.41% | 31900 | mike at nationwideinc.com 1.94% | 3 | 2.78% | 36796 | daniel_alexander at cable.comcast.com 1.94% | 3 | 2.52% | 33402 | dogwallah at gmail.com 2.58% | 4 | 1.86% | 24634 | paul at redbarn.org 1.29% | 2 | 2.19% | 28981 | kkargel at polartel.com 0.65% | 1 | 1.85% | 24532 | d.bucciero at wwpass.com 1.29% | 2 | 1.06% | 14060 | mpetach at netflight.com 1.29% | 2 | 1.01% | 13317 | gary.buhrmaster at gmail.com 1.29% | 2 | 0.87% | 11476 | springer at inlandnet.com 1.29% | 2 | 0.77% | 10240 | ebw at abenaki.wabanaki.net 0.65% | 1 | 1.02% | 13561 | lee at dilkie.com 0.65% | 1 | 0.73% | 9710 | dave at goflashpoint.com 0.65% | 1 | 0.70% | 9328 | tvest at eyeconomics.com 0.65% | 1 | 0.70% | 9259 | cja at daydream.com 0.65% | 1 | 0.61% | 8083 | gene.jeffers at emp.shentel.com 0.65% | 1 | 0.59% | 7857 | scottleibrand at gmail.com 0.65% | 1 | 0.53% | 7043 | narten at us.ibm.com 0.65% | 1 | 0.50% | 6601 | woody at pch.net 0.65% | 1 | 0.49% | 6550 | daved at lightwave.net 0.65% | 1 | 0.49% | 6454 | rriske at visionfinancialmarkets.com 0.65% | 1 | 0.49% | 6434 | jsahala at gmail.com 0.65% | 1 | 0.46% | 6087 | mike at willitsonline.com 0.65% | 1 | 0.43% | 5664 | ikiris at gmail.com 0.65% | 1 | 0.41% | 5416 | michael+ppml at burnttofu.net 0.65% | 1 | 0.40% | 5251 | lsawyer at gci.com 0.65% | 1 | 0.34% | 4469 | joe at oregon.uoregon.edu --------+------+--------+----------+------------------------ 100.00% | 155 |100.00% | 1323499 | Total From gbonser at seven.com Fri Feb 24 01:02:05 2012 From: gbonser at seven.com (George Bonser) Date: Fri, 24 Feb 2012 06:02:05 +0000 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> Message-ID: <596B74B410EE6B4CA8A30C3AF1A155EA09CE5FBB@RWC-MBX1.corp.seven.com> > On Behalf Of Tom Vest > Subject: Re: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based > Justification > > Consider how other de facto non-duplicable "bottleneck" inputs that are > critical to entering some market tend to be priced (absent regulatory > intervention) when the only source(s) for those inputs are incumbent > market participants. > > There is a straightforward explanation for this behavior, but it seems > to get very little attention, straightforward or otherwise, in > conventional economics. I don't believe it is within ARIN's mandate to "create markets" of any sort. And this would be particularly so out of creating "real estate" out of the IP address space at the precise point in time where things are going to already be bad enough in that space. Maybe after v4 becomes operationally obsolete, no big deal, but I still don't see how this gives all players in North America any operational advantage. The only advantage I could see is that some legacy holder might transfer some unused resources to someone with deep pockets but someone with deep pockets is likely to be the most capable of migrating to v6 and might be attempting to obtain v4 addresses for no other reason than to create a barrier of entry to competition. There might be other ways of accomplishing the voluntary relinquishing of unused legacy space. One of those ways might be simple peer pressure. Simply publishing the top ten holders of unused legacy space, for example, in a very public way might be enough to generate some movement over time. The thing is that any market (or more accurately, any "killing" to be made by brokering scarce resources) will probably have a very short window of time. I also don't believe it is in the community interest to do things that would foster the continued growth of IPv4. From tvest at eyeconomics.com Fri Feb 24 02:29:47 2012 From: tvest at eyeconomics.com (Tom Vest) Date: Fri, 24 Feb 2012 02:29:47 -0500 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <596B74B410EE6B4CA8A30C3AF1A155EA09CE5FBB@RWC-MBX1.corp.seven.com> References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <596B74B410EE6B4CA8A30C3AF1A155EA09CE5FBB@RWC-MBX1.corp.seven.com> Message-ID: <93FB0242-9986-47DE-88CC-9359BC573157@eyeconomics.com> On Feb 24, 2012, at 1:02 AM, George Bonser wrote: >> On Behalf Of Tom Vest >> Subject: Re: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based >> Justification >> >> Consider how other de facto non-duplicable "bottleneck" inputs that are >> critical to entering some market tend to be priced (absent regulatory >> intervention) when the only source(s) for those inputs are incumbent >> market participants. >> >> There is a straightforward explanation for this behavior, but it seems >> to get very little attention, straightforward or otherwise, in >> conventional economics. > > I don't believe it is within ARIN's mandate to "create markets" of any sort. I couldn't agree more, but I'm not sure how this has any bearing on the question of what considerations might motivate certain operators, under certain conditions, to exploit the increasing scarcity of globally interoperable (IPv4) addresses to strengthen their competitive positions, aka to exercise market power. > And this would be particularly so out of creating "real estate" out of the IP address space at the precise point in time where things are going to already be bad enough in that space. Maybe after v4 becomes operationally obsolete, no big deal, but I still don't see how this gives all players in North America any operational advantage. If you don't see how this would be advantageous to all market players in North America, that only means that you're paying attention ;-) > The only advantage I could see is that some legacy holder might transfer some unused resources to someone with deep pockets but someone with deep pockets is likely to be the most capable of migrating to v6 and might be attempting to obtain v4 addresses for no other reason than to create a barrier of entry to competition. Your hypothetical case is a classic example of the "allocative efficiency" argument -- which is not really an empirical argument/claim so much as it is a convenient axiom, sort of like the "transience" of private monopolies. As in the case of private monopolies, if one accepts that the highest bidder always yields the greatest allocative efficiency, then "creating a barrier to competition" just might be one of the manifestations of that "efficiency." > There might be other ways of accomplishing the voluntary relinquishing of unused legacy space. One of those ways might be simple peer pressure. Simply publishing the top ten holders of unused legacy space, for example, in a very public way might be enough to generate some movement over time. The thing is that any market (or more accurately, any "killing" to be made by brokering scarce resources) will probably have a very short window of time. I also don't believe it is in the community interest to do things that would foster the continued growth of IPv4. According to the Census Bureau, appx. 10% (13m) of all of the single-family dwellings in the US are currently unoccupied. Millions of those have been vacant for one or more years, and quite a few have never been occupied at all. Even in the face of a steadily growing national population and persistent and increasing unfulfilled demand (aka the homeless), the existence of a very liberal/open housing market doesn't prompt millions of frustrated residential developers and would-be landlords to rush all of those idle/unproductive (but nevertheless "efficiently allocated") properties to market; instead they tend to wait until they get the price that they want, and/or to adjust their expectations downward only *very* slowly and reluctantly, over a period of months-years. I decline to speculate what market boosters who predict that IPv4 markets would yield significantly different outcomes might be thinking, but the burden should be on them to make a persuasive and empirically (not just theoretically) grounded case as to why things would turn out differently in this case. TV From gbonser at seven.com Fri Feb 24 02:35:58 2012 From: gbonser at seven.com (George Bonser) Date: Fri, 24 Feb 2012 07:35:58 +0000 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <93FB0242-9986-47DE-88CC-9359BC573157@eyeconomics.com> References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <596B74B410EE6B4CA8A30C3AF1A155EA09CE5FBB@RWC-MBX1.corp.seven.com> <93FB0242-9986-47DE-88CC-9359BC573157@eyeconomics.com> Message-ID: <596B74B410EE6B4CA8A30C3AF1A155EA09CE60A8@RWC-MBX1.corp.seven.com> > If you don't see how this would be advantageous to all market players > in North America, that only means that you're paying attention ;-) Ok, say I am a non-profit organization operating on a shoestring and I need some IP addresses. How does this help? I am not going to be going to a broker or anyone else to buy addresses. How does this serve that organization who is just as much part of the internet community as everyone else? This is one of those cases of which there are actually darned few, where creating a "market" could actually be harmful. I would have no problem with this proposal in 5 years time. It should be just as "helpful" then as it is now, no? From astrodog at gmail.com Fri Feb 24 04:00:15 2012 From: astrodog at gmail.com (Astrodog) Date: Fri, 24 Feb 2012 03:00:15 -0600 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> Message-ID: On Thu, Feb 23, 2012 at 3:59 PM, John Curran wrote: > Milton - > > ? ?Is there an fairly straightforward economic explanation that addresses > ? ?the questions?that John Sweeting raised? ?If so, could you outline it? > > Thanks! > /John Sorry for hijacking a bit, but I do have an answer. > > From: "Sweeting, John" > Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification > Date: February 17, 2012 12:55:52 PM EST > To: Milton L Mueller , 'Paul Vixie' , > "jeffmehlenbacher at ipv4marketgroup.com" > > Cc: "arin-ppml at arin.net" > > Hi Milton, > > A few questions since I am not an expert in markets. ?Do you think there is > a scenario where the largest and wealthiest of the world's ISP's would buy > up as much address space as they could just to keep it out of the hands of > their competitors? Or new start ups in their markets? ?There are some very > wealthy companies out there that would not blink an eye at spending the > money needed to run their competitors out of the market but maybe that is > not possible in this particular market. Is there a way that a small but well > of portion of the market could insure prices are so high that the number of > competitors would be capped or even reduced? As I said I am not an expert on > markets so would very much welcome your views on this. > > Thanks, > John > ... It's very unlikely that large ISPs would make this sort of move for a number of reasons: First, it should be noted that even the largest ISPs are not particularly well positioned financially for this sort of endeavor. AT&T as an example, has ~$3.2 billion in cash, and after paying dividends, has lost money somewhat the past few years. When compared to some of the end users of address space, they simply wouldn't be competitive bidders, limiting how much of the "for sale" capacity they could acquire. Aside from this, the largest ISPs cannot cooperate on their purchases and would be at a significant disadvantage compared to their large competitors who did not attempt to drive up the price. It is also notable that large ISPs are not precluded from doing this under current policy. Simply through changing their address scheme for CPE, most large ISPs could nearly double their current allocation. Considering that in 8.3 transfers, they only need to show 24 month need, most could go significantly past this (for example, planning to offer customers public IPs for all of their various bits of network enabled equipment... note that under current policy, they do not have to actually do this. Merely intend to.) As a result of how rare auditing is, its unlikely that they would see revocations, either. Under current policy, a small ISP attempting to become a large one would face a much greater regulatory hurdle. I think there is consensus around the fact that long term, IPv4 allocations are likely to have little to no value. As a result, they are particularly unattractive as speculative investments. Someone holding a large number of addresses without utilizing them as an investment is taking a very large risk and would be very unlikely to hold those addresses for long, due to their value trending to zero. The same reasons why many of you have expressed... acceptance with removing needs requirements in a few years would make speculation on IP addresses today minimal. Finally, a major way to keep a handle on speculation would be for ARIN to hold some allocations back, post-exhaustion, with authorization to release some of those addresses if it appears that an entity is attempting to "corner the market" at a given point in time. Another option would be verbiage specifically prohibiting speculation, through post-purchase auditing. These do not need to occur frequently to eliminate speculative behavior. --- Harrison From astrodog at gmail.com Fri Feb 24 04:06:11 2012 From: astrodog at gmail.com (Astrodog) Date: Fri, 24 Feb 2012 03:06:11 -0600 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <596B74B410EE6B4CA8A30C3AF1A155EA09CE5FBB@RWC-MBX1.corp.seven.com> References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <596B74B410EE6B4CA8A30C3AF1A155EA09CE5FBB@RWC-MBX1.corp.seven.com> Message-ID: On Fri, Feb 24, 2012 at 12:02 AM, George Bonser wrote: > > > >> On Behalf Of Tom Vest >> Subject: Re: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based >> Justification >> >> Consider how other de facto non-duplicable "bottleneck" inputs that are >> critical to entering some market tend to be priced (absent regulatory >> intervention) when the only source(s) for those inputs are incumbent >> market participants. >> >> There is a straightforward explanation for this behavior, but it seems >> to get very little attention, straightforward or otherwise, in >> conventional economics. > > I don't believe it is within ARIN's mandate to "create markets" of any sort. And this would be particularly so out of creating "real estate" out of the IP address space at the precise point in time where things are going to already be bad enough in that space. ?Maybe after v4 becomes operationally obsolete, no big deal, but I still don't see how this gives all players in North America any operational advantage. > The market already exists, as 8.3 transfers can occur in exchange for financial consideration. This can only be rectified by eliminating 8.3 transfers entirely. > The only advantage I could see is that some legacy holder might transfer some unused resources to someone with deep pockets but someone with deep pockets is likely to be the most capable of migrating to v6 and might be attempting to obtain v4 addresses for no other reason than to create a barrier of entry to competition. > This would be a fairly expensive, transient barrier to entry. This is, again, aside from the fact that under current policy, large ISPs are already able to do something like this. > There might be other ways of accomplishing the voluntary relinquishing of unused legacy space. ?One of those ways might be simple peer pressure. ?Simply publishing the top ten holders of unused legacy space, for example, in a very public way might be enough to generate some movement over time. ?The thing is that any market (or more accurately, any "killing" to be made by brokering scarce resources) will probably have a very short window of time. ?I also don't believe it is in the community interest to do things that would foster the continued growth of IPv4. This short window of time is what makes such a move remarkably unattractive to speculation. --- Harrison From tvest at eyeconomics.com Fri Feb 24 13:45:48 2012 From: tvest at eyeconomics.com (Tom Vest) Date: Fri, 24 Feb 2012 13:45:48 -0500 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> Message-ID: On Feb 24, 2012, at 4:00 AM, Astrodog wrote: > On Thu, Feb 23, 2012 at 3:59 PM, John Curran wrote: >> Milton - >> >> Is there an fairly straightforward economic explanation that addresses >> the questions that John Sweeting raised? If so, could you outline it? >> >> Thanks! >> /John > > Sorry for hijacking a bit, but I do have an answer. > >> >> From: "Sweeting, John" >> Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification >> Date: February 17, 2012 12:55:52 PM EST >> To: Milton L Mueller , 'Paul Vixie' , >> "jeffmehlenbacher at ipv4marketgroup.com" >> >> Cc: "arin-ppml at arin.net" >> >> Hi Milton, >> >> A few questions since I am not an expert in markets. Do you think there is >> a scenario where the largest and wealthiest of the world's ISP's would buy >> up as much address space as they could just to keep it out of the hands of >> their competitors? Or new start ups in their markets? There are some very >> wealthy companies out there that would not blink an eye at spending the >> money needed to run their competitors out of the market but maybe that is >> not possible in this particular market. Is there a way that a small but well >> of portion of the market could insure prices are so high that the number of >> competitors would be capped or even reduced? As I said I am not an expert on >> markets so would very much welcome your views on this. >> >> Thanks, >> John >> ... > > It's very unlikely that large ISPs would make this sort of move for a > number of reasons: > > First, it should be noted that even the largest ISPs are not > particularly well positioned financially for this sort of endeavor. > AT&T as an example, has ~$3.2 billion in cash, and after paying > dividends, has lost money somewhat the past few years. When compared > to some of the end users of address space, they simply wouldn't be > competitive bidders, limiting how much of the "for sale" capacity they > could acquire. Aside from this, the largest ISPs cannot cooperate on > their purchases and would be at a significant disadvantage compared to > their large competitors who did not attempt to drive up the price. > > It is also notable that large ISPs are not precluded from doing this > under current policy. Simply through changing their address scheme for > CPE, most large ISPs could nearly double their current allocation. > Considering that in 8.3 transfers, they only need to show 24 month > need, most could go significantly past this (for example, planning to > offer customers public IPs for all of their various bits of network > enabled equipment... note that under current policy, they do not have > to actually do this. Merely intend to.) As a result of how rare > auditing is, its unlikely that they would see revocations, either. > Under current policy, a small ISP attempting to become a large one > would face a much greater regulatory hurdle. > > I think there is consensus around the fact that long term, IPv4 > allocations are likely to have little to no value. As a result, they > are particularly unattractive as speculative investments. Someone > holding a large number of addresses without utilizing them as an > investment is taking a very large risk and would be very unlikely to > hold those addresses for long, due to their value trending to zero. > The same reasons why many of you have expressed... acceptance with > removing needs requirements in a few years would make speculation on > IP addresses today minimal. > > Finally, a major way to keep a handle on speculation would be for ARIN > to hold some allocations back, post-exhaustion, with authorization to > release some of those addresses if it appears that an entity is > attempting to "corner the market" at a given point in time. Another > option would be verbiage specifically prohibiting speculation, through > post-purchase auditing. These do not need to occur frequently to > eliminate speculative behavior. > > --- Harrison Hi Harrison, That's a fine set of arguments, and I do hope that you are right, but it might be worth considering the following: 1. Your examples don't capture the most compelling incentive(s) that might hypothetically motivate an operator's attempt to strategically leverage IPv4 scarcity for commercial/competitive purposes. The Internet has a strong tendency to "route around" congestion, censorship, scarcity, and other bad things, not only (or primarily) because the technology just works that way, but because clever operators are constantly, actively looking for opportunities to optimize their network cost/performance characteristics -- i.e., by topologically "bypassing" such problems. Of course, network input suppliers (the majority of which are now also "operators" themselves) are fully aware of this fact, and as a class they naturally tend to be reluctant to compete on price ( -> commodification) *if* there is any other alternative. Consequently, smart input suppliers are constantly trying to identify and "capture" profitable market niches that are very likely to remain profitable because operators cannot easily bypass them -- i.e., because they constitute a "bottleneck" to profitably providing network service to some place/population. Sometimes (increasingly uncommon IMO) such bottlenecks are be embodied in some unique technology or non-fixed asset. Today, in this industry, such bottlenecks are far more likely to be explicitly or implicitly spatial/geographic in nature, e.g., a particularly attractive room in a building (e.g., an IXP/IDC), building in a particular neighborhood, neighborhood right-of-way in a city, city in a country, etc., or indirect access to the same via interconnection/traffic exchange with another operator that has better or perhaps exclusive topological access to to the desired "turf." 2. At various times/places, IPv4 can and has embodied an absolute bottleneck of the former (non-fixed) kind, at least for some network operators and/or would-be operators. The possibility (or rather "eventuality") that IPv4 would become a bottleneck was one of the factors that drove the creation of the RIR (needs-based) allocation system, and the limited accessibility of IPv4 on non-adversarial terms to aspiring network operators outside the US was one of the demand drivers that led to the spread of that address distribution model to every continent. Today, thanks to NAT, RFC1918, and IPv6, IPv4's status as a "quantitative bottleneck" to delivering many kinds of services has diminished substantially -- i.e., life might be vastly easier if one had more IPv4, but -- assuming that you have any at all -- an independent network operator can generally remain in business as such, and even continue growing, by strategically reassigning/multiplexing and/or supplementing their limited IPv4 holdings with private addressing and/or IPv6. However, for the overwhelming majority of places and aspiring (future) service providers, IPv4 still remains an absolute/qualitative bottleneck to entering (appx. any/all) Internet services market, at least with the same sort of "independent" status that all of one's incumbent competitors would enjoy. One day that might not be true, but when (or whether) that day might come is anyone's guess. You may be right that there is "consensus around the fact that long term, IPv4 allocations are likely to have little to no value," but if so that consensus is overwhelmingly among individuals that work for institutions that (a) have to-date put little if anything at risk to hasten that outcome, and (b) simply by virtue of their possession of IPv4 could have quite a lot to gain if the consensus prediction turns out to be wrong. Obviously there are some exceptions, e.g., networks that have literally bet the farm on IPv6, but they represent a tiny minority among those holding the "consensus" view. Note that I'm not suggesting that people are misrepresenting their actual beliefs, but it's a lot easier to have strong opinions about future unknowns when being wrong is a (privately) cost-free option. Like I said, I do hope that the consensus is right, but caveat emptor is always good advice. 3. Given the fact that, by itself, a strategy of "IPv4 hoarding" seems unlikely pay off in the near future, and might never become an effective means of *establishing* market power (i.e., except under relatively improbable circumstances/scenarios, for the perennially modest market segment of aspiring new entrants), but arguably has already/repeatedly proven to be quite effective as a strategy for *enhancing* market power under certain conditions (e.g., during the preRIR/early RIR era, in regions/bargaining situations where BYO addressing is unacceptable, etc.), one should assume that any shift toward strategic "IPv4 hoarding" would probably start -- and if left unchecked, end -- with the kind of entities that already control some other critical bottleneck(s) to Internet service delivery, as described in [1] above. Food for thought, TV From astrodog at gmail.com Fri Feb 24 13:56:09 2012 From: astrodog at gmail.com (Astrodog) Date: Fri, 24 Feb 2012 12:56:09 -0600 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> Message-ID: On Fri, Feb 24, 2012 at 12:45 PM, Tom Vest wrote: > > On Feb 24, 2012, at 4:00 AM, Astrodog wrote: > >> On Thu, Feb 23, 2012 at 3:59 PM, John Curran wrote: >>> Milton - >>> >>> ? ?Is there an fairly straightforward economic explanation that addresses >>> ? ?the questions that John Sweeting raised? ?If so, could you outline it? >>> >>> Thanks! >>> /John >> >> Sorry for hijacking a bit, but I do have an answer. >> >>> >>> From: "Sweeting, John" >>> Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification >>> Date: February 17, 2012 12:55:52 PM EST >>> To: Milton L Mueller , 'Paul Vixie' , >>> "jeffmehlenbacher at ipv4marketgroup.com" >>> >>> Cc: "arin-ppml at arin.net" >>> >>> Hi Milton, >>> >>> A few questions since I am not an expert in markets. ?Do you think there is >>> a scenario where the largest and wealthiest of the world's ISP's would buy >>> up as much address space as they could just to keep it out of the hands of >>> their competitors? Or new start ups in their markets? ?There are some very >>> wealthy companies out there that would not blink an eye at spending the >>> money needed to run their competitors out of the market but maybe that is >>> not possible in this particular market. Is there a way that a small but well >>> of portion of the market could insure prices are so high that the number of >>> competitors would be capped or even reduced? As I said I am not an expert on >>> markets so would very much welcome your views on this. >>> >>> Thanks, >>> John >>> ... >> >> It's very unlikely that large ISPs would make this sort of move for a >> number of reasons: >> >> First, it should be noted that even the largest ISPs are not >> particularly well positioned financially for this sort of endeavor. >> AT&T as an example, has ~$3.2 billion in cash, and after paying >> dividends, has lost money somewhat the past few years. When compared >> to some of the end users of address space, they simply wouldn't be >> competitive bidders, limiting how much of the "for sale" capacity they >> could acquire. Aside from this, the largest ISPs cannot cooperate on >> their purchases and would be at a significant disadvantage compared to >> their large competitors who did not attempt to drive up the price. >> >> It is also notable that large ISPs are not precluded from doing this >> under current policy. Simply through changing their address scheme for >> CPE, most large ISPs could nearly double their current allocation. >> Considering that in 8.3 transfers, they only need to show 24 month >> need, most could go significantly past this (for example, planning to >> offer customers public IPs for all of their various bits of network >> enabled equipment... note that under current policy, they do not have >> to actually do this. Merely intend to.) As a result of how rare >> auditing is, its unlikely that they would see revocations, either. >> Under current policy, a small ISP attempting to become a large one >> would face a much greater regulatory hurdle. >> >> I think there is consensus around the fact that long term, IPv4 >> allocations are likely to have little to no value. As a result, they >> are particularly unattractive as speculative investments. Someone >> holding a large number of addresses without utilizing them as an >> investment is taking a very large risk and would be very unlikely to >> hold those addresses for long, due to their value trending to zero. >> The same reasons why many of you have expressed... acceptance with >> removing needs requirements in a few years would make speculation on >> IP addresses today minimal. >> >> Finally, a major way to keep a handle on speculation would be for ARIN >> to hold some allocations back, post-exhaustion, with authorization to >> release some of those addresses if it appears that an entity is >> attempting to "corner the market" at a given point in time. Another >> option would be verbiage specifically prohibiting speculation, through >> post-purchase auditing. These do not need to occur frequently to >> eliminate speculative behavior. >> >> --- Harrison > > Hi Harrison, > > That's a fine set of arguments, and I do hope that you are right, but it might be worth considering the following: > > 1. Your examples don't capture the most compelling incentive(s) that might hypothetically motivate an operator's attempt to strategically leverage IPv4 scarcity for commercial/competitive purposes. The Internet has a strong tendency to "route around" congestion, censorship, scarcity, and other bad things, not only (or primarily) because the technology just works that way, but because clever operators are constantly, actively looking for opportunities to optimize their network cost/performance characteristics -- i.e., by topologically "bypassing" such problems. Of course, network input suppliers (the majority of which are now also "operators" themselves) are fully aware of this fact, and as a class they naturally tend to be reluctant to compete on price ( -> commodification) *if* there is any other alternative. Consequently, smart input suppliers are constantly trying to identify and "capture" profitable market niches that are very likely to remain profitable because operators cannot easily bypass them -- i.e., because they constitute a "bottleneck" to profitably providing network service to some place/population. Sometimes (increasingly uncommon IMO) such bottlenecks are be embodied in some unique technology or non-fixed asset. Today, in this industry, such bottlenecks are far more likely to be explicitly or implicitly spatial/geographic in nature, e.g., a particularly attractive room in a building (e.g., an IXP/IDC), building in a particular neighborhood, neighborhood right-of-way in a city, city in a country, etc., or indirect access to the same via interconnection/traffic exchange with another operator that has better or perhaps exclusive topological access to to the desired "turf." > > 2. At various times/places, IPv4 can and has embodied an absolute bottleneck of the former (non-fixed) kind, at least for some network operators and/or would-be operators. The possibility (or rather "eventuality") that IPv4 would become a bottleneck was one of the factors that drove the creation of the RIR (needs-based) allocation system, and the limited accessibility of IPv4 on non-adversarial terms to aspiring network operators outside the US was one of the demand drivers that led to the spread of that address distribution model to every continent. Today, thanks to NAT, RFC1918, and IPv6, IPv4's status as a "quantitative bottleneck" to delivering many kinds of services has diminished substantially -- i.e., life might be vastly easier if one had more IPv4, but -- assuming that you have any at all -- ?an independent network operator can generally remain in business as such, and even continue growing, by strategically reassigning/multiplexing and/or supplementing their limited IPv4 holdings with private addressing and/or IPv6. However, for the overwhelming majority of places and aspiring (future) service providers, IPv4 still remains an absolute/qualitative bottleneck to entering (appx. any/all) Internet services market, at least with the same sort of "independent" status that all of one's incumbent competitors would enjoy. > > One day that might not be true, but when (or whether) that day might come is anyone's guess. You may be right that there is "consensus around the fact that long term, IPv4 allocations are likely to have little to no value," but if so that consensus is overwhelmingly among individuals that work for institutions that (a) have to-date put little if anything at risk to hasten that outcome, and (b) simply by virtue of their possession of IPv4 could have quite a lot to gain if the consensus prediction turns out to be wrong. Obviously there are some exceptions, e.g., networks that have literally bet the farm on IPv6, but they represent a tiny minority among those holding the "consensus" view. > > Note that I'm not suggesting that people are misrepresenting their actual beliefs, but it's a lot easier to have strong opinions about future unknowns when being wrong is a (privately) cost-free option. Like I said, I do hope that the consensus is right, but caveat emptor is always good advice. > > 3. Given the fact that, by itself, a strategy of "IPv4 hoarding" seems unlikely pay off in the near future, and might never become an effective means of *establishing* market power (i.e., except under relatively improbable circumstances/scenarios, for the perennially modest market segment of aspiring new entrants), but arguably has already/repeatedly proven to be quite effective as a strategy for *enhancing* market power under certain conditions (e.g., during the preRIR/early RIR era, in regions/bargaining situations where BYO addressing is unacceptable, etc.), one should assume that any shift toward strategic "IPv4 hoarding" would probably start -- and if left unchecked, end -- with the kind of entities that already control some other critical bottleneck(s) to Internet service delivery, as described in [1] above. Thanks for the explanation. Those are definitely significant concerns, but I'm not sure how needs testing addresses them. Large ISPs already have the ability to horde address space, in that they can make relatively minor changes that would suddenly make them "need" (or, at least, qualify for) quite a bit more address space than they already have. These entities are also the ones most likely to be well versed in how to meet the letter of ARIN's requirements. It seems like the needs testing simply adds one more advantage they would have over their smaller counterparts and end-users. Perhaps the solution to this problem is a reserved block for small allocations, where the "reservation" survives 8.3 transfer? At least in a more open market, such entities may also decide that they can make more money using their space more effectively, and selling the extra on, post-exhaustion, though I'll admit this seems like a fairly unlikely outcome. --- Harrison From tvest at eyeconomics.com Fri Feb 24 15:50:57 2012 From: tvest at eyeconomics.com (Tom Vest) Date: Fri, 24 Feb 2012 15:50:57 -0500 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> Message-ID: <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> On Feb 24, 2012, at 1:56 PM, Astrodog wrote: > On Fri, Feb 24, 2012 at 12:45 PM, Tom Vest wrote: >> >> On Feb 24, 2012, at 4:00 AM, Astrodog wrote: >> >>> On Thu, Feb 23, 2012 at 3:59 PM, John Curran wrote: >>>> Milton - >>>> >>>> Is there an fairly straightforward economic explanation that addresses >>>> the questions that John Sweeting raised? If so, could you outline it? >>>> >>>> Thanks! >>>> /John >>> >>> Sorry for hijacking a bit, but I do have an answer. >>> >>>> >>>> From: "Sweeting, John" >>>> Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification >>>> Date: February 17, 2012 12:55:52 PM EST >>>> To: Milton L Mueller , 'Paul Vixie' , >>>> "jeffmehlenbacher at ipv4marketgroup.com" >>>> >>>> Cc: "arin-ppml at arin.net" >>>> >>>> Hi Milton, >>>> >>>> A few questions since I am not an expert in markets. Do you think there is >>>> a scenario where the largest and wealthiest of the world's ISP's would buy >>>> up as much address space as they could just to keep it out of the hands of >>>> their competitors? Or new start ups in their markets? There are some very >>>> wealthy companies out there that would not blink an eye at spending the >>>> money needed to run their competitors out of the market but maybe that is >>>> not possible in this particular market. Is there a way that a small but well >>>> of portion of the market could insure prices are so high that the number of >>>> competitors would be capped or even reduced? As I said I am not an expert on >>>> markets so would very much welcome your views on this. >>>> >>>> Thanks, >>>> John >>>> ... >>> >>> It's very unlikely that large ISPs would make this sort of move for a >>> number of reasons: >>> >>> First, it should be noted that even the largest ISPs are not >>> particularly well positioned financially for this sort of endeavor. >>> AT&T as an example, has ~$3.2 billion in cash, and after paying >>> dividends, has lost money somewhat the past few years. When compared >>> to some of the end users of address space, they simply wouldn't be >>> competitive bidders, limiting how much of the "for sale" capacity they >>> could acquire. Aside from this, the largest ISPs cannot cooperate on >>> their purchases and would be at a significant disadvantage compared to >>> their large competitors who did not attempt to drive up the price. >>> >>> It is also notable that large ISPs are not precluded from doing this >>> under current policy. Simply through changing their address scheme for >>> CPE, most large ISPs could nearly double their current allocation. >>> Considering that in 8.3 transfers, they only need to show 24 month >>> need, most could go significantly past this (for example, planning to >>> offer customers public IPs for all of their various bits of network >>> enabled equipment... note that under current policy, they do not have >>> to actually do this. Merely intend to.) As a result of how rare >>> auditing is, its unlikely that they would see revocations, either. >>> Under current policy, a small ISP attempting to become a large one >>> would face a much greater regulatory hurdle. >>> >>> I think there is consensus around the fact that long term, IPv4 >>> allocations are likely to have little to no value. As a result, they >>> are particularly unattractive as speculative investments. Someone >>> holding a large number of addresses without utilizing them as an >>> investment is taking a very large risk and would be very unlikely to >>> hold those addresses for long, due to their value trending to zero. >>> The same reasons why many of you have expressed... acceptance with >>> removing needs requirements in a few years would make speculation on >>> IP addresses today minimal. >>> >>> Finally, a major way to keep a handle on speculation would be for ARIN >>> to hold some allocations back, post-exhaustion, with authorization to >>> release some of those addresses if it appears that an entity is >>> attempting to "corner the market" at a given point in time. Another >>> option would be verbiage specifically prohibiting speculation, through >>> post-purchase auditing. These do not need to occur frequently to >>> eliminate speculative behavior. >>> >>> --- Harrison >> >> Hi Harrison, >> >> That's a fine set of arguments, and I do hope that you are right, but it might be worth considering the following: >> >> 1. Your examples don't capture the most compelling incentive(s) that might hypothetically motivate an operator's attempt to strategically leverage IPv4 scarcity for commercial/competitive purposes. The Internet has a strong tendency to "route around" congestion, censorship, scarcity, and other bad things, not only (or primarily) because the technology just works that way, but because clever operators are constantly, actively looking for opportunities to optimize their network cost/performance characteristics -- i.e., by topologically "bypassing" such problems. Of course, network input suppliers (the majority of which are now also "operators" themselves) are fully aware of this fact, and as a class they naturally tend to be reluctant to compete on price ( -> commodification) *if* there is any other alternative. Consequently, smart input suppliers are constantly trying to identify and "capture" profitable market niches that are very likely to remain profitable because operators cannot easily bypass them -- i.e., because they constitute a "bottleneck" to profitably providing network service to some place/population. Sometimes (increasingly uncommon IMO) such bottlenecks are be embodied in some unique technology or non-fixed asset. Today, in this industry, such bottlenecks are far more likely to be explicitly or implicitly spatial/geographic in nature, e.g., a particularly attractive room in a building (e.g., an IXP/IDC), building in a particular neighborhood, neighborhood right-of-way in a city, city in a country, etc., or indirect access to the same via interconnection/traffic exchange with another operator that has better or perhaps exclusive topological access to to the desired "turf." >> >> 2. At various times/places, IPv4 can and has embodied an absolute bottleneck of the former (non-fixed) kind, at least for some network operators and/or would-be operators. The possibility (or rather "eventuality") that IPv4 would become a bottleneck was one of the factors that drove the creation of the RIR (needs-based) allocation system, and the limited accessibility of IPv4 on non-adversarial terms to aspiring network operators outside the US was one of the demand drivers that led to the spread of that address distribution model to every continent. Today, thanks to NAT, RFC1918, and IPv6, IPv4's status as a "quantitative bottleneck" to delivering many kinds of services has diminished substantially -- i.e., life might be vastly easier if one had more IPv4, but -- assuming that you have any at all -- an independent network operator can generally remain in business as such, and even continue growing, by strategically reassigning/multiplexing and/or supplementing their limited IPv4 holdings with private addressing and/or IPv6. However, for the overwhelming majority of places and aspiring (future) service providers, IPv4 still remains an absolute/qualitative bottleneck to entering (appx. any/all) Internet services market, at least with the same sort of "independent" status that all of one's incumbent competitors would enjoy. >> >> One day that might not be true, but when (or whether) that day might come is anyone's guess. You may be right that there is "consensus around the fact that long term, IPv4 allocations are likely to have little to no value," but if so that consensus is overwhelmingly among individuals that work for institutions that (a) have to-date put little if anything at risk to hasten that outcome, and (b) simply by virtue of their possession of IPv4 could have quite a lot to gain if the consensus prediction turns out to be wrong. Obviously there are some exceptions, e.g., networks that have literally bet the farm on IPv6, but they represent a tiny minority among those holding the "consensus" view. >> >> Note that I'm not suggesting that people are misrepresenting their actual beliefs, but it's a lot easier to have strong opinions about future unknowns when being wrong is a (privately) cost-free option. Like I said, I do hope that the consensus is right, but caveat emptor is always good advice. >> >> 3. Given the fact that, by itself, a strategy of "IPv4 hoarding" seems unlikely pay off in the near future, and might never become an effective means of *establishing* market power (i.e., except under relatively improbable circumstances/scenarios, for the perennially modest market segment of aspiring new entrants), but arguably has already/repeatedly proven to be quite effective as a strategy for *enhancing* market power under certain conditions (e.g., during the preRIR/early RIR era, in regions/bargaining situations where BYO addressing is unacceptable, etc.), one should assume that any shift toward strategic "IPv4 hoarding" would probably start -- and if left unchecked, end -- with the kind of entities that already control some other critical bottleneck(s) to Internet service delivery, as described in [1] above. > > Thanks for the explanation. > > Those are definitely significant concerns, but I'm not sure how needs > testing addresses them. On this point I am inclined to (reluctantly) agree. Assuming very very generously that I got everything right in the predictive model described above, continued needs testing ala current practice might slow the inexorable, but probably not all that much (esp. in relative terms, since the ultimate result would be a market in which IPv4 conferred the same sort of status that land conferred upon its owners during the century or two after land first became "alienable" but land ownership still remained an appx. universal bottleneck input to the accumulation of personal wealth and/or the achievement of social/political non-nonperson status). > Large ISPs already have the ability to horde > address space, in that they can make relatively minor changes that > would suddenly make them "need" (or, at least, qualify for) quite a > bit more address space than they already have. These entities are also > the ones most likely to be well versed in how to meet the letter of > ARIN's requirements. It seems like the needs testing simply adds one > more advantage they would have over their smaller counterparts and > end-users. > > Perhaps the solution to this problem is a reserved block for small > allocations, where the "reservation" survives 8.3 transfer? In the final analysis, there are only two possible outcomes that matter: either IPv6 (or some other, as-yet unimagined technology that provides the same or better functionality on terms that are least as open/accessible to as broad a segment of aspiring Internet contributors as would be served by, e.g., an inexhaustible supply of IPv4) "promptly" achieves perfectly substitutability with IPv4 -- which mean that what happens to IPv4 doesn't really matter -- or else it doesn't, and possession of IPv4 continues to provide a variety of technical and commercial opportunities that are unattainable (or attainable only on commercially unsustainable terms) to anyone who does not possess IPv4, in perpetuity -- or at least until someone actually comes up with that "as-yet unimagined technology." Personally, it's not clear to me how or why the suggested changes would be likely to materially alter the current trajectory, but that may just reflect a failure of imagination (or understanding) on my part. > At least in a more open market, such entities may also decide that > they can make more money using their space more effectively, and > selling the extra on, post-exhaustion, though I'll admit this seems > like a fairly unlikely outcome. > > --- Harrison Absent some kind of intervention (divine, infernal, or bootstrap-directed), the economic logic that I attempted to map out permits only one high probability outcome. Of course, anything is possible, for some definitions of "possible." And caveat emptor is still always good advice ;-) Cheers, TV From arinfactcheck at gmail.com Sat Feb 25 13:07:15 2012 From: arinfactcheck at gmail.com (Jim Fleming) Date: Sat, 25 Feb 2012 12:07:15 -0600 Subject: [arin-ppml] ARIN Fact Check: /8 For Sale Message-ID: ARIN Fact Check: /8 For Sale Regarding: http://blog.internetgovernance.org/ A whole /8 for sale by Milton Mueller on Tue 14 Feb 2012 06:15 PM EST ARIN POLICY QUESTION: Is the following exchange verified to originate from the ARIN CEO John Curran ? Governance of Internet number resources... by John Curran on Tue 14 Feb 2012 08:37 PM EST | Profile | Permanent Link Milton - I was surprised that your article did not mention the more interesting Internet governance aspects of the situation. As you are aware, the Regional Internet Registries (RIRs) manage Internet number resources based on policies developed in each region. These policies are developed by the community in each region using open and transparent processes. The participants in the policy development efforts are predominantly service providers, but individual end-users, governments, educational, and civil society organizations are also common participants. In short, the Regional Internet number registry system works well, and is recognized by ICANN as a successful mechanism for the overall technical coordination of Internet number resources. The policies of the Internet number registry system change to reflect the requirements of the community, and this includes adoption in many regions of policies which support limited market-based mechanisms for encouraging more efficient address utilization. These policies balance a number of additional considerations, including both communities need to reduce routing table impact from address deaggregation as well as encouragement of IPv6 as the long-term solution to IPv4 runout. Your article implies that ARIN's policies "obsolete", but I will note these policies have been frequently updated by the community to provide for reasonable address availability while still managing the technical aspects of keeping the Internet running. ARIN operates the registry according to the community developed policy, and this includes all IP address blocks in the region including "legacy blocks." We follow these policies when approving transfers of address space because it respects the bottom-up policy development that has occurred and that is the hallmark of good Internet governance. Are you suggesting the ARIN disregard the policies set by the community when processing requests for transfers? How does that reconcile with fair and open Internet governance? As ARIN was formed "to give the users of IP numbers (mostly Internet service providers, corporations and other large institutions) a voice in the policies by which they are managed and allocated within the North American region", I am uncertain how we can now ignore those policies, and am curious why you are now advocating that doing so makes for good Internet governance. In http://blog.internetgovernance.org/blog/_archives/2010/4/20/4509826.html, you wrote: "To sum up, we've had pretty open, focused and (with the one exception noted) fair discussions here. For those with the technical background to understand the Internet governance implications of RIR decisions and policies, I'd encourage participation and membership in ARIN. " For those who heeded your call and have been participating, do you now believe that their input (and the rest of the community's) should simply be set aside to allow transfers outside of the system for maximum financial gain? Clarification on this point would be helpful. Thank you, /John John Curran President and CEO ARIN Reply Re: Governance of Internet number resources... by Milton Mueller on Wed 15 Feb 2012 08:50 PM EST | Profile | Permanent Link Hello, John You ask, "Are you suggesting the ARIN disregard the policies set by the community when processing requests for transfers?" My answer: No. I am, however, noting (as an objective fact) that ARIN policies do not apply to entities that have not signed contracts with ARIN. ARIN staff, and many of the people active within it, seem to have trouble accepting that fact. I would also note that ARIN has been warned repeatedly by people like me that it should abandon or drastically liberalize needs assessments for transfers because the nature of "need" for addresses (as any economist will tell you) depends on the buyers' time horizons, future prospects and other factors that cannot be "demonstrated" in a needs assessment. What matters is how much the bidder values addresses, not some arbitrary technical assessment. ARIN policies which set a 3 month time horizon for proving need are simply going to drive anyone who can legally avoid it outside of ARIN's transfer system. ARIN is beleaguered by a small number of anti-market ideologues who never wanted to allow transfers to begin with and, failing in their quest to prevent them completely, have chosen to hobble 8.3 transfers as much as possible. Therefore, transfers "outside the system" will in fact take place because they are in the interests of both parties and there is nothing to legally prevent them. Reply Re: Re: Governance of Internet number resources... by John Curran on Thu 16 Feb 2012 09:29 AM EST | Profile | Permanent Link Milton - You should work on sharing your views on what makes for appropriate transfer policies within the policy development process; all are welcome to participate. Regarding transfers "outside the system", I will note that ARIN operates the registry for the community according to the policies that they set. There is no obligation for ARIN to update the registry contrary to these policies and doing so would be contrary to our very reason for existence. The rights that various parties have to address block registrations is governed by policy set by the community, and we update those registrations accordingly. If someone attempts to transfer the address block in the registry, that requires putting in a request that meets those policies. ARIN has never had to make any change to the registry contrary to the community's wishes. These policies fully govern updates to the registry, and transfers of these registrations does not otherwise occur. I imagine that there are many things that folks could claim to sell in this world, but they do not relate to the rights that parties have to address blocks in the registry unless they comply with the community policy for the registry. Best wishes, /John John Curran President and CEO ARIN Reply Re: A whole /8 for sale by Charles Lee on Fri 17 Feb 2012 04:34 PM EST | Profile | Permanent Link Dear Professor Mueller: An open marketplace for the legitimate and legal sale of distributed but unused ?Legacy? IPv4 number blocks is good for access service providers, content platforms and users, and it as well solves the acute problems of a ?hard? landing while the Internet transitions to IPv6. This marketplace should be welcomed by everyone, including ARIN?s Board of Trustees, members of its advisory council and members. This marketplace can, and does, provide an essential service to enable the continued growth of the Internet. To that end, we can again confirm that one of Addrex Inc.?s clients is offering for sale a ?Class A? or ?/8? number block. Your article refers to ?ARIN?s obsolete ?needs assessment? policies,? which is a characterization that Mr. Curran, CEO of ARIN, objects to on the basis of his belief that his members, who have voted for these needs-basis ?policies?, are reacting to the overall direction that the ?community? deems appropriate. In reality, it is not the ?overall? community but the controlling members of ARIN who are dictating policy. This setting of rules for a marketplace, under the guise of ?governance?, is simply the buyers colluding to maintain access to low price assets while the sellers, whom we represent, are not members and have zero contractual relationship with ARIN, are financially harmed due to this anti-competitive behavior. Addrex?s position is that the marketplace should determine who has the greatest need, instead of ARIN, or any other third party, picking the winners and losers. We refer to your July and November, 2008 articles found in the ?newsroom? on our website . Such a marketplace offers a pragmatic solution, global in scale, with legitimate participants, unhampered by the bureaucratic disputes and ever-changing policies of the current five RIRs. (?Policies?, we might add, voted upon by a minority of interested ?members? in this completely voluntary association run by and for these members to the exclusion of non-members. The concept of ?need? becomes ?relative need? rather than some engineering-based calculation of absolute need, to use the Professor?s own words.) You, again, unfortunately are correct when you reference ARIN?s veiled threats. One such threat is that ARIN might retaliate, against any of their members who participate in the marketplace, by ?reclaiming? other number blocks which were distributed under a separate contract to that member organization by ARIN. This threat effectively seeks to deny the ARIN membership organizations the opportunity to compete in a fair market. The consequence of such a threat is that it manipulates the marketplace, to the detriment of sellers, by chilling potential buyers, and therefore limiting competition, and artificially lowers the price a seller might receive. Another threat is that ARIN might discriminate against marketplace participants by refusing to update the registry to reflect the newly-acquired number block(s). Mr. Curran?s latest retort states that ?There is no obligation for ARIN to update the registry??. This, too, limits competition and artificially lowers the price a seller might receive. Both of these threats are purportedly based on ARIN?s policy positions and/or contract provisions. The entire concept that ARIN and its controlling members can openly conspire in such a manner is rather surprising. Your article, we respectfully suggest, however, is incorrect when you state that ??such a trade would erode ARIN?s control over the IPv4 address space?.? In point of fact, neither ARIN nor any of the other regional Internet IP number registries (RIRs) has any jurisdiction or control over Legacy IPv4 numbers given out by the federal government or its contractors (of which ARIN is not and has never been one) unless, of course, that Legacy number block holder has been convinced to sign a contract with ARIN which then gives ARIN contractual authority over that specific number block. ARIN is a Virginia, non-stock (i.e., no stockholders) corporation, which later obtained exemption from federal taxation, just like any other chamber of commerce or business league. The concept of ?jurisdiction? no more applies to ARIN than your local chamber of commerce?s ?authority? over you. ARIN has no contract, written or otherwise, with the federal government, the federal government?s contractor (ICANN), or, for that matter, with the seller of the Legacy IPv4 number blocks. ?Apparent authority,? based on repeated self-declarations of authority is not real authority, no matter how many times ARIN says it. In fact, recall that the IANA, a function under ICANN?s contract with the federal government (U.S. Department of Commerce), is the registry of record for the Class A Legacy blocks. We would encourage your readers to review the recent article published in the AIPLA by Ernesto Rubi, Esq. which also is found in our newsroom, for more information on this topic. Mr. Curran, truly a master at not answering a direct question, has continued to avoid a concrete answer to the question posed by the Professor: Does ARIN have authority over Legacy IPv4 numbers and their owners? Mr. Curran simply hides behind ?buttoms-up policies? (mentioned 15 times in his response to the Professor) and a bewildering statement that ?ARIN operates the registry according to the community developed policy and this includes all IP address blocks in the region including ?legacy blocks?.? We have no idea what that means and, perhaps, neither does anyone else, but it certainly doesn?t answer the direct question. ARIN?s actual position, when it is sued, is just the opposite. In sworn affidavits in federal district court by Mr. Ray Plzak, then President and CEO of ARIN, he clearly states that: ?Like other ?legacy? address holder?s issued resources before ARIN began, ARIN has never had an agreement with {the Legacy IPv4 owner} that would give it authority over those specific resources.? ARIN describes these ?resources? (i.e. Legacy IPv4 number blocks) as ?IP Resources Not Issued Or Controlled By ARIN.? We will not speculate as to why there is apparent reluctance to publically acknowledge and reiterate what has already been sworn to in a federal court of law. We believe and, through your published articles well before the founding of Addrex in 2009, it would appear that you too believe that this marketplace is good for the Internet. It will, in an efficient and effective manner, enable the redistribution of needed IPv4 number blocks. By unleashing the economic driving forces of supply and demand from the artificial constraints of a third-party ?needs assessment?, the marketplace will enable underutilized number blocks to be redistributed to entities which will put those number blocks into actual use. Professor Mueller, you are far more persuasive and articulate in the articles cited above and found on our website. We encourage your readers to take the time to refresh their memories by rereading those articles, especially in light of the clairvoyant nature of your predictions. ?Right On? comes to mind. This marketplace will help the Internet ?community? grow and prosper. Many in the ?community? mistakenly thought that the commercialization of Internet transport services, and the monetization of domain name registrations, would end the Internet. Instead, it created billions of dollars in value, technology employment and a world connected, even in revolutions, by a suite of Internet protocols, and ushered in an era of broader Internet adoption and utility. The marketplace in Legacy IPv4 number blocks will, despite the fears of a vocal few, help to bridge the technology gap in timing, global distribution, and the incompatibility with IPv6, while IPv6 gains favor and broader adoption. Finally, allow me to observe that this marketplace operates in parallel with ARIN?s distribution of its contract-based IPv4 number blocks. It is a marketplace which complements ARIN?s role and its sworn objectives of competition and portability found within its Articles of Incorporation. The marketplace is not, and does not seek to be, a replacement for ARIN. It is a means to help achieve our shared goals of continued Internet growth, stability and security. Respectfully, Charles Lee President Addrex, Inc. Reply Re: Re: A whole /8 for sale by John Curran on Tue 21 Feb 2012 07:12 PM EST | Profile | Permanent Link Several of Mr. Lee's remarks are well considered, particularly because of the overlap in his positions and that of the ARIN community. For example, it is recognized that a marketplace for IP address blocks will enable underutilized number blocks to be redistributed to entities which will put those number blocks into actual use, and the ARIN community has developed transfer policies for this very purpose. Another area of agreement is the purported goals stated by Mr. Lee of Internet growth, stability and security - these are definitely important goals held the ARIN community. However, there are differences in perspective that are too large to be done justice in a brief response, but I will outline some points for reader's consideration: - ARIN was specifically formed to take over these registration services and (per NSF) "give the users of IP numbers (mostly Internet service providers, corporations and other large institutions) a voice in the policies by which they are managed and allocated within the North American region." This was a conscious decision to change from USG directed operations to multi-stakeholder community-led self-governance (just as was done the ICANN formation which followed several years later) - How IP address blocks are maintained are of critical importance to the entire Internet community, and has implications for global routing, law enforcement, privacy, etc. ARIN provides a successful forum for discussion and resolution of these issues in an open and transparent manner. It is uncertain how these issues would be addressed if registry were not operated according to community policy. - There are ongoing public discussions regarding what transfer policies are most appropriate for the marketplace. Most recently, this has resulted in changes to policy including revising the needs-assessment test and simplifying how address blocks may be subdivided. These policies do have implications to the service provider community, and we encourage discussion of any other changes that will improve the marketplace. ARIN operates as part of the Internet number registry system as coordinated by ICANN, and while some of Mr. Lee's goals may be achievable within that system, some clearly lie outside the present structure. It remains an open Internet governance question as to what process should be used in considering large scale structural changes to the system itself. Best, /John John Curran President and CEO ARIN Reply Does ARIN have authority over Legacy IPv4 numbers and their owners... by _McTim on Fri 24 Feb 2012 04:56 AM EST | Profile | Permanent Link Is perhaps the wrong question. The more central question (to me) is, "Under what conditions was the /8 allocated" In other words, was the block delegated by IANA to your customer with any provisos about it's usage and what should happen if the block was no longer needed? Do you have a (redacted of course) copy of the document that granted the use of the /8 to your customer that you can post online? I know it is asking a lot in terms of transparency, but Milton is correct when he talks about "the "exceptional" status of IP address governance" in that IP address distribution is the most open, transparent and bottom-up of all Internet governance processes. I think the "marketplace" should uphold the same ideals. Reply Re: A whole /8 for sale by E.W. on Sun 19 Feb 2012 11:58 AM EST | Profile | Permanent Link Mr. Curran, You?re saying that the Arin community is setup to create public policies regarding the transfer of IP address space, and I see that. In fact, that community welcomes all to participate and share their thoughts and have a voice in the policy, and I see that too. Now, Dr. Mueller seems to be saying that some of that IP address space was given out before the Arin community even existed and the owners of that IP space aren?t beholden to the well wishes of the community regarding what they can do with their IP space, and I see that too. Sometimes an analogy using not so technical comparisons can bring a point to light and may help technical people like yourselves better understand what each is trying to say so I?ll offer one here. Suppose you?re a farmer with a hundred acres of good land that?s been in your family for years, and that you?ve taken pride in cultivating crops on that land, bringing them to market, and ensuring a livelihood for your family while helping the people around you who buy your produce. Now suppose, over the years, people start moving in around you and what used to be open and free country becomes more crowded. The people form a community. The community incorporates into a town. The town forms a government ? a well-meaning, democratic government where everyone in it can come to town meetings, voice their opinions, and vote on the issues of the day. Because free land is starting to become scarce, the democratic community passes a law that no one can just squat on free land and grow their crops. The remaining free land is put under the stewardship of the town, and if someone wants farmland, they have to apply for it at Town Hall, and a Board of Commissioners will decide who needs the land the most and how much each applicant can get. The applicant has to sign a Community Land Agreement that says if they later want to sell off some of their land, they have to get the Board?s permission and the Board has to approve the Buyer to make sure the Buyer really needs it. Now, one day the farmer decides he?d like to sell his land and retire. Or maybe he decides he just wants to give it away to his son who?s learned the ways of farming under his father. Someone on the Board gets wind of it and says, ?No. You can?t do that. Only the Board decides how much land anyone can get in a land transfer according to our public policies.? The farmer replies, ?This is my land. I own it. I can do with it as I please.? The Board member answers, ?We appreciate all the work you?ve put into the land, which helped make this area so prosperous. In fact, you?re a part of our community too. Why don?t you come to the next town meeting and have your voice heard by others in the community? Maybe you can convince them to change public policy so you can sell your land to whomever you like.? Now the farmer isn?t a lawyer or a politician, but he has pretty good horse sense about these kinds of things. So his answer to the Board member is pretty clear. ?You?ve invited me to participate in your meeting, and maybe I?ll do that one day if I have something to say about how the town is dividing up the land that it owns. But I own my land and what I do with it is up to me. It?s not up to a politician or a community, even if I?m part of the community.? ?Fine?, says the Board member. ?It?s true it?s your land and isn?t subject to the Community Land Agreement that others have signed and you can do with your land whatever you please. But if you sell it or give it to your son, we?re not going to recognize the sale in the County Register. And you know a lot of people look at that Register to recognize land ownership.? It?s about then, I think, that the farmer decides he?s had enough of community organizers and gets himself a good property attorney. And that?s where we seem to be now, if you get my analogy. - E.W. Reply Created and issued for a purpose... by John Curran on Tue 21 Feb 2012 05:24 PM EST | Profile | Permanent Link E.W - An interesting analogy, but as with many analogies, somewhat of an imperfect fit to the reality of the situation. The point omitted is that the original "land" (to keep with your analogy) was created by the Internet community for a particular purpose, and was issued to parties by various predecessor registries so that the parties could participate in the Internet and/or use of Internet technologies. There were always rules and policies for how such address space should be used, and these policies which were refined by community discussion over the years. Your farmer was brought to the new land by ship with the plan of building a community, and it was agreed upon arrival that they should each settle on some land to start that process. The fact is that your farmer has forgotten how he got the land in the first place doesn't relieve him of the obligations. Best wishes, /John John Curran President and CEO ARIN Reply Re: Created and issued for a purpose... by Ernesto Rubi on Wed 22 Feb 2012 10:37 AM EST | Profile | Permanent Link What continues to trouble me is this concept of "community" - akin to the incantations of the "proletariat" that many in the past have used to quash free will, free markets and progress. The first issue - which is an obvious one - is that the entire proposition/argument rests on the assumption that "the community can do no wrong." The second is that ARIN's argument that "our authority comes from the community" is devoid of any basis in reality. ARIN's election process is open only to ARIN members - not to members of the Internet community (broadly defined as all those folks who use the Internet, have an interest in the Internet functions, or are affected by the Internet). In fact, it's not clear how many ARIN members actually vote in the ARIN election process. If participation is less than 5% then how can ARIN claim to represent the "community", much less its own members? And who counts the votes? ARIN? That's process is obviously transparent right? =) I think using your logic you would agree that Raul Castro and Hugo Chavez are elected by their 'community' every 5 years...so...they're not despots, thugs or ruthless dictators but rather - they are duly 'elected' in an 'open' process, in and they represent their wonderful-yet-starved community - the "ploretariat." Reply open and transparent policy development by John Curran on Wed 22 Feb 2012 01:31 PM EST | Profile | Permanent Link Ernesto - The community is anyone who has an interest in Internet number resource policies. Anyone may participate, regardless of whether you have a number number resources, are a service provider, or are a member of ARIN. Feel free to get involved - see https://www.arin.net/participate/how_to_participate.html for details. Regarding whether the community can do wrong, what we have established a process by which everyone is equally able to participate by expressing a position and its basis. Policy proposals are considered in an open and transparent manner, and go through several stages of refinement before being adopted as new policy. We do utilize an elected advisory council to assist in policy development, but provide a low-threshold online petition as a check and balance on their actions. This process results in policy which has been discussed extensively before adoption, has had any concerns raised and considered, and still enjoys support of the community. To the extent that you have any suggestions for improvement of the policy development process, I would welcome any input. Thanks! /John John Curran President and CEO ARIN From tvest at eyeconomics.com Sat Feb 25 14:39:44 2012 From: tvest at eyeconomics.com (Tom Vest) Date: Sat, 25 Feb 2012 14:39:44 -0500 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> Message-ID: <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> Point of clarification below: On Feb 24, 2012, at 3:50 PM, Tom Vest wrote: > > On Feb 24, 2012, at 1:56 PM, Astrodog wrote: > >> On Fri, Feb 24, 2012 at 12:45 PM, Tom Vest wrote: >>> >>> On Feb 24, 2012, at 4:00 AM, Astrodog wrote: >>> >>>> On Thu, Feb 23, 2012 at 3:59 PM, John Curran wrote: >>>>> Milton - >>>>> >>>>> Is there an fairly straightforward economic explanation that addresses >>>>> the questions that John Sweeting raised? If so, could you outline it? >>>>> >>>>> Thanks! >>>>> /John >>>> >>>> Sorry for hijacking a bit, but I do have an answer. >>>> >>>>> From: "Sweeting, John" >>>>> Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification >>>>> Date: February 17, 2012 12:55:52 PM EST >>>>> To: Milton L Mueller , 'Paul Vixie' , >>>>> "jeffmehlenbacher at ipv4marketgroup.com" >>>>> >>>>> Cc: "arin-ppml at arin.net" >>>>> >>>>> Hi Milton, >>>>> >>>>> A few questions since I am not an expert in markets. Do you think there is >>>>> a scenario where the largest and wealthiest of the world's ISP's would buy >>>>> up as much address space as they could just to keep it out of the hands of >>>>> their competitors? Or new start ups in their markets? There are some very >>>>> wealthy companies out there that would not blink an eye at spending the >>>>> money needed to run their competitors out of the market but maybe that is >>>>> not possible in this particular market. Is there a way that a small but well >>>>> of portion of the market could insure prices are so high that the number of >>>>> competitors would be capped or even reduced? As I said I am not an expert on >>>>> markets so would very much welcome your views on this. >>>>> >>>>> Thanks, >>>>> John >>>>> ... >>>> >>>> It's very unlikely that large ISPs would make this sort of move for a >>>> number of reasons: >>>> >>>> First, it should be noted that even the largest ISPs are not >>>> particularly well positioned financially for this sort of endeavor. >>>> AT&T as an example, has ~$3.2 billion in cash, and after paying >>>> dividends, has lost money somewhat the past few years. When compared >>>> to some of the end users of address space, they simply wouldn't be >>>> competitive bidders, limiting how much of the "for sale" capacity they >>>> could acquire. Aside from this, the largest ISPs cannot cooperate on >>>> their purchases and would be at a significant disadvantage compared to >>>> their large competitors who did not attempt to drive up the price. >>>> >>>> It is also notable that large ISPs are not precluded from doing this >>>> under current policy. Simply through changing their address scheme for >>>> CPE, most large ISPs could nearly double their current allocation. >>>> Considering that in 8.3 transfers, they only need to show 24 month >>>> need, most could go significantly past this (for example, planning to >>>> offer customers public IPs for all of their various bits of network >>>> enabled equipment... note that under current policy, they do not have >>>> to actually do this. Merely intend to.) As a result of how rare >>>> auditing is, its unlikely that they would see revocations, either. >>>> Under current policy, a small ISP attempting to become a large one >>>> would face a much greater regulatory hurdle. >>>> >>>> I think there is consensus around the fact that long term, IPv4 >>>> allocations are likely to have little to no value. As a result, they >>>> are particularly unattractive as speculative investments. Someone >>>> holding a large number of addresses without utilizing them as an >>>> investment is taking a very large risk and would be very unlikely to >>>> hold those addresses for long, due to their value trending to zero. >>>> The same reasons why many of you have expressed... acceptance with >>>> removing needs requirements in a few years would make speculation on >>>> IP addresses today minimal. >>>> >>>> Finally, a major way to keep a handle on speculation would be for ARIN >>>> to hold some allocations back, post-exhaustion, with authorization to >>>> release some of those addresses if it appears that an entity is >>>> attempting to "corner the market" at a given point in time. Another >>>> option would be verbiage specifically prohibiting speculation, through >>>> post-purchase auditing. These do not need to occur frequently to >>>> eliminate speculative behavior. >>>> >>>> --- Harrison >>> >>> Hi Harrison, >>> >>> That's a fine set of arguments, and I do hope that you are right, but it might be worth considering the following: >>> >>> 1. Your examples don't capture the most compelling incentive(s) that might hypothetically motivate an operator's attempt to strategically leverage IPv4 scarcity for commercial/competitive purposes. The Internet has a strong tendency to "route around" congestion, censorship, scarcity, and other bad things, not only (or primarily) because the technology just works that way, but because clever operators are constantly, actively looking for opportunities to optimize their network cost/performance characteristics -- i.e., by topologically "bypassing" such problems. Of course, network input suppliers (the majority of which are now also "operators" themselves) are fully aware of this fact, and as a class they naturally tend to be reluctant to compete on price ( -> commodification) *if* there is any other alternative. Consequently, smart input suppliers are constantly trying to identify and "capture" profitable market niches that are very likely to remain profitable because operators cannot easily bypass them -- i.e., because they constitute a "bottleneck" to profitably providing network service to some place/population. Sometimes (increasingly uncommon IMO) such bottlenecks are be embodied in some unique technology or non-fixed asset. Today, in this industry, such bottlenecks are far more likely to be explicitly or implicitly spatial/geographic in nature, e.g., a particularly attractive room in a building (e.g., an IXP/IDC), building in a particular neighborhood, neighborhood right-of-way in a city, city in a country, etc., or indirect access to the same via interconnection/traffic exchange with another operator that has better or perhaps exclusive topological access to to the desired "turf." >>> >>> 2. At various times/places, IPv4 can and has embodied an absolute bottleneck of the former (non-fixed) kind, at least for some network operators and/or would-be operators. The possibility (or rather "eventuality") that IPv4 would become a bottleneck was one of the factors that drove the creation of the RIR (needs-based) allocation system, and the limited accessibility of IPv4 on non-adversarial terms to aspiring network operators outside the US was one of the demand drivers that led to the spread of that address distribution model to every continent. Today, thanks to NAT, RFC1918, and IPv6, IPv4's status as a "quantitative bottleneck" to delivering many kinds of services has diminished substantially -- i.e., life might be vastly easier if one had more IPv4, but -- assuming that you have any at all -- an independent network operator can generally remain in business as such, and even continue growing, by strategically reassigning/multiplexing and/or supplementing their limited IPv4 holdings with private addressing and/or IPv6. However, for the overwhelming majority of places and aspiring (future) service providers, IPv4 still remains an absolute/qualitative bottleneck to entering (appx. any/all) Internet services market, at least with the same sort of "independent" status that all of one's incumbent competitors would enjoy. >>> >>> One day that might not be true, but when (or whether) that day might come is anyone's guess. You may be right that there is "consensus around the fact that long term, IPv4 allocations are likely to have little to no value," but if so that consensus is overwhelmingly among individuals that work for institutions that (a) have to-date put little if anything at risk to hasten that outcome, and (b) simply by virtue of their possession of IPv4 could have quite a lot to gain if the consensus prediction turns out to be wrong. Obviously there are some exceptions, e.g., networks that have literally bet the farm on IPv6, but they represent a tiny minority among those holding the "consensus" view. >>> >>> Note that I'm not suggesting that people are misrepresenting their actual beliefs, but it's a lot easier to have strong opinions about future unknowns when being wrong is a (privately) cost-free option. Like I said, I do hope that the consensus is right, but caveat emptor is always good advice. >>> >>> 3. Given the fact that, by itself, a strategy of "IPv4 hoarding" seems unlikely pay off in the near future, and might never become an effective means of *establishing* market power (i.e., except under relatively improbable circumstances/scenarios, for the perennially modest market segment of aspiring new entrants), but arguably has already/repeatedly proven to be quite effective as a strategy for *enhancing* market power under certain conditions (e.g., during the preRIR/early RIR era, in regions/bargaining situations where BYO addressing is unacceptable, etc.), one should assume that any shift toward strategic "IPv4 hoarding" would probably start -- and if left unchecked, end -- with the kind of entities that already control some other critical bottleneck(s) to Internet service delivery, as described in [1] above. >> >> Thanks for the explanation. >> >> Those are definitely significant concerns, but I'm not sure how needs >> testing addresses them. > > On this point I am inclined to (reluctantly) agree. > Assuming very very generously that I got everything right in the predictive model described above, continued needs testing ala current practice might slow the inexorable, but probably not all that much (esp. in relative terms, since the ultimate result would be a market in which IPv4 conferred the same sort of status that land conferred upon its owners during the century or two after land first became "alienable" but land ownership still remained an appx. universal bottleneck input to the accumulation of personal wealth and/or the achievement of social/political non-nonperson status). Addendum: Even if one agrees with me that at strategy of "IPv4 hoarding" would be unlikely to pay off for a "pure speculator" (i.e., an entity that could not satisfy any form of needs-based justification requirement) in the near term -- or rather, that it would be *relatively less likely* to pay off for them, as opposed to an entity that might be able to satisfy some kinds of needs nests -- that does NOT imply ANY of the following: -- that all "pure speculators" are by definition motivated solely by short-term payoffs; with "safe" economy interest rates parked at +/- 0.00% indefinitely, demand for everything else flat, and octillions of idled $?? just waiting patiently for the next attractor to appear, any such assumption would be foolish; -- that "pure speculators" would be necessarily be interested in or obliged to participate in the actual "IPv4 hoarding" themselves; -- that "pure speculators" should be incentivized to put any of this to the test, e.g., by dropping the justification requirement altogether. Short version: when/if these messages are tallied for informational purposes, please add this one to the "opposed" column. TV >> Large ISPs already have the ability to horde >> address space, in that they can make relatively minor changes that >> would suddenly make them "need" (or, at least, qualify for) quite a >> bit more address space than they already have. These entities are also >> the ones most likely to be well versed in how to meet the letter of >> ARIN's requirements. It seems like the needs testing simply adds one >> more advantage they would have over their smaller counterparts and >> end-users. >> >> Perhaps the solution to this problem is a reserved block for small >> allocations, where the "reservation" survives 8.3 transfer? > > In the final analysis, there are only two possible outcomes that matter: either IPv6 (or some other, as-yet unimagined technology that provides the same or better functionality on terms that are least as open/accessible to as broad a segment of aspiring Internet contributors as would be served by, e.g., an inexhaustible supply of IPv4) "promptly" achieves perfectly substitutability with IPv4 -- which mean that what happens to IPv4 doesn't really matter -- or else it doesn't, and possession of IPv4 continues to provide a variety of technical and commercial opportunities that are unattainable (or attainable only on commercially unsustainable terms) to anyone who does not possess IPv4, in perpetuity -- or at least until someone actually comes up with that "as-yet unimagined technology." > > Personally, it's not clear to me how or why the suggested changes would be likely to materially alter the current trajectory, but that may just reflect a failure of imagination (or understanding) on my part. > >> At least in a more open market, such entities may also decide that >> they can make more money using their space more effectively, and >> selling the extra on, post-exhaustion, though I'll admit this seems >> like a fairly unlikely outcome. >> >> --- Harrison > > Absent some kind of intervention (divine, infernal, or bootstrap-directed), the economic logic that I attempted to map out permits only one high probability outcome. > > Of course, anything is possible, for some definitions of "possible." > > And caveat emptor is still always good advice ;-) > > Cheers, > > TV > > From jcurran at arin.net Sat Feb 25 14:54:18 2012 From: jcurran at arin.net (John Curran) Date: Sat, 25 Feb 2012 19:54:18 +0000 Subject: [arin-ppml] ARIN Fact Check: /8 For Sale In-Reply-To: References: Message-ID: <8AED38F5-47D7-4F9C-97F8-AED5ACCEA340@corp.arin.net> On Feb 25, 2012, at 1:07 PM, Jim Fleming wrote: > Regarding: > http://blog.internetgovernance.org/ > A whole /8 for sale > by Milton Mueller on Tue 14 Feb 2012 06:15 PM EST > > ARIN POLICY QUESTION: > > Is the following exchange verified to originate from the ARIN CEO John Curran ? Jim - I do not know what policy question you refer, but I did respond to the several entries in the referenced blog. I hope this answers your question, /John John Curran President and CEO ARIN From arinfactcheck at gmail.com Sat Feb 25 15:06:56 2012 From: arinfactcheck at gmail.com (Jim Fleming) Date: Sat, 25 Feb 2012 14:06:56 -0600 Subject: [arin-ppml] ARIN Fact Check: Term Limit Policies, etc. Message-ID: ARIN Fact Check: Term Limit Policies 1. ARIN was founded in 1997. 2. ARIN Founders have extracted substantial financial gains from the alleged non-profit corporation for many years 3. Recent 990 filings show former ARIN executives with $250,000+ annual compensation ARIN Policy Question(s) What are the Term Limit and Compensation Limit Policies of ARIN ? From jcurran at arin.net Sat Feb 25 15:25:08 2012 From: jcurran at arin.net (John Curran) Date: Sat, 25 Feb 2012 20:25:08 +0000 Subject: [arin-ppml] ARIN Fact Check: Term Limit Policies, etc. In-Reply-To: References: Message-ID: <6796056A-6443-4AF3-8254-C279642BED47@corp.arin.net> On Feb 25, 2012, at 3:06 PM, Jim Fleming wrote: > ARIN Fact Check: Term Limit Policies > > 1. ARIN was founded in 1997. > 2. ARIN Founders have extracted substantial financial gains from the > alleged non-profit corporation for many years > 3. Recent 990 filings show former ARIN executives with $250,000+ > annual compensation > > ARIN Policy Question(s) > > What are the Term Limit and Compensation Limit Policies of ARIN ? Jim - The PPML mailing list is for Internet number resource policy questions. Your query is not about number resource policy. In the future, please feel free to send me questions such these or post them to arin-discuss, and I will get you answers. Summary answer to your query: 1) No term limits on trustees at present; note that trustees are not compensated for their service. 2) As President and CEO, I am indeed compensated; our compensation philosophy document is online here: https://www.arin.net/about_us/corp_docs/compensation.html Thanks! /John John Curran President and CEO ARIN From sean.copeland at ibips.com Sat Feb 25 15:30:06 2012 From: sean.copeland at ibips.com (Sean Copeland) Date: Sat, 25 Feb 2012 12:30:06 -0800 Subject: [arin-ppml] ARIN-PPML Digest, Vol 80, Issue 51 In-Reply-To: References: Message-ID: Sent from my iPad On 2012-02-25, at 11:39, arin-ppml-request at arin.net wrote: > Send ARIN-PPML mailing list submissions to > arin-ppml at arin.net > > To subscribe or unsubscribe via the World Wide Web, visit > http://lists.arin.net/mailman/listinfo/arin-ppml > or, via email, send a message with subject or body 'help' to > arin-ppml-request at arin.net > > You can reach the person managing the list at > arin-ppml-owner at arin.net > > When replying, please edit your Subject line so it is more specific > than "Re: Contents of ARIN-PPML digest..." > > > Today's Topics: > > 1. ARIN Fact Check: /8 For Sale (Jim Fleming) > 2. Re: Fwd: ARIN-prop-165 Eliminate Needs-Based Justification > (Tom Vest) > > > ---------------------------------------------------------------------- > > Message: 1 > Date: Sat, 25 Feb 2012 12:07:15 -0600 > From: Jim Fleming > To: arin-ppml at arin.net > Subject: [arin-ppml] ARIN Fact Check: /8 For Sale > Message-ID: > > Content-Type: text/plain; charset=windows-1252 > > ARIN Fact Check: /8 For Sale > > Regarding: > http://blog.internetgovernance.org/ > A whole /8 for sale > by Milton Mueller on Tue 14 Feb 2012 06:15 PM EST > > ARIN POLICY QUESTION: > > Is the following exchange verified to originate from the ARIN CEO John Curran ? > > Governance of Internet number resources... > by John Curran on Tue 14 Feb 2012 08:37 PM EST | Profile | Permanent Link > Milton - > > I was surprised that your article did not mention the more interesting > Internet governance aspects of the situation. > > As you are aware, the Regional Internet Registries (RIRs) manage > Internet number resources based on policies developed in each region. > These policies are developed by the community in each region using > open and transparent processes. The participants in the policy > development efforts are predominantly service providers, but > individual end-users, governments, educational, and civil society > organizations are also common participants. > > In short, the Regional Internet number registry system works well, and > is recognized by ICANN as a successful mechanism for the overall > technical coordination of Internet number resources. > > The policies of the Internet number registry system change to reflect > the requirements of the community, and this includes adoption in many > regions of policies which support limited market-based mechanisms for > encouraging more efficient address utilization. These policies balance > a number of additional considerations, including both communities need > to reduce routing table impact from address deaggregation as well as > encouragement of IPv6 as the long-term solution to IPv4 runout. > > Your article implies that ARIN's policies "obsolete", but I will note > these policies have been frequently updated by the community to > provide for reasonable address availability while still managing the > technical aspects of keeping the Internet running. > > ARIN operates the registry according to the community developed > policy, and this includes all IP address blocks in the region > including "legacy blocks." We follow these policies when approving > transfers of address space because it respects the bottom-up policy > development that has occurred and that is the hallmark of good > Internet governance. > > Are you suggesting the ARIN disregard the policies set by the > community when processing requests for transfers? How does that > reconcile with fair and open Internet governance? As ARIN was formed > "to give the users of IP numbers (mostly Internet service providers, > corporations and other large institutions) a voice in the policies by > which they are managed and allocated within the North American > region", I am uncertain how we can now ignore those policies, and am > curious why you are now advocating that doing so makes for good > Internet governance. > > In http://blog.internetgovernance.org/blog/_archives/2010/4/20/4509826.html, > you wrote: "To sum up, we've had pretty open, focused and (with the > one exception noted) fair discussions here. For those with the > technical background to understand the Internet governance > implications of RIR decisions and policies, I'd encourage > participation and membership in ARIN. " > > For those who heeded your call and have been participating, do you now > believe that their input (and the rest of the community's) should > simply be set aside to allow transfers outside of the system for > maximum financial gain? > > Clarification on this point would be helpful. > > Thank you, > /John > > John Curran > President and CEO > ARIN > > > > > > Reply > Re: Governance of Internet number resources... > by Milton Mueller on Wed 15 Feb 2012 08:50 PM EST | Profile | Permanent Link > Hello, John > You ask, "Are you suggesting the ARIN disregard the policies set by > the community when processing requests for transfers?" My answer: No. > I am, however, noting (as an objective fact) that ARIN policies do not > apply to entities that have not signed contracts with ARIN. ARIN > staff, and many of the people active within it, seem to have trouble > accepting that fact. > I would also note that ARIN has been warned repeatedly by people like > me that it should abandon or drastically liberalize needs assessments > for transfers because the nature of "need" for addresses (as any > economist will tell you) depends on the buyers' time horizons, future > prospects and other factors that cannot be "demonstrated" in a needs > assessment. What matters is how much the bidder values addresses, not > some arbitrary technical assessment. ARIN policies which set a 3 month > time horizon for proving need are simply going to drive anyone who can > legally avoid it outside of ARIN's transfer system. ARIN is > beleaguered by a small number of anti-market ideologues who never > wanted to allow transfers to begin with and, failing in their quest to > prevent them completely, have chosen to hobble 8.3 transfers as much > as possible. Therefore, transfers "outside the system" will in fact > take place because they are in the interests of both parties and there > is nothing to legally prevent them. > Reply > Re: Re: Governance of Internet number resources... > by John Curran on Thu 16 Feb 2012 09:29 AM EST | Profile | Permanent Link > Milton - > > You should work on sharing your views on what makes for appropriate > transfer policies within the policy development process; all are > welcome to participate. > > Regarding transfers "outside the system", I will note that ARIN > operates the registry for the community according to the policies that > they set. There is no obligation for ARIN to update the registry > contrary to these policies and doing so would be contrary to our very > reason for existence. > > The rights that various parties have to address block registrations is > governed by policy set by the community, and we update those > registrations accordingly. If someone attempts to transfer the address > block in the registry, that requires putting in a request that meets > those policies. > > ARIN has never had to make any change to the registry contrary to the > community's wishes. These policies fully govern updates to the > registry, and transfers of these registrations does not otherwise > occur. I imagine that there are many things that folks could claim to > sell in this world, but they do not relate to the rights that parties > have to address blocks in the registry unless they comply with the > community policy for the registry. > > Best wishes, > /John > > John Curran > President and CEO > ARIN > > > Reply > Re: A whole /8 for sale > by Charles Lee on Fri 17 Feb 2012 04:34 PM EST | Profile | Permanent Link > Dear Professor Mueller: > > An open marketplace for the legitimate and legal sale of distributed > but unused ?Legacy? IPv4 number blocks is good for access service > providers, content platforms and users, and it as well solves the > acute problems of a ?hard? landing while the Internet transitions to > IPv6. This marketplace should be welcomed by everyone, including > ARIN?s Board of Trustees, members of its advisory council and members. > This marketplace can, and does, provide an essential service to enable > the continued growth of the Internet. > > To that end, we can again confirm that one of Addrex Inc.?s clients is > offering for sale a ?Class A? or ?/8? number block. > > Your article refers to ?ARIN?s obsolete ?needs assessment? policies,? > which is a characterization that Mr. Curran, CEO of ARIN, objects to > on the basis of his belief that his members, who have voted for these > needs-basis ?policies?, are reacting to the overall direction that the > ?community? deems appropriate. In reality, it is not the ?overall? > community but the controlling members of ARIN who are dictating > policy. This setting of rules for a marketplace, under the guise of > ?governance?, is simply the buyers colluding to maintain access to low > price assets while the sellers, whom we represent, are not members and > have zero contractual relationship with ARIN, are financially harmed > due to this anti-competitive behavior. > > Addrex?s position is that the marketplace should determine who has the > greatest need, instead of ARIN, or any other third party, picking the > winners and losers. We refer to your July and November, 2008 articles > found in the ?newsroom? on our website . Such a marketplace offers a > pragmatic solution, global in scale, with legitimate participants, > unhampered by the bureaucratic disputes and ever-changing policies of > the current five RIRs. (?Policies?, we might add, voted upon by a > minority of interested ?members? in this completely voluntary > association run by and for these members to the exclusion of > non-members. The concept of ?need? becomes ?relative need? rather than > some engineering-based calculation of absolute need, to use the > Professor?s own words.) > > You, again, unfortunately are correct when you reference ARIN?s veiled > threats. One such threat is that ARIN might retaliate, against any of > their members who participate in the marketplace, by ?reclaiming? > other number blocks which were distributed under a separate contract > to that member organization by ARIN. This threat effectively seeks to > deny the ARIN membership organizations the opportunity to compete in a > fair market. The consequence of such a threat is that it manipulates > the marketplace, to the detriment of sellers, by chilling potential > buyers, and therefore limiting competition, and artificially lowers > the price a seller might receive. Another threat is that ARIN might > discriminate against marketplace participants by refusing to update > the registry to reflect the newly-acquired number block(s). Mr. > Curran?s latest retort states that ?There is no obligation for ARIN to > update the registry??. This, too, limits competition and artificially > lowers the price a seller might receive. Both of these threats are > purportedly based on ARIN?s policy positions and/or contract > provisions. The entire concept that ARIN and its controlling members > can openly conspire in such a manner is rather surprising. > > Your article, we respectfully suggest, however, is incorrect when you > state that ??such a trade would erode ARIN?s control over the IPv4 > address space?.? In point of fact, neither ARIN nor any of the other > regional Internet IP number registries (RIRs) has any jurisdiction or > control over Legacy IPv4 numbers given out by the federal government > or its contractors (of which ARIN is not and has never been one) > unless, of course, that Legacy number block holder has been convinced > to sign a contract with ARIN which then gives ARIN contractual > authority over that specific number block. ARIN is a Virginia, > non-stock (i.e., no stockholders) corporation, which later obtained > exemption from federal taxation, just like any other chamber of > commerce or business league. The concept of ?jurisdiction? no more > applies to ARIN than your local chamber of commerce?s ?authority? over > you. ARIN has no contract, written or otherwise, with the federal > government, the federal government?s contractor (ICANN), or, for that > matter, with the seller of the Legacy IPv4 number blocks. ?Apparent > authority,? based on repeated self-declarations of authority is not > real authority, no matter how many times ARIN says it. In fact, recall > that the IANA, a function under ICANN?s contract with the federal > government (U.S. Department of Commerce), is the registry of record > for the Class A Legacy blocks. We would encourage your readers to > review the recent article published in the AIPLA by Ernesto Rubi, Esq. > which also is found in our newsroom, for more information on this > topic. > > Mr. Curran, truly a master at not answering a direct question, has > continued to avoid a concrete answer to the question posed by the > Professor: Does ARIN have authority over Legacy IPv4 numbers and their > owners? Mr. Curran simply hides behind ?buttoms-up policies? > (mentioned 15 times in his response to the Professor) and a > bewildering statement that ?ARIN operates the registry according to > the community developed policy and this includes all IP address blocks > in the region including ?legacy blocks?.? We have no idea what that > means and, perhaps, neither does anyone else, but it certainly doesn?t > answer the direct question. ARIN?s actual position, when it is sued, > is just the opposite. In sworn affidavits in federal district court by > Mr. Ray Plzak, then President and CEO of ARIN, he clearly states that: > ?Like other ?legacy? address holder?s issued resources before ARIN > began, ARIN has never had an agreement with {the Legacy IPv4 owner} > that would give it authority over those specific resources.? ARIN > describes these ?resources? (i.e. Legacy IPv4 number blocks) as ?IP > Resources Not Issued Or Controlled By ARIN.? We will not speculate as > to why there is apparent reluctance to publically acknowledge and > reiterate what has already been sworn to in a federal court of law. > > We believe and, through your published articles well before the > founding of Addrex in 2009, it would appear that you too believe that > this marketplace is good for the Internet. It will, in an efficient > and effective manner, enable the redistribution of needed IPv4 number > blocks. By unleashing the economic driving forces of supply and demand > from the artificial constraints of a third-party ?needs assessment?, > the marketplace will enable underutilized number blocks to be > redistributed to entities which will put those number blocks into > actual use. Professor Mueller, you are far more persuasive and > articulate in the articles cited above and found on our website. We > encourage your readers to take the time to refresh their memories by > rereading those articles, especially in light of the clairvoyant > nature of your predictions. ?Right On? comes to mind. This marketplace > will help the Internet ?community? grow and prosper. Many in the > ?community? mistakenly thought that the commercialization of Internet > transport services, and the monetization of domain name registrations, > would end the Internet. Instead, it created billions of dollars in > value, technology employment and a world connected, even in > revolutions, by a suite of Internet protocols, and ushered in an era > of broader Internet adoption and utility. The marketplace in Legacy > IPv4 number blocks will, despite the fears of a vocal few, help to > bridge the technology gap in timing, global distribution, and the > incompatibility with IPv6, while IPv6 gains favor and broader > adoption. > > Finally, allow me to observe that this marketplace operates in > parallel with ARIN?s distribution of its contract-based IPv4 number > blocks. It is a marketplace which complements ARIN?s role and its > sworn objectives of competition and portability found within its > Articles of Incorporation. The marketplace is not, and does not seek > to be, a replacement for ARIN. It is a means to help achieve our > shared goals of continued Internet growth, stability and security. > > Respectfully, > > Charles Lee > President > Addrex, Inc. > Reply > Re: Re: A whole /8 for sale > by John Curran on Tue 21 Feb 2012 07:12 PM EST | Profile | Permanent Link > Several of Mr. Lee's remarks are well considered, particularly because > of the overlap in his positions and that of the ARIN community. > > For example, it is recognized that a marketplace for IP address blocks > will enable underutilized number blocks to be redistributed to > entities which will put those number blocks into actual use, and the > ARIN community has developed transfer policies for this very purpose. > Another area of agreement is the purported goals stated by Mr. Lee of > Internet growth, stability and security - these are definitely > important goals held the ARIN community. > > However, there are differences in perspective that are too large to be > done justice in a brief response, but I will outline some points for > reader's consideration: > > - ARIN was specifically formed to take over these registration > services and (per NSF) "give the users of IP numbers (mostly Internet > service providers, corporations and other large institutions) a voice > in the policies by which they are managed and allocated within the > North American region." This was a conscious decision to change from > USG directed operations to multi-stakeholder community-led > self-governance (just as was done the ICANN formation which followed > several years later) > > - How IP address blocks are maintained are of critical importance to > the entire Internet community, and has implications for global > routing, law enforcement, privacy, etc. ARIN provides a successful > forum for discussion and resolution of these issues in an open and > transparent manner. It is uncertain how these issues would be > addressed if registry were not operated according to community policy. > > - There are ongoing public discussions regarding what transfer > policies are most appropriate for the marketplace. Most recently, this > has resulted in changes to policy including revising the > needs-assessment test and simplifying how address blocks may be > subdivided. These policies do have implications to the service > provider community, and we encourage discussion of any other changes > that will improve the marketplace. > > ARIN operates as part of the Internet number registry system as > coordinated by ICANN, and while some of Mr. Lee's goals may be > achievable within that system, some clearly lie outside the present > structure. It remains an open Internet governance question as to what > process should be used in considering large scale structural changes > to the system itself. > > Best, > /John > > John Curran > President and CEO > ARIN > Reply > Does ARIN have authority over Legacy IPv4 numbers and their owners... > by _McTim on Fri 24 Feb 2012 04:56 AM EST | Profile | Permanent Link > Is perhaps the wrong question. > > The more central question (to me) is, "Under what conditions was the > /8 allocated" In other words, was the block delegated by IANA to your > customer with any provisos about it's usage and what should happen if > the block was no longer needed? > > Do you have a (redacted of course) copy of the document that granted > the use of the /8 to your customer that you can post online? > > I know it is asking a lot in terms of transparency, but Milton is > correct when he talks about "the "exceptional" status of IP address > governance" in that IP address distribution is the most open, > transparent and bottom-up of all Internet governance processes. I > think the "marketplace" should uphold the same ideals. > > > > Reply > Re: A whole /8 for sale > by E.W. on Sun 19 Feb 2012 11:58 AM EST | Profile | Permanent Link > Mr. Curran, > > You?re saying that the Arin community is setup to create public > policies regarding the transfer of IP address space, and I see that. > In fact, that community welcomes all to participate and share their > thoughts and have a voice in the policy, and I see that too. > > Now, Dr. Mueller seems to be saying that some of that IP address space > was given out before the Arin community even existed and the owners of > that IP space aren?t beholden to the well wishes of the community > regarding what they can do with their IP space, and I see that too. > > Sometimes an analogy using not so technical comparisons can bring a > point to light and may help technical people like yourselves better > understand what each is trying to say so I?ll offer one here. Suppose > you?re a farmer with a hundred acres of good land that?s been in your > family for years, and that you?ve taken pride in cultivating crops on > that land, bringing them to market, and ensuring a livelihood for your > family while helping the people around you who buy your produce. > > Now suppose, over the years, people start moving in around you and > what used to be open and free country becomes more crowded. The people > form a community. The community incorporates into a town. The town > forms a government ? a well-meaning, democratic government where > everyone in it can come to town meetings, voice their opinions, and > vote on the issues of the day. > > Because free land is starting to become scarce, the democratic > community passes a law that no one can just squat on free land and > grow their crops. The remaining free land is put under the stewardship > of the town, and if someone wants farmland, they have to apply for it > at Town Hall, and a Board of Commissioners will decide who needs the > land the most and how much each applicant can get. The applicant has > to sign a Community Land Agreement that says if they later want to > sell off some of their land, they have to get the Board?s permission > and the Board has to approve the Buyer to make sure the Buyer really > needs it. > > Now, one day the farmer decides he?d like to sell his land and retire. > Or maybe he decides he just wants to give it away to his son who?s > learned the ways of farming under his father. Someone on the Board > gets wind of it and says, ?No. You can?t do that. Only the Board > decides how much land anyone can get in a land transfer according to > our public policies.? > > The farmer replies, ?This is my land. I own it. I can do with it as I please.? > > The Board member answers, ?We appreciate all the work you?ve put into > the land, which helped make this area so prosperous. In fact, you?re a > part of our community too. Why don?t you come to the next town meeting > and have your voice heard by others in the community? Maybe you can > convince them to change public policy so you can sell your land to > whomever you like.? > > Now the farmer isn?t a lawyer or a politician, but he has pretty good > horse sense about these kinds of things. So his answer to the Board > member is pretty clear. ?You?ve invited me to participate in your > meeting, and maybe I?ll do that one day if I have something to say > about how the town is dividing up the land that it owns. But I own my > land and what I do with it is up to me. It?s not up to a politician or > a community, even if I?m part of the community.? > > ?Fine?, says the Board member. ?It?s true it?s your land and isn?t > subject to the Community Land Agreement that others have signed and > you can do with your land whatever you please. But if you sell it or > give it to your son, we?re not going to recognize the sale in the > County Register. And you know a lot of people look at that Register to > recognize land ownership.? > > It?s about then, I think, that the farmer decides he?s had enough of > community organizers and gets himself a good property attorney. > > And that?s where we seem to be now, if you get my analogy. > > - E.W. > Reply > Created and issued for a purpose... > by John Curran on Tue 21 Feb 2012 05:24 PM EST | Profile | Permanent Link > E.W - > > An interesting analogy, but as with many analogies, somewhat of an > imperfect fit to the reality of the situation. > > The point omitted is that the original "land" (to keep with your > analogy) was created by the Internet community for a particular > purpose, and was issued to parties by various predecessor registries > so that the parties could participate in the Internet and/or use of > Internet technologies. There were always rules and policies for how > such address space should be used, and these policies which were > refined by community discussion over the years. > > Your farmer was brought to the new land by ship with the plan of > building a community, and it was agreed upon arrival that they should > each settle on some land to start that process. > > The fact is that your farmer has forgotten how he got the land in the > first place doesn't relieve him of the obligations. > > Best wishes, > /John > > John Curran > President and CEO > ARIN > Reply > Re: Created and issued for a purpose... > by Ernesto Rubi on Wed 22 Feb 2012 10:37 AM EST | Profile | Permanent Link > What continues to trouble me is this concept of "community" - akin to > the incantations of the "proletariat" that many in the past have used > to quash free will, free markets and progress. > > The first issue - which is an obvious one - is that the entire > proposition/argument rests on the assumption that "the community can > do no wrong." > > The second is that ARIN's argument that "our authority comes from the > community" is devoid of any basis in reality. ARIN's election process > is open only to ARIN members - not to members of the Internet > community (broadly defined as all those folks who use the Internet, > have an interest in the Internet functions, or are affected by the > Internet). In fact, it's not clear how many ARIN members actually vote > in the ARIN election process. If participation is less than 5% then > how can ARIN claim to represent the "community", much less its own > members? And who counts the votes? ARIN? That's process is obviously > transparent right? =) > > I think using your logic you would agree that Raul Castro and Hugo > Chavez are elected by their 'community' every 5 years...so...they're > not despots, thugs or ruthless dictators but rather - they are duly > 'elected' in an 'open' process, in and they represent their > wonderful-yet-starved community - the "ploretariat." > > Reply > open and transparent policy development > by John Curran on Wed 22 Feb 2012 01:31 PM EST | Profile | Permanent Link > Ernesto - > > The community is anyone who has an interest in Internet number > resource policies. Anyone may participate, regardless of whether you > have a number number resources, are a service provider, or are a > member of ARIN. > Feel free to get involved - see > https://www.arin.net/participate/how_to_participate.html for details. > > Regarding whether the community can do wrong, what we have established > a process by which everyone is equally able to participate by > expressing a position and its basis. > Policy proposals are considered in an open and transparent manner, and > go through several stages of refinement before being adopted as new > policy. We do utilize an elected advisory council to assist in policy > development, but provide a low-threshold online petition as a check > and balance on their actions. > > This process results in policy which has been discussed extensively > before adoption, has had any concerns raised and considered, and still > enjoys support of the community. > > To the extent that you have any suggestions for improvement of the > policy development process, I would welcome any input. > > Thanks! > /John > > John Curran > President and CEO > ARIN > > > ------------------------------ > > Message: 2 > Date: Sat, 25 Feb 2012 14:39:44 -0500 > From: Tom Vest > To: ARIN PPML > Subject: Re: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based > Justification > Message-ID: <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6 at eyeconomics.com> > Content-Type: text/plain; charset=utf-8 > > Point of clarification below: > > On Feb 24, 2012, at 3:50 PM, Tom Vest wrote: > >> >> On Feb 24, 2012, at 1:56 PM, Astrodog wrote: >> >>> On Fri, Feb 24, 2012 at 12:45 PM, Tom Vest wrote: >>>> >>>> On Feb 24, 2012, at 4:00 AM, Astrodog wrote: >>>> >>>>> On Thu, Feb 23, 2012 at 3:59 PM, John Curran wrote: >>>>>> Milton - >>>>>> >>>>>> Is there an fairly straightforward economic explanation that addresses >>>>>> the questions that John Sweeting raised? If so, could you outline it? >>>>>> >>>>>> Thanks! >>>>>> /John >>>>> >>>>> Sorry for hijacking a bit, but I do have an answer. >>>>> >>>>>> From: "Sweeting, John" >>>>>> Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification >>>>>> Date: February 17, 2012 12:55:52 PM EST >>>>>> To: Milton L Mueller , 'Paul Vixie' , >>>>>> "jeffmehlenbacher at ipv4marketgroup.com" >>>>>> >>>>>> Cc: "arin-ppml at arin.net" >>>>>> >>>>>> Hi Milton, >>>>>> >>>>>> A few questions since I am not an expert in markets. Do you think there is >>>>>> a scenario where the largest and wealthiest of the world's ISP's would buy >>>>>> up as much address space as they could just to keep it out of the hands of >>>>>> their competitors? Or new start ups in their markets? There are some very >>>>>> wealthy companies out there that would not blink an eye at spending the >>>>>> money needed to run their competitors out of the market but maybe that is >>>>>> not possible in this particular market. Is there a way that a small but well >>>>>> of portion of the market could insure prices are so high that the number of >>>>>> competitors would be capped or even reduced? As I said I am not an expert on >>>>>> markets so would very much welcome your views on this. >>>>>> >>>>>> Thanks, >>>>>> John >>>>>> ... >>>>> >>>>> It's very unlikely that large ISPs would make this sort of move for a >>>>> number of reasons: >>>>> >>>>> First, it should be noted that even the largest ISPs are not >>>>> particularly well positioned financially for this sort of endeavor. >>>>> AT&T as an example, has ~$3.2 billion in cash, and after paying >>>>> dividends, has lost money somewhat the past few years. When compared >>>>> to some of the end users of address space, they simply wouldn't be >>>>> competitive bidders, limiting how much of the "for sale" capacity they >>>>> could acquire. Aside from this, the largest ISPs cannot cooperate on >>>>> their purchases and would be at a significant disadvantage compared to >>>>> their large competitors who did not attempt to drive up the price. >>>>> >>>>> It is also notable that large ISPs are not precluded from doing this >>>>> under current policy. Simply through changing their address scheme for >>>>> CPE, most large ISPs could nearly double their current allocation. >>>>> Considering that in 8.3 transfers, they only need to show 24 month >>>>> need, most could go significantly past this (for example, planning to >>>>> offer customers public IPs for all of their various bits of network >>>>> enabled equipment... note that under current policy, they do not have >>>>> to actually do this. Merely intend to.) As a result of how rare >>>>> auditing is, its unlikely that they would see revocations, either. >>>>> Under current policy, a small ISP attempting to become a large one >>>>> would face a much greater regulatory hurdle. >>>>> >>>>> I think there is consensus around the fact that long term, IPv4 >>>>> allocations are likely to have little to no value. As a result, they >>>>> are particularly unattractive as speculative investments. Someone >>>>> holding a large number of addresses without utilizing them as an >>>>> investment is taking a very large risk and would be very unlikely to >>>>> hold those addresses for long, due to their value trending to zero. >>>>> The same reasons why many of you have expressed... acceptance with >>>>> removing needs requirements in a few years would make speculation on >>>>> IP addresses today minimal. >>>>> >>>>> Finally, a major way to keep a handle on speculation would be for ARIN >>>>> to hold some allocations back, post-exhaustion, with authorization to >>>>> release some of those addresses if it appears that an entity is >>>>> attempting to "corner the market" at a given point in time. Another >>>>> option would be verbiage specifically prohibiting speculation, through >>>>> post-purchase auditing. These do not need to occur frequently to >>>>> eliminate speculative behavior. >>>>> >>>>> --- Harrison >>>> >>>> Hi Harrison, >>>> >>>> That's a fine set of arguments, and I do hope that you are right, but it might be worth considering the following: >>>> >>>> 1. Your examples don't capture the most compelling incentive(s) that might hypothetically motivate an operator's attempt to strategically leverage IPv4 scarcity for commercial/competitive purposes. The Internet has a strong tendency to "route around" congestion, censorship, scarcity, and other bad things, not only (or primarily) because the technology just works that way, but because clever operators are constantly, actively looking for opportunities to optimize their network cost/performance characteristics -- i.e., by topologically "bypassing" such problems. Of course, network input suppliers (the majority of which are now also "operators" themselves) are fully aware of this fact, and as a class they naturally tend to be reluctant to compete on price ( -> commodification) *if* there is any other alternative. Consequently, smart input suppliers are constantly trying to identify and "capture" profitable market niches that are very likely to remain profitable because opera > tors cannot easily bypass them -- i.e., because they constitute a "bottleneck" to profitably providing network service to some place/population. Sometimes (increasingly uncommon IMO) such bottlenecks are be embodied in some unique technology or non-fixed asset. Today, in this industry, such bottlenecks are far more likely to be explicitly or implicitly spatial/geographic in nature, e.g., a particularly attractive room in a building (e.g., an IXP/IDC), building in a particular neighborhood, neighborhood right-of-way in a city, city in a country, etc., or indirect access to the same via interconnection/traffic exchange with another operator that has better or perhaps exclusive topological access to to the desired "turf." >>>> >>>> 2. At various times/places, IPv4 can and has embodied an absolute bottleneck of the former (non-fixed) kind, at least for some network operators and/or would-be operators. The possibility (or rather "eventuality") that IPv4 would become a bottleneck was one of the factors that drove the creation of the RIR (needs-based) allocation system, and the limited accessibility of IPv4 on non-adversarial terms to aspiring network operators outside the US was one of the demand drivers that led to the spread of that address distribution model to every continent. Today, thanks to NAT, RFC1918, and IPv6, IPv4's status as a "quantitative bottleneck" to delivering many kinds of services has diminished substantially -- i.e., life might be vastly easier if one had more IPv4, but -- assuming that you have any at all -- an independent network operator can generally remain in business as such, and even continue growing, by strategically reassigning/multiplexing and/or supplementing their lim > ited IPv4 holdings with private addressing and/or IPv6. However, for the overwhelming majority of places and aspiring (future) service providers, IPv4 still remains an absolute/qualitative bottleneck to entering (appx. any/all) Internet services market, at least with the same sort of "independent" status that all of one's incumbent competitors would enjoy. >>>> >>>> One day that might not be true, but when (or whether) that day might come is anyone's guess. You may be right that there is "consensus around the fact that long term, IPv4 allocations are likely to have little to no value," but if so that consensus is overwhelmingly among individuals that work for institutions that (a) have to-date put little if anything at risk to hasten that outcome, and (b) simply by virtue of their possession of IPv4 could have quite a lot to gain if the consensus prediction turns out to be wrong. Obviously there are some exceptions, e.g., networks that have literally bet the farm on IPv6, but they represent a tiny minority among those holding the "consensus" view. >>>> >>>> Note that I'm not suggesting that people are misrepresenting their actual beliefs, but it's a lot easier to have strong opinions about future unknowns when being wrong is a (privately) cost-free option. Like I said, I do hope that the consensus is right, but caveat emptor is always good advice. >>>> >>>> 3. Given the fact that, by itself, a strategy of "IPv4 hoarding" seems unlikely pay off in the near future, and might never become an effective means of *establishing* market power (i.e., except under relatively improbable circumstances/scenarios, for the perennially modest market segment of aspiring new entrants), but arguably has already/repeatedly proven to be quite effective as a strategy for *enhancing* market power under certain conditions (e.g., during the preRIR/early RIR era, in regions/bargaining situations where BYO addressing is unacceptable, etc.), one should assume that any shift toward strategic "IPv4 hoarding" would probably start -- and if left unchecked, end -- with the kind of entities that already control some other critical bottleneck(s) to Internet service delivery, as described in [1] above. >>> >>> Thanks for the explanation. >>> >>> Those are definitely significant concerns, but I'm not sure how needs >>> testing addresses them. >> >> On this point I am inclined to (reluctantly) agree. >> Assuming very very generously that I got everything right in the predictive model described above, continued needs testing ala current practice might slow the inexorable, but probably not all that much (esp. in relative terms, since the ultimate result would be a market in which IPv4 conferred the same sort of status that land conferred upon its owners during the century or two after land first became "alienable" but land ownership still remained an appx. universal bottleneck input to the accumulation of personal wealth and/or the achievement of social/political non-nonperson status). > > Addendum: Even if one agrees with me that at strategy of "IPv4 hoarding" would be unlikely to pay off for a "pure speculator" (i.e., an entity that could not satisfy any form of needs-based justification requirement) in the near term -- or rather, that it would be *relatively less likely* to pay off for them, as opposed to an entity that might be able to satisfy some kinds of needs nests -- that does NOT imply ANY of the following: > > -- that all "pure speculators" are by definition motivated solely by short-term payoffs; with "safe" economy interest rates parked at +/- 0.00% indefinitely, demand for everything else flat, and octillions of idled $?? just waiting patiently for the next attractor to appear, any such assumption would be foolish; > > -- that "pure speculators" would be necessarily be interested in or obliged to participate in the actual "IPv4 hoarding" themselves; > > -- that "pure speculators" should be incentivized to put any of this to the test, e.g., by dropping the justification requirement altogether. > > Short version: when/if these messages are tallied for informational purposes, please add this one to the "opposed" column. > > TV > >>> Large ISPs already have the ability to horde >>> address space, in that they can make relatively minor changes that >>> would suddenly make them "need" (or, at least, qualify for) quite a >>> bit more address space than they already have. These entities are also >>> the ones most likely to be well versed in how to meet the letter of >>> ARIN's requirements. It seems like the needs testing simply adds one >>> more advantage they would have over their smaller counterparts and >>> end-users. >>> >>> Perhaps the solution to this problem is a reserved block for small >>> allocations, where the "reservation" survives 8.3 transfer? >> >> In the final analysis, there are only two possible outcomes that matter: either IPv6 (or some other, as-yet unimagined technology that provides the same or better functionality on terms that are least as open/accessible to as broad a segment of aspiring Internet contributors as would be served by, e.g., an inexhaustible supply of IPv4) "promptly" achieves perfectly substitutability with IPv4 -- which mean that what happens to IPv4 doesn't really matter -- or else it doesn't, and possession of IPv4 continues to provide a variety of technical and commercial opportunities that are unattainable (or attainable only on commercially unsustainable terms) to anyone who does not possess IPv4, in perpetuity -- or at least until someone actually comes up with that "as-yet unimagined technology." >> >> Personally, it's not clear to me how or why the suggested changes would be likely to materially alter the current trajectory, but that may just reflect a failure of imagination (or understanding) on my part. >> >>> At least in a more open market, such entities may also decide that >>> they can make more money using their space more effectively, and >>> selling the extra on, post-exhaustion, though I'll admit this seems >>> like a fairly unlikely outcome. >>> >>> --- Harrison >> >> Absent some kind of intervention (divine, infernal, or bootstrap-directed), the economic logic that I attempted to map out permits only one high probability outcome. >> >> Of course, anything is possible, for some definitions of "possible." >> >> And caveat emptor is still always good advice ;-) >> >> Cheers, >> >> TV >> >> > > > > ------------------------------ > > _______________________________________________ > ARIN-PPML mailing list > ARIN-PPML at arin.net > http://lists.arin.net/mailman/listinfo/arin-ppml > > End of ARIN-PPML Digest, Vol 80, Issue 51 > ***************************************** From arinfactcheck at gmail.com Sat Feb 25 15:43:25 2012 From: arinfactcheck at gmail.com (Jim Fleming) Date: Sat, 25 Feb 2012 14:43:25 -0600 Subject: [arin-ppml] ARIN Fact Check: GAAP for IANA (ICANN) /8 Assets Message-ID: ARIN Fact Check: GAAP for IANA (ICANN) /8 Assets "The PPML mailing list is for Internet number resource policy questions" 1. IPv4 /8 ASSETS have become scarce and valuable 2. A /8 allocation could easily be valued like FCC Spectrum 3. A /8 allocation as an ASSET could have a value in excess of $2,000,000,000 4. nnn.IN-ADDR.ARPA Domain Names are used to delegate billion dollar /8 Assets What is the ARIN Policy for accounting for billion dollar /8 ASSETS from ICANN (IANA) ? [Are the /8 Assets shown on the ARIN Balance Sheets ?] [What did ARIN pay for the /8 assets ?] [How many /8 assets does ARIN claim to own ?] GAAP - Generally Accepted Accounting Practices From jcurran at arin.net Sat Feb 25 15:55:18 2012 From: jcurran at arin.net (John Curran) Date: Sat, 25 Feb 2012 20:55:18 +0000 Subject: [arin-ppml] ARIN Fact Check: GAAP for IANA (ICANN) /8 Assets In-Reply-To: References: Message-ID: <6DD061E2-08DB-40E1-8D51-72F1D44DCCC0@corp.arin.net> On Feb 25, 2012, at 3:43 PM, Jim Fleming > wrote: "The PPML mailing list is for Internet number resource policy questions" Correct. Pleae make a policy proposal or comment on one of the existing proposals or draft policies under consideration. Thanks, /John John Curran President and CEO ARIN -------------- next part -------------- An HTML attachment was scrubbed... URL: From info at arin.net Sat Feb 25 22:10:14 2012 From: info at arin.net (ARIN) Date: Sat, 25 Feb 2012 22:10:14 -0500 Subject: [arin-ppml] Draft Policy 2012-2: IPv6 Subsequent Allocations Utilization Requirement Message-ID: <4F49A296.5090503@arin.net> Correction. Earlier post did not use updated policy text. Draft Policy ARIN-2012-2 IPv6 Subsequent Allocations Utilization Requirement On 16 February 2012 the ARIN Advisory Council (AC) selected "Clarifying requirements for IPv4 transfers" as a draft policy for adoption discussion on the PPML and at the Public Policy Meeting in Vancouver in April. The draft was developed by the AC from policy proposal "ARIN-prop-159 IPv6 Subsequent Allocations Utilization Requirement." Per the Policy Development Process the AC submitted text to ARIN for a staff and legal assessment prior to its selection as a draft policy. Below the draft policy is the ARIN staff and legal assessment, followed by the text that was submitted by the AC. Draft Policy ARIN-2012-2 is below and can be found at: https://www.arin.net/policy/proposals/2012_2.html You are encouraged to discuss Draft Policy 2012-2 on the PPML prior to the April Public Policy Meeting. Both the discussion on the list and at the meeting will be used by the ARIN Advisory Council to determine the community consensus for adopting this as policy. The ARIN Policy Development Process 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, Member Services American Registry for Internet Numbers (ARIN) ## * ## Draft Policy ARIN-2012-2 IPv6 Subsequent Allocations Utilization Requirement Date: 22 February 2012 Policy statement: Proposal text: Modify 6.5.3.b as follows: An LIR may request a subsequent allocation when they can show utilization of: 75% or more of their total address space or more than 90% of any serving site or when 75% of the aggregate has been subnetted, and each subnet contains at least 1* customer or infrastructure allocation or assignment ( *1 can be replaced here with any reasonable number) Original Rationale: If you are executing to a long term plan, you should be able to continue to execute on your approved allocation and assignment plan regardless of the number of regions/groupings you originally planned for. We want to promote tie downs on nibbles and long term planning. Timetable for implementation: Immediately ########## ARIN Staff and Legal Assessment Draft Policy: PP 159 ?IPv6 Subsequent Allocations Utilization Requirement? Date of Assessment: 15 Feb 2012 1. Proposal Summary (Staff Understanding) The intent of this proposal is to allow an additional way for ISP's that have already begun using their IPv6 space but who may not have sufficiently planned for longer term growth, to receive an additional allocation. This policy would allow an organization to qualify for an additional IPv6 allocation if they can show that 75% of their IPv6 address space as a whole is subnetted, provided that each subnet has at least 1 customer or infrastructure assignment/allocation. 2. Staff Comments: A. ARIN Staff Comments: If this policy were to be implemented exactly as written, ARIN staff would approve an additional IPv6 allocation as long as a network had subnetted at least 75% of their IPv6 allocation, with at least one customer or internal assignment/allocation in each subnet. ARIN would not evaluate subnet size; as long as any portion of a subnet is used, then that subnet would be considered to be fully used, regardless of its size. Effectively, this allows an operator to qualify for IPv6 addresses any time they want, because it's trivial to subnet out 75% of an allocation(s) and use at least a tiny portion of each, and may not encourage conservation of IPv6 address space. If the author's intent is to allow operators to make reasonable decisions about their IPv6 deployment, another option would be to simplify the IPv6 additional allocation policy to allow an operator to qualify for more IPv6 addresses when they can show a need for them. Alternatively, if the author's intent is to have ARIN staff evaluate whether those decisions are reasonable, then specific criteria needs to be laid out to give staff guidance as to how we do that (e.g. block size, timeframes, etc.). The author's original proposal rationale stated that the expectation would be for ARIN to use its discretion to weed out such requests, but there is no policy basis for doing so. Nothing in this text gives staff any basis for rejecting any subnet size, regardless of how reasonable we think it is. If the author wants ARIN to review requests to determine if technically reasonable, than some criteria or guidance must be provided within the policy text. B. ARIN General Counsel ? This policy does not create significant legal issues. 3. Resource Impact This policy would have minimal resource impact from an implementation aspect. It is estimated that implementation could occur within 3 months after ratification by the ARIN Board of Trustees. The following would be needed in order to implement: Guidelines and procedures need to be updated Staff training Proposal text: Modify 6.5.3.b as follows: An LIR may request a subsequent allocation when they can show utilization of: 75% or more of their total address space or more than 90% of any serving site or when 75% of the aggregate has been subnetted, and each subnet contains at least 1* customer or infrastructure allocation or assignment ( *1 can be replaced here with any reasonable number) Original Rationale: If you are executing to a long term plan, you should be able to continue to execute on your approved allocation and assignment plan regardless of the number of regions/groupings you originally planned for. We want to promote tie downs on nibbles and long term planning. From mpetach at netflight.com Sun Feb 26 15:56:19 2012 From: mpetach at netflight.com (Matthew Petach) Date: Sun, 26 Feb 2012 12:56:19 -0800 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> Message-ID: After mulling over this thread for a few days, I think what I'm coming to realize is that my primary concern for maintaining the "needs based" rule is that it enforces a dichotomy in the market. Newer players must abide strictly by the needs-based assessment of the ARIN staff to get addresses. Their world is strictly defined through the eyes of the ARIN staff evaluation, and their vision and growth is strictly curtailed by that evaluation. Older players, especially legacy players, are not required to follow any type of needs-based assessment to hold onto their resources; they may squander it at will, or dream big, and roll out an audacious undertaking that might never pass the ARIN staff "needs" scrutiny. In doing so, we've created an "Old Boys Club", where those who already have space essentially *are* the speculators; those with legacy /8s, for example, may have no plans for actually making use of the vast majority of their space, and thus have no "needs" based justification for it; but we allow them to sit on it indefinitely, as the scarcity of the resource increases for everyone else. I think my support for abolition of the needs-based allocation stems from a desire to see equal treatment in the market for everyone; upon further reflection, I can see that a similar level of equality can be achieved by subjecting *everyone* to the same requirements, no matter when the address space was registered. Annual audits, and if the need is no longer shown to be present, the resource registration is revoked, applied equally to everyone with v4 address resources. I suspect that my alternate option for establishing equality in the market will be met with a great outcry from those hoarders already holding blocks of address space that they know darn well don't meet a "needs-based" criterion. And those holders will fight tooth and nail to hold onto those allocations; because in spite of all the rhetoric about how v4 address allocations aren't property, and will someday have no value...right now, deep down, they sure as hell believe that what they have has real value, and with increasing scarcity in the market, that what they have has *increasing* value in the market. And, if you're holding onto a scarce resource in a time of increasing scarcity with no demonstrated need for the resource...well, in most books, that would make you a speculator. The fact that your chunk of the resource was gifted to you years ago doesn't negate the fact that you're holding onto an unused portion of a scarce resource, thus driving up the market price for that resource. So. Let's call a spade a spade. We already have speculation in the IPv4 address allocation market. We have a set of investors who have large chunks of address space that they have obtained without demonstrated need, and are holding onto them in spite of not having a demonstrated need at a time when scarcity is driving the value of those resources up. We can't turn a blind eye to them, and claim we have to preserve "needs-based" allocations to keep spectators out, *because they're already here.* If we're not willing to make things equitable by enforcing needs-based requirements on them, then the only other way to make this situation equitable is to remove the needs-based requirements on the rest of the participants. And thus, I continue to support removal of the need-based requirement, in the interests of restoring equality among the market participants. Thanks! Matt (now to start digging through the NRPM and see if it's time to propose an AC action to replace "legacy" with "speculator" throughout it, in the interests of clarity and honesty.) From mpetach at netflight.com Sun Feb 26 21:42:15 2012 From: mpetach at netflight.com (Matthew Petach) Date: Sun, 26 Feb 2012 18:42:15 -0800 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> Message-ID: After a private request for clarification, I do think that much like with other markets, there should be some overall "sanity" checks in place; define a minimum blocksize that can be transferred, say a /24, somewhat analogous to a single stock or commodity share; you can't trade in volumes smaller than that on those markets, and I think it would behoove us to have a similar "smallest possible unit of transfer" concept. Likewise, I share Geoff's sentiment that having accurate data in the registry is paramount; so all valid transfers would be publicly registered and visible in the registry. Hopefully that helps clarify my position on the matter. Thanks! Matt From tvest at eyeconomics.com Sun Feb 26 22:02:18 2012 From: tvest at eyeconomics.com (Tom Vest) Date: Sun, 26 Feb 2012 22:02:18 -0500 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> Message-ID: On Feb 26, 2012, at 3:56 PM, Matthew Petach wrote: > After mulling over this thread for a few days, I think what I'm coming to > realize is that my primary concern for maintaining the "needs based" > rule is that it enforces a dichotomy in the market. > > Newer players must abide strictly by the needs-based assessment of > the ARIN staff to get addresses. Their world is strictly defined through > the eyes of the ARIN staff evaluation, and their vision and growth is > strictly curtailed by that evaluation. > > Older players, especially legacy players, are not required to follow any > type of needs-based assessment to hold onto their resources; they > may squander it at will, or dream big, and roll out an audacious > undertaking that might never pass the ARIN staff "needs" scrutiny. > > In doing so, we've created an "Old Boys Club", where those who already > have space essentially *are* the speculators; those with legacy /8s, for > example, may have no plans for actually making use of the vast majority > of their space, and thus have no "needs" based justification for it; but we > allow them to sit on it indefinitely, as the scarcity of the resource increases > for everyone else. > > I think my support for abolition of the needs-based allocation stems from > a desire to see equal treatment in the market for everyone; upon further > reflection, I can see that a similar level of equality can be achieved by > subjecting *everyone* to the same requirements, no matter when the > address space was registered. Annual audits, and if the need is no > longer shown to be present, the resource registration is revoked, applied > equally to everyone with v4 address resources. > > I suspect that my alternate option for establishing equality in the market > will be met with a great outcry from those hoarders already holding blocks > of address space that they know darn well don't meet a "needs-based" > criterion. And those holders will fight tooth and nail to hold onto > those allocations; > because in spite of all the rhetoric about how v4 address allocations aren't > property, and will someday have no value...right now, deep down, they > sure as hell believe that what they have has real value, and with increasing > scarcity in the market, that what they have has *increasing* value in the > market. And, if you're holding onto a scarce resource in a time of > increasing scarcity with no demonstrated need for the resource...well, in > most books, that would make you a speculator. The fact that your chunk > of the resource was gifted to you years ago doesn't negate the fact that > you're holding onto an unused portion of a scarce resource, thus driving > up the market price for that resource. > > So. Let's call a spade a spade. We already have speculation in the IPv4 > address allocation market. We have a set of investors who have large chunks > of address space that they have obtained without demonstrated need, and > are holding onto them in spite of not having a demonstrated need at a time > when scarcity is driving the value of those resources up. We can't turn a > blind eye to them, and claim we have to preserve "needs-based" allocations > to keep spectators out, *because they're already here.* If we're not willing > to make things equitable by enforcing needs-based requirements on them, > then the only other way to make this situation equitable is to remove the > needs-based requirements on the rest of the participants. And thus, I > continue to support removal of the need-based requirement, in the > interests of restoring equality among the market participants. > > Thanks! > > Matt > (now to start digging through the NRPM and see if it's time to propose > an AC action to replace "legacy" with "speculator" throughout it, in the > interests of clarity and honesty.) Hi Matt, You seem to be arguing the following: 1. "IPv4 Speculation" is bad (or maybe good for the lucky speculators, but bad/unfair for everyone else). 2. Possession of IPv4 today == "IPv4 Speculation." 3. Therefore, anyone/everyone (today) should have an equal right to be an IPv4 speculator. Questions: Is there something uniquely unfair that is inherent specifically in an IPv4 holder's right to sell not just to sell IPv4, but to sell it without restriction based on current needs-based policies. In other words, is there something that makes that narrow privilege more important than any/every other right/privilege that an IPv4 holder might enjoy, e.g., in world of IP addressing scarcity (e.g., max. freedom to expand, to add new customers, to add peers at will, reachability to/from all of the the rest of the Internet)? Even if one thinks that that narrow selling-related privilege *is* more important and more unfair than all of the other advantages of having IPv4, doesn't the privilege also confer to any/all subsequent IPv4 buyers? If it does confer, then (following the logic that people use to justify a transfer market in general), what makes the idea of having to buy that particular privilege *more* intolerable than the idea of having to buy any of the other privileges that every current IPv4 holder in the world currently enjoys simply by virtue of their possession of allocated/assigned IPv4? If you believe that RIR-era needs justification rules retroactively render legacy IPv4 assignments so unfair and illegitimate that an ex post facto equalization (to your benefit) is now justified, and the community actually ratifies that notion, I wonder how future community members will interpret that precedent a few years from now, when they start comparing what they're obliged to do/give up to get usable IP addresses to what was expected of *anyone* that was lucky enough to acquire IPv4 at any time in before IPv4 exhaustion... Am I missing something? Thanks, TV From gbonser at seven.com Sun Feb 26 22:45:20 2012 From: gbonser at seven.com (George Bonser) Date: Mon, 27 Feb 2012 03:45:20 +0000 Subject: [arin-ppml] ARIN Fact Check: Term Limit Policies, etc. In-Reply-To: <6796056A-6443-4AF3-8254-C279642BED47@corp.arin.net> References: <6796056A-6443-4AF3-8254-C279642BED47@corp.arin.net> Message-ID: <596B74B410EE6B4CA8A30C3AF1A155EA09CE7AB0@RWC-MBX1.corp.seven.com> > -----Original Message----- > From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On > Behalf Of John Curran > 1) No term limits on trustees at present; note that trustees are not > compensated for their service. Oh, PLEASE don't EVER introduce "term limits" (seriously), that is about the worst idea that can possibly ever be done. We would end up like California where people would be quite happy to vote for horrible decisions because they know they won't be around when the consequences of that bad decision come to fruition. Term limits act in civil government to further enable graft and bribery. A politician might hesitate to make a decision now that is thought to be likely to cause harm in 10 years time if the politician feels they might get held responsible for it. One facing term limits well before that time has no problem voting for such legislation if there's enough "kick" in the campaign fund. They know someone else will be left holding the bag. Term limits are *always* a bad idea. The notion that someone better stop us before we vote again is just insane. It means some small vocal minority isn't enough to kick someone out of a position so they lobby to have a law put in place that does it for them. "Term Limits" are a bad idea. I *would* however make sure there aren't such things any continuing benefits beyond the term of one's service in an elected position. And $250K for a CEO in the tech field is actually paltry. Small potatoes. Measly. There are a companies where individual contributors can make nearly that much depending on what they are working on. Getting someone on board for any less than that would be very difficult, particularly in the DC suburbs. At least getting anyone with a skill set capable of handling such a position. From mpetach at netflight.com Mon Feb 27 12:40:13 2012 From: mpetach at netflight.com (Matthew Petach) Date: Mon, 27 Feb 2012 09:40:13 -0800 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> Message-ID: On Sun, Feb 26, 2012 at 7:02 PM, Tom Vest wrote: > Hi Matt, > > You seem to be arguing the following: > > 1. "IPv4 Speculation" is bad (or maybe good for the lucky speculators, but bad/unfair for everyone else). I was trying not to assign it a category of "good' or "bad"--simply stating it does exist today; and thus, one of the arguments *against* a free and unfettered market is not relevant. The cry of "but if we allow anyone to buy and sell IP blocks, we'll be overrun with speculators" rings hollow when the market is already supporting dozens of speculators who operate outside the needs-based criteria. > 2. Possession of IPv4 today == "IPv4 Speculation." Not quite; I meant "posession of IPv4 today *above and beyond what the ARIN needs-based justification would approve* == IPv4 speculation." > 3. Therefore, anyone/everyone (today) should have an equal right to be an IPv4 speculator. Given that there are many players already who hold IPv4 resources that wildly flaunt any needs-based justification whatsoever, I propose that anyone and everyone should likewise be able to participate in the market to that same degree. If we're going to turn a blind eye towards holders of large blocks and not require any needs-based justification for them, then be fair and do away with the needs-based justification for everyone. Otherwise, apply it equally across the board. > Questions: > Is there something uniquely unfair that is inherent specifically in an IPv4 holder's right to sell not just to sell IPv4, but to sell it without restriction based on current needs-based policies. There's nothing unfair in the right; what is unfair is that the rights are not being applied equally to everyone within the ARIN purview. I'm advocating that we either apply the rules equally to *everyone*, or apply them to no-one. The current "have" and "have-not" scenario is a ludicrous parody of medieval fiefdoms. > In other words, is there something that makes that narrow privilege more important than any/every other right/privilege that an IPv4 holder might enjoy, e.g., in ?world of IP addressing scarcity (e.g., max. freedom to expand, to add new customers, to add peers at will, reachability to/from all of the the rest of the Internet)? ?Even if one thinks that that narrow selling-related privilege *is* more important and more unfair than all of the other advantages of having IPv4, ?doesn't the privilege also confer to any/all subsequent IPv4 buyers? If it does confer, then (following the logic that people use to justify a transfer market in general), what makes the idea of having to buy that particular privilege *more* intolerable than the idea of having to buy any of the other privileges that every current IPv4 holder in the world currently enjoys simply by virtue of their possession of allocated/assigned IPv4? > > If you believe that RIR-era needs justification rules retroactively render legacy IPv4 assignments so unfair and illegitimate that an ex post facto equalization (to your benefit) is now justified, and the community actually ratifies that notion, I wonder how future community members will interpret that precedent a few years from now, when they start comparing what they're obliged to do/give up to get usable IP addresses to what was expected of *anyone* that was lucky enough to acquire IPv4 at any time in before IPv4 exhaustion... > It's refreshing to see people admitting that yes, the legacy block holders do enjoy privilege and status far above everyone else who operates under the RIR needs-based rules. However, I'm not advocating that we take up pitchforks and torches and storm the castles of the wealthly landed gentry; instead, I'm advocating removal of the unfair and unreasonable rules that deny anyone else the ability to gain access to similar levels of resources. The old boy's club has their wealth and power and prestige in the form of large, unjustified swaths of IPv4 space; let's bring equality and fairness to the market, and allow everyone the *opportunity* to participate in that mode. Or are you arguing in favour of the status quo, that it's fine for some players to hold onto large, unjustified blocks of IPv4 space, simply due to their age, but everyone else has to sit in the back of the bus? Have we really come to the days of "separate but equal", and segregation on the internet?? Is it time for the next Rosa Parks to take a stand, and not meekly move to the back of the bus, based solely on an arbitrary discriminant like skin colour? Why should the age of your IPv4 block confer special rights to a select few that are denied to everyone else? Very simply, my stance is "equal rights for all." If we're not enforcing needs-based justification for everyone, then don't enforce it on just a select minority. That's not equality, that's discrimination. Help me end discrimination on the internet; vote to remove discriminatory needs-based rules that are applied only to the non-privileged minorities. Vote YES on prop 165! > Am I missing something? I hope this has helped clarify the points you might have missed in my earlier missive; and with that increased clarity will come support for true equality in the ARIN region, and an end to unfair, discriminatory practices. > Thanks, > TV Thanks! Matt From jrhett at netconsonance.com Mon Feb 27 14:32:21 2012 From: jrhett at netconsonance.com (Jo Rhett) Date: Mon, 27 Feb 2012 11:32:21 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> Message-ID: <3D80425B-B9F8-47C9-8BC0-1B44A3D65A64@netconsonance.com> On Feb 27, 2012, at 9:40 AM, Matthew Petach wrote: > There's nothing unfair in the right; what is unfair is that the > rights are not being applied equally to everyone within the > ARIN purview. I'm advocating that we either apply the rules > equally to *everyone*, or apply them to no-one. The current > "have" and "have-not" scenario is a ludicrous parody of > medieval fiefdoms. Can you be specific about how you see the rules not being fairly applied? Do you see ARIN giving new blocks to some segment of its clients by a different criteria than it provides new blocks to others? Please be specific. I am only asking because all of your commentary to date has to do with providers who already have large blocks, and that's not the business that ARIN's membership has asked it to perform. I have seen and supported numerous proposals for ARIN to review and audit existing allocations for compliance, and these proposals have always failed. Thus ARIN has been explicitly told by its members that it is not a policing body. Therefore it can only apply these policies when handing out *new* allocations. (be they transferred blocks or not) If I am reading your complain correctly, it would appear that your main complaint has nothing to do with this transfer policy and everything to do with the old and much-argued complaint about historical allocations. If so, I would argue that none of your concerns are made any better or worse by the proposed transfer policy, and that your concerns should be addressed by a new policy that very explicitly addresses review of historical allocations. For what it is worth, I would totally support this policy however I suspect ARIN doesn't have the legal authority on which to enforce this. And, as past discussion has proven, this would be extremely unpopular. -- Jo Rhett Net Consonance : consonant endings by net philanthropy, open source and other randomness -------------- next part -------------- An HTML attachment was scrubbed... URL: From astrodog at gmail.com Mon Feb 27 15:19:02 2012 From: astrodog at gmail.com (Astrodog) Date: Mon, 27 Feb 2012 14:19:02 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <3D80425B-B9F8-47C9-8BC0-1B44A3D65A64@netconsonance.com> References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> <3D80425B-B9F8-47C9-8BC0-1B44A3D65A64@netconsonance.com> Message-ID: On Mon, Feb 27, 2012 at 1:32 PM, Jo Rhett wrote: > On Feb 27, 2012, at 9:40 AM, Matthew Petach wrote: > > There's nothing unfair in the right; what is unfair is that the > rights are not being applied equally to everyone within the > ARIN purview. ?I'm advocating that we either apply the rules > equally to *everyone*, or apply them to no-one. ?The current > "have" and "have-not" scenario is a ludicrous parody of > medieval fiefdoms. > > > Can you be specific about how you see the rules not being fairly applied? Do > you see ARIN giving new blocks to some segment of its clients by a different > criteria than it provides new blocks to others? ?Please be specific. > > I am only asking because all of your commentary to date has to do with > providers who already have large blocks, and that's not the business that > ARIN's membership has asked it to perform. ?I have seen and supported > numerous proposals for ARIN to review and audit existing allocations for > compliance, and these proposals have always failed. ?Thus ARIN has been > explicitly told by its members that it is not a policing body. ?Therefore it > can only apply these policies when handing out *new* allocations. (be they > transferred blocks or not) > > If I am reading your complain correctly, it would appear that your main > complaint has nothing to do with this transfer policy and everything to do > with the old and much-argued complaint about historical allocations. ?If so, > I would argue that none of your concerns are made any better or worse by the > proposed transfer policy, and that your concerns should be addressed by a > new policy that very explicitly addresses review of historical allocations. > ?For what it is worth, I would totally support this policy however I suspect > ARIN doesn't have the legal authority on which to enforce this. ?And, as > past discussion has proven, this would be extremely unpopular. > If I'm understanding the context correctly, this is limited to transfers under 8.3. I don't think the proposal addresses allocations from ARIN. --- Harrison From cengel at conxeo.com Mon Feb 27 15:16:23 2012 From: cengel at conxeo.com (Chris Engel) Date: Mon, 27 Feb 2012 15:16:23 -0500 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> Message-ID: As an end-user network which generally obtains it's space from transit providers, I don't have much insight into the transfer process or direct assignments in general. However, I do have to wonder what the practical difference is between a transfer (whether needs based or not) and simply having an existing registrant act as a "figure-head" and farm out or sell access to some portion of their space instead? For example, assuming a Legacy (or maybe even RSA) holder that had unused space, what would stop them from saying "Hey, we have all this unused space that could provide us with a revenue source. We don't want the hassle/overhead of acting as a real transit provider. We also don't want any potential roadblocks of an outside organization (ARIN) having to sign off on a sale of these IP resources..... so rather then sell the IP resources themselves (or I guess technically the registration of them) ...we just sell the right to use those resources. We'll reach an agreement with XYZ corporation....we'll still act as the "Name on the Door" as far as the Registration is concerned....but they assume all real operational control of this space...and in turn simply pay us for the right to use this portion of our registration". Taking that a step further what's to stop an organization that didn't want to deal with the marketing and brokering of such deals to sell those access rights to a middle-man that would act as a broker for those resources, and depending upon the structure of the deal, couldn't a broker engaged in such practices effectively even act as a speculator? Obviously that sort of deal is less attractive to a "buyer" since their access to the space they would be using is still dependent on the official Registrant. I also assume there may be some risk to the value of the Registrants own resources dependent upon the behavior of those they are "sub-letting" their space to. However I assume those risks would simply be reflected in the pricing of that sort of deal. Assuming the above, my questions are... 1) In terms of ARIN's current practices, is there anything that would prevent such behavior? 2) If not, to what extent is such behavior already occurring? 3) What would be the difference in impact to the community from such behavior as opposed to a straight transfer? I believe the answers to the above questions may be informative as to the practicality of continuation of a needs based transfer requirement in an environment of growing scarcity. Note, I'm not taking a stance philosophically one way or the other on Needs based requirements. However, I have some experience with trying to understand the operational impacts of policies. The question that I always consider when a policy is put in place to control some behavior is what emergent behavior is likely to result from said policy...what's the impact of that behavior....and what do/can you do about it? Christopher Engel From Keith at jcc.com Mon Feb 27 15:24:11 2012 From: Keith at jcc.com (Keith W. Hare) Date: Mon, 27 Feb 2012 15:24:11 -0500 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> Message-ID: <62D20B771F8F9C4EA8AEE574FF38696212D37B5801@mercury.jcc.com> Matthew, To me, your arguments sound like another round of the "legacy resource holders are evil because ____" arguments that have popped up on the ARIN lists every so often since I've been subscribed. When we obtained our class C (now /24) assignment 20 years ago, we had to specify what we needed. This was a pretty simple question at that point -- the options were A, B, or C. At the time, we thought a C was sufficient but if we'd had a better understanding of where computing was going, I'm pretty sure we could have justified a B. So, I guess this time, as a legacy resource holder, I'm evil because we got our assignment when the criteria was much simpler. And, for the record, I oppose Prop 165 and any other attempt to eliminate Needs Based Justification on either new allocations or section 8.whatever transfers. I guess that puts me in the "old boy's club" with "wealth and power and prestige", although our swath of IPv4 space is not that large. As far as I can tell, everyone who has IPv4 address space had to do some level of justification. Your argument really is that the justification criteria have changed over the last twenty years, so you would either like everyone to meet today's criteria or go back to the twenty year old "this is what I think I need" criteria. Perhaps I'm dense, but I still don't understand how having to adhere to today's justification criteria discriminates against you. Exactly what is it that requiring a needs justification is preventing you from doing? Keith Hare From mpetach at netflight.com Mon Feb 27 15:25:59 2012 From: mpetach at netflight.com (Matthew Petach) Date: Mon, 27 Feb 2012 12:25:59 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <3D80425B-B9F8-47C9-8BC0-1B44A3D65A64@netconsonance.com> References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> <3D80425B-B9F8-47C9-8BC0-1B44A3D65A64@netconsonance.com> Message-ID: On Mon, Feb 27, 2012 at 11:32 AM, Jo Rhett wrote: > On Feb 27, 2012, at 9:40 AM, Matthew Petach wrote: > > There's nothing unfair in the right; what is unfair is that the > rights are not being applied equally to everyone within the > ARIN purview. ?I'm advocating that we either apply the rules > equally to *everyone*, or apply them to no-one. ?The current > "have" and "have-not" scenario is a ludicrous parody of > medieval fiefdoms. > > Can you be specific about how you see the rules not being fairly applied? Do > you see ARIN giving new blocks to some segment of its clients by a different > criteria than it provides new blocks to others? ?Please be specific. I see ARIN equally applying the rules to all the serfs coming to apply for a plot of land, while turning a blind eye to the large country estates all around. If we consider ARINs clients to be *only* those who fall under the needs-based justification rules, then ARIN is indeed being fair and equitable among them; but if that is our definition of the ARIN clientele, then the legacy holders are explicitly not among the ARIN clientele, and should be free to engage in whatever market buying and selling of address space they have, free and clear of any ARIN involvement. If, however, the claim is made that the legacy holders are part and parcel of the ARIN clientele...then clearly, no the same rules are not being applied to everyone. We need to either explicitly exclude the legacy blocks from all ARIN control, in which case those blocks are free and clear to transfer as deemed economically viable; or, we need to clearly state that the legacy blocks are part and parcel of the ARIN clientele and subject to all the same rules and restrictions in terms of determined need justification for the resources. > I am only asking because all of your commentary to date has to do with > providers who already have large blocks, and that's not the business that > ARIN's membership has asked it to perform. ?I have seen and supported > numerous proposals for ARIN to review and audit existing allocations for > compliance, and these proposals have always failed. ?Thus ARIN has been > explicitly told by its members that it is not a policing body. ?Therefore it > can only apply these policies when handing out *new* allocations. (be they > transferred blocks or not). If the block is handed out not by ARIN, but by a legacy holder, should ARIN's rules still apply? Fundamentally, does ARIN have any right to limit the ability of someone to purchase address rights from an entity that has thus far not been explicitly acknowledged to be a part of ARIN's constituency? I'm struggling with this notion that ARIN has any leg to stand on with respect to limiting the buying and selling of address block rights in an open market from people that they have eschewed any control over thus far. How can ARIN take a hands-off stance for the blocks as long as they stay in legacy-holders hands, but the moment a non-legacy holder wishes to purchase a block, suddenly ARIN has rights to limit that transaction? If a legacy holder (that ARIN seems to feel it has no rights to control or limit) sells the block to a buyer in a different region, and that region has no needs-based restriction, would there be any reason not to allow the transfer? Or would ARIN suddenly leap out of its seat, and decide that it needed to engage and interfere in control over a block it had heretofore decided existed outside the range of its rules and requirements? I genuinely don't know the answer to that, by the way. If ARIN truly does take a hands-off view of the non RSA/LRSA signatories, then that transfer should happen unopposed. If ARIN *doesn't* allow the transfer, then it would be claiming it has control over blocks that it had previously claimed it did not have control over. The reason I'm wrestling with that, is if we grant special status for transfers to one set of v4 rights holders, but not others, we've created a discriminatory marketplace, and I'll fight tooth and nail to eliminate arbitrary segregation and discrimination like that. On the other hand, if ARIN interferes equally in all transfers, even those from non-signatories to other non-ARIN entities, it would indicate ARIN considers *all* blocks within the region to be under its control and auspices, *even those held by parties that have not signed an RSA/LRSA*--and I suspect that will irk a different subset of the readers. > If I am reading your complain correctly, it would appear that your main > complaint has nothing to do with this transfer policy and everything to do > with the old and much-argued complaint about historical allocations. ?If so, > I would argue that none of your concerns are made any better or worse by the > proposed transfer policy, and that your concerns should be addressed by a > new policy that very explicitly addresses review of historical allocations. The transfer policy is acting as litmus test for the scope of ARIN control over address resources; at the heart of the matter, I think it may come down to a court case between a legacy holder wishing to sell IP space to a high bidder outside the ARIN region, and ARIN's legal counsel, if ARIN tries to interfere in the sale. I'm somewhat hoping that I can delve deeply enough here on the list first to figure out which side ARIN is on; do they consider legacy holders to be completely outside their domain if they haven't signed an RSA/LRSA, or do they consider them to be somehow implicitly under ARIN control even with no signed agreement? If they're *not* under ARIN control if they haven't signed an RSA/LRSA, there should be nothing stopping them from selling address blocks outside the ARIN region, as ARIN would have no control over either the seller or the buyer. If ARIN *does* try to enforce needs-based justification on the transfer, they can't do it based on the purchaser if they're outside the region; they could only do it based on some assertion of control over the resource, even in the absence of an RSA/LRSA; and if they're going to assert that level of control, I would demand they equally assert *all* restrictions and regulations that are applied to the rest of the membership. > For what it is worth, I would totally support this policy however I suspect > ARIN doesn't have the legal authority on which to enforce this. And, as > past discussion has proven, this would be extremely unpopular. Ending discrimination is seldom popular among the privileged ones who benefit from the discrimination, you are quite correct. :) > -- > Jo Rhett > Net Consonance : consonant endings by net philanthropy, open source and > other randomness > Thanks! Matt leaping astride Rocinante once again, lance at the ready... From kkargel at polartel.com Mon Feb 27 16:00:29 2012 From: kkargel at polartel.com (Kevin Kargel) Date: Mon, 27 Feb 2012 15:00:29 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> <3D80425B-B9F8-47C9-8BC0-1B44A3D65A64@netconsonance.com> Message-ID: <8695009A81378E48879980039EEDAD28011E05E41E@MAIL1.polartel.local> Matthew, Once again we are entering into a round of discussion where people are forgetting where the "legacy" spaceholders came from. They were on the spot as the internet was getting started and they were the ones that jumped in with time and people and resources to develop and experiment and get things working. The internet we have today is precisely because of all the good work of the "legacy" spaceholders. When they were granted their space it was given to them at a time when there was space in abundance, and nobody was worried about how much space anybody had. They were granted rights to their space without limit or restriction. Now that space is becoming at all valuable the vultures are circling and forgetting the origins of what we have. The common refrain is "What have you done for me lately" of "I want a free piece of the pie and I don't want to have to work for it". We all still owe the "legacy" holders a debt of gratitude and all of this nipping at their heels late in the game is rather sad. The whole "What have you done for me lately" philosophy does none of us any credit. And no, I am not a legacy holder nor do I have any affiliations with a legacy holder. I do admire and respect all of the good works done by these pioneers of the internet. Turning the IP space in to a free for all without restrictions or controls is a really bad idea, unless one's only concern is just to turn a quick buck while one can and one has no concern for the future. If that's what we want to do then lets just divvy up what's left as one recent proposal suggested and be done with it. If we remove all need requirements then I hereby request all the space that's left. Finding the finances to do it would not be a problem. OK, I'll step down off my soap box again and let you all have at it. > -----Original Message----- > From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On > Behalf Of Matthew Petach > Sent: Monday, February 27, 2012 2:26 PM > To: Jo Rhett > Cc: ARIN PPML > Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification > > On Mon, Feb 27, 2012 at 11:32 AM, Jo Rhett > wrote: > > On Feb 27, 2012, at 9:40 AM, Matthew Petach wrote: > > > > There's nothing unfair in the right; what is unfair is that the > > rights are not being applied equally to everyone within the > > ARIN purview. ?I'm advocating that we either apply the rules > > equally to *everyone*, or apply them to no-one. ?The current > > "have" and "have-not" scenario is a ludicrous parody of > > medieval fiefdoms. > > > > Can you be specific about how you see the rules not being fairly > applied? Do > > you see ARIN giving new blocks to some segment of its clients by a > different > > criteria than it provides new blocks to others? ?Please be specific. > > I see ARIN equally applying the rules to all the serfs coming to apply > for a plot of land, while turning a blind eye to the large country estates > all around. > > If we consider ARINs clients to be *only* those who fall under the > needs-based justification rules, then ARIN is indeed being fair and > equitable among them; but if that is our definition of the ARIN > clientele, then the legacy holders are explicitly not among the > ARIN clientele, and should be free to engage in whatever market > buying and selling of address space they have, free and clear of > any ARIN involvement. > > If, however, the claim is made that the legacy holders are part > and parcel of the ARIN clientele...then clearly, no the same rules > are not being applied to everyone. We need to either explicitly > exclude the legacy blocks from all ARIN control, in which case > those blocks are free and clear to transfer as deemed economically > viable; or, we need to clearly state that the legacy blocks are > part and parcel of the ARIN clientele and subject to all the same > rules and restrictions in terms of determined need justification > for the resources. > > > > I am only asking because all of your commentary to date has to do with > > providers who already have large blocks, and that's not the business > that > > ARIN's membership has asked it to perform. ?I have seen and supported > > numerous proposals for ARIN to review and audit existing allocations for > > compliance, and these proposals have always failed. ?Thus ARIN has been > > explicitly told by its members that it is not a policing body. > ?Therefore it > > can only apply these policies when handing out *new* allocations. (be > they > > transferred blocks or not). > > If the block is handed out not by ARIN, but by a legacy holder, > should ARIN's rules still apply? Fundamentally, does ARIN have > any right to limit the ability of someone to purchase address rights > from an entity that has thus far not been explicitly acknowledged > to be a part of ARIN's constituency? > > I'm struggling with this notion that ARIN has any leg to stand > on with respect to limiting the buying and selling of address block > rights in an open market from people that they have eschewed > any control over thus far. How can ARIN take a hands-off stance > for the blocks as long as they stay in legacy-holders hands, but > the moment a non-legacy holder wishes to purchase a block, > suddenly ARIN has rights to limit that transaction? > > If a legacy holder (that ARIN seems to feel it has no rights to > control or limit) sells the block to a buyer in a different region, > and that region has no needs-based restriction, would there > be any reason not to allow the transfer? Or would ARIN > suddenly leap out of its seat, and decide that it needed to > engage and interfere in control over a block it had heretofore > decided existed outside the range of its rules and requirements? > > I genuinely don't know the answer to that, by the way. > > If ARIN truly does take a hands-off view of the non RSA/LRSA > signatories, then that transfer should happen unopposed. > If ARIN *doesn't* allow the transfer, then it would be claiming > it has control over blocks that it had previously claimed it > did not have control over. > > The reason I'm wrestling with that, is if we grant special > status for transfers to one set of v4 rights holders, but > not others, we've created a discriminatory marketplace, > and I'll fight tooth and nail to eliminate arbitrary > segregation and discrimination like that. > > On the other hand, if ARIN interferes equally in all transfers, > even those from non-signatories to other non-ARIN entities, > it would indicate ARIN considers *all* blocks within the > region to be under its control and auspices, *even those > held by parties that have not signed an RSA/LRSA*--and > I suspect that will irk a different subset of the readers. > > > > If I am reading your complain correctly, it would appear that your main > > complaint has nothing to do with this transfer policy and everything to > do > > with the old and much-argued complaint about historical allocations. ?If > so, > > I would argue that none of your concerns are made any better or worse by > the > > proposed transfer policy, and that your concerns should be addressed by > a > > new policy that very explicitly addresses review of historical > allocations. > > The transfer policy is acting as litmus test for the scope of ARIN > control over address resources; at the heart of the matter, I think > it may come down to a court case between a legacy holder wishing > to sell IP space to a high bidder outside the ARIN region, and ARIN's > legal counsel, if ARIN tries to interfere in the sale. > > I'm somewhat hoping that I can delve deeply enough here on the list > first to figure out which side ARIN is on; do they consider legacy > holders to be completely outside their domain if they haven't signed > an RSA/LRSA, or do they consider them to be somehow implicitly > under ARIN control even with no signed agreement? > If they're *not* under ARIN control if they haven't signed an RSA/LRSA, > there should be nothing stopping them from selling address blocks > outside the ARIN region, as ARIN would have no control over either > the seller or the buyer. > If ARIN *does* try to enforce needs-based justification on the transfer, > they can't do it based on the purchaser if they're outside the region; > they could only do it based on some assertion of control over the > resource, even in the absence of an RSA/LRSA; and if they're > going to assert that level of control, I would demand they equally > assert *all* restrictions and regulations that are applied to the > rest of the membership. > > > For what it is worth, I would totally support this policy however I > suspect > > ARIN doesn't have the legal authority on which to enforce this. And, as > > past discussion has proven, this would be extremely unpopular. > > Ending discrimination is seldom popular among the privileged > ones who benefit from the discrimination, you are quite correct. :) > > > -- > > Jo Rhett > > Net Consonance : consonant endings by net philanthropy, open source and > > other randomness > > > > Thanks! > > Matt > leaping astride Rocinante once again, lance at the ready... > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. -------------- next part -------------- A non-text attachment was scrubbed... Name: smime.p7s Type: application/x-pkcs7-signature Size: 4935 bytes Desc: not available URL: From jrhett at netconsonance.com Mon Feb 27 16:02:26 2012 From: jrhett at netconsonance.com (Jo Rhett) Date: Mon, 27 Feb 2012 13:02:26 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> <3D80425B-B9F8-47C9-8BC0-1B44A3D65A64@netconsonance.com> Message-ID: <8DB9278C-9DBC-4EAF-A1E7-B255575C28A7@netconsonance.com> > On Mon, Feb 27, 2012 at 11:32 AM, Jo Rhett wrote: >> Can you be specific about how you see the rules not being fairly applied? Do >> you see ARIN giving new blocks to some segment of its clients by a different >> criteria than it provides new blocks to others? Please be specific. On Feb 27, 2012, at 12:25 PM, Matthew Petach wrote: > If, however, the claim is made that the legacy holders are part > and parcel of the ARIN clientele...then clearly, no the same rules > are not being applied to everyone. As I said above, please provide explicit examples of situations where legacy holders have not been subject to the same rules as others for new assignments. > If the block is handed out not by ARIN, but by a legacy holder, > should ARIN's rules still apply? Fundamentally, does ARIN have > any right to limit the ability of someone to purchase address rights > from an entity that has thus far not been explicitly acknowledged > to be a part of ARIN's constituency? I believe that this is the issue in question. For my opinion, I believe that ARIN should be involved and that the same policies should be applied to all new allocations, be they allocations or transfers. To me, any reassignment is an allocation. > I'm struggling with this notion that ARIN has any leg to stand > on with respect to limiting the buying and selling of address block This is all very old topic. Please review the mailing list archives for extensive debate of this topic. > How can ARIN take a hands-off stance > for the blocks as long as they stay in legacy-holders hands, but > the moment a non-legacy holder wishes to purchase a block, > suddenly ARIN has rights to limit that transaction? Very simple: ARIN was tasked with policies for allocation, and has not been given authority or direction to review existing allocations. If you want a new block, you get it from ARIN one way or the other. What you do with your block is not something ARIN has control over, until you want to acquire more space. This is very common in many other industries. > If ARIN *doesn't* allow the transfer, then it would be claiming > it has control over blocks that it had previously claimed it > did not have control over. You seem to misunderstand some of the basic issues involved here. I would suggest reading the documents which created ARIN, and the policy documents which have since guided ARIN's direction. In doing so you will understand the nature of things that ARIN does control and does not control, and significant, has legal ability to control and does not have legal ability to control. Obviously this is an evolving situation, but you really should become acquainted with the history. > The reason I'm wrestling with that, ?. I'll fight tooth and nail to eliminate arbitrary segregation and discrimination like that. I'm really not trying to be snarky, but you are proposing to fight tooth and nail over something you haven't learned enough to understand. You appear to lack basic comprehension of the issues here. A very good thing for you to understand would be the nouns involved -- what they are, and how they relate. Arguing about whether this or that verb is something ARIN can control is much easier to understand when the nouns make sense to you. > The transfer policy is acting as litmus test for the scope of ARIN > control over address resources; at the heart of the matter, I think > it may come down to a court case between a legacy holder wishing > to sell IP space to a high bidder outside the ARIN region, and ARIN's > legal counsel, if ARIN tries to interfere in the sale. This has already happened, several times. Review of mailing list history will illuminate much. > first to figure out which side ARIN is on; ARIN is a membership-run organization whose policy is defined on this very mailing list. > do they consider legacy > holders to be completely outside their domain if they haven't signed > an RSA/LRSA, or do they consider them to be somehow implicitly > under ARIN control even with no signed agreement? Google is your friend. But perhaps more importantly, the RSA and LRSA are good reading material here. This is all very old topics worked out a long time ago. There are of course divergent opinions, but what stance ARIN takes on this topic is very well described in the RSA and LRSA documents themselves. -- Jo Rhett Net Consonance : consonant endings by net philanthropy, open source and other randomness -------------- next part -------------- An HTML attachment was scrubbed... URL: From astrodog at gmail.com Mon Feb 27 16:10:42 2012 From: astrodog at gmail.com (Astrodog) Date: Mon, 27 Feb 2012 15:10:42 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <8695009A81378E48879980039EEDAD28011E05E41E@MAIL1.polartel.local> References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> <3D80425B-B9F8-47C9-8BC0-1B44A3D65A64@netconsonance.com> <8695009A81378E48879980039EEDAD28011E05E41E@MAIL1.polartel.local> Message-ID: On Mon, Feb 27, 2012 at 3:00 PM, Kevin Kargel wrote: > Matthew, > Once again we are entering into a round of discussion where people are > forgetting where the "legacy" spaceholders came from. ?They were on the spot > as the internet was getting started and they were the ones that jumped in > with time and people and resources to develop and experiment and get things > working. ?The internet we have today is precisely because of all the good > work of the "legacy" spaceholders. > > When they were granted their space it was given to them at a time when there > was space in abundance, and nobody was worried about how much space anybody > had. ?They were granted rights to their space without limit or restriction. > > Now that space is becoming at all valuable the vultures are circling and > forgetting the origins of what we have. ?The common refrain is "What have > you done for me lately" of "I want a free piece of the pie and I don't want > to have to work for it". > > We all still owe the "legacy" holders a debt of gratitude and all of this > nipping at their heels late in the game is rather sad. The whole "What have > you done for me lately" philosophy does none of us any credit. > > And no, I am not a legacy holder nor do I have any affiliations with a > legacy holder. ?I do admire and respect all of the good works done by these > pioneers of the internet. > > Turning the IP space in to a free for all without restrictions or controls > is a really bad idea, unless one's only concern is just to turn a quick buck > while one can and one has no concern for the future. ?If that's what we want > to do then lets just divvy up what's left as one recent proposal suggested > and be done with it. ?If we remove all need requirements then I hereby > request all the space that's left. Finding the finances to do it would not > be a problem. > > OK, I'll step down off my soap box again and let you all have at it. > I'm finding myself in an odd position.... I agree with both of you. I agree that needs-based justification makes sense for "new" allocations from ARIN. Something should be in place to prevent exactly the situation you describe: "I'll take whatever you've got left.". Inter-registrant transfers, on the other hand, make less sense to me. The "unfair market" problem Matthew outlined applies, plus there's a whole other set of issues surrounding a company "delegating" IPs, issues with failed sales, etc. I think it is important to examine the two sets of circumstances separately. There is a significant difference in how they function. Inter-registrant transfers will, in the end, always be limited by price and risk, while "new" allocations are not. --- Harrison From jrhett at netconsonance.com Mon Feb 27 16:16:32 2012 From: jrhett at netconsonance.com (Jo Rhett) Date: Mon, 27 Feb 2012 13:16:32 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> <3D80425B-B9F8-47C9-8BC0-1B44A3D65A64@netconsonance.com> <8695009A81378E48879980039EEDAD28011E05E41E@MAIL1.polartel.local> Message-ID: On Feb 27, 2012, at 1:10 PM, Astrodog wrote: > I agree that needs-based justification makes sense for "new" allocations from ARIN. > Inter-registrant transfers, on the other hand, make less sense to me. > ?. > I think it is important to examine the two sets of circumstances separately. Just for those who might be counting, I disagree entirely. I see an allocation as an allocation, no matter the source. I think that all recipients of allocations should have the exact same policy applied to them. -- Jo Rhett Net Consonance : consonant endings by net philanthropy, open source and other randomness -------------- next part -------------- An HTML attachment was scrubbed... URL: From kkargel at polartel.com Mon Feb 27 16:34:56 2012 From: kkargel at polartel.com (Kevin Kargel) Date: Mon, 27 Feb 2012 15:34:56 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> <3D80425B-B9F8-47C9-8BC0-1B44A3D65A64@netconsonance.com> <8695009A81378E48879980039EEDAD28011E05E41E@MAIL1.polartel.local> Message-ID: <8695009A81378E48879980039EEDAD28011E05E420@MAIL1.polartel.local> ? ________________________________________ >From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On >Behalf Of Jo Rhett >Sent: Monday, February 27, 2012 3:17 PM >To: ARIN PPML >Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification >On Feb 27, 2012, at 1:10 PM, Astrodog wrote: >I?agree that needs-based justification makes sense for "new" >allocations?from ARIN. >Inter-registrant transfers, on the other hand, make less sense to me. > . >I think it is important to examine the two sets of >circumstances?separately. >Just for those who might be counting, I disagree entirely. I see an >allocation as an allocation, no matter the source. I think that all >recipients of allocations should have the exact same policy applied to >them. [kjk] +1 -- I will agree with Jo. I will even go further and say that a registration is a registration and that all registrants should be subject to the same policy. The only place this fails is with the ?legacy? holders who do not fall under the common umbrella but for whom registrations are maintained per prior agreement and for the good of the community. Now - if a "legacy" holder returns or relinquishes or transfers space and a new registration or allocation or transfer needs to be effected then I do strongly feel that the "new" allocation should fall under the common rules, restrictions and aegis provided by the community via ARIN RSA (*not* LRSA). >--? >Jo Rhett >Net Consonance : consonant endings by net philanthropy, open source and >other randomness > -------------- next part -------------- A non-text attachment was scrubbed... Name: smime.p7s Type: application/x-pkcs7-signature Size: 4935 bytes Desc: not available URL: From tvest at eyeconomics.com Mon Feb 27 16:46:30 2012 From: tvest at eyeconomics.com (Tom Vest) Date: Mon, 27 Feb 2012 16:46:30 -0500 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> Message-ID: Thanks for the responses Matt -- follow-ups inline... On Feb 27, 2012, at 12:40 PM, Matthew Petach wrote: > On Sun, Feb 26, 2012 at 7:02 PM, Tom Vest wrote: >> Hi Matt, >> >> You seem to be arguing the following: >> >> 1. "IPv4 Speculation" is bad (or maybe good for the lucky speculators, but bad/unfair for everyone else). > > I was trying not to assign it a category of "good' or "bad"--simply stating > it does exist today; and thus, one of the arguments *against* a free and > unfettered market is not relevant. The cry of "but if we allow anyone to > buy and sell IP blocks, we'll be overrun with speculators" rings hollow > when the market is already supporting dozens of speculators who operate > outside the needs-based criteria. But, notwithstanding rhetorical force of habit, is anyone actually crying about "allowing anyone to buy and sell IP blocks" i.e., as opposed to "allowing non-operators (or those who can't demonstrate the equivalent of an operator's "need") to buy IP blocks?" You're still trying to conflate the prerogatives of an(y) aspiring IPv4 seller with those of a(ny) potential IPv4 buyer -- but you really can't claim that the two are the same, or that the differences don't matter without explaining why. Membership in the class of "anyone that can sell IPv4" is bounded by the material fact that in order to sell IPv4 one must actually have some to sell -- and throughout all time to the present moment, 100% of the members of that class have already satisfied, at minimum, whatever definition of "operator" was officially recognized at the time when they received their address resources (and in most cases, additional/more demanding eligibility requirements that came thereafter). By contrast, the class of "anyone that can buy IPv4" has no equivalent limiting factor. Needless to say, you have every right to argue (i.e., give *reasons* why) we should henceforth ignore these real-world material and historical distinctions -- but simply claiming that, suddenly, the differences don't exist is not only unpersuasive, it's not even an argument. Granted, at the moment the very notion of claiming that something will make the IPv4 transfer market itself "fair" or even "less unfair" in any nontrivial way seems absurd to me, if not completely incoherent -- sort of like claiming that launching the post-feudal age with a series of land auctions that were open to both nobles (who own 100% of the land/wealth at the time) and serfs (who possess 0% land/wealth) would have ushered in an eternity of economic "fairness" for nobles, serfs, and all of their respective descendants forevermore. Even so I'll try to keep an open mind ;-) >> 2. Possession of IPv4 today == "IPv4 Speculation." > > Not quite; I meant "posession of IPv4 today *above and beyond what the > ARIN needs-based justification would approve* == IPv4 speculation." Here you seem to be implying either one or both of the following; (a) anything that anyone accomplished/acquired in the past, under conditions that are "easier" than they are now, is by definition unfair; either the "old boys" should be stripped of all accumulated "unfair" benefits, or I should be compensated to make up for the difference. In general any/all past or present legal contracts that provide(d) someone else with forward-looking terms to something that I want that are more more favorable than terms that are currently available to me are automatically rendered null and void simply by that fact. (b) the fairness of anything that anyone previously accomplished/acquired and which is also subject to some kind of ongoing administrative oversight is automatically negated if the current administrative mechanisms are not universally recognized as being 100% infallible at all moments in time. If at any point in time there is any nonzero possibility that the administrative process has failed to identify and punish anyone that is noncompliant with the policy, then it may be reasonably assumed that everyone is noncompliant; either everyone else should be stripped of their accumulated "unfair" gains, or else I should be compensated to make up for the difference. Either way, this is a one-time deal that is available only to me and my contemporaries; anyone that comes along later, and who might have similar objections, can suck it. I think that many of us may succumb to thinking along the lines of (a) from time to time, even though at other times we recognize those feelings for what they are, i.e., "sour grapes." At all times/places, someone somewhere has inherited some "unfair" present-day advantage that they didn't "earn" in the way that I'd have to earn it myself. Except in cases where the consequences of that inheritance are so profound/intolerable that they justify bloody revolution (if such a thing is possible), we tend to shrug and move on... (b) is just a variant of a straw man argument that applies equally (i.e., with equal non-validity) to all organizations/processes in human history. "Someone somewhere is breaking the law -- I believe, anyway... no, I don't have any actual evidence -- but my suspicions about the fallibility and non-impartiality of law enforcement are sufficient in themselves to declare that the law is unfair and illegitimate." If I'm missing or misunderstanding something, and you actually have some other method for deriving and calculating the "unfair" portion of an institution's IPv4 holdings, I'd be interested in hearing it. Alternately, one could embrace and reconcile both sorts of grievances by proposing a policy that would unilaterally strip all IPv4 possession rights from all past and present IPv4 holders holders without exception, and compel everyone who still wants IPv4 for future use to rebid for that privilege in a neutral open auction. That, at least, would be a coherent/consistent response -- though I doubt many people would call it "fair." >> 3. Therefore, anyone/everyone (today) should have an equal right to be an IPv4 speculator. > > Given that there are many players already who hold IPv4 resources that wildly > flaunt any needs-based justification whatsoever, I propose that anyone and > everyone should likewise be able to participate in the market to that same > degree. If we're going to turn a blind eye towards holders of large blocks > and not require any needs-based justification for them, then be fair and > do away with the needs-based justification for everyone. This is the same straw man argument coupled with the same, completely orthogonal proposed remedy. You really need to come up with a better way to frame this argument than "Someone else can wildly flaunt their indifference, but I can't, and that's not fair" > Otherwise, > apply it equally across the board. > >> Questions: >> Is there something uniquely unfair that is inherent specifically in an IPv4 holder's right to sell not just to sell IPv4, but to sell it without restriction based on current needs-based policies. > > There's nothing unfair in the right; what is unfair is that the > rights are not being applied equally to everyone within the > ARIN purview. Sure they are, you're just failing to acknowledge (or to accept) that there is an historical dimension to certain kinds of rules and enforcement mechanisms in every system. Much as we may find some or all of them distasteful, the recognition of various "legacies" and "inheritances" is extremely common if not universal feature of human rule-based institutions. > I'm advocating that we either apply the rules > equally to *everyone*, or apply them to no-one. The current > "have" and "have-not" scenario is a ludicrous parody of > medieval fiefdoms. > >> In other words, is there something that makes that narrow privilege more important than any/every other right/privilege that an IPv4 holder might enjoy, e.g., in world of IP addressing scarcity (e.g., max. freedom to expand, to add new customers, to add peers at will, reachability to/from all of the the rest of the Internet)? Even if one thinks that that narrow selling-related privilege *is* more important and more unfair than all of the other advantages of having IPv4, doesn't the privilege also confer to any/all subsequent IPv4 buyers? If it does confer, then (following the logic that people use to justify a transfer market in general), what makes the idea of having to buy that particular privilege *more* intolerable than the idea of having to buy any of the other privileges that every current IPv4 holder in the world currently enjoys simply by virtue of their possession of allocated/assigned IPv4? >> >> If you believe that RIR-era needs justification rules retroactively render legacy IPv4 assignments so unfair and illegitimate that an ex post facto equalization (to your benefit) is now justified, and the community actually ratifies that notion, I wonder how future community members will interpret that precedent a few years from now, when they start comparing what they're obliged to do/give up to get usable IP addresses to what was expected of *anyone* that was lucky enough to acquire IPv4 at any time in before IPv4 exhaustion... >> > > It's refreshing to see people admitting that yes, the legacy > block holders do enjoy privilege and status far above everyone > else who operates under the RIR needs-based rules. They simply have a different status, which imposes a different (and granted, lighter) set of compliance obligations. No doubt we would also have liked to have been around a century ago to have staked a free ("verbal commitment to improve") claim to a couple hundred acres of good farmland -- or rather, it'd be nice to cleanly inherit that land today without actually having live through, worked/maintained that land for the intervening years. But even if someone granted you narrow but absolute power to "rectify that injustice" today, by changing *only* the rules that governed who could buy and sell land, what change could you possibly make that that would cause the non-inheritance of that land by you to be "fair" or "more fair" -- and not just for you, but more fair for *everyone* now and in the future who did not and will never enjoy such an inheritance? > However, > I'm not advocating that we take up pitchforks and torches and > storm the castles of the wealthly landed gentry; instead, I'm > advocating removal of the unfair and unreasonable rules that > deny anyone else the ability to gain access to similar levels > of resources. Sorry, but I can't see how your proposal adds any additional "fairness" to any element of the system that is not already on the winning side of broader fairness/unfairness divide(s) that are already inherent in this situation, while I can see all sorts of ways that it would be likely further exacerbate those otherwise unrelated problems... > The old boy's club has their wealth and power and prestige > in the form of large, unjustified swaths of IPv4 space; let's > bring equality and fairness to the market, and allow > everyone the *opportunity* to participate in that mode. Please stop using the using the term "participate" to erroneously (or misleadingly) conflate the separate and distinct prerogatives and material capabilities of all hypothetical IPv4 buyers and IPv4 sellers. Make a positive argument for why the differences should not matter, and/or why ignoring all of the current differences that you'd like to ignore going forward -- including "operators" vs. "non-operators" -- would make the future better or "more fair" than a future in which those distinctions continue to be honored. Proof by assertion is not strengthened by continued repetition (!). > Or are you arguing in favour of the status quo, that it's > fine for some players to hold onto large, unjustified blocks > of IPv4 space, simply due to their age, but everyone else > has to sit in the back of the bus? Actually, I have advocated a coordinated, incremental decommissioning of all of the buses, so that no one *who can actually drive* is ever forced to ride when they'd prefer to drive themselves. I really don't see how transportation services are going to be improved or made "more fair" by allowing you to sell off idled buses to someone who cannot drive, or who refuses to positively assert that they're actually going to put the buses they purchase back on the road! But hey, if you want to argue that it would be even fairer to eliminate all bus drivers licensing requirements, and/or that the transportation market would be greatly improved by encouraging new entrants to acquire buses and put them to their most profitable use, which might well mean parking nine to maximize fare on the tenth, go for it. > Have we really come to the days of "separate but equal", > and segregation on the internet?? Is it time for the next > Rosa Parks to take a stand, and not meekly move to the > back of the bus, based solely on an arbitrary discriminant > like skin colour? Why should the age of your IPv4 block > confer special rights to a select few that are denied to > everyone else? > > Very simply, my stance is "equal rights for all." If we're not > enforcing needs-based justification for everyone, then don't > enforce it on just a select minority. That's not equality, that's > discrimination. > > Help me end discrimination on the internet; vote to remove > discriminatory needs-based rules that are applied only to > the non-privileged minorities. Vote YES on prop 165! > >> Am I missing something? > > I hope this has helped clarify the points you might have > missed in my earlier missive; and with that increased > clarity will come support for true equality in the ARIN > region, and an end to unfair, discriminatory practices. Thanks again for the detailed response, but no it didn't provide any new information. Heavy and elaborate reinforcement of the same still-unrelated propositions, yes, but the gaping holes where a positive argument connecting reality > problem > solution > reality should be are still there, waiting to be filled... TV >> Thanks, >> TV > > Thanks! > > Matt From owen at delong.com Mon Feb 27 17:16:37 2012 From: owen at delong.com (Owen DeLong) Date: Mon, 27 Feb 2012 14:16:37 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> <3D80425B-B9F8-47C9-8BC0-1B44A3D65A64@netconsonance.com> <8695009A81378E48879980039EEDAD28011E05E41E@MAIL1.polartel.local> Message-ID: <049B8118-A1F3-4848-9087-637FAD212004@delong.com> On Feb 27, 2012, at 1:16 PM, Jo Rhett wrote: > On Feb 27, 2012, at 1:10 PM, Astrodog wrote: >> I agree that needs-based justification makes sense for "new" allocations from ARIN. >> Inter-registrant transfers, on the other hand, make less sense to me. >> ?. >> I think it is important to examine the two sets of circumstances separately. > > Just for those who might be counting, I disagree entirely. I see an allocation as an allocation, no matter the source. I think that all recipients of allocations should have the exact same policy applied to them. > +1 Owen From astrodog at gmail.com Mon Feb 27 17:35:44 2012 From: astrodog at gmail.com (Astrodog) Date: Mon, 27 Feb 2012 16:35:44 -0600 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <049B8118-A1F3-4848-9087-637FAD212004@delong.com> References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> <3D80425B-B9F8-47C9-8BC0-1B44A3D65A64@netconsonance.com> <8695009A81378E48879980039EEDAD28011E05E41E@MAIL1.polartel.local> <049B8118-A1F3-4848-9087-637FAD212004@delong.com> Message-ID: On Mon, Feb 27, 2012 at 4:16 PM, Owen DeLong wrote: > > On Feb 27, 2012, at 1:16 PM, Jo Rhett wrote: > >> On Feb 27, 2012, at 1:10 PM, Astrodog wrote: >>> I agree that needs-based justification makes sense for "new" allocations from ARIN. >>> Inter-registrant transfers, on the other hand, make less sense to me. >>> ?. >>> I think it is important to examine the two sets of circumstances separately. >> >> Just for those who might be counting, I disagree entirely. I see an allocation as an allocation, no matter the source. I think that all recipients of allocations should have the exact same policy applied to them. >> > > +1 > > Owen That would be ideal, but simply isn't the case. A transfer wherein someone fills out the paperwork, and pays a nominal fee to ARIN, and then has the allocation within the RSA is very different from one where they pay an unrelated third party some sum to transfer some or all of the rights to an allocation, plus the paperwork, RSA, and nominal fee. In the latter, any number of conditions may apply, in addition to the registrant's RSA. For example, an entity could perform an 8.3 transfer, on the condition that some transit exchange occurs as well... if the transit exchange fails to occur, or something else breaches the agreement to the point where it becomes void, the receiving entity becomes obligated to transfer the resources back to the original party. Strictly speaking, under 8.3, this can't happen, because there is no guarantee ARIN would allow the return (and, in fact, in may be prohibited). This limits IP-related transactions to "instant" cash or equity transfers, which is exactly the sort of transaction speculators would attempt to monetize. By removing the needs test, you allow organizations to create long term agreements around the use of IP addresses, instead of forcing them to "buy" the allocation outright, at once. --- Harrison. From owen at delong.com Mon Feb 27 18:11:37 2012 From: owen at delong.com (Owen DeLong) Date: Mon, 27 Feb 2012 15:11:37 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> <3D80425B-B9F8-47C9-8BC0-1B44A3D65A64@netconsonance.com> <8695009A81378E48879980039EEDAD28011E05E41E@MAIL1.polartel.local> <049B8118-A1F3-4848-9087-637FAD212004@delong.com> Message-ID: <7C171CC2-3A2B-41EF-A4C5-3C2759F76EA3@delong.com> On Feb 27, 2012, at 2:35 PM, Astrodog wrote: > On Mon, Feb 27, 2012 at 4:16 PM, Owen DeLong wrote: >> >> On Feb 27, 2012, at 1:16 PM, Jo Rhett wrote: >> >>> On Feb 27, 2012, at 1:10 PM, Astrodog wrote: >>>> I agree that needs-based justification makes sense for "new" allocations from ARIN. >>>> Inter-registrant transfers, on the other hand, make less sense to me. >>>> ?. >>>> I think it is important to examine the two sets of circumstances separately. >>> >>> Just for those who might be counting, I disagree entirely. I see an allocation as an allocation, no matter the source. I think that all recipients of allocations should have the exact same policy applied to them. >>> >> >> +1 >> >> Owen > > That would be ideal, but simply isn't the case. A transfer wherein > someone fills out the paperwork, and pays a nominal fee to ARIN, and > then has the allocation within the RSA is very different from one > where they pay an unrelated third party some sum to transfer some or > all of the rights to an allocation, plus the paperwork, RSA, and > nominal fee. > From an addressing policy perspective, how, exactly is it different? Remember, we're talking about policy here. The fees paid to ARIN and most certainly any compensation which may or may not exist in the transfers between two other parties is utterly and completely unrelated to the policy. We very carefully and deliberately crafted 8.3 to separate those issues. > In the latter, any number of conditions may apply, in addition to the > registrant's RSA. For example, an entity could perform an 8.3 > transfer, on the condition that some transit exchange occurs as > well... if the transit exchange fails to occur, or something else > breaches the agreement to the point where it becomes void, the > receiving entity becomes obligated to transfer the resources back to > the original party. Strictly speaking, under 8.3, this can't happen, > because there is no guarantee ARIN would allow the return (and, in > fact, in may be prohibited). This limits IP-related transactions to > "instant" cash or equity transfers, which is exactly the sort of > transaction speculators would attempt to monetize. By removing the > needs test, you allow organizations to create long term agreements > around the use of IP addresses, instead of forcing them to "buy" the > allocation outright, at once. > I would say that this behooves the seller to understand the policies covering the transfer of addresses. Generally, if you're transferring addresses based on a transit contract, this would be done through the normal ISP allocation process and not through 8.3 anyway, so, it really doesn't make a lot of sense to me that you would do so. I believe it is our policy intent to limit transfers to being those which, other than any independent compensation agreements that ARIN is not party to, are generally aligned with Allocations/Assignments as ARIN would make them if they were requested from the free pool. The fact that someone may run off the rails and do something different in the current environment is a corner case that I would support policy to limit or eliminate, but, I certainly don't think it's a reason to abandon good existing policy when things are working as intended. Owen > --- Harrison. From hannigan at gmail.com Mon Feb 27 20:04:19 2012 From: hannigan at gmail.com (Martin Hannigan) Date: Mon, 27 Feb 2012 20:04:19 -0500 Subject: [arin-ppml] Proposal 2011-7 Fail Was:Re: ARIN-prop-165 Eliminate Needs-Based Justification Message-ID: On Mon, Feb 27, 2012 at 2:32 PM, Jo Rhett wrote: > [ clip ] > ARIN's membership has asked it to perform. ?I have seen and supported > numerous proposals for ARIN to review and audit existing allocations for > compliance, and these proposals have always failed. ?Thus ARIN has been > explicitly told by its members that it is not a policing body. ?Therefore it > can only apply these policies when handing out *new* allocations. (be they > transferred blocks or not) It's interesting that you acknowledge that the membership has told ARIN to stop futzing around with Section 12. I, and many others in the past version of this "proposal" agree. And we are still doing it. This proposal is on-going for almost a year https://www.arin.net/policy/proposals/2011_7.html and a small AC minority appear to disagree and battle on regardless of what the community wants. In this case, we're being protected from ourselves. >From the rationale of the proposal: "To date the community has not documented or firmly established use of an effective enforcement mechanism." Best, -M< From owen at delong.com Tue Feb 28 04:08:56 2012 From: owen at delong.com (Owen DeLong) Date: Tue, 28 Feb 2012 01:08:56 -0800 Subject: [arin-ppml] 2011-7 Status Message-ID: The feedback from the community so far on this proposal has actually been in favor of the AC continuing to work on it. A small minority of the AC cannot keep a propsal alive. It only takes 8 AC members at any point to pass a motion to abandon a draft policy. (A simple majority of quorum will do for anything that is not yet a draft policy.) As such, I have trouble reconciling the actual reality with statements by my colleague earlier on this list. 2011-7 as revised based on community feedback is slated for discussion in Vancouver. I encourage people who have an interest in this policy, whether in favor or in opposition to make their opinions known on this list. There is still time to incorporate community feedback into revisions to the draft policy before taking it to Vancouver. Owen From mpetach at netflight.com Tue Feb 28 05:23:26 2012 From: mpetach at netflight.com (Matthew Petach) Date: Tue, 28 Feb 2012 02:23:26 -0800 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> Message-ID: On Mon, Feb 27, 2012 at 1:46 PM, Tom Vest wrote: > Thanks for the responses Matt -- follow-ups inline... > > On Feb 27, 2012, at 12:40 PM, Matthew Petach wrote: > >> On Sun, Feb 26, 2012 at 7:02 PM, Tom Vest wrote: >>> Hi Matt, >>> >>> You seem to be arguing the following: >>> >>> 1. "IPv4 Speculation" is bad (or maybe good for the lucky speculators, but bad/unfair for everyone else). >> >> I was trying not to assign it a category of "good' or "bad"--simply stating >> it does exist today; and thus, one of the arguments *against* a free and >> unfettered market is not relevant. ?The cry of "but if we allow anyone to >> buy and sell IP blocks, we'll be overrun with speculators" rings hollow >> when the market is already supporting dozens of speculators who operate >> outside the needs-based criteria. > > But, notwithstanding rhetorical force of habit, is anyone actually crying about "allowing anyone to buy and sell IP blocks" i.e., as opposed to "allowing non-operators (or those who can't demonstrate the equivalent of an operator's "need") to buy IP blocks?" You're still trying to conflate the prerogatives of an(y) aspiring IPv4 seller with those of a(ny) potential IPv4 buyer -- but you really can't claim that the two are the same, or that the differences don't matter without explaining why. Membership in the class of "anyone that can sell IPv4" is bounded by the material fact that in order to sell IPv4 one must actually have some to sell -- and throughout all time to the present moment, 100% of the members of that class have already satisfied, at minimum, whatever definition of "operator" was officially recognized ?at the time when they received their address resources (and in most cases, additional/more demanding eligibility requirements that came thereafter). By contrast, the class of "anyone that can buy IPv4" has no equivalent limiting factor. I suppose what I'm stumbling over is that today, we have large blocks of v4 address space that today are held be registrants who are not routing them as part of the global IPv4 routing table. You seem to feel that they somehow qualified as "operators" in a way that has significance, in spite of them not routing their address space in a reachable fashion, whereas "speculators" would somehow be categorized as "non-operators". Can I ask, what characteristic would you use to distinguish an "operator" from a "non-operator" that we can externally observe? I see large chunks of address space assigned by IANA that are not operationally visible on the v4 internet; the CAIDA heat-map survey found similar results: http://www.iana.org/assignments/ipv4-address-space/ipv4-address-space.xml http://www.caida.org/research/traffic-analysis/arin-heatmaps/ I would argue that your attempt to differentiate between "operator" and "non-operator" is specious and meaningless, as entities you claim to have qualified as "operators" are in fact externally indistinguishable from the category of "non- operators" in that none of the IPv4 address space assigned to them is routed or visible on the global IPv4 network. And if there is no distinguishable difference between "operators" and "non-operators", then the class of "operators", who managed to obtain IP space thus far, in spite of not actually routing it on the global internet, is functionally equivalent to the class of "anyone that can buy IPv4"--ie, non-operators. So...again...please help me understand the nature of the category of "operator" that allows one to obtain globally routable IP space with no plans to route it on the global internet, from the category of "speculator"? I ask, because the one line I keep hearing over and over again in defense of a needs-based assignment system is that without it, IP space will be hoarded up by speculators. And if we can't actually tell the difference between a "speculator" and an "operator" from an external viewpoint, that defense becomes meaningless. > Needless to say, you have every right to argue (i.e., give *reasons* why) we should henceforth ignore these real-world material and historical distinctions -- but simply claiming that, suddenly, the differences don't exist is not only unpersuasive, it's not even an argument. > Ah. Agreed, the historical differences may have existed at one time, or so people claim; not having a time machine, we cannot go back to verify such claims. What I *am* asserting is that at the present moment in time, there is no observable characteristic that distinguishes them; and thus, at the moment, the difference exists only based on a historical record, not on any observable difference that can empirically be observed. > Granted, at the moment the very notion of claiming that something will make the IPv4 transfer market itself "fair" or even "less unfair" in any nontrivial way seems absurd to me, if not completely incoherent -- sort of like claiming that launching the post-feudal age with a series of land auctions that were open to both nobles (who own 100% of the land/wealth at the time) and serfs (who possess 0% land/wealth) would have ushered in ?an eternity of economic "fairness" for nobles, serfs, and all of their respective descendants forevermore. > > Even so I'll try to keep an open mind ?;-) Reasonable point; my use of the word 'fair' without definition did nothing to clarify the discussion. >>> 2. Possession of IPv4 today == "IPv4 Speculation." >> >> Not quite; I meant "posession of IPv4 today *above and beyond what the >> ARIN needs-based justification would approve* == IPv4 speculation." > > Here you seem to be implying either one or both of the following; > > (a) anything that anyone accomplished/acquired in the past, under conditions that are "easier" than they are now, is by definition unfair; either the "old boys" should be stripped of all accumulated "unfair" benefits, or I should be compensated to make up for the difference. In general any/all past or present legal contracts that provide(d) someone else with forward-looking terms to something that I want that are more more favorable than terms that are currently available to me are automatically rendered null and void simply by that fact. > > (b) the fairness of anything that anyone previously accomplished/acquired and which is also subject to some kind of ongoing administrative oversight is automatically negated if the current administrative mechanisms are not universally recognized as being 100% infallible at all moments in time. If at any point in time there is any nonzero possibility that the administrative process has failed to identify and punish anyone that is noncompliant with the policy, then it may be reasonably assumed that everyone is noncompliant; either everyone else should be stripped of their accumulated "unfair" gains, or else I should be compensated to make up for the difference. > > Either way, this is a one-time deal that is available only to me and my contemporaries; anyone that comes along later, and who might have similar objections, can suck it. > > I think that many of us may succumb to thinking along the lines of (a) from time to time, even though at other times we recognize those feelings for what they are, i.e., "sour grapes." At all times/places, someone somewhere has inherited some "unfair" present-day advantage that they didn't "earn" in the way that I'd have to earn it myself. Except in cases where the consequences of that inheritance are so profound/intolerable that they justify bloody revolution (if such a thing is possible), we tend to shrug and move on... > > (b) is just a variant of a straw man argument that applies equally (i.e., with equal non-validity) to all organizations/processes in human history. "Someone somewhere is breaking the law -- I believe, anyway... no, I don't have any actual evidence -- but my suspicions about the fallibility and non-impartiality of law enforcement are sufficient in themselves to declare that the law is unfair and illegitimate." > > If I'm missing or misunderstanding something, and you actually have some other method for deriving and calculating the "unfair" portion of an institution's IPv4 holdings, I'd be interested in hearing it. You read far too much into what I said. I'm simply trying to come up with a definition of what an IP Speculator might be, as people are very concerned that an unfettered market would Lead To Rampant IPv4 Speculation--with the attendant implication that such a situation would be a Bad Thing(tm). I'm postulating that one such definition might be that an IPv4 Speculator is an entity that obtains more globally routable IPv4 address space than they actually need for running their business. I then point out that based on such a definition, it is clear that there are entities that already meet that definition. For those who are unsure of who those entities might be, I again refer them to: http://www.iana.org/assignments/ipv4-address-space/ipv4-address-space.xml http://www.caida.org/research/traffic-analysis/arin-heatmaps/ from which they can easily see large swaths of IPv4 space which has been allocated for decades, but is not being used on the global IPv4 internet. And, given the existence (as shown) of IPv4 non-operating speculators that have existed throughout the entire history of this mailing list, it is clearly foolishness to now suddenly object to allowing free and unfettered transfer of resources on the grounds that it might lead to IPv4 speculation. > Alternately, one could embrace and reconcile both sorts of grievances by proposing a policy that would unilaterally strip all IPv4 possession rights from all past and present IPv4 holders holders without exception, and compel everyone who still wants IPv4 for future use to rebid for that privilege in a neutral open auction. > That, at least, would be a coherent/consistent response -- ?though I doubt many people would call it "fair." If you go back through the history of the ARIN debates about evaluating number resource usage, that was very close to the heart of the policy language that was included in early years allowing for annual audits of number resource usage; in essence, if you obtained a resource, and it was later found you no longer had justifiable need for it, the resource could be reclaimed and returned to the pool for others to request. At the Eugene meeting, the microphones were occupied frequently by advocates on both sides; those who felt that once a resource had been granted, it was forever yours, and those who felt resources should be re-justified on an ongoing basis, or be forfeit back to the pool for others to use. The policy language to support that model was proposed and discussed, and eventually a variant that allows for reclamation was finally agreed on, and is at the heart of every contract ARIN members sign: "If ARIN determines that the number resources or any other Services are not being used in compliance with this Agreement, the Policies, or the purposes for which they are intended, ARIN may: (i) revoke the number resources; (ii) cease providing the Services to Applicant; and/or (iii) terminate this Agreement." (from https://www.arin.net/resources/agreements/rsa.pdf ) ARIN has never proposed doing a massive, all-at-once audit and reclamation back from everyone it deems to not be in compliance--but that ability is there in the contract, so it's not too far-fetched to consider that as a possible scenario. >>> 3. Therefore, anyone/everyone (today) should have an equal right to be an IPv4 speculator. >> >> Given that there are many players already who hold IPv4 resources that wildly >> flaunt any needs-based justification whatsoever, I propose that anyone and >> everyone should likewise be able to participate in the market to that same >> degree. ?If we're going to turn a blind eye towards holders of large blocks >> and not require any needs-based justification for them, then be fair and >> do away with the needs-based justification for everyone. > > This is the same straw man argument coupled with the same, completely orthogonal proposed remedy. > You really need to come up with a better way to frame this argument than "Someone else can wildly flaunt their indifference, but I can't, and that's not fair" So, let me make sure I understand your position on this; from your perspective, it is entirely proper to have different rules that apply to different entities within the ARIN region. There is no requirement to have the rules equally apply to everyone? > >> Otherwise, >> apply it equally across the board. >> >>> Questions: >>> Is there something uniquely unfair that is inherent specifically in an IPv4 holder's right to sell not just to sell IPv4, but to sell it without restriction based on current needs-based policies. >> >> There's nothing unfair in the right; what is unfair is that the >> rights are not being applied equally to everyone within the >> ARIN purview. > > Sure they are, you're just failing to acknowledge (or to accept) that there is an historical dimension to certain kinds of rules and enforcement mechanisms in every system. Much as we may find some or all of them distasteful, the recognition of various "legacies" and "inheritances" is extremely common if not universal feature of human rule-based institutions. > OK. I'll grant that there are inherited legacies that are governed by different rules than those applied to the rest of a population. I may not personally like it, but yes, I concede your point that such inheritances do exist throughout society. >> I'm advocating that we either apply the rules >> equally to *everyone*, or apply them to no-one. ?The current >> "have" and "have-not" scenario is a ludicrous parody of >> medieval fiefdoms. >> >>> In other words, is there something that makes that narrow privilege more important than any/every other right/privilege that an IPv4 holder might enjoy, e.g., in ?world of IP addressing scarcity (e.g., max. freedom to expand, to add new customers, to add peers at will, reachability to/from all of the the rest of the Internet)? ?Even if one thinks that that narrow selling-related privilege *is* more important and more unfair than all of the other advantages of having IPv4, ?doesn't the privilege also confer to any/all subsequent IPv4 buyers? If it does confer, then (following the logic that people use to justify a transfer market in general), what makes the idea of having to buy that particular privilege *more* intolerable than the idea of having to buy any of the other privileges that every current IPv4 holder in the world currently enjoys simply by virtue of their possession of allocated/assigned IPv4? Exactly! The two should be fairly and equitably applied across the board to both populations. I'm glad you were able to clarify the inequality in terms that made more sense to you. >>> If you believe that RIR-era needs justification rules retroactively render legacy IPv4 assignments so unfair and illegitimate that an ex post facto equalization (to your benefit) is now justified, and the community actually ratifies that notion, I wonder how future community members will interpret that precedent a few years from now, when they start comparing what they're obliged to do/give up to get usable IP addresses to what was expected of *anyone* that was lucky enough to acquire IPv4 at any time in before IPv4 exhaustion... >>> Much like with the shared wireless spectrum, I anticipate ongoing adjustments being made to allocations, with the entire community having to make concessions and adjustments, not just new entrants to the field. As spectrum became more and more in demand, and the push for trying to pack more uses into the limited spectrum range increased, the adjustments were applied across the board. It didn't matter if you had been using analog TV broadcast frequencies for 50 years; when the push for reallocation of spectrum came along, you had to give up your swath of analog spectrum and move to new frequency ranges. Nobody got to say "but I qualified for this spectrum under the rules from 10 years ago, so you can't touch it." Likewise, I think in the IPv4 space a similar situation could exist; as the limited resource comes under increasing demand, reapportioning across the board could become necessary. We have a nice precedent for it in the analog TV spectrum, so I don't think it's an outrageous model to propose at all. >> >> It's refreshing to see people admitting that yes, the legacy >> block holders do enjoy privilege and status far above everyone >> else who operates under the RIR needs-based rules. > > They simply have a different status, which imposes a different (and granted, lighter) set of compliance obligations. No doubt we would also have liked to have been around a century ago to have staked a free ("verbal commitment to improve") claim to a couple hundred acres of good farmland -- or rather, it'd be nice to cleanly inherit that land today without actually having live through, worked/maintained that land for the intervening years. But even if someone granted you narrow but absolute power to "rectify that injustice" today, ?by changing *only* the rules that governed who could buy and sell land, what change could you possibly make that that would cause the non-inheritance of that land by you to be "fair" or "more fair" -- and not just for you, but more fair for *everyone* now and in the future who did not and will never enjoy such an inheritance? > I think the analogy I'm looking at is more along the lines of someone who has inherited land being allowed to sell that land to overseas investors, completely tax-free, whereas everyone who did not inherit their property must sell the property with government involvement, including restrictions on the zoning of the land being sold, and taxes on the transfer of the land. >> However, >> I'm not advocating that we take up pitchforks and torches and >> storm the castles of the wealthly landed gentry; instead, I'm >> advocating removal of the unfair and unreasonable rules that >> deny anyone else the ability to gain access to similar levels >> of resources. > > Sorry, but I can't see how your proposal adds any additional "fairness" to any element of the system that is not already on the winning side of broader fairness/unfairness divide(s) that are already inherent in this situation, while I can see all sorts of ways that it would be likely further exacerbate those otherwise unrelated problems... > I'm not actually proposing anything, I'm simply advocating for the removal of needs-based allocations. I've just been pulling out more analogies than other supporters have, which might make it seem like I'm advocating for more than they have. >> The old boy's club has their wealth and power and prestige >> in the form of large, unjustified swaths of IPv4 space; let's >> bring equality and fairness to the market, and allow >> everyone the *opportunity* to participate in that mode. > > Please stop using the using the term "participate" to erroneously (or misleadingly) conflate the separate and distinct prerogatives and material capabilities of all hypothetical IPv4 buyers and IPv4 sellers. Make a positive argument for why the differences should not matter, and/or why ignoring all of the current differences that you'd like to ignore going forward -- including "operators" vs. "non-operators" -- would make the future better or "more fair" than a future in which those distinctions continue to be honored. Proof by assertion is not strengthened by continued repetition (!). > I've already indicated up above that the distinction between operators and non-operators doesn't exist, and cited links to concrete evidence. I didn't realize you needed me to connect the dots for you; I apologize for the omission the first time around, and hope that now it's clearer that this is not simply proof by assertion. >> Or are you arguing in favour of the status quo, that it's >> fine for some players to hold onto large, unjustified blocks >> of IPv4 space, simply due to their age, but everyone else >> has to sit in the back of the bus? > > Actually, I have advocated a coordinated, incremental decommissioning of all of the buses, so that no one *who can actually drive* is ever forced to ride when they'd prefer to drive themselves. I really don't see how transportation services are going to be improved or made "more fair" by allowing you to sell off idled buses to someone who cannot drive, or who refuses to positively assert that they're actually going to put the buses they purchase back on the road! > > But hey, if you want to argue that it would be even fairer to eliminate all bus drivers licensing requirements, and/or that the transportation market would be greatly improved by encouraging ?new entrants to acquire buses and put them to their most profitable use, which might well mean parking nine to maximize fare on the tenth, go for it. Cool. Thanks for giving me your blessing to continue. >> Have we really come to the days of "separate but equal", >> and segregation on the internet?? ?Is it time for the next >> Rosa Parks to take a stand, and not meekly move to the >> back of the bus, based solely on an arbitrary discriminant >> like skin colour? ?Why should the age of your IPv4 block >> confer special rights to a select few that are denied to >> everyone else? >> >> Very simply, my stance is "equal rights for all." ?If we're not >> enforcing needs-based justification for everyone, then don't >> enforce it on just a select minority. ?That's not equality, that's >> discrimination. >> >> Help me end discrimination on the internet; vote to remove >> discriminatory needs-based rules that are applied only to >> the non-privileged minorities. ?Vote YES on prop 165! >> >>> Am I missing something? >> >> I hope this has helped clarify the points you might have >> missed in my earlier missive; and with that increased >> clarity will come support for true equality in the ARIN >> region, and an end to unfair, discriminatory practices. > > Thanks again for the detailed response, but no it didn't provide any new information. > Heavy and elaborate reinforcement of the same still-unrelated propositions, yes, but the gaping holes where a positive argument connecting reality > problem > solution > reality should be are still there, waiting to be filled... Is this helping fill your holes at all? Honestly, I find your writing to be very hard to follow, so I'm not entirely certain which pieces you're missing, and need more clarification on; but as you point out the gaps, I'll do my best to fill them. Thanks! Matt From owen at delong.com Tue Feb 28 06:25:32 2012 From: owen at delong.com (Owen DeLong) Date: Tue, 28 Feb 2012 03:25:32 -0800 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> Message-ID: <6FBFA779-0ACA-48C9-82A7-4F1BFAA9A7C0@delong.com> On Feb 28, 2012, at 2:23 AM, Matthew Petach wrote: > On Mon, Feb 27, 2012 at 1:46 PM, Tom Vest wrote: >> Thanks for the responses Matt -- follow-ups inline... >> >> On Feb 27, 2012, at 12:40 PM, Matthew Petach wrote: >> >>> On Sun, Feb 26, 2012 at 7:02 PM, Tom Vest wrote: >>>> Hi Matt, >>>> >>>> You seem to be arguing the following: >>>> >>>> 1. "IPv4 Speculation" is bad (or maybe good for the lucky speculators, but bad/unfair for everyone else). >>> >>> I was trying not to assign it a category of "good' or "bad"--simply stating >>> it does exist today; and thus, one of the arguments *against* a free and >>> unfettered market is not relevant. The cry of "but if we allow anyone to >>> buy and sell IP blocks, we'll be overrun with speculators" rings hollow >>> when the market is already supporting dozens of speculators who operate >>> outside the needs-based criteria. >> >> But, notwithstanding rhetorical force of habit, is anyone actually crying about "allowing anyone to buy and sell IP blocks" i.e., as opposed to "allowing non-operators (or those who can't demonstrate the equivalent of an operator's "need") to buy IP blocks?" You're still trying to conflate the prerogatives of an(y) aspiring IPv4 seller with those of a(ny) potential IPv4 buyer -- but you really can't claim that the two are the same, or that the differences don't matter without explaining why. Membership in the class of "anyone that can sell IPv4" is bounded by the material fact that in order to sell IPv4 one must actually have some to sell -- and throughout all time to the present moment, 100% of the members of that class have already satisfied, at minimum, whatever definition of "operator" was officially recognized at the time when they received their address resources (and in most cases, additional/more demanding eligibility requirements that came thereafter). By contrast, the class of "anyone that can buy IPv4" has no equivalent limiting factor. > > I suppose what I'm stumbling over is that today, we > have large blocks of v4 address space that today > are held be registrants who are not routing them > as part of the global IPv4 routing table. You seem > to feel that they somehow qualified as "operators" > in a way that has significance, in spite of them not > routing their address space in a reachable fashion, > whereas "speculators" would somehow be categorized > as "non-operators". > Even under today's policies, there are legitimate purposes for obtaining a registration that do not involve a route appearing in the global table or any routing table you are likely to be able to see. Just because their network isn't visible to you does not mean that it is not operating and/or is not connected to a network that is connected to the internet. > Can I ask, what characteristic would you use to > distinguish an "operator" from a "non-operator" > that we can externally observe? I see large > chunks of address space assigned by IANA > that are not operationally visible on the v4 internet; > the CAIDA heat-map survey found similar results: > This question would seem to indicate that you are operating from an assumption that operating==visible in the routing table. ARIN uses a variety of means to assess whether a network operator is actually operating a network or not. Sometimes that involves receiving the information under mutual NDA, so, it may not be externally observable. Nonetheless, it is very possible to have a legitimate network operation that requires globally unique addresses that is not visible. > http://www.iana.org/assignments/ipv4-address-space/ipv4-address-space.xml > http://www.caida.org/research/traffic-analysis/arin-heatmaps/ > > I would argue that your attempt to differentiate between > "operator" and "non-operator" is specious and meaningless, > as entities you claim to have qualified as "operators" are in > fact externally indistinguishable from the category of "non- > operators" in that none of the IPv4 address space assigned > to them is routed or visible on the global IPv4 network. > And if there is no distinguishable difference between > "operators" and "non-operators", then the class of > "operators", who managed to obtain IP space thus > far, in spite of not actually routing it on the global > internet, is functionally equivalent to the class of > "anyone that can buy IPv4"--ie, non-operators. > While you may not be able to make the distinction, ARIN staff usually can make said distinction. As such, your assertions are not correct. > So...again...please help me understand the nature > of the category of "operator" that allows one to > obtain globally routable IP space with no plans > to route it on the global internet, from the category > of "speculator"? > Speculator, at least for me in the context of this discussion means someone who does not intend to use the addresses to operate an actual network (whether connected to the internet or not) and is merely attempting to profit from price differentials in address trading and/or to manipulate the price of address resources. > I ask, because the one line I keep hearing over and > over again in defense of a needs-based assignment > system is that without it, IP space will be hoarded > up by speculators. And if we can't actually tell the > difference between a "speculator" and an "operator" > from an external viewpoint, that defense becomes > meaningless. > We as a community may be unable to tell the difference, but, ARIN staff has proven rather adept at it. >> Needless to say, you have every right to argue (i.e., give *reasons* why) we should henceforth ignore these real-world material and historical distinctions -- but simply claiming that, suddenly, the differences don't exist is not only unpersuasive, it's not even an argument. >> > > Ah. Agreed, the historical differences may have > existed at one time, or so people claim; not having > a time machine, we cannot go back to verify such > claims. > > What I *am* asserting is that at the present moment > in time, there is no observable characteristic that > distinguishes them; and thus, at the moment, the > difference exists only based on a historical record, > not on any observable difference that can empirically > be observed. > Observable is a function of the position of the observer and the visibility from that vantage point. I would argue that ARIN staff likely has a position of much greater visibility than you do and that as such, your assertion about what can be seen based entirely on your own perspective is probably not an accurate measure by which to judge overall visibility. A flee on the back of a dog may be unaware that the dog has a belly because he cannot see it. This does not mean that the dog does not have a belly. > You read far too much into what I said. > > I'm simply trying to come up with a definition > of what an IP Speculator might be, as people > are very concerned that an unfettered market > would Lead To Rampant IPv4 Speculation--with > the attendant implication that such a situation > would be a Bad Thing(tm). > > I'm postulating that one such definition might > be that an IPv4 Speculator is an entity that > obtains more globally routable IPv4 address > space than they actually need for running their > business. > That is a partial definition. See above for a more complete definition. A speculator must be someone that obtains more address space than they need. However, not everyone who does so is necessarily a speculator. > I then point out that based on such a definition, > it is clear that there are entities that already > meet that definition. For those who are unsure > of who those entities might be, I again refer > them to: > http://www.iana.org/assignments/ipv4-address-space/ipv4-address-space.xml > http://www.caida.org/research/traffic-analysis/arin-heatmaps/ > from which they can easily see large swaths > of IPv4 space which has been allocated for > decades, but is not being used on the global > IPv4 internet. > First, not being used visibly on the IPv4 internet != not being used. Second, even if that is true, it is not sufficient to define them as a speculator. > And, given the existence (as shown) of IPv4 non-operating > speculators that have existed throughout the entire history > of this mailing list, it is clearly foolishness to now suddenly > object to allowing free and unfettered transfer of resources > on the grounds that it might lead to IPv4 speculation. > Since this depends on the earlier failed assertions, it is, of course, the product of failed logic. >> Alternately, one could embrace and reconcile both sorts of grievances by proposing a policy that would unilaterally strip all IPv4 possession rights from all past and present IPv4 holders holders without exception, and compel everyone who still wants IPv4 for future use to rebid for that privilege in a neutral open auction. >> That, at least, would be a coherent/consistent response -- though I doubt many people would call it "fair." > > If you go back through the history of the ARIN debates about > evaluating number resource usage, that was very close to > the heart of the policy language that was included in early > years allowing for annual audits of number resource usage; > in essence, if you obtained a resource, and it was later found > you no longer had justifiable need for it, the resource could be > reclaimed and returned to the pool for others to request. > At the Eugene meeting, the microphones were occupied > frequently by advocates on both sides; those who felt that > once a resource had been granted, it was forever yours, and > those who felt resources should be re-justified on an ongoing > basis, or be forfeit back to the pool for others to use. Technically, anyone with an RSA can be subject to an annual audit and have unused space reclaimed as per section 12. > > The policy language to support that model was proposed and > discussed, and eventually a variant that allows for reclamation > was finally agreed on, and is at the heart of every contract > ARIN members sign: > > "If ARIN determines that the number resources or any other > Services are not being used in compliance with this Agreement, > the Policies, or the purposes for which they are intended, ARIN may: > (i) revoke the number resources; (ii) cease providing the > Services to Applicant; and/or (iii) terminate this Agreement." > This is also backed by NRPM section 12. > (from https://www.arin.net/resources/agreements/rsa.pdf ) > > ARIN has never proposed doing a massive, all-at-once audit > and reclamation back from everyone it deems to not be in > compliance--but that ability is there in the contract, so it's > not too far-fetched to consider that as a possible scenario. First, not feasible without significant additional resources. Second, not at all what was proposed in the alternative solution above. I would not oppose the audit-based reclamation of which you speak. I would be very opposed to a mass reclamation of all resources requiring all registrants to bid for what they previously had without any indication that they were not properly utilizing it. (which is what was proposed above). > > >>>> 3. Therefore, anyone/everyone (today) should have an equal right to be an IPv4 speculator. >>> >>> Given that there are many players already who hold IPv4 resources that wildly >>> flaunt any needs-based justification whatsoever, I propose that anyone and >>> everyone should likewise be able to participate in the market to that same >>> degree. If we're going to turn a blind eye towards holders of large blocks >>> and not require any needs-based justification for them, then be fair and >>> do away with the needs-based justification for everyone. >> Continuing to make this assertion does not make it correct. >> This is the same straw man argument coupled with the same, completely orthogonal proposed remedy. >> You really need to come up with a better way to frame this argument than "Someone else can wildly flaunt their indifference, but I can't, and that's not fair" > > So, let me make sure I understand your position on this; > from your perspective, it is entirely proper to have different > rules that apply to different entities within the ARIN region. > There is no requirement to have the rules equally apply to > everyone? > The rules apply equally to all requestors receiving resources under ARIN stewardship. At best, you can make a claim that some people received resources prior to ARIN's existence that were granted under different policies. In some cases, those entities may not meet current policies. Applying current policies to those organizations may be cost-prohibitive to the organization. The fact that there are historical recipients who received addresses under different policies is not in my mind different from the fact that recipients in the other RIR regions also receive addresses under different policies. Sometimes policy changes are not practical to apply retroactively. Much like the smog laws do not force 1970s era vehicles to comply with modern emissions standards. Nonetheless, anyone receiving resources today, whether through transfer or by allocation or assignment from ARIN should have to comply with the same qualification criteria and policies and they should be applied equally. If you know of a situation where that is not happening, you should probably inform ARIN of it so that they can take appropriate action. If you feel that you are not getting a sufficient response from ARIN, I suggest you discuss the matter with the ARIN CEO or any member of the AC or BoT. > Much like with the shared wireless spectrum, I anticipate > ongoing adjustments being made to allocations, with the > entire community having to make concessions and > adjustments, not just new entrants to the field. As spectrum > became more and more in demand, and the push for trying > to pack more uses into the limited spectrum range increased, > the adjustments were applied across the board. It didn't matter > if you had been using analog TV broadcast frequencies for 50 > years; when the push for reallocation of spectrum came along, > you had to give up your swath of analog spectrum and move to > new frequency ranges. Nobody got to say "but I qualified for this > spectrum under the rules from 10 years ago, so you can't touch > it." Likewise, I think in the IPv4 space a similar situation could > exist; as the limited resource comes under increasing demand, > reapportioning across the board could become necessary. We > have a nice precedent for it in the analog TV spectrum, so I don't > think it's an outrageous model to propose at all. > Having watched much of the spectrum issues over the last 20 years (KB6MER, Extra Class FCC Licensee), I have to say that I think taking a similar approach to IP addressing would be one of the worst possible outcomes we could consider. > I think the analogy I'm looking at is more along the lines > of someone who has inherited land being allowed to sell > that land to overseas investors, completely tax-free, whereas > everyone who did not inherit their property must sell the > property with government involvement, including restrictions > on the zoning of the land being sold, and taxes on the transfer > of the land. > I'm not sure what makes you think that legacy holders are able to transfer their addresses to recipients that don't meet current policy. ARIN will not recognize such a transfer and the recipient in such a transaction is at risk for ARIN reclaiming the resources and issuing them to other parties if ARIN discovers that the original organization no longer exists or is no longer using the addresses. >>> However, >>> I'm not advocating that we take up pitchforks and torches and >>> storm the castles of the wealthly landed gentry; instead, I'm >>> advocating removal of the unfair and unreasonable rules that >>> deny anyone else the ability to gain access to similar levels >>> of resources. >> >> Sorry, but I can't see how your proposal adds any additional "fairness" to any element of the system that is not already on the winning side of broader fairness/unfairness divide(s) that are already inherent in this situation, while I can see all sorts of ways that it would be likely further exacerbate those otherwise unrelated problems... >> > > I'm not actually proposing anything, I'm simply advocating > for the removal of needs-based allocations. I've just been > pulling out more analogies than other supporters have, > which might make it seem like I'm advocating for more > than they have. > Yes, it does seem that you are advocating strongly for proposal 165 which is tantamount to proposing something. There's nothing wrong with this at all. But it does limit the veracity of a claim that you are not proposing anything. >>> The old boy's club has their wealth and power and prestige >>> in the form of large, unjustified swaths of IPv4 space; let's >>> bring equality and fairness to the market, and allow >>> everyone the *opportunity* to participate in that mode. >> >> Please stop using the using the term "participate" to erroneously (or misleadingly) conflate the separate and distinct prerogatives and material capabilities of all hypothetical IPv4 buyers and IPv4 sellers. Make a positive argument for why the differences should not matter, and/or why ignoring all of the current differences that you'd like to ignore going forward -- including "operators" vs. "non-operators" -- would make the future better or "more fair" than a future in which those distinctions continue to be honored. Proof by assertion is not strengthened by continued repetition (!). >> > > I've already indicated up above that the distinction > between operators and non-operators doesn't exist, > and cited links to concrete evidence. I didn't realize > you needed me to connect the dots for you; I apologize > for the omission the first time around, and hope that > now it's clearer that this is not simply proof by assertion. > No, you've shown that the distinction cannot be perceived from your vantage point. You've also shown that you don't entirely understand the definition of operators. Everything that follows from that is an assertion based on those two inaccuracies. >> Thanks again for the detailed response, but no it didn't provide any new information. >> Heavy and elaborate reinforcement of the same still-unrelated propositions, yes, but the gaping holes where a positive argument connecting reality > problem > solution > reality should be are still there, waiting to be filled... > > Is this helping fill your holes at all? > It's certainly not helping to fill mine. I think i have been pretty blunt as to why and how above. Owen From ppml at rs.seastrom.com Tue Feb 28 08:22:35 2012 From: ppml at rs.seastrom.com (Robert E. Seastrom) Date: Tue, 28 Feb 2012 08:22:35 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <8695009A81378E48879980039EEDAD28011E05E420@MAIL1.polartel.local> (Kevin Kargel's message of "Mon, 27 Feb 2012 15:34:56 -0600") References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> <3D80425B-B9F8-47C9-8BC0-1B44A3D65A64@netconsonance.com> <8695009A81378E48879980039EEDAD28011E05E41E@MAIL1.polartel.local> <8695009A81378E48879980039EEDAD28011E05E420@MAIL1.polartel.local> Message-ID: <86fwdvrt2c.fsf@seastrom.com> Kevin Kargel writes: > Now - if a "legacy" holder returns or relinquishes or transfers space and a > new registration or allocation or transfer needs to be effected then I do > strongly feel that the "new" allocation should fall under the common rules, > restrictions and aegis provided by the community via ARIN RSA (*not* LRSA). What is the difference between the two RSAs upon which your opinion pivots? Does it simply boil down to amount of revenue that ARIN gets from a particular database entry? Disclaimer: I am (personally) an LRSA signatory. % whois -h whois.arin.net '! > RES-Z' -r From farmer at umn.edu Tue Feb 28 08:46:05 2012 From: farmer at umn.edu (David Farmer) Date: Tue, 28 Feb 2012 07:46:05 -0600 Subject: [arin-ppml] 2011-7 Status In-Reply-To: References: Message-ID: <4F4CDA9D.5070203@umn.edu> On 2/28/12 03:08 CST, Owen DeLong wrote: > The feedback from the community so far on this proposal has actually been in favor of the AC continuing to work on it. > > A small minority of the AC cannot keep a proposal alive. It only takes 8 AC members at any point to pass a motion to abandon a draft policy. (A simple majority of quorum will do for anything that is not yet a draft policy.) > > As such, I have trouble reconciling the actual reality with statements by my colleague earlier on this list. > > 2011-7 as revised based on community feedback is slated for discussion in Vancouver. I encourage people who have an interest in this policy, whether in favor or in opposition to make their opinions known on this list. There is still time to incorporate community feedback into revisions to the draft policy before taking it to Vancouver. > > Owen Personally, I continue to be skeptical of the idea of using DNS as a lever for compliance regarding documentation of reassignments. However, I agree with Owen that the sense of the room at the Philly meeting was to continue working on this proposal, and I think important changes identified by the community have been made. I therefore support this proposal returning to the Vancouver meeting for additional discussion, despite my personal skepticism of the proposal. While I remain open to persuasion regarding this proposal, and would like to see more discussion of it by the community; At the moment, I doubt I will be able to recommend the adoption of this proposal. -- =============================================== David Farmer Email:farmer at umn.edu Networking & Telecommunication Services Office of Information Technology University of Minnesota 2218 University Ave SE Phone: 612-626-0815 Minneapolis, MN 55414-3029 Cell: 612-812-9952 =============================================== From hannigan at gmail.com Tue Feb 28 10:24:49 2012 From: hannigan at gmail.com (Martin Hannigan) Date: Tue, 28 Feb 2012 10:24:49 -0500 Subject: [arin-ppml] 2011-7 Status FAIL Message-ID: On Tue, Feb 28, 2012 at 8:46 AM, David Farmer wrote: > > [ reordered ] > > > Personally, I continue to be skeptical of the idea of using DNS as a lever > for compliance regarding documentation of reassignments. ?However, I agree > with Owen that the sense of the room at the Philly meeting was to continue > working on this proposal, and I think important changes identified by the > community have been made. ?I therefore support this proposal returning to > the Vancouver meeting for additional discussion, despite my personal > skepticism of the proposal. With respect to the DNS issue, this would not be the first time that there have been objections. You said during the AC meeting of 16 November: >DF stated he was uncomfortable with the DNS issues in the DP, and did not see overwhelming support. He was against the motion. And even though the the PPM did not have consensus supporting it, an attempt to move it to last call occurred and the AC answered that with: >The motion to forward to last call failed with 9 against (DA, CA, MC, MH, DF, BS, RS, HS, JS), 2 in favor (BD, CG), and 1 abstention (OD) >via roll call. Yet another revision containing the DNS issue that we're all objecting has been recently published. More v4 and Section 12 time wasting. > On 2/28/12 03:08 CST, Owen DeLong wrote: >> [ clip ] >> As such, I have trouble reconciling the actual reality with statements by >> my colleague earlier on this list. >> The minutes demonstrate that an "overwhelming" majority at the PPM in Philadelphia objected to at least the DNS requirement yet again. https://www.arin.net/participate/meetings/reports/ARIN_XXVIII/ppm1_transcript.html#anchor_7 Putting all of that aside, the question should be is shutting off DNS from the perspective of this proposal sound technical policy? It would seem that the vast majority of the discussion has pointed to "no". Hence, my question as to why we are still doing this. Best, -M< From cgrundemann at gmail.com Tue Feb 28 10:57:14 2012 From: cgrundemann at gmail.com (Chris Grundemann) Date: Tue, 28 Feb 2012 08:57:14 -0700 Subject: [arin-ppml] 2011-7 Status FAIL In-Reply-To: References: Message-ID: On Tue, Feb 28, 2012 at 08:24, Martin Hannigan wrote: > The minutes demonstrate that an "overwhelming" majority at the PPM in > Philadelphia objected to at least the DNS requirement yet again. > > https://www.arin.net/participate/meetings/reports/ARIN_XXVIII/ppm1_transcript.html#anchor_7 >From the link that you included: "In relation to the second motion, whether the AC should be asked to continue to work on it, the total number of people in the meeting room and by remote are 167. In favor of asking them to do further work on it were 57 and against them doing further work on it is 6." To be clear, that's 57 to 6 in favor of further work on 2011-7. I'm really not sure how you can misinterpret that. Cheers, ~Chris > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. -- @ChrisGrundemann http://chrisgrundemann.com From admin at bango.org.bb Tue Feb 28 10:50:34 2012 From: admin at bango.org.bb (admin at bango.org.bb) Date: Tue, 28 Feb 2012 11:50:34 -0400 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <86fwdvrt2c.fsf@seastrom.com> References: <86fwdvrt2c.fsf@seastrom.com> Message-ID: <986D092ECF1A471BB67CEFF98513F792@BANGO> Really! While it may be agreeable that those who were in the front line should be rewarded, it should also be recognised that others, if they had the opportunity would have been right there as well and could have been equally rewarded but are not and could well do with some of those resources. To give "legacy holders" boundless resources way beyond their needs, is the kind of thinking that is now wreaking havoc on this world because a few have far too much. We are complaining about the one percent but yet our minds are so conditioned as to continue the madness. We must move to stamp out inequalities in this world; especially large divides as this usually means that some will inevitably be left without down the road and leaving people without is the cause of all the pain in this world; one way or another. We must be careful how we establish a few to become the power houses of this world. Legacy holders will pass on someday and leave to their children what their children were not in the front line fighting for and will probably forget what the fight was about but become heirs to resources beyond their needs to wield as they please and possibly against the wishes of the parents who fought. Are we doomed to repeat the mistakes of our past just like that? ROK -----Original Message----- From: Robert E. Seastrom Sent: Tuesday, February 28, 2012 9:22 AM To: Kevin Kargel Cc: ARIN PPML Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification Kevin Kargel writes: > Now - if a "legacy" holder returns or relinquishes or transfers space and > a > new registration or allocation or transfer needs to be effected then I do > strongly feel that the "new" allocation should fall under the common > rules, > restrictions and aegis provided by the community via ARIN RSA (*not* > LRSA). What is the difference between the two RSAs upon which your opinion pivots? Does it simply boil down to amount of revenue that ARIN gets from a particular database entry? Disclaimer: I am (personally) an LRSA signatory. % whois -h whois.arin.net '! > RES-Z' -r _______________________________________________ PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). Unsubscribe or manage your mailing list subscription at: http://lists.arin.net/mailman/listinfo/arin-ppml Please contact info at arin.net if you experience any issues. From hannigan at gmail.com Tue Feb 28 11:12:45 2012 From: hannigan at gmail.com (Martin Hannigan) Date: Tue, 28 Feb 2012 11:12:45 -0500 Subject: [arin-ppml] 2011-7 Status FAIL In-Reply-To: References: Message-ID: On Tue, Feb 28, 2012 at 10:57 AM, Chris Grundemann wrote: > On Tue, Feb 28, 2012 at 08:24, Martin Hannigan wrote: > >> The minutes demonstrate that an "overwhelming" majority at the PPM in >> Philadelphia objected to at least the DNS requirement yet again. >> >> https://www.arin.net/participate/meetings/reports/ARIN_XXVIII/ppm1_transcript.html#anchor_7 > > From the link that you included: > > "In relation to the second motion, whether the AC should be asked to > continue to work on it, the total number of people in the meeting room > and by remote are 167. ?In favor of asking them to do further work on > it were 57 and against them doing further work on it is 6." > > To be clear, that's 57 to 6 in favor of further work on 2011-7. I'm > really not sure how you can misinterpret that. > Let's put this back into context: The minutes demonstrate that an "overwhelming" majority at the PPM in Philadelphia objected to at least the DNS requirement yet again. ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^ Best, -M< From tvest at eyeconomics.com Tue Feb 28 12:17:12 2012 From: tvest at eyeconomics.com (Tom Vest) Date: Tue, 28 Feb 2012 12:17:12 -0500 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> Message-ID: <699D39E0-E403-4052-890B-1A9C1C7ACCCD@eyeconomics.com> On Feb 28, 2012, at 5:23 AM, Matthew Petach wrote: > On Mon, Feb 27, 2012 at 1:46 PM, Tom Vest wrote: >> Thanks for the responses Matt -- follow-ups inline... >> >> On Feb 27, 2012, at 12:40 PM, Matthew Petach wrote: >> >>> On Sun, Feb 26, 2012 at 7:02 PM, Tom Vest wrote: >>>> Hi Matt, >>>> >>>> You seem to be arguing the following: >>>> >>>> 1. "IPv4 Speculation" is bad (or maybe good for the lucky speculators, but bad/unfair for everyone else). >>> >>> I was trying not to assign it a category of "good' or "bad"--simply stating >>> it does exist today; and thus, one of the arguments *against* a free and >>> unfettered market is not relevant. The cry of "but if we allow anyone to >>> buy and sell IP blocks, we'll be overrun with speculators" rings hollow >>> when the market is already supporting dozens of speculators who operate >>> outside the needs-based criteria. >> >> But, notwithstanding rhetorical force of habit, is anyone actually crying about "allowing anyone to buy and sell IP blocks" i.e., as opposed to "allowing non-operators (or those who can't demonstrate the equivalent of an operator's "need") to buy IP blocks?" You're still trying to conflate the prerogatives of an(y) aspiring IPv4 seller with those of a(ny) potential IPv4 buyer -- but you really can't claim that the two are the same, or that the differences don't matter without explaining why. Membership in the class of "anyone that can sell IPv4" is bounded by the material fact that in order to sell IPv4 one must actually have some to sell -- and throughout all time to the present moment, 100% of the members of that class have already satisfied, at minimum, whatever definition of "operator" was officially recognized at the time when they received their address resources (and in most cases, additional/more demanding eligibility requirements that came thereafter). By contrast, the class of "anyone that can buy IPv4" has no equivalent limiting factor. > > I suppose what I'm stumbling over is that today, we > have large blocks of v4 address space that today > are held be registrants who are not routing them > as part of the global IPv4 routing table. You seem > to feel that they somehow qualified as "operators" > in a way that has significance, in spite of them not > routing their address space in a reachable fashion, > whereas "speculators" would somehow be categorized > as "non-operators". > > Can I ask, what characteristic would you use to > distinguish an "operator" from a "non-operator" > that we can externally observe? You are right to call attention to the fact "we" (here meaning anyone who correctly recognizes their common interest in the productive allocation of this, or any other critical+finite/scarce shared resource) have a very real ongoing *need to know* that address resources are being made available *as appropriate* to the private sector players (aka "operators") that have the privilege($$$)/responsibility of moving those resource into productive use in the broader economy. However, just as in certain other critical service industries that are involved in the distribution of other valuable but finite shared resources, it is often impossible for third parties to accurately gauge the exact "compliance status" of individual private sector operators. Did operator (x) actually satisfy any/all applicable prerequisites that were/are deemed necessary in order to qualify to deliver that service? Do they still possess the mean to deliver that critical service now, (n) days/weeks/months/years after the most recent assessment of their capabilities? Are they actually delivering the service in a prudent/sustainable manner, in accordance with any/all applicable industry or externally defined performance requirements, or are they hoarding, or squandering and/or misallocating that service? The reason that such things tend to be impossible for third parties to observe is not because the service itself is ephemeral -- though it is in both cases -- but rather because in both industries the operators themselves insist on strictly controlling and limiting the release of information about their internal operations. In both domains, operators argue (quite reasonably) that such controls are essential to ongoing commercial viability (not just their own, but everybody's), both because every industry member is necessarily/unavoidably vulnerable in certain ways to systemic or transitive events triggered by remote third parties, and also because, in both domains, most providers operate in a crowded and competitive marketplace in which any release of internal operational information could be commercially exploited to their disadvantage by other industry members. So you see, ours is not the only critical service industry that embodies this particular conflict between the public's need for assurances of ongoing/long-term service availability on one hand, and the private sector's need for commercial confidentiality on the other. That coincidence may help to explain why, over time, both industries also witnessed the emergence of the exact same kinds of endogenous mechanisms for mitigating that fundamental conflict in information requirements. In both cases, those mechanisms include things like: (a) Identification and administration of certain industry-specific technical eligibility criteria that all aspiring new service providers must satisfy in order to be officially recognized as "operators" in that industry. Our own criteria relate "need" for addresses to beneficial access (including but not limited to outright ownership) of network-related hardware plus fractional use rights to various telecom capital assets to connect the hardware together. The other industry typically describes their criteria in reverse terms, i.e., as the "adequacy" of an aspiring service provider's portfolio of directly owned and beneficially "accessible" capital reserves/assets, etc., relative to a a given volume of the service they provider (which in their case is called "credit" or "liquidity"). (b) Maintenance of a similar set of uniform, neutrally administered pre-qualification requirements for any/all subsequent service expansions that invoke the same conflicting public/private information requirements. In our industry, vetting of service expansion proposals are handled by the same institution(s) that administer new industry member establishment, i.e., the RIRs. In the other (i.e., banking/credit creation) industry, established operators are required to publicly disclose limited but truthful* summary information in an ongoing basis, while oversight of major new one-off credit extensions are currently evaluated by a separate set of institutions (i.e., the CRAs). (c) Establishment of a standing deliberative body of industry experts empowered to assure that, as technology, industry circumstances, and overall economic conditions change, the sort of rules and administrative practices that are employed to assess new service/industry expansion proposals ala (a,b) also adapt as necessary, so that the overall service/industry/operating environment continues to satisfy both public and private requirements, and (insh'Allah) the industry continues to avoid succumbing to one of its intrinsic systemic vulnerabilities (e.g., gross oversupply/oversubscription leading to "hyperinflation," gross undersupply/maldistribution leading to a "deflationary spiral," broad-based e2e degradation partially offset with with costly ad hoc technical patches leading to system-wide "stagflation," etc.), and then collapsing. Granted, history is positively full of examples showing that such industry-centric conflict-mitigation mechanisms are far from infallible -- and institutions that ultimately fail to maintain a satisfactory balance of interests and outcomes tend to pay the ultimate price and disappear forevermore. Note for example that, at various points during the 17th-19th century, many (most?) of what are now the world's richest countries had banking/monetary policy sectors that were coordinated by industry-led institutions not unlike our own RIRs. By the early 20th century, however, that number had fallen to 0.00, and that's where it remains today, and will likely remain forevermore (at least on this planet). As you probably know, the vacuum created by the disappearance of those old banking industry self-governance mechanisms did not remain empty for long -- nor were the resulting breaches filled with institutions that were more flexible and accommodating of changing conditions or individual industry members' private demands. They really couldn't be, because like it or not the conflicts of interest over allocation and information sharing practices that those old systems temporarily succeeded but eventually failed to balance, are both real and unavoidable; they are an intrinsic feature of all liquidity (or exchange-facilitating) industries -- like ours, like the monetary/banking sector -- that are critically dependent on some distributed technology that performs as expected only under relatively narrow conditions, and that tend fail absolutely in one ugly way or another whenever aggregate usage patterns substantially exceeds those bounds. Needless to say, history provides even more examples suggesting that government-administered industry "regulatory" regimes are no less vulnerable (and quite possibly even more vulnerable) to the same sort of errors, missteps, and plain dumb luck that ultimately led to the disappearance of their private, industry consortia-led predecessors. Even so, after a century and counting of uniformly public/gov-centric monetary and banking regulation worldwide, it looks like the odds that the banking industry might ever get another chance at self-governance is appx. 0.00%. So... you and everyone else that participates in this particular industry coordination mechanism are not only right, but positively obligated to demand "reasonable" assurance that number resources are allocated prudently -- not just IPv4, not just now, in consideration of the critical role that IPv4 will play during the next few years -- but always, for all protocol number resources. That said, I personally think that the demands for detailed assurances about the cumulative historical distribution of IPv4 that you have articulated in the course of this discussion fall well outside of the bounds of what's "reasonable," and also that the proposed changes embodied in your current proposal would have an overwhelmingly negative net effect on the subsequent distribution of IPv4 going forward. >> Here you seem to be implying either one or both of the following; >> >> (a) anything that anyone accomplished/acquired in the past, under conditions that are "easier" than they are now, is by definition unfair; either the "old boys" should be stripped of all accumulated "unfair" benefits, or I should be compensated to make up for the difference. In general any/all past or present legal contracts that provide(d) someone else with forward-looking terms to something that I want that are more more favorable than terms that are currently available to me are automatically rendered null and void simply by that fact. >> >> (b) the fairness of anything that anyone previously accomplished/acquired and which is also subject to some kind of ongoing administrative oversight is automatically negated if the current administrative mechanisms are not universally recognized as being 100% infallible at all moments in time. If at any point in time there is any nonzero possibility that the administrative process has failed to identify and punish anyone that is noncompliant with the policy, then it may be reasonably assumed that everyone is noncompliant; either everyone else should be stripped of their accumulated "unfair" gains, or else I should be compensated to make up for the difference. >> >> Either way, this is a one-time deal that is available only to me and my contemporaries; anyone that comes along later, and who might have similar objections, can suck it. >> >> I think that many of us may succumb to thinking along the lines of (a) from time to time, even though at other times we recognize those feelings for what they are, i.e., "sour grapes." At all times/places, someone somewhere has inherited some "unfair" present-day advantage that they didn't "earn" in the way that I'd have to earn it myself. Except in cases where the consequences of that inheritance are so profound/intolerable that they justify bloody revolution (if such a thing is possible), we tend to shrug and move on... >> >> (b) is just a variant of a straw man argument that applies equally (i.e., with equal non-validity) to all organizations/processes in human history. "Someone somewhere is breaking the law -- I believe, anyway... no, I don't have any actual evidence -- but my suspicions about the fallibility and non-impartiality of law enforcement are sufficient in themselves to declare that the law is unfair and illegitimate." >> >> If I'm missing or misunderstanding something, and you actually have some other method for deriving and calculating the "unfair" portion of an institution's IPv4 holdings, I'd be interested in hearing it. > > You read far too much into what I said. You can chalk that up to misplaced overcompensation; you read far too little into what you actually said, and seemingly remain oblivious of all of the things that you propose to put at risk without even bothering to mention. Regards, TV From cgrundemann at gmail.com Tue Feb 28 12:19:41 2012 From: cgrundemann at gmail.com (Chris Grundemann) Date: Tue, 28 Feb 2012 10:19:41 -0700 Subject: [arin-ppml] 2011-7 Status FAIL In-Reply-To: References: Message-ID: >>> https://www.arin.net/participate/meetings/reports/ARIN_XXVIII/ppm1_transcript.html#anchor_7 >> >> From the link that you included: >> >> "In relation to the second motion, whether the AC should be asked to >> continue to work on it, the total number of people in the meeting room >> and by remote are 167. ?In favor of asking them to do further work on >> it were 57 and against them doing further work on it is 6." >> >> To be clear, that's 57 to 6 in favor of further work on 2011-7. I'm >> really not sure how you can misinterpret that. >> > > > Let's put this back into context: > > The minutes demonstrate that an "overwhelming" majority at the PPM in > Philadelphia objected to at least the DNS requirement yet again. > ? ? ? ? ? ? ? ? ? ?^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^ Let's put this back in the realm of objectivity: "In relation to Draft Policy No. 2011-7, Compliance Requirements, the total number of people meeting in the meeting room and remote was 167. Those in favor to move forward were 20; those against were 34." Yes there were more folks against the draft as presented than for it, but 34 to 20 against is not what I would call overwhelming. In fact, the 57 to 6 in favor of further work is _much_ more apt to be called overwhelming. Further: "PPML discussion. 12 posts by 7 people; 0 in favor and 0 against. It's mostly editing the version. Earlier discussion. 22 posts by 10 people; 2 in favor and 2 against." So on the PPML it was 2 to 2. Can anyone claim that is "overwhelming?" As the primary shepherd of this draft policy, I can not ignore the realities contained in the records that have been sited here. I can not in good conscience turn away from the community on request of one person (AC member or not). Thus, I continue to shepherd this policy through the process. That process includes hearing from the broader community. As such, I would love to hear specific feedback from other members of the community. Repeated badgering by a lone voice will be ignored - I will know it as badgering in part based on language used, especially in subject lines. Cheers, ~Chris > > Best, > > -M< -- @ChrisGrundemann http://chrisgrundemann.com From tvest at eyeconomics.com Tue Feb 28 12:50:13 2012 From: tvest at eyeconomics.com (Tom Vest) Date: Tue, 28 Feb 2012 12:50:13 -0500 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <699D39E0-E403-4052-890B-1A9C1C7ACCCD@eyeconomics.com> References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> <699D39E0-E403-4052-890B-1A9C1C7ACCCD@eyeconomics.com> Message-ID: On Feb 28, 2012, at 12:17 PM, Tom Vest wrote: > > On Feb 28, 2012, at 5:23 AM, Matthew Petach wrote: > >> On Mon, Feb 27, 2012 at 1:46 PM, Tom Vest wrote: >>> Thanks for the responses Matt -- follow-ups inline... >>> >>> On Feb 27, 2012, at 12:40 PM, Matthew Petach wrote: >>> >>>> On Sun, Feb 26, 2012 at 7:02 PM, Tom Vest wrote: >>>>> Hi Matt, >>>>> >>>>> You seem to be arguing the following: >>>>> >>>>> 1. "IPv4 Speculation" is bad (or maybe good for the lucky speculators, but bad/unfair for everyone else). >>>> >>>> I was trying not to assign it a category of "good' or "bad"--simply stating >>>> it does exist today; and thus, one of the arguments *against* a free and >>>> unfettered market is not relevant. The cry of "but if we allow anyone to >>>> buy and sell IP blocks, we'll be overrun with speculators" rings hollow >>>> when the market is already supporting dozens of speculators who operate >>>> outside the needs-based criteria. >>> >>> But, notwithstanding rhetorical force of habit, is anyone actually crying about "allowing anyone to buy and sell IP blocks" i.e., as opposed to "allowing non-operators (or those who can't demonstrate the equivalent of an operator's "need") to buy IP blocks?" You're still trying to conflate the prerogatives of an(y) aspiring IPv4 seller with those of a(ny) potential IPv4 buyer -- but you really can't claim that the two are the same, or that the differences don't matter without explaining why. Membership in the class of "anyone that can sell IPv4" is bounded by the material fact that in order to sell IPv4 one must actually have some to sell -- and throughout all time to the present moment, 100% of the members of that class have already satisfied, at minimum, whatever definition of "operator" was officially recognized at the time when they received their address resources (and in most cases, additional/more demanding eligibility requirements that came thereafter). By contrast, the class of "anyone that can buy IPv4" has no equivalent limiting factor. >> >> I suppose what I'm stumbling over is that today, we >> have large blocks of v4 address space that today >> are held be registrants who are not routing them >> as part of the global IPv4 routing table. You seem >> to feel that they somehow qualified as "operators" >> in a way that has significance, in spite of them not >> routing their address space in a reachable fashion, >> whereas "speculators" would somehow be categorized >> as "non-operators". >> >> Can I ask, what characteristic would you use to >> distinguish an "operator" from a "non-operator" >> that we can externally observe? > > You are right to call attention to the fact "we" (here meaning anyone who correctly recognizes their common interest in the productive allocation of this, or any other critical+finite/scarce shared resource) have a very real ongoing *need to know* that address resources are being made available *as appropriate* to the private sector players (aka "operators") that have the privilege($$$)/responsibility of moving those resource into productive use in the broader economy. However, just as in certain other critical service industries that are involved in the distribution of other valuable but finite shared resources, it is often impossible for third parties to accurately gauge the exact "compliance status" of individual private sector operators. Did operator (x) actually satisfy any/all applicable prerequisites that were/are deemed necessary in order to qualify to deliver that service? Do they still possess the mean to deliver that critical service now, (n) days/weeks/months/years after the most recent assessment of their capabilities? Are they actually delivering the service in a prudent/sustainable manner, in accordance with any/all applicable industry or externally defined performance requirements, or are they hoarding, or squandering and/or misallocating that service? The reason that such things tend to be impossible for third parties to observe is not because the service itself is ephemeral -- though it is in both cases -- but rather because in both industries the operators themselves insist on strictly controlling and limiting the release of information about their internal operations. In both domains, operators argue (quite reasonably) that such controls are essential to ongoing commercial viability (not just their own, but everybody's), both because every industry member is necessarily/unavoidably vulnerable in certain ways to systemic or transitive events triggered by remote third parties, and also because, in both domains, most providers operate in a crowded and competitive marketplace in which any release of internal operational information could be commercially exploited to their disadvantage by other industry members. > > So you see, ours is not the only critical service industry that embodies this particular conflict between the public's need for assurances of ongoing/long-term service availability on one hand, and the private sector's need for commercial confidentiality on the other. That coincidence may help to explain why, over time, both industries also witnessed the emergence of the exact same kinds of endogenous mechanisms for mitigating that fundamental conflict in information requirements. In both cases, those mechanisms include things like: > > (a) Identification and administration of certain industry-specific technical eligibility criteria that all aspiring new service providers must satisfy in order to be officially recognized as "operators" in that industry. Our own criteria relate "need" for addresses to beneficial access (including but not limited to outright ownership) of network-related hardware plus fractional use rights to various telecom capital assets to connect the hardware together. The other industry typically describes their criteria in reverse terms, i.e., as the "adequacy" of an aspiring service provider's portfolio of directly owned and beneficially "accessible" capital reserves/assets, etc., relative to a a given volume of the service they provider (which in their case is called "credit" or "liquidity"). [just in case the point didn't come across, THIS is where the "operator" vs. "non-oprator" distinctions come from...] > (b) Maintenance of a similar set of uniform, neutrally administered pre-qualification requirements for any/all subsequent service expansions that invoke the same conflicting public/private information requirements. In our industry, vetting of service expansion proposals are handled by the same institution(s) that administer new industry member establishment, i.e., the RIRs. In the other (i.e., banking/credit creation) industry, established operators are required to publicly disclose limited but truthful* summary information in an ongoing basis, while oversight of major new one-off credit extensions are currently evaluated by a separate set of institutions (i.e., the CRAs). [...and THIS is the mechanism that's prevents established operators from thereafter making unreasonable ~ infinite demands on shared+finite resources ] > (c) Establishment of a standing deliberative body of industry experts empowered to assure that, as technology, industry circumstances, and overall economic conditions change, the sort of rules and administrative practices that are employed to assess new service/industry expansion proposals ala (a,b) also adapt as necessary, so that the overall service/industry/operating environment continues to satisfy both public and private requirements, and (insh'Allah) the industry continues to avoid succumbing to one of its intrinsic systemic vulnerabilities (e.g., gross oversupply/oversubscription leading to "hyperinflation," gross undersupply/maldistribution leading to a "deflationary spiral," broad-based e2e degradation partially offset with with costly ad hoc technical patches leading to system-wide "stagflation," etc.), and then collapsing. [...and THIS is the feedback loop that assures that actual industry/technology expertise continues to inform the institutional and technical and processes that determine who gets what and who knows as time passes and circumstances change ] > Granted, history is positively full of examples showing that such industry-centric conflict-mitigation mechanisms are far from infallible -- and institutions that ultimately fail to maintain a satisfactory balance of interests and outcomes tend to pay the ultimate price and disappear forevermore. Note for example that, at various points during the 17th-19th century, many (most?) of what are now the world's richest countries had banking/monetary policy sectors that were coordinated by industry-led institutions not unlike our own RIRs. By the early 20th century, however, that number had fallen to 0.00, and that's where it remains today, and will likely remain forevermore (at least on this planet). > > As you probably know, the vacuum created by the disappearance of those old banking industry self-governance mechanisms did not remain empty for long -- nor were the resulting breaches filled with institutions that were more flexible and accommodating of changing conditions or individual industry members' private demands. They really couldn't be, because like it or not the conflicts of interest over allocation and information sharing practices that those old systems temporarily succeeded but eventually failed to balance, are both real and unavoidable; they are an intrinsic feature of all liquidity (or exchange-facilitating) industries -- like ours, like the monetary/banking sector -- that are critically dependent on some distributed technology that performs as expected only under relatively narrow conditions, and that tend fail absolutely in one ugly way or another whenever aggregate usage patterns substantially exceeds those bounds. > > Needless to say, history provides even more examples suggesting that government-administered industry "regulatory" regimes are no less vulnerable (and quite possibly even more vulnerable) to the same sort of errors, missteps, and plain dumb luck that ultimately led to the disappearance of their private, industry consortia-led predecessors. Even so, after a century and counting of uniformly public/gov-centric monetary and banking regulation worldwide, it looks like the odds that the banking industry might ever get another chance at self-governance is appx. 0.00%. > > So... you and everyone else that participates in this particular industry coordination mechanism are not only right, but positively obligated to demand "reasonable" assurance that number resources are allocated prudently -- not just IPv4, not just now, in consideration of the critical role that IPv4 will play during the next few years -- but always, for all protocol number resources. > > That said, I personally think that the demands for detailed assurances about the cumulative historical distribution of IPv4 that you have articulated in the course of this discussion fall well outside of the bounds of what's "reasonable," and also that the proposed changes embodied in your current proposal would have an overwhelmingly negative net effect on the subsequent distribution of IPv4 going forward. > >>> Here you seem to be implying either one or both of the following; >>> >>> (a) anything that anyone accomplished/acquired in the past, under conditions that are "easier" than they are now, is by definition unfair; either the "old boys" should be stripped of all accumulated "unfair" benefits, or I should be compensated to make up for the difference. In general any/all past or present legal contracts that provide(d) someone else with forward-looking terms to something that I want that are more more favorable than terms that are currently available to me are automatically rendered null and void simply by that fact. >>> >>> (b) the fairness of anything that anyone previously accomplished/acquired and which is also subject to some kind of ongoing administrative oversight is automatically negated if the current administrative mechanisms are not universally recognized as being 100% infallible at all moments in time. If at any point in time there is any nonzero possibility that the administrative process has failed to identify and punish anyone that is noncompliant with the policy, then it may be reasonably assumed that everyone is noncompliant; either everyone else should be stripped of their accumulated "unfair" gains, or else I should be compensated to make up for the difference. >>> >>> Either way, this is a one-time deal that is available only to me and my contemporaries; anyone that comes along later, and who might have similar objections, can suck it. >>> >>> I think that many of us may succumb to thinking along the lines of (a) from time to time, even though at other times we recognize those feelings for what they are, i.e., "sour grapes." At all times/places, someone somewhere has inherited some "unfair" present-day advantage that they didn't "earn" in the way that I'd have to earn it myself. Except in cases where the consequences of that inheritance are so profound/intolerable that they justify bloody revolution (if such a thing is possible), we tend to shrug and move on... >>> >>> (b) is just a variant of a straw man argument that applies equally (i.e., with equal non-validity) to all organizations/processes in human history. "Someone somewhere is breaking the law -- I believe, anyway... no, I don't have any actual evidence -- but my suspicions about the fallibility and non-impartiality of law enforcement are sufficient in themselves to declare that the law is unfair and illegitimate." >>> >>> If I'm missing or misunderstanding something, and you actually have some other method for deriving and calculating the "unfair" portion of an institution's IPv4 holdings, I'd be interested in hearing it. >> >> You read far too much into what I said. > > You can chalk that up to misplaced overcompensation; you read far too little into what you actually said, and seemingly remain oblivious of all of the things that you propose to put at risk without even bothering to mention. > > Regards, > > TV > From ppml at rs.seastrom.com Tue Feb 28 13:32:11 2012 From: ppml at rs.seastrom.com (Robert E. Seastrom) Date: Tue, 28 Feb 2012 13:32:11 -0500 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <986D092ECF1A471BB67CEFF98513F792@BANGO> (admin@bango.org.bb's message of "Tue, 28 Feb 2012 11:50:34 -0400") References: <86fwdvrt2c.fsf@seastrom.com> <986D092ECF1A471BB67CEFF98513F792@BANGO> Message-ID: <86booiizbo.fsf@seastrom.com> Hello "ROK", Without devolving into a meta-discussion about Keynesianism and social justice, can you identify particular problems with resources that have been transfered under 8.3 being registered under the LRSA rather than the regular RSA? https://www.arin.net/resources/agreements/legacy_rsa.pdf https://www.arin.net/resources/agreements/rsa.pdf Thanks, -r writes: > Really! While it may be agreeable that those who were in the front > line should be rewarded, it should also be recognised that others, if > they had the opportunity would have been right there as well and could > have been equally rewarded but are not and could well do with some of > those resources. To give "legacy holders" boundless resources way > beyond their needs, is the kind of thinking that is now wreaking havoc > on this world because a few have far too much. We are complaining > about the one percent but yet our minds are so conditioned as to > continue the madness. > > We must move to stamp out inequalities in this world; especially large > divides as this usually means that some will inevitably be left > without down the road and leaving people without is the cause of all > the pain in this world; one way or another. We must be careful how we > establish a few to become the power houses of this world. Legacy > holders will pass on someday and leave to their children what their > children were not in the front line fighting for and will probably > forget what the fight was about but become heirs to resources beyond > their needs to wield as they please and possibly against the wishes of > the parents who fought. > > Are we doomed to repeat the mistakes of our past just like that? > > ROK > > -----Original Message----- > From: Robert E. Seastrom > Sent: Tuesday, February 28, 2012 9:22 AM > To: Kevin Kargel > Cc: ARIN PPML > Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification > > > Kevin Kargel writes: > >> Now - if a "legacy" holder returns or relinquishes or transfers >> space and a >> new registration or allocation or transfer needs to be effected then I do >> strongly feel that the "new" allocation should fall under the common >> rules, >> restrictions and aegis provided by the community via ARIN RSA (*not* >> LRSA). > > What is the difference between the two RSAs upon which your opinion > pivots? Does it simply boil down to amount of revenue that ARIN gets > from a particular database entry? > > Disclaimer: I am (personally) an LRSA signatory. > % whois -h whois.arin.net '! > RES-Z' > > -r > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From mpetach at netflight.com Tue Feb 28 13:53:54 2012 From: mpetach at netflight.com (Matthew Petach) Date: Tue, 28 Feb 2012 10:53:54 -0800 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <6FBFA779-0ACA-48C9-82A7-4F1BFAA9A7C0@delong.com> References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> <6FBFA779-0ACA-48C9-82A7-4F1BFAA9A7C0@delong.com> Message-ID: On Tue, Feb 28, 2012 at 3:25 AM, Owen DeLong wrote: > > On Feb 28, 2012, at 2:23 AM, Matthew Petach wrote: > >> On Mon, Feb 27, 2012 at 1:46 PM, Tom Vest wrote: >>> Thanks for the responses Matt -- follow-ups inline... >>> >>> On Feb 27, 2012, at 12:40 PM, Matthew Petach wrote: >>> >>>> On Sun, Feb 26, 2012 at 7:02 PM, Tom Vest wrote: >>>>> Hi Matt, >>>>> >>>>> You seem to be arguing the following: >>>>> >>>>> 1. "IPv4 Speculation" is bad (or maybe good for the lucky speculators, but bad/unfair for everyone else). >>>> >>>> I was trying not to assign it a category of "good' or "bad"--simply stating >>>> it does exist today; and thus, one of the arguments *against* a free and >>>> unfettered market is not relevant. ?The cry of "but if we allow anyone to >>>> buy and sell IP blocks, we'll be overrun with speculators" rings hollow >>>> when the market is already supporting dozens of speculators who operate >>>> outside the needs-based criteria. >>> >>> But, notwithstanding rhetorical force of habit, is anyone actually crying about "allowing anyone to buy and sell IP blocks" i.e., as opposed to "allowing non-operators (or those who can't demonstrate the equivalent of an operator's "need") to buy IP blocks?" You're still trying to conflate the prerogatives of an(y) aspiring IPv4 seller with those of a(ny) potential IPv4 buyer -- but you really can't claim that the two are the same, or that the differences don't matter without explaining why. Membership in the class of "anyone that can sell IPv4" is bounded by the material fact that in order to sell IPv4 one must actually have some to sell -- and throughout all time to the present moment, 100% of the members of that class have already satisfied, at minimum, whatever definition of "operator" was officially recognized ?at the time when they received their address resources (and in most cases, additional/more demanding eligibility requirements that came thereafter). By contrast, the class of "anyone that can buy IPv4" has no equivalent limiting factor. >> >> I suppose what I'm stumbling over is that today, we >> have large blocks of v4 address space that today >> are held be registrants who are not routing them >> as part of the global IPv4 routing table. ?You seem >> to feel that they somehow qualified as "operators" >> in a way that has significance, in spite of them not >> routing their address space in a reachable fashion, >> whereas "speculators" would somehow be categorized >> as "non-operators". >> > > Even under today's policies, there are legitimate purposes for obtaining a registration that do not involve a route appearing in the global table or any routing table you are likely to be able to see. > > Just because their network isn't visible to you does not mean that it is not operating and/or is not connected to a network that is connected to the internet. > OK. Trimming the rest down, because I think those two lines really are the crux of a challenge point for me, and the rest of Owen's reply reiterated that much of my repeated concern hinges upon that point. It seems that participation in the global routing table is not a requirement condition for being an operator, and that indeed there is no externally visible condition or attribute that can be seen to indicate whether an entity is an operator or not. Is the collected judgment of the ARIN staff the only determining differentiator between speculators and legitimate non-connected-to-the-internet operators? And if so, do we trust that judgment sufficiently to have it be the sole arbiter of the market? If we do, then I'd think about removing my support for proposal 165, and instead support a proposal for an open, unfettered market for exchange of IPv4 address resources *between operators*, with the results of transfers to be registered by ARIN. The key distinction being that ARIN would not limit the market based on *their* opinion of your need, but simply on whether or not you qualified as a network operator, as apparently they are the only ones in a position to make that determination. I think that would find the best balance between allowing the market to thrive, while at the same time removing the horrible specter of "speculation" that seems to be the one reason most often cited for *not* allowing the market to develop naturally. Thanks! Matt seeking to gain deeper insights through continued dialogue From admin at bango.org.bb Tue Feb 28 13:54:51 2012 From: admin at bango.org.bb (admin at bango.org.bb) Date: Tue, 28 Feb 2012 14:54:51 -0400 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <86booiizbo.fsf@seastrom.com> References: <86fwdvrt2c.fsf@seastrom.com><986D092ECF1A471BB67CEFF98513F792@BANGO> <86booiizbo.fsf@seastrom.com> Message-ID: <72E4AFB402C7405898161EB732CAFA05@BANGO> That's how you see it? A discussion on Keynesianism and social justice? You dismiss the plight of millions who live it everyday on an "ism". Well, if you are insulated, good for you. ROK -----Original Message----- From: Robert E. Seastrom Sent: Tuesday, February 28, 2012 2:32 PM To: admin at bango.org.bb Cc: Kevin Kargel ; Robert E. Seastrom ; ARIN PPML Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification Hello "ROK", Without devolving into a meta-discussion about Keynesianism and social justice, can you identify particular problems with resources that have been transfered under 8.3 being registered under the LRSA rather than the regular RSA? https://www.arin.net/resources/agreements/legacy_rsa.pdf https://www.arin.net/resources/agreements/rsa.pdf Thanks, -r writes: > Really! While it may be agreeable that those who were in the front > line should be rewarded, it should also be recognised that others, if > they had the opportunity would have been right there as well and could > have been equally rewarded but are not and could well do with some of > those resources. To give "legacy holders" boundless resources way > beyond their needs, is the kind of thinking that is now wreaking havoc > on this world because a few have far too much. We are complaining > about the one percent but yet our minds are so conditioned as to > continue the madness. > > We must move to stamp out inequalities in this world; especially large > divides as this usually means that some will inevitably be left > without down the road and leaving people without is the cause of all > the pain in this world; one way or another. We must be careful how we > establish a few to become the power houses of this world. Legacy > holders will pass on someday and leave to their children what their > children were not in the front line fighting for and will probably > forget what the fight was about but become heirs to resources beyond > their needs to wield as they please and possibly against the wishes of > the parents who fought. > > Are we doomed to repeat the mistakes of our past just like that? > > ROK > > -----Original Message----- > From: Robert E. Seastrom > Sent: Tuesday, February 28, 2012 9:22 AM > To: Kevin Kargel > Cc: ARIN PPML > Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification > > > Kevin Kargel writes: > >> Now - if a "legacy" holder returns or relinquishes or transfers >> space and a >> new registration or allocation or transfer needs to be effected then I do >> strongly feel that the "new" allocation should fall under the common >> rules, >> restrictions and aegis provided by the community via ARIN RSA (*not* >> LRSA). > > What is the difference between the two RSAs upon which your opinion > pivots? Does it simply boil down to amount of revenue that ARIN gets > from a particular database entry? > > Disclaimer: I am (personally) an LRSA signatory. > % whois -h whois.arin.net '! > RES-Z' > > -r > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From jrhett at netconsonance.com Tue Feb 28 14:32:14 2012 From: jrhett at netconsonance.com (Jo Rhett) Date: Tue, 28 Feb 2012 11:32:14 -0800 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> Message-ID: <0E3AC506-2E08-4CC5-98BA-A6BE2CA51F57@netconsonance.com> On Feb 28, 2012, at 2:23 AM, Matthew Petach wrote: > I suppose what I'm stumbling over is that today, we > have large blocks of v4 address space that today > are held be registrants who are not routing them > as part of the global IPv4 routing table. You seem > to feel that they somehow qualified as "operators" > in a way that has significance, in spite of them not > routing their address space in a reachable fashion, ... > I see large chunks of address space assigned by IANA that are not operationally visible on the v4 internet; There are many, many reasons that people use globally unique addresses for private purposes. Just because an IP range is not providing service to you, does not mean it is not a valid use of globally unique space. Just a few of those reasons include transit links through diverse providers, private interconnects for paid services, etc. And no, RFC1918 space is not always a workable option for these situations. > whereas "speculators" would somehow be categorized as "non-operators". Where do end user organizations fall in your scheme? You seem to be applying a very narrow selection to what you consider valid uses of IP space. > And if there is no distinguishable difference between > "operators" and "non-operators", then the class of > "operators", who managed to obtain IP space thus > far, in spite of not actually routing it on the global > internet, is functionally equivalent to the class of > "anyone that can buy IPv4"--ie, non-operators. I don't believe that this is confusing in ARIN policy sense. I believe that this is confusing to you, but that doesn't prevent the current policy from being valid. > So...again...please help me understand the nature > of the category of "operator" that allows one to > obtain globally routable IP space with no plans > to route it on the global internet, from the category > of "speculator"? May I suggest that instead of asking us to educate you, that you start by reading the existing ARIN documents for valid reasons for assignment of IP space? This seems very clearly defined to me. > I'm simply trying to come up with a definition > of what an IP Speculator might be, Definition is simple: someone who wants to make money from IP space. The problem is that you can't make policy that prevents it only during allocation. Almost all of the IP speculators were once businesses with valid uses of IP space, which have either failed or transitioned in such a manner than their IP space is no longer used. The only way to solve this problem is to direct ARIN to recover IP space based on some criteria, and that battle has been fought for many years with no resolution in sight. The only policy which might be necessary to prevent "pure" speculators (ones who never had need of the space except to sell) is that space could be recovered if proof was provided that the assignee had lied to ARIN, and that policy already exists. And again, only if they have signed a recent RSA. > So, let me make sure I understand your position on this; > from your perspective, it is entirely proper to have different > rules that apply to different entities within the ARIN region. > There is no requirement to have the rules equally apply to > everyone? There are different rules for different types of organizations, and there are different rules for different types of resources. I don't see any chance of unifying them, nor do I see any reasonable argument for changing the current structure. > I think the analogy I'm looking at is more along the lines > of someone who has inherited land being allowed to sell > that land to overseas investors, completely tax-free, whereas > everyone who did not inherit their property must sell the > property with government involvement, including restrictions > on the zoning of the land being sold, and taxes on the transfer > of the land. No, to be clear you are complaining because people who paid 10cents for the land hundreds of years ago are making more profit than people who paid modern rates for it, and there was a lot less land to grab recently. You should look up the settlement of the west of the US and "homesteading" for good historical analogies. There is no fault in those who paid for their land in sweat equity, but you sure are trying to make a case for it. I disagree. > I'm not actually proposing anything, I'm simply advocating > for the removal of needs-based allocations. And none of your logic makes any sense, mostly because you would appear to be unaware of most of what you are arguing about. The needs-based policies make perfect sense, and I fully support their continued employment. And I'm going to stop here, because you talk a lot but you neither read the available documents nor listen to those who try to educate you. -- Jo Rhett Net Consonance : consonant endings by net philanthropy, open source and other randomness -------------- next part -------------- An HTML attachment was scrubbed... URL: From owen at delong.com Tue Feb 28 14:35:48 2012 From: owen at delong.com (Owen DeLong) Date: Tue, 28 Feb 2012 11:35:48 -0800 Subject: [arin-ppml] 2011-7 Status FAIL In-Reply-To: References: Message-ID: > And even though the the PPM did not have consensus supporting it, an > attempt to move it to last call occurred and the AC answered that > with: > I believe the PPM had limited consensus and that the revisions proposed prior to the last call motion addressed the majority of the objections. >> The motion to forward to last call failed with 9 against (DA, CA, MC, MH, DF, BS, RS, HS, JS), 2 in favor (BD, CG), and 1 abstention (OD) >via roll call. > > Yet another revision containing the DNS issue that we're all objecting > has been recently published. More v4 and Section 12 time wasting. > I find it very interesting that you can characterize a simple majority+1 of the AC as "all". >> On 2/28/12 03:08 CST, Owen DeLong wrote: >>> > > [ clip ] > > >>> As such, I have trouble reconciling the actual reality with statements by >>> my colleague earlier on this list. >>> > > The minutes demonstrate that an "overwhelming" majority at the PPM in > Philadelphia objected to at least the DNS requirement yet again. > > https://www.arin.net/participate/meetings/reports/ARIN_XXVIII/ppm1_transcript.html#anchor_7 > All but one (KB) of the objections prior to Bill Woodcock reflected fundamental misunderstandings of the proposal text, so, it's hard to put much stock in them. Many of the other objections are about the existing policy language and not the proposal itself. When you distill those out, you're left with a pretty small minority opposing the draft policy as written at the time. From those, the subsequent modifications actually address most of the issues raised. > Putting all of that aside, the question should be is shutting off DNS > from the perspective of this proposal sound technical policy? It would > seem that the vast majority of the discussion has pointed to "no". > Hence, my question as to why we are still doing this. There are certainly those who say no. There are those who say yes. Unfortunately, in the sea of comments on other aspects not even in this proposal it was hard (at least for me) to actually gauge the level of support or opposition to this particular aspect. Finally, from the minutes you cited: In relation to the second motion, whether the AC should be asked to continue to work on it, the total number of people in the meeting room and by remote are 167. In favor of asking them to do further work on it were 57 and against them doing further work on it is 6. So, while there was a relatively even split on whether to move it forward or not (20:34), there was overwhelming support (57:6) for continuing to work on it. In fact, more people favored continuing to work on it than voted at all on whether or not to move it forward. I'd say that's a pretty good reason for us to still be working on it. Owen From celestea at usc.edu Tue Feb 28 14:47:19 2012 From: celestea at usc.edu (Celeste Anderson) Date: Tue, 28 Feb 2012 11:47:19 -0800 Subject: [arin-ppml] 2011-7 Status FAIL In-Reply-To: References: Message-ID: <014e01ccf651$c7d2da10$57788e30$@usc.edu> All, I am opposed to this policy as written ( the revised version). I believe that ARIN resources could be better directed to other efforts. --celeste. -----Original Message----- From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of Owen DeLong Sent: Tuesday, February 28, 2012 11:36 AM To: arin-ppml at arin.net List Subject: Re: [arin-ppml] 2011-7 Status FAIL > And even though the the PPM did not have consensus supporting it, an > attempt to move it to last call occurred and the AC answered that > with: > I believe the PPM had limited consensus and that the revisions proposed prior to the last call motion addressed the majority of the objections. >> The motion to forward to last call failed with 9 against (DA, CA, MC, MH, DF, BS, RS, HS, JS), 2 in favor (BD, CG), and 1 abstention (OD) >via roll call. > > Yet another revision containing the DNS issue that we're all objecting > has been recently published. More v4 and Section 12 time wasting. > I find it very interesting that you can characterize a simple majority+1 of the AC as "all". >> On 2/28/12 03:08 CST, Owen DeLong wrote: >>> > > [ clip ] > > >>> As such, I have trouble reconciling the actual reality with >>> statements by my colleague earlier on this list. >>> > > The minutes demonstrate that an "overwhelming" majority at the PPM in > Philadelphia objected to at least the DNS requirement yet again. > > https://www.arin.net/participate/meetings/reports/ARIN_XXVIII/ppm1_tra > nscript.html#anchor_7 > All but one (KB) of the objections prior to Bill Woodcock reflected fundamental misunderstandings of the proposal text, so, it's hard to put much stock in them. Many of the other objections are about the existing policy language and not the proposal itself. When you distill those out, you're left with a pretty small minority opposing the draft policy as written at the time. From those, the subsequent modifications actually address most of the issues raised. > Putting all of that aside, the question should be is shutting off DNS > from the perspective of this proposal sound technical policy? It would > seem that the vast majority of the discussion has pointed to "no". > Hence, my question as to why we are still doing this. There are certainly those who say no. There are those who say yes. Unfortunately, in the sea of comments on other aspects not even in this proposal it was hard (at least for me) to actually gauge the level of support or opposition to this particular aspect. Finally, from the minutes you cited: In relation to the second motion, whether the AC should be asked to continue to work on it, the total number of people in the meeting room and by remote are 167. In favor of asking them to do further work on it were 57 and against them doing further work on it is 6. So, while there was a relatively even split on whether to move it forward or not (20:34), there was overwhelming support (57:6) for continuing to work on it. In fact, more people favored continuing to work on it than voted at all on whether or not to move it forward. I'd say that's a pretty good reason for us to still be working on it. Owen _______________________________________________ PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). Unsubscribe or manage your mailing list subscription at: http://lists.arin.net/mailman/listinfo/arin-ppml Please contact info at arin.net if you experience any issues. From jrhett at netconsonance.com Tue Feb 28 14:48:08 2012 From: jrhett at netconsonance.com (Jo Rhett) Date: Tue, 28 Feb 2012 11:48:08 -0800 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> <6FBFA779-0ACA-48C9-82A7-4F1BFAA9A7C0@delong.com> Message-ID: <6A72B49C-4E38-497D-9CE5-0EEA63478289@netconsonance.com> On Feb 28, 2012, at 10:53 AM, Matthew Petach wrote: > It seems that participation in the global > routing table is not a requirement condition for > being an operator, and that indeed there is no > externally visible condition or attribute that can > be seen to indicate whether an entity is an > operator or not. Whether or not someone is an operator is not a useful distinction. The current policy asks for whether or not they need the space, which is the useful attribute but you seem to be fighting against for reasons nobody can quite understand. > And if so, do we trust that judgment sufficiently to have it be the sole arbiter of the market? Um, no. The current policy is to focus on the need for space, which is in fact what ARIN is directed to deal with. > If we do, then I'd think about removing my support > for proposal 165, and instead support a proposal > for an open, unfettered market for exchange of IPv4 > address resources *between operators*, with the > results of transfers to be registered by ARIN. You have consistently shouted out against people having gotten big allocations in the early Internet, and now you are suggesting you'd advocate for a policy that would allow all of these "privileged classes" (your words) to trade between each other without ARIN oversight? I am beginning to believe that I fell for a troll. Sorry, everyone. -- Jo Rhett Net Consonance : consonant endings by net philanthropy, open source and other randomness -------------- next part -------------- An HTML attachment was scrubbed... URL: From admin at bango.org.bb Tue Feb 28 15:45:49 2012 From: admin at bango.org.bb (admin at bango.org.bb) Date: Tue, 28 Feb 2012 16:45:49 -0400 Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <596B74B410EE6B4CA8A30C3AF1A155EA09CEA222@RWC-MBX1.corp.seven.com> References: <86fwdvrt2c.fsf@seastrom.com> <986D092ECF1A471BB67CEFF98513F792@BANGO> <596B74B410EE6B4CA8A30C3AF1A155EA09CEA038@RWC-MBX1.corp.seven.com> <3A7D4D77A0CB4F8A8700317EB4B69CC8@BANGO> <596B74B410EE6B4CA8A30C3AF1A155EA09CEA222@RWC-MBX1.corp.seven.com> Message-ID: I really don't know what you are on about. First recognise a difference between diversity and inequality. Secondly, you should have noted that I had no objection to the inequality, it is the gross inequality of which I speak and object to. Other than that you can continue to argue with yourself. ROK -----Original Message----- From: George Bonser Sent: Tuesday, February 28, 2012 4:16 PM To: admin at bango.org.bb Subject: RE: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification Yes. For example, we are all born with different levels of talents in various things and reach different levels of success or lack of success. It is pure insanity to expect any "equal" result for all people. That takes away incentive to get better. Why should I bust my ass at something if I am not going to get anything more for it than the other guy? And once that starts to happen EVERYONE suffers because that results in a general lack of advancement of the sort that has been experienced in, for example, socialist economies. It just doesn't work, it goes against basic natural fundamentals and basic arithmetic. You cannot micromanage things to that level. So you have some people who have a natural interest or talent in something. They work hard at it, not because they are doing it out of some altruistic desire to "help people" but because they derive pleasure from it OR it comes easy to them and is very lucrative. So they create great things from which the rest of us get to benefit from having in our society. Life is not fair. Can you imagine someone attempting to create a forest where every single tree is exactly equal? It would not be able to advance beyond the weakest member. It would die, it would become extinct. Equality is one of those things that *sounds* nice but in reality is impossible. Would you play a video game where nobody could be any better than anyone else? I *WANT* my children to advance beyond their peers. I *WANT* them to be more successful. I am not interested in impeding anyone else, but I am interested in taking the best advantage of opportunities as they come along and having skills to take advantage of them. When I hear people talk about *equality*, I generally hear self-loathing. Someone is envious of what someone else has and believes they can never attain it, so they want to take away what someone else has in order to somehow make them more equal. That is destructive and hurts everyone. > -----Original Message----- > From: admin at bango.org.bb [mailto:admin at bango.org.bb] > Sent: Tuesday, February 28, 2012 10:52 AM > To: George Bonser > Subject: Re: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based > Justification > > Inequality is a fact of life, get used to it? Well facism is a fact of > life get used to it... Poverty is a fact of life, get used to it. Wow! > Easy for those on the giving end to say, but what about those on the > receiving end? > As for uselessness of the resources, how short sighted can one get? > > ROK > > -----Original Message----- > From: George Bonser > Sent: Tuesday, February 28, 2012 2:06 PM > To: admin at bango.org.bb > Subject: RE: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based > Justification > > > > > -----Original Message----- > > From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] > On > > Behalf Of admin at bango.org.bb > > > > We must move to stamp out inequalities in this world; especially > large > > divides as this usually means that some will inevitably be left > without > > down the road and leaving people without is the cause of all the pain > > in this world; one way or another. We must be careful how we > establish > > a few to become the power houses of this world. Legacy holders will > > pass on someday and leave to their children what their children were > > not in the front line fighting for and will probably forget what the > > fight was about but become heirs to resources beyond their needs to > > wield as they please and possibly against the wishes of the parents > who > > fought. > > > > Are we doomed to repeat the mistakes of our past just like that? > > > > ROK > > Inequality is a fact of life. Embrace it. We cannot time-warp > decisions > made many years ago into today's reality. An assignment given in good > faith > using proper procedure at the time cannot suddenly be undone today > because > someone thinks the decision made many years ago is no longer fair in > today's > light. It was a decision that was agreed to. How is suddenly changing > the > requirements on someone who already has an assignment "fair" for that > person? > > Legacy holders will someday pass on a useless pile of obsolete IP > addresses > that nobody wants at any price. We should be spending more time > deploying > v6 services and less time complaining about v4. It really is as simple > as > that. Native v6 services to the growing number of native v6 user > deployments is the answer. Is the goal of this simply to generate some > cash > windfall for legacy holders during the crunch time or is it designed to > create a cash windfall for middlemen who will make out great in the > initial > transfers and leave others holding the bag when the market crashes? > > This is exactly the wrong time to eliminate needs requirements. Take > of > your cape, crusader. The only way to find "equality" is in poverty. > From bill at herrin.us Tue Feb 28 18:03:11 2012 From: bill at herrin.us (William Herrin) Date: Tue, 28 Feb 2012 18:03:11 -0500 Subject: [arin-ppml] 2011-7 Status FAIL In-Reply-To: References: Message-ID: On Tue, Feb 28, 2012 at 10:24 AM, Martin Hannigan wrote: > On Tue, Feb 28, 2012 at 8:46 AM, David Farmer wrote: >> Personally, I continue to be skeptical of the idea of using DNS as a lever >> for compliance regarding documentation of reassignments. > > With respect to the DNS issue, this would not be the first time that > there have been objections. Hy Martin, Strike the following and I think I'd be more or less satisfied with the draft: If progress of resource returns or record corrections has not occurred within sixty (60) days after ARIN initiated contact, ARIN shall cease providing reverse DNS services for the resources in question. ARIN shall negotiate a longer term with the organization if ARIN believes the organization is working in good faith to restore compliance and has a valid need for additional time. Here's my reasoning: stopping reverse DNS is *really* penny ante. The first use in 12.5 is potentially reasonable: a last ditch effort to get in touch with an uncommunicative registrant before revoking the resources. Beyond that, its punitive and unhelpful. ARIN doesn't need to prove that it's really truly serious. Either revoke the resources for cause or don't. Regards, Bill Herrin -- William D. Herrin ................ herrin at dirtside.com? bill at herrin.us 3005 Crane Dr. ...................... Web: Falls Church, VA 22042-3004 From cgrundemann at gmail.com Tue Feb 28 18:38:53 2012 From: cgrundemann at gmail.com (Chris Grundemann) Date: Tue, 28 Feb 2012 16:38:53 -0700 Subject: [arin-ppml] 2011-7 Status FAIL In-Reply-To: References: Message-ID: On Tue, Feb 28, 2012 at 16:03, William Herrin wrote: > Strike the following and I think I'd be more or less satisfied with the draft: > > If progress of > resource returns or record corrections has not occurred within sixty > (60) days after ARIN initiated contact, ARIN shall cease providing > reverse DNS services for the resources in question. ARIN shall negotiate > a longer term with the organization if ARIN believes the organization is > working in good faith to restore compliance and has a valid need for > additional time. > > > Here's my reasoning: stopping reverse DNS is *really* penny ante. The > first use in 12.5 is potentially reasonable: a last ditch effort to > get in touch with an uncommunicative registrant before revoking the > resources. Beyond that, its punitive and unhelpful. ARIN doesn't need > to prove that it's really truly serious. Either revoke the resources > for cause or don't. Thanks for the feedback Bill! FYI: The intent of adding the reverse DNS hook was twofold. First, as you very correctly observe, it should help grab attention when needed as an intermediate step before revoking resources, kind of a last chance mechanism. The other intent is to grab attention when revocation is too extreme, such as a failure to register downstream delegations in WHOIS. As a community, we have identified time and again the need for an accurate WHOIS. This "penny ante" mechanism may help ARIN to ensure that the WHOIS database is as accurate and complete as possible. Cheers, ~Chris > Regards, > Bill Herrin > > > > -- > William D. Herrin ................ herrin at dirtside.com? bill at herrin.us > 3005 Crane Dr. ...................... Web: > Falls Church, VA 22042-3004 > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. -- @ChrisGrundemann http://chrisgrundemann.com From mpetach at netflight.com Tue Feb 28 19:03:24 2012 From: mpetach at netflight.com (Matthew Petach) Date: Tue, 28 Feb 2012 16:03:24 -0800 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <6A72B49C-4E38-497D-9CE5-0EEA63478289@netconsonance.com> References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> <6FBFA779-0ACA-48C9-82A7-4F1BFAA9A7C0@delong.com> <6A72B49C-4E38-497D-9CE5-0EEA63478289@netconsonance.com> Message-ID: On Tue, Feb 28, 2012 at 11:48 AM, Jo Rhett wrote: > On Feb 28, 2012, at 10:53 AM, Matthew Petach wrote: > > It seems that participation in the global > routing table is not a requirement condition for > being an operator, and that indeed there is no > externally visible condition or attribute that can > be seen to indicate whether an entity is an > operator or not. > > > Whether or not someone is an operator is not a useful distinction. The > current policy asks for whether or not they need the space, which is the > useful attribute but you seem to be fighting against for reasons nobody can > quite understand. I apologize. I was simply going to leave it as "+1 in favor of proposition 165" but I was asked to explain why I supported proposal 165. If you cannot understand my reasons, that's unfortunate, but that doesn't invalidate my vote, and as such, rather than take up more space on the list, I suppose it might make people happier if I simply leave it as "please record for the official PPML tally on this proposal one more vote in favour of it" rather than trying to explain my thinking. > And if so, do we trust that judgment?sufficiently to have it be the sole > arbiter of the?market? > > Um, no. The current policy is to focus on the need for space, which is in > fact what ARIN is directed to deal with. I guess I should simply be happy that the term "need" is sufficiently vague to allow anyone to apply for IP space based on their stated "need" for it, whether or not that "need" translates into real-world usage, as it seems it can be sufficient to "need" it for an internal network not visible to the rest of the internet. > If we do, then I'd think about removing my support > for proposal 165, and instead support a proposal > for an open, unfettered market for exchange of IPv4 > address resources *between operators*, with the > results of transfers to be registered by ARIN. > > You have consistently shouted out against people having gotten big > allocations in the early Internet, and now you are suggesting you'd advocate > for a policy that would allow all of these "privileged classes" (your words) > to trade between each other without ARIN oversight? > > I am beginning to believe that I fell for a troll. ?Sorry, everyone. I've been careful to avoid using capitalization or other typography that would indicate shouting. I apologize if anything I've said came across as shouting in any way. This was merely meant to point out my thoughts on the matter. As it is not a requirement of ARIN membership to have to explain one's thought processes to an uninterested audience, I'll cease to waste your time, and will simply vote in the way that makes the most sense for me. I encourage others to do likewise. Thanks! Matt From scottleibrand at gmail.com Tue Feb 28 19:22:13 2012 From: scottleibrand at gmail.com (Scott Leibrand) Date: Tue, 28 Feb 2012 16:22:13 -0800 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> <6FBFA779-0ACA-48C9-82A7-4F1BFAA9A7C0@delong.com> <6A72B49C-4E38-497D-9CE5-0EEA63478289@netconsonance.com> Message-ID: On Tue, Feb 28, 2012 at 4:03 PM, Matthew Petach wrote: > > As it is not a requirement of ARIN membership to have > to explain one's thought processes to an uninterested > audience, I'll cease to waste your time > > For the record, this particular member of your audience was quite interested to read your thoughts on this proposal. Thanks. -Scott -------------- next part -------------- An HTML attachment was scrubbed... URL: From bill at herrin.us Tue Feb 28 20:21:39 2012 From: bill at herrin.us (William Herrin) Date: Tue, 28 Feb 2012 20:21:39 -0500 Subject: [arin-ppml] 2011-7 Status FAIL In-Reply-To: References: Message-ID: On Tue, Feb 28, 2012 at 6:38 PM, Chris Grundemann wrote: > FYI: The intent of adding the reverse DNS hook was twofold. First, as > you very correctly observe, it should help grab attention when needed > as an intermediate step before revoking resources, kind of a last > chance mechanism. The other intent is to grab attention when > revocation is too extreme, such as a failure to register downstream > delegations in WHOIS. As a community, we have identified time and > again the need for an accurate WHOIS. This "penny ante" mechanism may > help ARIN to ensure that the WHOIS database is as accurate and > complete as possible. Hi Chris, I can't think of a single hypothetical case in which revocation is too extreme but canceling RDNS is an appropriate punishment. WHOIS isn't up to snuff? Not taking ARIN's complaints seriously? Issue a revocation with the policy 6-months to renumber out of the block. If WHOIS magically improves and they pay ARIN's auditing costs so that the rest of us don't get burned by the bad behavior, then clearly there's no further need to complete the revocation. I'm okay with RDNS revocation as a last ditch "we couldn't get in touch with you any other way" measure, but that use isn't punitive. As a punitive measure, RDNS revocation is, frankly, beneath ARIN's dignity. Regards, Bill -- William D. Herrin ................ herrin at dirtside.com? bill at herrin.us 3005 Crane Dr. ...................... Web: Falls Church, VA 22042-3004 From scottleibrand at gmail.com Tue Feb 28 20:55:32 2012 From: scottleibrand at gmail.com (Scott Leibrand) Date: Tue, 28 Feb 2012 17:55:32 -0800 Subject: [arin-ppml] 2011-7 Status FAIL In-Reply-To: References: Message-ID: On Tue, Feb 28, 2012 at 5:21 PM, William Herrin wrote: > On Tue, Feb 28, 2012 at 6:38 PM, Chris Grundemann > wrote: > > FYI: The intent of adding the reverse DNS hook was twofold. First, as > > you very correctly observe, it should help grab attention when needed > > as an intermediate step before revoking resources, kind of a last > > chance mechanism. The other intent is to grab attention when > > revocation is too extreme, such as a failure to register downstream > > delegations in WHOIS. As a community, we have identified time and > > again the need for an accurate WHOIS. This "penny ante" mechanism may > > help ARIN to ensure that the WHOIS database is as accurate and > > complete as possible. > > Hi Chris, > > I can't think of a single hypothetical case in which revocation is too > extreme but canceling RDNS is an appropriate punishment. > > WHOIS isn't up to snuff? Not taking ARIN's complaints seriously? Issue > a revocation with the policy 6-months to renumber out of the block. If > WHOIS magically improves and they pay ARIN's auditing costs so that > the rest of us don't get burned by the bad behavior, then clearly > there's no further need to complete the revocation. > > I'm okay with RDNS revocation as a last ditch "we couldn't get in > touch with you any other way" measure, but that use isn't punitive. As > a punitive measure, RDNS revocation is, frankly, beneath ARIN's > dignity. Not sure if a non-profit has dignity, but otherwise I would tend to agree with Bill here. I'm uncomfortable *requiring* ARIN to stop providing reverse DNS services. If we want to give ARIN permission to do so, fine. (I don't think they'll abuse that tool, or even use it much.) But I'm still unconvinced that requiring them to do so serves any useful purpose. So I'm fine with "If an organization fails to respond within thirty (30) days, ARIN may cease providing reverse DNS services to that organization." But I would strike "If progress of resource returns or record corrections has not occurred within sixty (60) days after ARIN initiated contact, ARIN shall cease providing reverse DNS services for the resources in question." It's also worth noting that I support the new 12.4 language, adding "update reassignment information or" so it reads "Organizations found by ARIN to be out of compliance with current ARIN policy shall be required to update reassignment information or return resources as needed to bring them into (or reasonably close to) compliance." -Scott -------------- next part -------------- An HTML attachment was scrubbed... URL: From jsw at inconcepts.biz Tue Feb 28 21:01:53 2012 From: jsw at inconcepts.biz (Jeff Wheeler) Date: Tue, 28 Feb 2012 21:01:53 -0500 Subject: [arin-ppml] 2011-7 Status FAIL In-Reply-To: References: Message-ID: On Tue, Feb 28, 2012 at 8:55 PM, Scott Leibrand wrote: > So I'm fine with "If an organization fails to respond within thirty (30) > days, ARIN may cease providing reverse DNS services to that organization." If I were supreme dictator of the Internet, I would simply return PTR records like "THIS-IP-ADDRESS-SPACE-IS-STALE-OR-HIJACKED-VISIT-WWW.ARIN.NET" Simply making reverse DNS fail may not attract the attention of organizations that simply haven't done a good job of updating their resource records. $0.02. -- Jeff S Wheeler Sr Network Operator? /? Innovative Network Concepts From lar at mwtcorp.net Tue Feb 28 21:19:45 2012 From: lar at mwtcorp.net (Larry Ash) Date: Tue, 28 Feb 2012 19:19:45 -0700 Subject: [arin-ppml] 2011-7 Status FAIL In-Reply-To: References: Message-ID: +1. Much better. Larry Ash Mountain West Telephone On Feb 28, 2012, at 7:01 PM, Jeff Wheeler wrote: > On Tue, Feb 28, 2012 at 8:55 PM, Scott Leibrand wrote: >> So I'm fine with "If an organization fails to respond within thirty (30) >> days, ARIN may cease providing reverse DNS services to that organization." > > If I were supreme dictator of the Internet, I would simply return PTR > records like "THIS-IP-ADDRESS-SPACE-IS-STALE-OR-HIJACKED-VISIT-WWW.ARIN.NET" > > Simply making reverse DNS fail may not attract the attention of > organizations that simply haven't done a good job of updating their > resource records. > > $0.02. > -- > Jeff S Wheeler > Sr Network Operator / Innovative Network Concepts > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From owen at delong.com Tue Feb 28 22:14:32 2012 From: owen at delong.com (Owen DeLong) Date: Tue, 28 Feb 2012 19:14:32 -0800 Subject: [arin-ppml] 2011-7 Status FAIL In-Reply-To: References: Message-ID: That might actually be a good idea. I would support modifying the policy to require that DNS actions prior to revocation result in a wildcard PTR that returns (a more polite) phrasing to that effect. Owen On Feb 28, 2012, at 6:19 PM, Larry Ash wrote: > +1. > Much better. > > Larry Ash > Mountain West Telephone > > > On Feb 28, 2012, at 7:01 PM, Jeff Wheeler wrote: > >> On Tue, Feb 28, 2012 at 8:55 PM, Scott Leibrand wrote: >>> So I'm fine with "If an organization fails to respond within thirty (30) >>> days, ARIN may cease providing reverse DNS services to that organization." >> >> If I were supreme dictator of the Internet, I would simply return PTR >> records like "THIS-IP-ADDRESS-SPACE-IS-STALE-OR-HIJACKED-VISIT-WWW.ARIN.NET" >> >> Simply making reverse DNS fail may not attract the attention of >> organizations that simply haven't done a good job of updating their >> resource records. >> >> $0.02. >> -- >> Jeff S Wheeler >> Sr Network Operator / Innovative Network Concepts >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. From hannigan at gmail.com Tue Feb 28 22:59:11 2012 From: hannigan at gmail.com (Martin Hannigan) Date: Tue, 28 Feb 2012 22:59:11 -0500 Subject: [arin-ppml] 2011-7 Status FAIL In-Reply-To: References: Message-ID: On Tue, Feb 28, 2012 at 8:55 PM, Scott Leibrand wrote: > On Tue, Feb 28, 2012 at 5:21 PM, William Herrin wrote: >> >> On Tue, Feb 28, 2012 at 6:38 PM, Chris Grundemann >> wrote: >> > FYI: The intent of adding the reverse DNS hook was twofold. First, as >> > you very correctly observe, it should help grab attention when needed >> > as an intermediate step before revoking resources, kind of a last >> > chance mechanism. The other intent is to grab attention when >> > revocation is too extreme, such as a failure to register downstream >> > delegations in WHOIS. As a community, we have identified time and >> > again the need for an accurate WHOIS. This "penny ante" mechanism may >> > help ARIN to ensure that the WHOIS database is as accurate and >> > complete as possible. >> >> Hi Chris, >> >> I can't think of a single hypothetical case in which revocation is too >> extreme but canceling RDNS is an appropriate punishment. >> >> WHOIS isn't up to snuff? Not taking ARIN's complaints seriously? Issue >> a revocation with the policy 6-months to renumber out of the block. If >> WHOIS magically improves and they pay ARIN's auditing costs so that >> the rest of us don't get burned by the bad behavior, then clearly >> there's no further need to complete the revocation. >> >> I'm okay with RDNS revocation as a last ditch "we couldn't get in >> touch with you any other way" measure, but that use isn't punitive. As >> a punitive measure, RDNS revocation is, frankly, beneath ARIN's >> dignity. > > > Not sure if a non-profit has dignity, but otherwise I would tend to agree > with Bill here. ?I'm uncomfortable *requiring* ARIN to stop providing > reverse DNS services. ?If we want to give ARIN permission to do so, fine. > ?(I don't think they'll abuse that tool, or even use it much.) ?But I'm > still unconvinced that requiring them to do so serves any useful purpose. The NRPM contains enough vague language that we've demonstrated can be applied unevenly. I don't think adding more is productive. > So I'm fine with "If an organization fails to respond within thirty (30) > days, ARIN may cease providing reverse DNS services to that organization." > ?But I would strike "If progress of resource returns or record corrections > has not occurred within sixty (60) days after ARIN initiated contact, ARIN > shall cease providing reverse DNS services for the resources in question." Experience with ARIN Section 12 audit seems to be limited in this thread at least for an extra-large amount of address space, pardon me if I'm wrong.. These audit policies don't only apply to the small networks and the complexity, time and cost involved vary greatly along the lines of size. If this were something more reasonable, the time frame could be more along the lines of at least 120 days. Still, ARIN already has all of the necessary "tools" to do their job including their lawyers. A breach of the RSA is a legal issue, not a technical one. Best, -M< From alan at batie.org Tue Feb 28 22:50:29 2012 From: alan at batie.org (Alan Batie) Date: Tue, 28 Feb 2012 19:50:29 -0800 Subject: [arin-ppml] 2011-7 Status FAIL In-Reply-To: References: Message-ID: <4F4DA085.4050206@batie.org> On 2/28/12 7:14 PM, Owen DeLong wrote: > That might actually be a good idea. I would support modifying the policy to require that DNS actions prior to revocation result in a wildcard PTR that returns (a more polite) phrasing to that effect. More than politeness, it would be nice if it referred to a web page that described exactly what they needed to do to correct the situation. -------------- next part -------------- A non-text attachment was scrubbed... Name: smime.p7s Type: application/pkcs7-signature Size: 6238 bytes Desc: S/MIME Cryptographic Signature URL: From jeffrey.lyon at blacklotus.net Wed Feb 29 03:45:29 2012 From: jeffrey.lyon at blacklotus.net (Jeffrey Lyon) Date: Wed, 29 Feb 2012 03:45:29 -0500 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> <6FBFA779-0ACA-48C9-82A7-4F1BFAA9A7C0@delong.com> <6A72B49C-4E38-497D-9CE5-0EEA63478289@netconsonance.com> Message-ID: I suppose Prop 165 in spirit, but not necessarily as written. Some immediate concerns: - Should be reworded to exclude anyone sellers from making "free pool" requests for an extended period of time, say 24 months - Should not be limited to IPv4 (can't see a reason for such a provision) - The current wording infers, but does not explicitly remove needs basis from the transfer. This should be made more clear. - Transferred resources should be subject to higher ARIN fees, if doing so would substantially subsidize the cost of requests made in the "free pool." Thanks, -- Jeffrey Lyon, Leadership Team jeffrey.lyon at blacklotus.net | http://www.blacklotus.net Black Lotus Communications - AS32421 First and Leading in DDoS Protection Solutions From ppml at rs.seastrom.com Wed Feb 29 08:54:33 2012 From: ppml at rs.seastrom.com (Robert E. Seastrom) Date: Wed, 29 Feb 2012 08:54:33 -0500 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: (Jeffrey Lyon's message of "Wed, 29 Feb 2012 03:45:29 -0500") References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> <6FBFA779-0ACA-48C9-82A7-4F1BFAA9A7C0@delong.com> <6A72B49C-4E38-497D-9CE5-0EEA63478289@netconsonance.com> Message-ID: <861updwxra.fsf@seastrom.com> Jeffrey Lyon writes: > I suppose Prop 165 in spirit, but not necessarily as written. Some > immediate concerns: I gather that "suppose" is half support half oppose? Thx, -r From jeffrey.lyon at blacklotus.net Wed Feb 29 08:59:07 2012 From: jeffrey.lyon at blacklotus.net (Jeffrey Lyon) Date: Wed, 29 Feb 2012 08:59:07 -0500 Subject: [arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification In-Reply-To: <861updwxra.fsf@seastrom.com> References: <90100EA6-CA1C-4F38-9D4A-AF6CC1C661C1@corp.arin.net> <85F403CE-6828-4D10-BB4B-3345929DAD80@eyeconomics.com> <2A1E9EA1-7D44-4A3E-87AB-A86EAB2FFAA6@eyeconomics.com> <6FBFA779-0ACA-48C9-82A7-4F1BFAA9A7C0@delong.com> <6A72B49C-4E38-497D-9CE5-0EEA63478289@netconsonance.com> <861updwxra.fsf@seastrom.com> Message-ID: On Feb 29, 2012 8:55 AM, "Robert E. Seastrom" wrote: > > > Jeffrey Lyon writes: > > > I suppose Prop 165 in spirit, but not necessarily as written. Some > > immediate concerns: > > I gather that "suppose" is half support half oppose? > > Thx, > > -r > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. Its what "support" looks like at 3am before I've had any Monster :) Thanks, Jeff -------------- next part -------------- An HTML attachment was scrubbed... URL: From kkargel at polartel.com Wed Feb 29 11:18:27 2012 From: kkargel at polartel.com (Kevin Kargel) Date: Wed, 29 Feb 2012 10:18:27 -0600 Subject: [arin-ppml] 2011-7 Status FAIL In-Reply-To: References: Message-ID: <8695009A81378E48879980039EEDAD28011E05E435@MAIL1.polartel.local> _____ From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of Scott Leibrand Sent: Tuesday, February 28, 2012 7:56 PM To: William Herrin Cc: arin-ppml at arin.net List Subject: Re: [arin-ppml] 2011-7 Status FAIL On Tue, Feb 28, 2012 at 5:21 PM, William Herrin wrote: On Tue, Feb 28, 2012 at 6:38 PM, Chris Grundemann wrote: > FYI: The intent of adding the reverse DNS hook was twofold. First, as > you very correctly observe, it should help grab attention when needed > as an intermediate step before revoking resources, kind of a last > chance mechanism. The other intent is to grab attention when > revocation is too extreme, such as a failure to register downstream > delegations in WHOIS. As a community, we have identified time and > again the need for an accurate WHOIS. This "penny ante" mechanism may > help ARIN to ensure that the WHOIS database is as accurate and > complete as possible. Hi Chris, I can't think of a single hypothetical case in which revocation is too extreme but canceling RDNS is an appropriate punishment. WHOIS isn't up to snuff? Not taking ARIN's complaints seriously? Issue a revocation with the policy 6-months to renumber out of the block. If WHOIS magically improves and they pay ARIN's auditing costs so that the rest of us don't get burned by the bad behavior, then clearly there's no further need to complete the revocation. I'm okay with RDNS revocation as a last ditch "we couldn't get in touch with you any other way" measure, but that use isn't punitive. As a punitive measure, RDNS revocation is, frankly, beneath ARIN's dignity. Not sure if a non-profit has dignity, but otherwise I would tend to agree with Bill here. I'm uncomfortable *requiring* ARIN to stop providing reverse DNS services. If we want to give ARIN permission to do so, fine. (I don't think they'll abuse that tool, or even use it much.) But I'm still unconvinced that requiring them to do so serves any useful purpose. [kjk] To my way of thinking, it is a no-op to include policy "may" in absence of a "may-not". Without policy preventing ARIN from modifying or removing RDNS they already "may" do so. Specifically allowing something that is not prohibited is just fluff. So I'm fine with "If an organization fails to respond within thirty (30) days, ARIN may cease providing reverse DNS services to that organization." But I would strike "If progress of resource returns or record corrections has not occurred within sixty (60) days after ARIN initiated contact, ARIN shall cease providing reverse DNS services for the resources in question." It's also worth noting that I support the new 12.4 language, adding "update reassignment information or" so it reads "Organizations found by ARIN to be out of compliance with current ARIN policy shall be required to update reassignment information or return resources as needed to bring them into (or reasonably close to) compliance." -Scott -------------- next part -------------- An HTML attachment was scrubbed... URL: -------------- next part -------------- A non-text attachment was scrubbed... Name: smime.p7s Type: application/x-pkcs7-signature Size: 4935 bytes Desc: not available URL: From jeffrey.lyon at blacklotus.net Wed Feb 29 11:39:57 2012 From: jeffrey.lyon at blacklotus.net (Jeffrey Lyon) Date: Wed, 29 Feb 2012 11:39:57 -0500 Subject: [arin-ppml] 2011-7 Status FAIL In-Reply-To: <8695009A81378E48879980039EEDAD28011E05E435@MAIL1.polartel.local> References: <8695009A81378E48879980039EEDAD28011E05E435@MAIL1.polartel.local> Message-ID: On Feb 29, 2012 11:17 AM, "Kevin Kargel" wrote: > > > > > > > > ________________________________ > > From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of Scott Leibrand > Sent: Tuesday, February 28, 2012 7:56 PM > To: William Herrin > Cc: arin-ppml at arin.net List > > Subject: Re: [arin-ppml] 2011-7 Status FAIL > > > > On Tue, Feb 28, 2012 at 5:21 PM, William Herrin wrote: > > On Tue, Feb 28, 2012 at 6:38 PM, Chris Grundemann wrote: > > FYI: The intent of adding the reverse DNS hook was twofold. First, as > > you very correctly observe, it should help grab attention when needed > > as an intermediate step before revoking resources, kind of a last > > chance mechanism. The other intent is to grab attention when > > revocation is too extreme, such as a failure to register downstream > > delegations in WHOIS. As a community, we have identified time and > > again the need for an accurate WHOIS. This "penny ante" mechanism may > > help ARIN to ensure that the WHOIS database is as accurate and > > complete as possible. > > Hi Chris, > > I can't think of a single hypothetical case in which revocation is too > extreme but canceling RDNS is an appropriate punishment. > > WHOIS isn't up to snuff? Not taking ARIN's complaints seriously? Issue > a revocation with the policy 6-months to renumber out of the block. If > WHOIS magically improves and they pay ARIN's auditing costs so that > the rest of us don't get burned by the bad behavior, then clearly > there's no further need to complete the revocation. > > I'm okay with RDNS revocation as a last ditch "we couldn't get in > touch with you any other way" measure, but that use isn't punitive. As > a punitive measure, RDNS revocation is, frankly, beneath ARIN's > dignity. > > > > Not sure if a non-profit has dignity, but otherwise I would tend to agree with Bill here. I'm uncomfortable *requiring* ARIN to stop providing reverse DNS services. If we want to give ARIN permission to do so, fine. (I don't think they'll abuse that tool, or even use it much.) But I'm still unconvinced that requiring them to do so serves any useful purpose. > > [kjk] To my way of thinking, it is a no-op to include policy ?may? in absence of a ?may-not?. Without policy preventing ARIN from modifying or removing RDNS they already ?may? do so. Specifically allowing something that is not prohibited is just fluff. > > > > So I'm fine with "If an organization fails to respond within thirty (30) days, ARIN may cease providing reverse DNS services to that organization." But I would strike "If progress of resource returns or record corrections has not occurred within sixty (60) days after ARIN initiated contact, ARIN shall cease providing reverse DNS services for the resources in question." > > > > It's also worth noting that I support the new 12.4 language, adding "update reassignment information or" so it reads "Organizations found by ARIN to be out of compliance with current ARIN policy shall be required to update reassignment information or return resources as needed to bring them into (or reasonably close to) compliance." > > > > -Scott > > > _______________________________________________ > PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-ppml > Please contact info at arin.net if you experience any issues. I do not believe ARIN needs to take any action beyond a notice of noncompliance, and then making that listing public, thereby allowing the rest of us to decide how to use that information. Jeff -------------- next part -------------- An HTML attachment was scrubbed... URL: From info at arin.net Wed Feb 29 22:37:17 2012 From: info at arin.net (ARIN) Date: Wed, 29 Feb 2012 22:37:17 -0500 Subject: [arin-ppml] Advisory Council Meeting Results - February 2012 In-Reply-To: <4F4571B6.90504@arin.net> References: <4F4571B6.90504@arin.net> Message-ID: <4F4EEEED.9040306@arin.net> > The AC abandoned proposals 161, 163 and 164. The AC is advancing draft > policy text for proposals 151 and 159 that differs from the original > proposal texts. Anyone dissatisfied with these decisions may initiate > a petition. The petition to advance these proposals is the "Discussion > Petition." The deadline to begin a petition will be five business days > after the AC's draft meeting minutes are published. The minutes of the AC's 16 February 2012 meeting have been published and are available at: https://www.arin.net/about_us/ac/index.html The deadline to begin petitions for proposals 161, 151, and 159 is 7 March 2012 (there are already petitions underway for proposals 163 and 164). Draft Policy and Policy Proposal texts are available at: https://www.arin.net/policy/proposals/index.html Regards, Communications and Member Services American Registry for Internet Numbers (ARIN) On 2/22/12 5:52 PM, ARIN wrote: > In accordance with the ARIN Policy Development Process, the ARIN > Advisory Council (AC) held a meeting on 16 February 2012 and made > decisions about several proposals. > > The AC selected the following proposals as draft policies for adoption > discussion online and at the ARIN XXIX Public Policy Meeting in > Vancouver in April. The draft policies will be posted shortly to the > PPML. > > ARIN-prop-151 Limiting needs requirements for IPv4 Transfers > ARIN-prop-159 IPv6 Subsequent Allocations Utilization Requirement > > The AC abandoned the following proposals: > > ARIN-prop-161 Normalize Free pool and Transfer justification periods > ARIN-prop-163 Dedicated resources for initial ISP allocations > ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion > > The AC stated the following about proposal 161, "Based on similarities > between proposals 161 and 162 combined with the greater support of 162 > on PPML, the AC decided to abandon 161 and focus on development of 162." > > Regarding proposal 163, the AC stated, "Based on a lack of significant > support or extenuating circumstances that would require the creation > of a specially designated class of v4 address space within the ARIN > region, the AC chose to abandon proposal 163. Without a compelling > inequity present, it's difficult to make a case for carve-outs of any > kind other than for critical infrastructure. The community has > underscored this with significant expressions of support for fewer v4 > initiatives and more focus on transition." > > And regarding proposal 164, the AC said, "Due to a lack of support and > strong opposition among the community on PPML, the AC abandoned > proposal 164." > > The AC thanks the authors and the community for their continuing effort > and contributions to these and all other policy considerations. > > The AC abandoned proposals 161, 163 and 164. The AC is advancing draft > policy text for proposals 151 and 159 that differs from the original > proposal texts. Anyone dissatisfied with these decisions may initiate > a petition. The petition to advance these proposals is the "Discussion > Petition." The deadline to begin a petition will be five business days > after the AC's draft meeting minutes are published. > > For more information on starting and participating in petitions, see > PDP Petitions at: > https://www.arin.net/policy/pdp_petitions.html > > Draft Policy and Proposal texts are available at: > https://www.arin.net/policy/proposals/index.html > > The ARIN Policy Development Process can be found at: > https://www.arin.net/policy/pdp.html > > Regards, > > Communications and Member Services > American Registry for Internet Numbers (ARIN) From info at arin.net Wed Feb 29 22:38:41 2012 From: info at arin.net (ARIN) Date: Wed, 29 Feb 2012 22:38:41 -0500 Subject: [arin-ppml] Petition for Discussion of ARIN-prop-164 In-Reply-To: <4F46ABF8.80206@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F46ABF8.80206@arin.net> Message-ID: <4F4EEF41.5000908@arin.net> > The duration of the petition is until five business days after the AC's > draft meeting minutes are published. ARIN staff will post the result of > the petition to PPML. The minutes of the AC's 16 February 2012 meeting have been published and are available at: https://www.arin.net/about_us/ac/index.html This petition will end on 7 March 2012. Regards, Communications and Member Services American Registry for Internet Numbers (ARIN) On 2/23/12 4:13 PM, ARIN wrote: > The message below started a petition regarding the ARIN Advisory > Council's decision to abandon ARIN-prop-164. The AC's decision was > posted by ARIN staff to PPML on 22 February 2012. > > If successful, this petition will change ARIN-prop-164 into a Draft > Policy which will be published for adoption discussion on the PPML and > at the Public Policy Meeting in April 2012. If the petition fails, the > proposal will be closed. > > For this petition to be successful, the petition needs statements of > support from at least 10 different people from 10 different > organizations. If you wish to support this petition, post a statement of > support to PPML on this thread. > > The duration of the petition is until five business days after the AC's > draft meeting minutes are published. ARIN staff will post the result of > the petition to PPML. > > For more information on starting and participating in petitions, see PDP > Petitions at: > https://www.arin.net/policy/pdp_petitions.html > > The proposal text is below and at: > https://www.arin.net/policy/proposals/index.html > > The ARIN Policy Development Process can be found at: > https://www.arin.net/policy/pdp.html > > Regards, > > Communications and Member Services > American Registry for Internet Numbers (ARIN) > > > ##### > > >> -----Original Message----- >> From: Joe Maimon >> Date: Wed, 22 Feb 2012 23:47:12 -0500 >> To: "ppml >> \"ppml at arin.net\"" >> Subject: [arin-ppml] Petition for advancement of Policy Proposal #164 >> Predictable ARIN IPv4 Resource exhaustion, to Draft Policy status >> >> All, >> >> I am unsatisfied with the AC's abandonment of Policy Proposal #164 >> Predictable ARIN IPv4 Resource exhaustion. >> >> I formally petition you, the members of this regional community, for >> your support in advancing to draft policy status the proposal and for it >> to be discussed at an upcoming ARIN Public Policy meeting. >> >> I ask you for statements in support of this petition. >> >> The full policy proposal text is available at >> >> http://lists.arin.net/pipermail/arin-ppml/2012-February/024055.html >> >> Best and my thanks, >> >> Joe >> >> >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. > > ARIN-prop-164 Predictable ARIN IPv4 Resource exhaustion > > Proposal Originator: Joe Maimon > > Proposal Version: 1.0 > > Date: 1 February 2012 > > Proposal type: New > > Policy term: Temporary > > Policy statement: > > Add a section to 4 > > Upon the last calendar date of the year that this proposal is adopted, > ARIN will disburse all of its available IPv4 resources to its existing > members, in proportion to their fee schedule, with the smallest > allocation of size /24, to be effective immediately. > > Rationale: > > Many people feel that ARIN has too much available resources. Many people > also believe that the uncertainty as to when ARIN will run out of these > resources is not good. This proposal seeks to resolve both of these > concerns. > > Timetable for implementation: Immediate > > > From info at arin.net Wed Feb 29 22:39:17 2012 From: info at arin.net (ARIN) Date: Wed, 29 Feb 2012 22:39:17 -0500 Subject: [arin-ppml] Petition for Discussion of ARIN-prop-163 In-Reply-To: <4F46AC77.8060206@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F46AC77.8060206@arin.net> Message-ID: <4F4EEF65.9070902@arin.net> > The duration of the petition is until five business days after the AC's > draft meeting minutes are published. ARIN staff will post the result of > the petition to PPML. The minutes of the AC's 16 February 2012 meeting have been published and are available at: https://www.arin.net/about_us/ac/index.html This petition will end on 7 March 2012. Regards, Communications and Member Services American Registry for Internet Numbers (ARIN) On 2/23/12 4:15 PM, ARIN wrote: > The message below started a petition regarding the ARIN Advisory > Council's decision to abandon ARIN-prop-163. The AC's decision was > posted by ARIN staff to PPML on 22 February 2012. > > If successful, this petition will change ARIN-prop-163 into a Draft > Policy which will be published for adoption discussion on the PPML and > at the Public Policy Meeting in April 2012. If the petition fails, the > proposal will be closed. > > For this petition to be successful, the petition needs statements of > support from at least 10 different people from 10 different > organizations. If you wish to support this petition, post a statement of > support to PPML on this thread. > > The duration of the petition is until five business days after the AC's > draft meeting minutes are published. ARIN staff will post the result of > the petition to PPML. > > For more information on starting and participating in petitions, see PDP > Petitions at: > https://www.arin.net/policy/pdp_petitions.html > > The proposal text is below and at: > https://www.arin.net/policy/proposals/index.html > > The ARIN Policy Development Process can be found at: > https://www.arin.net/policy/pdp.html > > Regards, > > Communications and Member Services > American Registry for Internet Numbers (ARIN) > > > ##### > > >> -----Original Message----- >> From: Joe Maimon >> Date: Wed, 22 Feb 2012 23:47:10 -0500 >> To: "ppml >> \"ppml at arin.net\"" >> Subject: [arin-ppml] Petition for advancement of Policy Proposal #163 >> Dedicated resources for initial ISP allocations, to Draft Policy status >> >> All, >> >> I am unsatisfied with the AC's abandonment of Policy Proposal #163 >> Dedicated resources for initial ISP allocations. >> >> I formally petition you, the members of this regional community, for >> your support in advancing to draft policy status the proposal and for it >> to be discussed at an upcoming ARIN Public Policy meeting. >> >> I ask you for statements in support of this petition. >> >> The full policy proposal text is available at >> >> http://lists.arin.net/pipermail/arin-ppml/2012-February/024054.html >> >> Best and my thanks, >> >> Joe >> >> >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact info at arin.net if you experience any issues. > > > ARIN-prop-163 Dedicated resources for initial ISP allocations > > Proposal Originator: Joe Maimon > > Proposal Version: 1.0 > > Date: 1 February 2012 > > Proposal type: New > > Policy term: Temporary > > Policy statement: > > Add > > 4.2.2.4. Resources dedicated for initial ISP allocations. > > Prior to any allocation or assignment that will cause ARIN's total > available, unreserved and non-dedicated resources to fall under a total > of a /8, ARIN will first ensure that dedicated resources equivalent to a > /10 are available from the remainder of the available resources. These > resources are to be used solely for initial ISP allocations that cannot > be fulfilled from any other available ARIN resources. > > 4.2.2.4.1 Restrictions > > ARIN may require qualifying organizations to demonstrate that they were > not created solely to receive resources from these dedicated resources. > > 4.2.2.4.2 Replenishment > > ARIN will replenish the available dedicated resources, up to the total > of a /10 of available resources, whenever there are sufficient available > resources, with no more than 25% of the available resources going for > this purpose. > > 4.2.2.4.3 Reporting > > ARIN will keep numbers and statistics available as to the total size of > the dedicated resources, allocated and unallocated and to how many > members allocations were made, available annually. > > 4.2.2.4.4 Retirement > > ARIN will retire this section whenever two full calendar years go by > that no allocations are made from these resources, following their > creation. > > Rationale: > > I believe it is important to ensure access to new entities to the IPv4 > resources ARIN maintains stewardship over. Without a policy like this > one, they are unlikely to have any alternative other then to use PA > space or utilize transfers that may be prohibitively burdensome. > > I also believe it is important to ARIN to be an essential and relevant > entity to the process of getting these new ISP's to their footing with > IPv4 resources. > > ARIN informal numbers: > > Total first time IPv4 allocations to ISPs approved in 2011: 318 > Total IPv4 space approved for: 2,812 /24s > > Total additional IPv4 allocations to ISPs in 2011: 497 ISP accounts > received at least one additional IPv4 allocation. > Total IPv4 space approved for: 70,569 /24s > > This suggests that maintaining resources for these new ISPs can ensure a > steady influx of new members who would otherwise have much more limited > options, and that a /10 can provide an estimated 4 years of access to > these resources. > > This same /10 would last for additional allocations less than a year. > > Timetable for implementation: Before ARIN has less than a /8 in > its free pool. > > From bill at herrin.us Wed Feb 29 23:04:12 2012 From: bill at herrin.us (William Herrin) Date: Wed, 29 Feb 2012 23:04:12 -0500 Subject: [arin-ppml] Petition for Discussion of ARIN-prop-163 In-Reply-To: <4F46AC77.8060206@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F46AC77.8060206@arin.net> Message-ID: On Thu, Feb 23, 2012 at 4:15 PM, ARIN wrote: > The message below started a petition regarding the ARIN Advisory > Council's decision to abandon ARIN-prop-163. The AC's decision was > posted by ARIN staff to PPML on 22 February 2012. As the AC has not shown cause why proposal 163 should not be considered by the wider community, I SUPPORT the petition to advance it to formal discussion. Regards, Bill Herrin -- William D. Herrin ................ herrin at dirtside.com? bill at herrin.us 3005 Crane Dr. ...................... Web: Falls Church, VA 22042-3004 From bill at herrin.us Wed Feb 29 23:14:44 2012 From: bill at herrin.us (William Herrin) Date: Wed, 29 Feb 2012 23:14:44 -0500 Subject: [arin-ppml] Petition for Discussion of ARIN-prop-164 In-Reply-To: <4F46ABF8.80206@arin.net> References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F46ABF8.80206@arin.net> Message-ID: On Thu, Feb 23, 2012 at 4:13 PM, ARIN wrote: > The message below started a petition regarding the ARIN Advisory > Council's decision to abandon ARIN-prop-164. The AC's decision was > posted by ARIN staff to PPML on 22 February 2012. > > Add a section to 4 > > Upon the last calendar date of the year that this proposal is adopted, > ARIN will disburse all of its available IPv4 resources to its existing > members, in proportion to their fee schedule, with the smallest > allocation of size /24, to be effective immediately. Joe, With due respect, this is not a serious proposal. This is an "Oh, so that's the way you want to play it" response to someone who upset you. If there's something worth discussing, it's whatever it is that angered you in the first place. Not this proposal. Regards, Bill Herrin -- William D. Herrin ................ herrin at dirtside.com? bill at herrin.us 3005 Crane Dr. ...................... Web: Falls Church, VA 22042-3004 From jmaimon at chl.com Wed Feb 29 23:27:47 2012 From: jmaimon at chl.com (Joe Maimon) Date: Wed, 29 Feb 2012 23:27:47 -0500 Subject: [arin-ppml] Petition for Discussion of ARIN-prop-164 In-Reply-To: References: <8A5E1973-DD08-436E-8D5F-F79F28197DFA@delong.com> <4F46ABF8.80206@arin.net> Message-ID: <4F4EFAC3.8080907@chl.com> William Herrin wrote: > > Joe, > > With due respect, this is not a serious proposal. This is an "Oh, so > that's the way you want to play it" response to someone who upset you. > If there's something worth discussing, it's whatever it is that > angered you in the first place. Not this proposal. > > Regards, > Bill Herrin > > Bill, Consider this proposal in light of the other active proposal with both having the same result, the ARIN free pool exhausted within a year or so. Joe