From sleibrand at internap.com Mon May 10 15:30:52 2010 From: sleibrand at internap.com (Scott Leibrand) Date: Mon, 10 May 2010 12:30:52 -0700 Subject: [ARIN-consult] =?windows-1252?q?Consultation_=96_Transfer_Listing?= =?windows-1252?q?_Service?= In-Reply-To: <4BCF2AAA.40905@arin.net> References: <4BCF2AAA.40905@arin.net> Message-ID: <4BE85EEC.9080508@internap.com> On Wed 4/21/2010 9:41 AM, Member Services wrote: > ARIN is seeking community input regarding the implementation of a > Transfer Listing Service for parties with documented need who are > seeking IPv4 address space and parties who are authorized resource > holders that may potentially be able to make IPv4 number resource > available for transfer. The Transfer Listing Service is proposed to > facilitate the implementation of Section 8.3 of the Number Resource > Policy Manual (NRPM), entitled ?Transfers to Specified Recipients?, > which allows a party to designate transfer of IPv4 number resources to a > specified qualified recipient. Thanks. I think this will help ensure that the transfer market enabled by NRPM 8.3 operates smoothly. > The proposed Transfer Listing Service is located at > www.arin.net/resources/transfer_listing.html. It is a hypothetical model > to generate discussion; ARIN is specifically interested in receiving > feedback on the following: > > 1. How long should ARIN offer a Transfer Listing Service and what, if > any, conditions should be tied to its availability? IMO the transfer listing service should be provided as long as it is needed. Once usage of the service drops off, or once the IPv4 free pool starts getting enough returns to clear out the waiting list, then the transfer listing service can be retired. > 2. As proposed, there is a usage agreement for participation. Is this a > fair and reasonable requirement? As long as this is an acceptable usage policy that is simply posted alongside the data, that should be fine. I would be reluctant to have any sort of agreement that has to be signed before someone can view the data. > 3. Under what conditions should ARIN disallow or remove either an > organization listing or seeking IPv4 address space from the service? For > example, if an organization has a Registration Services Agreement > (?RSA?) with ARIN and is not current on payments with ARIN, should they > be allowed to participate? I believe it would be entirely appropriate for ARIN to restrict participation to organizations in good standing, and temporarily remove listings from organizations that fall behind on payments owed. > 4. Should there be a fee associated with the Transfer Listing Service? > If so, on what factors should the fee be based? IMO, if there are any fees associated with transfers, they should be based on the actual 8.3 transfer transaction, and should be no higher than the fee associated with obtaining the same size addresses block from the ARIN free pool. There should be no fees for use of the transfer listing service above and beyond any fee on 8.3 transfers generally. > 5. Are there any other factors that ARIN should consider in providing > this service? The transfer listing service should be usable both by individual users seeking to contact a party to arrange a transaction directly, and by brokers, web sites, and other third parties seeking to verify the eligibility of potential transferors and transferees. Thanks again, Scott > > A Transfer Listing Service will begin operation as soon as possible > after the successful completion of this community consultation. > > Comments regarding this proposed Transfer Listing Service can be > submitted through the ARIN Consultation and Suggestion Process, > available at: https://www.arin.net/participate/acsp/index.html > > Discussion on arin-consult at arin.net will close on 21 May 2010, at noon EDT. > > ARIN welcomes community-wide participation. Please address any process > questions to info at arin.net. > > Regards, > > > Member Services > American Registry for Internet Numbers > > > > _______________________________________________ > ARIN-Consult > You are receiving this message because you are subscribed to the ARIN > Consult Mailing > List (ARIN-consult at arin.net). > Unsubscribe or manage your mailing list subscription at: > http://lists.arin.net/mailman/listinfo/arin-consult Please contact the > ARIN Member Services > Help Desk at info at arin.net if you experience any issues. From mysidia at gmail.com Tue May 11 02:25:47 2010 From: mysidia at gmail.com (James Hess) Date: Tue, 11 May 2010 01:25:47 -0500 Subject: [ARIN-consult] =?windows-1252?q?Consultation_=96_Transfer_Listing?= =?windows-1252?q?_Service?= In-Reply-To: <4BCF2AA0.90709@arin.net> References: <4BCF2AA0.90709@arin.net> Message-ID: On Wed, Apr 21, 2010 at 11:41 AM, Member Services wrote: > 1. How long should ARIN offer a Transfer Listing Service and what, if any, > conditions should be tied to its availability? The condition tied to its availability should be the usefulness of the service. The service should end some duration after ARIN has allocated its final /8 there are few or no active listings, and few or no changes to the active listings. > 2. As proposed, there is a usage agreement for participation. Is this a fair > and reasonable requirement? This is a reasonable requirement. > 3. Under what conditions should ARIN disallow or remove either an > organization listing or seeking IPv4 address space from the service? For > example, if an organization has a Registration Services Agreement > (?RSA?) with ARIN and is not current on payments with ARIN, should they >be allowed to participate? Of course ARIN needs to protect itself, and ensure it can recover its costs. I would suggest they should not be allowed to participate. As a condition for using the listing service, if they are not in good standing, not current on membership fees, then any payments made to ARIN be applied first to the unpaid dues or maintenance fees. Before they can be applied to fees for new allocations, transfers, or listing service. > 4. Should there be a fee associated with the Transfer Listing Service? > If so, on what factors should the fee be based? It would cost ARIN something to run a listing service, and maintain listings, so there should be a fee, for submitting data to the listing service. Also.. in order to discourage organizations from abandoning their listing, creating frivolous listings, or using the listing service to facilitate 'backdoor' channels for unofficially transferring addresses -- (not reporting the transfer or showing it in WHOIS, and avoiding any applicable ARIN transfer fee, using internal contracts to effect de-facto transfer). Any fees should be reasonable, or the listing service would simply not be used. At least once a year, the organization responsible for the listing should need to contact ARIN, or the listing should expire and be dropped. There should be a requirement for that annual review of each listing, otherwise, there will eventually be poorly-maintained listings that are obsolete but never get removed. I would suggest the fee requirement should be on the order of $100/year to pre-paid to maintain a listing in the service. Or a deposit in some percentage of ARIN transfer fees, to actually be refunded (if the listing is cancelled), or cover part of transfer fee, if the listing results in transfer. Or with the listing fee waived for any paid ARIN member in good standing, any organization who pays a larger amount in annual maintenance fees, or anyone obtaining IP addresses under the transfer policy and pays transfer fees during that year above the amount. > 5. Are there any other factors that ARIN should consider in providing this > service? ARIN should consider that given a transfer listing service, after ARIN can no longer meet IP address assignment requests, there are likely to be a large number of resource requestors in a transfer listing service, and possibly scant IP resources for anyone to actually offer. Primarily legacy and other holders, who will free up IP addresses, when they find the market value of their IP addresses seems to exceed their cost to renumber in order to make blocks available for transfer. Since payment of a fee is one of the most likely reasons for a legacy IP holder to be convinced to transfer IPs. ARIN might want to consider specifically ordering or prioritizing requests in some way; such as: order requests were received in, utilization criteria / degree of need, and BID in $ offer per IP. With listing fee varying commesurate (in some way) to the reported need. And hopefully the sum of any fees collected from IPv4 transfer listing or tarnsfer process, would eventually help to reduce fees for new IPv6 address allocations.... -- -J Hess From mueller at syr.edu Tue May 11 20:59:24 2010 From: mueller at syr.edu (Milton L Mueller) Date: Tue, 11 May 2010 20:59:24 -0400 Subject: [ARIN-consult] Comments of the Internet Governance Project Message-ID: <75822E125BCB994F8446858C4B19F0D701DC22790F@SUEX07-MBX-04.ad.syr.edu> Comments of the Internet Governance Project (IGP) on the proposed Transfer Listing Service ARIN is to be commended for making this first attempt to implement a Transfer Listing Service (TLS). In effect, ARIN is setting up a market intermediary or exchange. In our view, ARIN should strive to make this market as liquid, open, efficient and responsive to supply and demand as possible. General comments To design it correctly, ARIN must have a clear understanding of two things: the purpose of the Transfer Listing Service (TLS) and its own role in the transfer process. Regarding the TLS's purpose, in our view the design should be based on the following premises: * There will be legitimate needs for IPv4 addresses well beyond the exhaustion of the free pool * Prolonged scarcity of ipv4 addresses means that there must be a mechanism to move ipv4 resources from lower-value to higher-value uses; * It is vital to retain ARIN's function as a comprehensive and accurate address registry, and transfers that take place without its knowledge or recordkeeping risk undermining this function; * It is more important to get parties who hold address blocks they don't really need to release them for others to use than it is to ascertain whether these parties actually needed the block they currently hold, or whether they are signatories to ARIN contracts. Those receiving resources can be brought into the contractual regime; it is less important whether those releasing resources meet rigid guidelines. (Obviously, sales of hijacked or illegitimately claimed resources must be screened out.) Regarding ARIN's role, what ARIN calls a "Transfer listing service" implies four conceptually distinct functions: 1. Verification of who is a legitimate offerer of ipv4 address assets and verification, through "needs assessment," of who is a qualified seeker or bidder. 2. A listing process which publicly identifies seekers (bidders) and offerers (askers) of ipv4 address assets; 3. A process for matching of bid/ask prices; 4. A clearing house which formally registers the transaction once verifying that appropriate payments are made (including any transaction or listing fees imposed by ARIN), and officially alters the title to the resources. In our view, ARIN only needs to do #1 and #4. Our understanding of the proposed TLS is that ARIN has devoted most of its attention to the first and second functions, has completely ignored the third function, and has not fully thought through its approach to the fourth function. Ideally, ARIN policy should foster an efficient and decentralized market in which its role is restricted to authenticating legitimate sellers and transferring titles to legitimate buyers once transactions are concluded. In this view, the second and third functions could emerge in the market based on authoritative information supplied by ARIN. However, setting in place the infrastructure for a more robust and competitive exchange system could be more complicated than a more closed and monopolistic system. Due to the need for immediate action, it is important to get the TLS up and running in a simpler form and consider ways to improve it in the second and third iterations. ARIN needs to specify whether the listing service will list asking price (we think it should) and whether seekers can also specify their initial bid price (we think they should be able to). The market will be more efficient and prices for seekers will be lower if this information is public. Askers and bidders should be able to modify their listed ask/bid price easily and quickly. ARIN should publish the clearing price of address resources, both to facilitate research and assessment of the transfer policy and to aid industry planning and operations. (Organizations that may not yet need addresses but think they might in the future have a legitimate interest in access to information about the volume, price and specific blocks traded.) Questions posed by the Consultation: 1. How long should ARIN offer a Transfer Listing Service and what, if any, conditions should be tied to its availability? ARIN should maintain the TLS indefinitely. The listing service should be offered as long as ipv4 addresses are in use and for the duration of a full transition to ipv6. Because no one knows when ipv6 will completely supplant ipv4 it is unwise to set an arbitrary time limit on the TLS. ARIN should, however, periodically reconsider the design of the TLS. ARIN might commit itself to a review of the service design every 18 months or so. 2. As proposed, there is a usage agreement for participation. Is this a fair and reasonable requirement? As (vaguely) described in the consultation, the usage agreement specifies that parties can only participate in the TLS "for the purposes of meeting the requirements of the Transfer Listing Service participants." We don't know for sure what this means. If it is simply an anti-spam agreement, we have no objections, although misbehavior of that sort might already be covered by existing laws. If it is an attempt to strongly restrict who can look at listings of seekers and offerers, for example by limiting access to parties who actually hold address resources or who have contracts or "demonstrated need," we think it is a bad idea. Listing information should be public if it is to serve its primary function of facilitating transfers among parties. Transparency and liquidity go hand in hand. Brokers and intermediaries who could facilitate the effective functioning of the transfer market would have a legitimate interest in access to the information, as well as academic and industry researchers. Once the information is public, ARIN is not in a very strong position to control subsequent "uses" of the information, which could be compiled, stored, exchanged and analyzed by anyone who possessed it. Thus, we question the need for such an agreement. 3. Under what conditions should ARIN disallow or remove either an organization listing or seeking IPv4 address space from the service? For example, if an organization has a Registration Services Agreement ("RSA") with ARIN and is not current on payments with ARIN, should they be allowed to participate? ARIN must clearly define its priorities with respect to the proposed listing service. In our view, the most vital purpose is to facilitate the movement of resources from parties with unneeded or larger-than-needed assignments to those with too few address resources. An equally vital function is to preempt the development of underground trading of address resources. Those two purposes should take priority over all others. ARIN can and should insist that those receiving resources under the policy (successful bidders) be under an RSA and able to demonstrate technical requirements or "need" for them. But ARIN should be much more liberal about regulating legitimate address block holders who are willing to release resources through the listing service. The movement of resources from legacy, non-contracting parties to contracting, fee-paying parties benefits both ARIN and, presumably, the public by bringing them under a consistent policy regime. ARIN should do everything it can to encourage participation by legacy holders and remove all obstacles to their participation. While obviously ARIN should not allow hijacked or illegitimately identified resources to be transferred, the listing service should not be confused with some kind of tool for retroactive punishment of past overconsumption, or as a way to coerce organizations into signing RSAs. Such an approach would simply discourage participation and undermine the net benefits that could be gained from efficiency-enhancing transfers. Attempting to leverage the listing service to achieve unrelated objectives produces no corresponding benefits, as parties could simply avoid it. With respect to unpaid ARIN fees, it makes no sense to bar an organization from participation in the transfer market on that basis - but it would be justifiable to make the final settlement and re-registration of the address resources contingent upon the back payments. Buyer payments to the seller could be tapped for this purpose during the settlement stage. 4. Should there be a fee associated with the Transfer Listing Service? If so, on what factors should the fee be based? ARIN's primary purpose is to facilitate liquidity and the matching of supply and demand for v4 addresses. Fee mechanisms and fee levels that discourage participation in the listing service should be avoided. But we have no objection to flat, simple listing fees that cover the costs of providing the service. Bear in mind that issues related to the size of fees become less difficult if and when competition enters into the picture. As noted before, TLS designs that allow competing third parties to operate exchanges should be explored going forward. 5. Are there any other factors that ARIN should consider in providing this service? * How will the success or failure of a particular TLS design be assessed? * Will it be possible for third parties/consultants or other intermediaries to provide gateways into the ARIN listing service? Milton Mueller Brenden Kuerbis Lee McKnight Michel van Eeten (IGP) -------------- next part -------------- An HTML attachment was scrubbed... URL: From info at arin.net Fri May 21 16:38:41 2010 From: info at arin.net (Member Services) Date: Fri, 21 May 2010 16:38:41 -0400 Subject: [ARIN-consult] Consultation Closed: Transfer Listing Service Message-ID: <4BF6EF51.8030902@arin.net> ARIN thanks the community for its input regarding the implementation of a Transfer Listing Service. ARIN will be reviewing the input received over the next ten days and will provide a final message to the community at that time with any changes resulting from the consultation. The archives of this discussion are available at: http://lists.arin.net/pipermail/arin-consult/ Regards, Member Services American Registry for Internet Numbers (ARIN)