[ARIN-consult] Consultation – Transfer Listing Service

James Hess mysidia at gmail.com
Tue May 11 02:25:47 EDT 2010

On Wed, Apr 21, 2010 at 11:41 AM, Member Services <info at arin.net> 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

> 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

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

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