[arin-ppml] ARIN Board Statement on Transfer Policy Status and Timing

[William Herrin]

On Mon, Apr 6, 2009 at 11:25 PM, John Curran <jcurran at istaff.org> wrote:
> The differences between policy proposal 2009-1
> and policy 2008-6 are:
> 1) Policy proposal 2009-1 does not have the
> delayed timetable for implementation;

As proposed in 2009-1 I am opposed. Were it offered in the scope of a
normal policy proposal, I would likely be neutral.

I observe that a number of the supporters of 2008-6 expressed a desire
to delay implementation until the free pool was exhausted or nearly
so. They found the activation requirement  addressed their concern
enough that they could support the proposal.

> 2) It makes explicit that resources are
> returned to ARIN before being redistributed to
> the designated recipient;

This was adequately addressed in 2008-6 and did not need additional
wordsmithing. As proposed in 2009-1 I am opposed. Were it offered as a
normal policy proposal, I would not object to an adequately vetted
tightening of the language.

> 3) It eliminates the sunset clause, which,
> if retained, would introduce unpredictability
> in network planning;

Because defying the community and instigating a policy fight
introduces no uncertainty at all.

I am opposed and I believe the community lacks consensus for any
specific transfer proposal absent the sunset clause. I want to see how
it works out before it becomes a permanent part of the process, and
I'm not the only one.

> 4) It explicitly limits use of the policy to parties
> in the ARIN region, clearly ruling put interregional
> transfers, since those are an easily-separable matter
> of great additional controversy;

Nothing about the policy text in 2008-6 suggested permission for
interregional transfers. As proposed in 2009-1 I am opposed. Were it
offered as a normal policy proposal, I would not object to an
adequately vetted tightening of the language.

> 5) It refers to "number resources" rather than
> specifically IPv4 addresses, in an effort to retain
> simplicity and policy uniformity within the Number
> Resource Policy Manual; and

As proposed in 2009-1 I am opposed. Were it offered in the scope of a
normal policy proposal, I would likely be neutral.

I observe that a number of the supporters of 2008-6 listed the
restriction to IPv4 resources among the criteria that made it possible
for them to support the proposal.


> 6) It clarifies the NRPM definition of
> "organization" in a way that the Board
> considers should prevent gaming of the
> transfer policy by malefactors, a matter
> the community had expressed significant
> concern about in the discussion of policy
> proposal 2008-6.

This is not germane to a transfer policy proposal and has no business
being there. I am opposed to its presence in 2009-1. I would be
opposed to its presence in any other transfer proposal.

I question its enforceability. More often than not, information about
the ownership and control of a legal entity is privately held and
would be unavailable to ARIN absent substantial additional paperwork.
It's generally a bad idea to introduce regulation that can't be
readily enforced. It encourages scofflawism.

Before I could support a standalone proposal with this change, I would
want to see adequate plans for fairly enforcing such a policy change
without creating lots of new documentation work.


> 2) "IPv4 address resources in the
> ARIN Region reach a threshold of scarcity
>  recognized by the ARIN Board of Trustees as
> requiring this policy implementation."
> It is the judgment of the Board that the second
> criterion has already been satisfied, in light of
> a number of unfortunate conditions: the
> looming scarcity of IPv4 addresses and the
> consequent possibility of an accelerating "run
> on the bank," and the decaying accuracy of
> the WHOIS contact database as the probable
> number of unacknowledged transfers accumulate.

This is a particularly specious bit of argument.

First, neither of the listed indicators evidence a scarcity of IPv4
addresses, as the policy requires the board to find.

Second, the run on the bank is well underway and no part of proposals
2008-6 or 2009-1 promises to change that. To slow the run on the bank,
you'd need to do much more analysis of need and you'd have to
disqualify a needs that are obvious candidates for NAT. Good luck with
that. The members who attend the meetings and vote are the ones
running the bank.

Third, ARIN has long accepted properly formed update requests for
every part of the resource record except the org name. There's little
chance of the transfer proposals having more than a miniscule effect
on any part of the whois records other than the org name. Legacy
holders are going to sign an RSA just so they can fix their org names?
Now that's wishful thinking.

Regards,
Bill Herrin


-- 
William D. Herrin ................ herrin at dirtside.com  bill at herrin.us
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