[arin-ppml] Draft Policy 2009-1: Transfer Policy ? Revisedandforwarded to the Board
Scott Leibrand
scottleibrand at gmail.com
Tue May 5 19:24:19 EDT 2009
Ted,
Owen's proposal was rejected by the AC simply because the timing was
poor. If a similar proposal were to be resubmitted (by Owen or anyone
else) I would vote to accept it onto our docket, develop it into draft
policy, and have it on the agenda at the fall meeting.
-Scott
Ted Mittelstaedt wrote:
> Scott,
>
> Owen already attempted to submit a policy change to 2009-1 that
> re-instituted the sunset clause into 2009-1
> and on April 8th the AC used (IMHO) a procedural trick to abandon his
> policy submission, claiming that 2009-1
> is already reviewing whether to remove a sunset clause from the NRPM
> or not. Of course, all "reviewing" has
> come up with NOT reintroducing the sunset clause, (a foregone
> conclusion) so when 2009-1 is instituted it will
> have no sunset clause.
>
> That is very strong disincentive from the Board to use sunset
> clauses on this transfer market business.
> It is also very strong disincentive to ever again bother with
> submitting any proposals at all.
>
> Ted
>
> ------------------------------------------------------------------------
> *From:* Scott Leibrand [mailto:scottleibrand at gmail.com]
> *Sent:* Monday, May 04, 2009 2:49 PM
> *To:* Ted Mittelstaedt
> *Cc:* John Sweeting; arin ppml
> *Subject:* Re: [arin-ppml] Draft Policy 2009-1: Transfer Policy ?
> Revisedandforwarded to the Board
>
> Ted,
>
> I feel that a 3-year sunset would be bad policy given the
> immediate imlementation of 2008-6. I think 5 years, or 3 years
> after IANA exhaustion, would be appropriate, but I feel that would
> be best discussed as a normal policy proposal. Anyone is welcome
> to introduce such a policy if you think it's important. It would
> most likely be on the agenda this fall along with 2009-1.
>
> -Scott
>
> On May 4, 2009, at 2:40 PM, "Ted Mittelstaedt" <tedm at ipinc.net
> <mailto:tedm at ipinc.net>> wrote:
>
>> AC had no need to make further policy to deal with the impact
>> since 2008-6 had an
>> automatic sunset. The entire point of the sunset in 2008-6 was
>> to see what the
>> unintended consequences would be and the only way to find them
>> out was to
>> implement the policy and see what happened. I think most people
>> expected that
>> after a year or so of 2008-6 that, armed with the knowledge
>> learned from the
>> experiment, we would write a much more comprehensive policy that
>> would
>> supersede 2008-6. The sunset was a deadline that guaranteed this
>> would
>> happen.
>>
>> Ted
>>
>> ------------------------------------------------------------------------
>> *From:* arin-ppml-bounces at arin.net
>> <mailto:arin-ppml-bounces at arin.net>
>> [mailto:arin-ppml-bounces at arin.net] *On Behalf Of *John Sweeting
>> *Sent:* Monday, May 04, 2009 12:28 PM
>> *To:* Leo Bicknell; arin ppml
>> *Subject:* Re: [arin-ppml] Draft Policy 2009-1: Transfer
>> Policy ? Revisedandforwarded to the Board
>>
>> A few more bits of information. One reason that the AC moved
>> this proposal forward was that 2008-6 was already approved
>> and set to be implemented on June 1 so the issue was already
>> there. I believe it was accepted that the AC would make
>> further review and come up with a proposal that would deal
>> with this impact. Also a point to note is that this policy
>> must be recertified at the next Public Policy Meeting since
>> it went through the Emergency Policy process.
>>
>>
>> On 5/4/09 3:00 PM, "Leo Bicknell" <bicknell at ufp.org
>> <mailto:bicknell at ufp.org>> wrote:
>>
>> In a message written on Mon, May 04, 2009 at 12:21:01PM
>> -0400, Member Services wrote:
>> > The ARIN Advisory Council (AC) met on 29 April 2009 and
>> decided to send
>> > a revised version of 2009-1 to the Board for their
>> consideration:
>>
>> This policy isn't in "last-call" per se, but given the
>> PDP process
>> I feel this is the only appropriate time for me to make these
>> remarks.
>>
>> I am a member of the Advisory Council, speaking only for
>> myself.
>> During the various reviews and discussions the Advisory
>> Council
>> performs after the meeting a particular aspect of this
>> policy was
>> brought to (most of?) the AC's attention. I would like
>> to bring
>> it to the community's attention as well. I did not write
>> notes on
>> this at the time, so I am doing this from memory. If I
>> get it
>> wrong, I hope someone corrects me.
>>
>> Billy has a /16, and he's using it for dial up services
>> which is
>> not paying the bills anymore.
>>
>> Suzie wants a /16 for her hot new social networking
>> experiment.
>>
>> Billy and Suzie find each other and agree to transfer
>> Billy's /16
>> to Suzie under the result of 2008-6 + 2009-1.
>>
>> Billy goes to ARIN and says "Here's a /16, please give it
>> to Suzie."
>>
>> Suzie goes to ARIN and says, "I'm here for Billy's /16".
>> In the
>> process, ARIN checks Suzie's justification, and realizes
>> Suzie can
>> only justify a /18.
>>
>> My understanding of the current interpretation of 2008-6
>> + 2009-1
>> is that ARIN would give Suzie a /18, and keep a /18 and
>> /17 in the
>> free pool.
>>
>> Billy has given up his /16, and Suzie only got a /18 of it.
>>
>> This ends up being an artifact of the legal requirement
>> that transfers
>> must occur through ARIN. My own personal view on how
>> this would
>> work prior to finding this out was if Suzie couldn't
>> receive Billy's
>> /16 for any reason, Billy would retain the /16. Thus my
>> surprise,
>> and I'm wondering if this isn't a surprise for others in the
>> community.
>>
>> The recommended "fix", is that Suzie will be able to
>> "pre-qualify",
>> that is go to ARIN with all of her paperwork and get
>> approved for
>> a /18 before Billy and Suzie do a deal, so Suzie knows
>> this will
>> not happen.
>>
>> I think this ends up being bad for three distinct reasons:
>>
>> Technically:
>>
>> This causes deaggregation. In the example given a /16
>> was turned into
>> a /17 and two /18's. However, because a /17 and /18
>> are both now in
>> the free pool they may be further subdivided into /20's
>> (or smaller,
>> in some cases).
>>
>> Business:
>>
>> It is likely Billy and Suzie exchanged something of
>> value during this
>> transaction to make it happen. Suzie has now
>> "overpaid" for her /18,
>> and is likely to demand a refund from Billy, or
>> challenge ARIN's
>> stance she can only justify a /18, or both. Billy, of
>> course, isn't
>> going to want to give a refund as he is out the entire
>> /16, but he may
>> also be unhappy at ARIN for only approving her for a
>> /18. It sounds
>> like a good way to get all the parties in a transaction
>> unhappy.
>>
>> But also, it opens up an interesting fraud. Alice
>> could go to Billy
>> and offer to buy the /16 for a hundred million dollars.
>> Billy gets
>> so excited over the idea of retiring from the dial up
>> business that
>> he takes the deal. Alice gives him a fake check, and
>> Billy fills out
>> the ARIN paperwork.
>>
>> But you see, it is a fake check, and Alice had no
>> intention of ever
>> justifying the addresses to ARIN. Billy figures out
>> two weeks later
>> the check is fake from the bank, but he's already
>> released the addresses
>> to ARIN and can't get them back. What's Alice's
>> motivation? Well,
>> her alter-ego Janice is sitting near the front of the
>> line of folks
>> waiting for space to end up in the free pool. Good for
>> her, a /16
>> just showed up.
>>
>> But really this is all added risk, and what business
>> wants to
>> participate in a system with extra risk?
>>
>> Politically:
>>
>> This interpretation of the policy is likely to affect
>> the most
>> vulnerable the most. The savvy folks who are doing all
>> sorts of
>> transfers are reading this post on PPML now, and will
>> understand
>> the pitfalls of the system and work around these issues
>> by doing
>> things like prequalifing.
>>
>> This issue is much more likely to trip up the "one
>> time" casual
>> transferor or transferee who last delt with ARIN in
>> 1999 and
>> doesn't do this as a day job anymore. They are the
>> ones who will
>> accidently encounter this situation.
>>
>> Personally, I think ARIN should not let this happen. The
>> simplest
>> fix I have come up with is to require Suzie to fill out
>> the recipient
>> paperwork first. Billy should not be able to designate a
>> recipient
>> without having some assurance that end of the transaction
>> is already
>> approved from ARIN. This could be as simple as Suzie
>> giving Billy
>> the ticket number under which Suzie was approved, and
>> Billy having
>> to provide that ticket number to release resources. In
>> this way
>> an exact match could be insured, eliminating all of the
>> problems
>> listed above.
>>
>> The AC obviously moved this proposal on; so this was not
>> seen as a
>> show-stopper issue by the majority of the AC. At a
>> minimum, I
>> wanted to get the issue out to the community so if
>> nothing is changed
>> the community is aware of the issue and will be able to
>> avoid it.
>> I would hope this would end up documented on the ARIN web
>> site in
>> fairly clear language as well; but given the accelerated
>> timetable
>> for this proposal I didn't want to wait for that to occur
>> first.
>>
>> --
>> Leo Bicknell - bicknell at ufp.org
>> <mailto:bicknell at ufp.org> - CCIE 3440
>> PGP keys at http://www.ufp.org/~bicknell/
>> <http://www.ufp.org/%7Ebicknell/>
>>
>> ------------------------------------------------------------------------
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