[arin-ppml] Draft Policy 2009-1: Transfer Policy ? Revisedandforwarded to the Board
Ted Mittelstaedt
tedm at ipinc.net
Tue May 5 19:32:40 EDT 2009
I am glad to hear that.
Ted
> -----Original Message-----
> From: Scott Leibrand [mailto:scottleibrand at gmail.com]
> Sent: Tuesday, May 05, 2009 4:24 PM
> To: Ted Mittelstaedt
> Cc: 'arin ppml'
> Subject: Re: [arin-ppml] Draft Policy 2009-1: Transfer Policy
> ? Revisedandforwarded to the Board
>
> 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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