[arin-ppml] ARIN / Microsoft press release regarding IP address Transfers

Ted Mittelstaedt tedm at ipinc.net
Sat Apr 16 02:21:37 EDT 2011


On 4/15/2011 9:28 PM, Stephen Sprunk wrote:
> On 15-Apr-11 20:06, Ted Mittelstaedt wrote:
>> What concerns me here is that the community very much wants these
>> transfer resources to go under RSA and be subject to fee payments.
>
> And who appointed you spokesman for the entire community?
>

The vast majority of posters on
this list have stated they want transfers to END UP under an RSA.
The Simplified M&A policy justification stated that - and that
policy was adopted.

Many posters want the SELLING organization to sign an LRSA first, before
even being ALLOWED to "sell"

RSA implies fee payments.

My statement stands, with backup.  What about yours?

>> With the size of the transfer that would be a very significant amount
>> of money every year from the richest company on the planet into ARINs
>> coffers ...
>
> That depends on whether it's classified as an assignment or an
> allocation.  If the former, which I suspect it is, the maximum
> maintenance fee would be $100/yr, which Microsoft is already paying for
> other resources.  IOW, there would be no net-new recurring revenue to ARIN.
>

That's fine with me.  However I think that the amount of IP cannot
be justified unless it's going to MSN, it is just too large.  Last
year MS declared around 89K employees.  The Nortel to MS transfer is
around 665K IPv4 addresses. (allowing for subnetting consumption)
Is it reasonable to assume that every Microsoft employee has 7
computers under their desk???  And what about their existing resources?

I don't have a problem with any org, even the largest ones, consuming
even as much as a "class A" for their internal use as long as they have 
the required number of hosts to meet justification.  They are not out
there selling internet connectivity and using free numbers to compete
against everyone with an unfair advantage.

But a cell company, or MSN, is an ISP.  Cell companies are essentially
ISPs due to tethering of phones - the general public just hasn't really
woken up to the fact that for $30 a month they can root their phone and
run all their home computers off of an unlimited data plan, but they
are figuring it out pretty quick.  But cell companies have such large
IP needs that they are running from IPv4 and to IPv6, they aren't the
problem.  The problem is traditional ISPs particularly the national
ones who are foot-dragging on IPv6 deployment.  Allowing them to
buy up large IPv4 blocks merely perpetuates the problem of not
switching to Ipv6, and when your letting them buy legacy blocks and
then get out of paying registration fees, that is the icing on the cake.

> I personally disagree with that fee structure, but that's not a matter
> for PPML.
>

Neither is this entire discussion on the Nortel transfer, including all
your posts.  The adage about the stone in the neighbors
eye and the boulder in your own comes to mind.

>> Claiming that "they followed the rules" means nothing because ARIN can
>> selectively apply the rules depending on what happened.
>
> ARIN staff cannot "selectively" apply rules unless the NRPM explicitly
> gives them the authority to do so, which is rare.  What specific
> provision granting such authority in this case are you referring?
>

The NRPM has many areas that ARIN staff is given authority to 
selectively apply the rules.  For example:

8.1  ARIN is tasked with making prudent decisions on whether to approve 
the transfer of number resources

8.2   ARIN will work with the resource holder(s) to return, aggregate, 
or reclaim resources as appropriate

8.3  IPv4 number resources within the ARIN region may be released to
Note 'may be' not 'must be'

The NRPM routinely uses phrases like "may be" instead of "must be" or
"is required to be"  The language in it takes pains in many sections
to merely strongly encourage and not require things to happen.

I will also refer you to the following language from

https://www.arin.net/policy/proposals/2010_6.html:

Preferably that would happen voluntarily under the policies of NRPM 4.6 
(Amnesty), but it also leaves the door open for ARIN to revoke space 
under NRPM 12 (Resource Review) if necessary. By implication, future

LEAVES THE DOOR OPEN?  That is granting authority to selectively
apply rules, period.

> If we, the community, failed to draft a policy that handled this
> situation the way we want it handled then that's on us, the community,
> and not ARIN staff.
>

Utter baloney.  Section 8.1, 8.2 & 8.3 did not come from the
community.  They came from ARIN Board of Trustees use of the Emergency 
Policy Development Process, not from the community.

Ted

> S
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