[arin-ppml] ARIN-prop-145 STLS Listing Immunity

[Mike Burns]

Scott,

I think these are excellent ideas and that they will serve to free up addresses for transfer by reducing fear of ARIN.
Particularly extending the safe harbor to all sales venues.

What would free up even more addresses is a total elimination of needs analyses for all transfers. ;-)

Although needs analyses are still required, I support your changes as they move policy in the right direction.

Regards,
Mike



  ----- Original Message ----- 
  From: Scott Leibrand 
  To: ARIN-PPML List 
  Sent: Monday, May 02, 2011 2:50 PM
  Subject: Re: [arin-ppml] ARIN-prop-145 STLS Listing Immunity


  On Mon, May 2, 2011 at 10:59 AM, ARIN <info at arin.net> wrote:
    ARIN-prop-145 STLS Listing Immunity



  <snip>

    Add a subsection to Section 12 (Resource Review) of the NRPM:

    ARIN may not revoke any resources issued by ARIN that are presently
    listed as "available" on the ARIN Specified Transfer Listing Service
    unless there is sufficient reason to believe that the holder does not in
    fact intend to transfer these resources.



  Another way to accomplish this would be with the following language from the original transfer policy proposal, 2008-2:


  The fact that an IPv4 address holder is making IPv4 addresses available for transfer, pursuant to this policy, does not, in and of itself, indicate that the address holder lacks the need required for an allocation under ARIN policy.




    Rationale:

    An entity may list space as available and might begin the process of
    moving out of that space in order to facilitate the transfer. A review
    after such work was in progress might reveal that the addresses are not
    sufficiently utilized.

    Additionally, because posting a listing on the STLS signals directly to
    ARIN that an entity believes it can use addresses more efficiently, ARIN
    might simply use STLS listings in order to trigger audit under 12.2(c).
    This would not be fair. (And would be a disincentive to using the ARIN
    STLS at all in order to list available space)



  I believe that ARIN has made assurances that this will not be done, but I would support such assurances into policy as well if people think it's needed. 


    This policy would also serve to increase the value of the ARIN STLS over
    other possible transfer listing services, increasing the transparency of
    the transfer market, particularly to ARIN, who wishes to ensure that
    transfers take place within NRPM 8.3.




  I think it's important to make any "Safe Harbor" statement apply to all IPv4 addresses being made available for transfer (including those on eBay etc.) not just those offered through ARIN's Specified Transfer Listing Service. ARIN has repeatedly made clear that the STLS is completely optional, which I believe is the right way to approach it.  I don't believe we should be giving the STLS preferential treatment in the transfer policy in any way.


  -Scott


  P.S. Thanks for all the straightforward, well-thought-out proposals.


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