[arin-ppml] NRPN 8.2 & 2.3

Mike Burns mike at nationwideinc.com
Mon May 2 15:57:18 EDT 2011


>It seems the community is
>rather divided with some advocating a complete abandonment
>of the principles of stewardship in favor of a laissez faire
>address economy while others favor preservation of the
>principles of stewardship and justified need while enabling
>market incentives to free up space.
>Owen


Removing artificial restrictions on the transfer of IP address space is not, as Owen persists in characterizing it, an abandonment of the principles of stewardship.
Stewardship simply means different things pre- and post-exhaust.
Pre-exhaust requires needs analyses to ensure efficient use of address space.
Post-exahust, efficient use is ensured by the same market incentives you claim enables the freeing up of space.
To wit, price.

I don't believe that there has been an answer to those of us who said that while it is grammatically acceptable to decide that a "single aggregate" relates to the needs justification, it is nonsensical to do that, as all needs analyses result in a single aggregate. You don't have a needs analysis at any time where it is found that a need is outside CIDR boundaries. Need assessment has always rounded up to that boundary.

No, the only way to interpret the language of 8.3 is that the reception of the addresses should occur as a single aggregate, which is clear has not occurred with 8.3.
To say the staff or the board acted outside of policy is correct in the MS/Nortel case.

Regards,
Mike



  ----- Original Message ----- 
  From: Owen DeLong 
  To: Rudolph Daniel 
  Cc: arin-ppml at arin.net 
  Sent: Monday, May 02, 2011 3:44 PM
  Subject: Re: [arin-ppml] NRPN 8.2 & 2.3


  At this point, I would agree. However, I would like to wait until I
  get a chance to discuss the matter with ARIN Counsel and
  further discuss it with staff before I start crafting proposals
  to do so.


  I don't feel that staff or the board have acted improperly. I think
  that policy failed to express the community intent well enough
  as to achieve or goals.


  I will continue to work on finding a way to bring policy better in
  line with community intent, but, the hard part will be achieving
  consensus on what that intent is. It seems the community is
  rather divided with some advocating a complete abandonment
  of the principles of stewardship in favor of a laissez faire
  address economy while others favor preservation of the
  principles of stewardship and justified need while enabling
  market incentives to free up space.


  It is most unfortunate that we failed to produce clear policy
  in 2009-1. I hope we can correct it at Philadelphia.


  Owen


  On Apr 30, 2011, at 6:48 PM, Rudolph Daniel wrote:


    It would seem clear to me that at the very least, NRPN 8.2 and 8.3 requires rephrasing. Is that also the view of the ppml?


    rd





      >> for such resources, as a single aggregate", not that a single
      >> aggregate be transferred.
      >
      > ... I do not believe that Stephen's interpretation below matches the
      > meaning or the intent of the policy as I understand it. ...

      I don't think it does either, for the record.  However, this points out
      how bad wording has left us in a situation where we're not sure /what/
      the policy text means--much less whether we agree with it.

      > I do agree that your interpretation would be a syntactically  and
      > grammatically valid construction, but, I believe it is contextually
      > nonsensical and not the intended meaning of the words.
      >
      > If anyone has a suggestion for making the actual intent more clear, I
      > am open to suggestions and would support making an editorial
      > correction for clarity.

      If you can provide examples of transfers you both do and don't wish to
      allow, I'll be happy to come up with wording to express your intent.  As
      it stands, though, I don't understand your (or anyone else's) intent
      well enough to try.

      S

      --
      Stephen Sprunk         "God does not play dice."  --Albert Einstein
      CCIE #3723         "God is an inveterate gambler, and He throws the
      K5SSS        dice at every possible opportunity." --Stephen Hawking

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      Message: 2
      Date: Sat, 30 Apr 2011 20:28:39 -0400
      From: William Herrin <bill at herrin.us>
      To: John Curran <jcurran at arin.net>
      Cc: Public Policy Mailing List <ppml at arin.net>
      Subject: Re: [arin-ppml] Call for a study & survey to obtain necessary
             information for policy development
      Message-ID: <BANLkTi=0i9isaCTnsTQC9NO=PX2RAcSt1A at mail.gmail.com>
      Content-Type: text/plain; charset=ISO-8859-1

      On Sat, Apr 30, 2011 at 7:51 AM, John Curran <jcurran at arin.net> wrote:
      > ? contains a specific call for ARIN to charter a study including
      > ? a survey in order to obtain additional information to assist in
      > ? policy development.
      >
      > ? I've not seen any discussion of this suggestion; would it be
      > ? possible to get feedback from the otherwise shy participants
      > ? on the PPML mailing list?
      >
      > On Apr 29, 2011, at 5:46 PM, Jeffrey Lyon wrote:
      >> what we should do is
      >> charter ARIN to conduct a comprehensive study and:
      >>
      >> - Conduct a survey of the public at large, PPML users, full members,
      >> resource holders, and the AC to gain a clear understanding of
      >> sentiment for or against an open market.
      >> - Determine how many companies actually have IPv6 migration plans and
      >> ascertain road blocks, either legitimate or financial, that are
      >> preventing migration.
      >> - Would resource holders support a model that allowed ARIN to take a
      >> small commission on resource sales and then discontinue the practice
      >> of charging an annual fee to its members who are not buying and
      >> selling resources.

      These seem like they could be determined by survey.


      >> - In the survey, ask IPv4 resource holders to anonymously disclose
      >> their true utilization rates and determine if companies are hoarding
      >> resources either in hopes of future resale or to cover an arbitrary
      >> future need.
      >> - Determine the amount of participants that would come forward if told
      >> they could resell their space on the open market and ultimately
      >> determine how much unneeded space is being locked away in loosely
      >> justified allocations.
      >> - Determine if resource holders would be encouraged to tighten up
      >> internal policies and free up more space if there were a fair market
      >> value assigned to their space.

      These strike me as very difficult to determine by anything approaching
      a statistically valid survey. I would want to see a detailed
      methodology proposed before agreeing either that money should be spent
      conducting the survey or that the results would have merit to
      contribute to the policy debate.


      >> - Determine the economic impact. Would resource holders be better off
      >> selling their resources to more affluent companies who would be able
      >> to put the space to better use? Might there be a host of struggling
      >> small businesses who would like to put their /17 - /21 on the balance
      >> sheet? Are there companies that would purchase IPv4 space at a premium
      >> if allowed to do so?

      This would require a cost analysis of a great many factors, only some
      of which have been touched on in the listed survey. Given the abject
      lack of use of cost analysis in the Internet industry, it would
      require at least three independent cost analyses and considerable
      subsequent debate on and validation of the methodologies...

      Start here: http://www.sceaonline.net/

      Disclaimer: my father is a crotchety old cost analyst so I get a
      regular earful about this stuff.

      Regards,
      Bill Herrin


      --
      William D. Herrin ................ herrin at dirtside.com? bill at herrin.us
      3005 Crane Dr. ...................... Web: <http://bill.herrin.us/>
      Falls Church, VA 22042-3004


      ------------------------------

      Message: 3
      Date: Sat, 30 Apr 2011 20:39:08 -0400
      From: William Herrin <bill at herrin.us>
      To: Owen DeLong <owen at delong.com>
      Cc: John Curran <jcurran at arin.net>, arin-ppml <arin-ppml at arin.net>
      Subject: Re: [arin-ppml] Analogies
      Message-ID: <BANLkTimzAx7_S=oaHiEB2epuXmMiBc136w at mail.gmail.com>
      Content-Type: text/plain; charset=ISO-8859-1

      On Sat, Apr 30, 2011 at 1:31 AM, Owen DeLong <owen at delong.com> wrote:
      > I will point out that ARIN is the only registry that did not start
      > charging their legacy holders shortly after coming into existence.
      >
      > APNIC, RIPE, AfriNIC, and LACNIC all charge their legacy holders
      > annual fees to the best of my knowledge.
      >
      > I do not know whether a contract was required in any or all cases,
      > but, the fee portion of the equation is unique to ARIN to the best
      > of my knowledge.

      Hi Owen,

      I will suggest that an attempt by ARIN to charge $100/year under a
      contract simplified to, "We agree to keep your whois data and RDNS
      delegations intact as is for one year increments until either of us
      choose to cancel this contract" would meet with at most mild
      resistance from the legacy registrants. It would also, IMHO, provide
      an excellent way to weed out the abandoned registrations.

      This hasn't been done in part because we, in this forum, have insisted
      that legacy registrants should not be invited into the fold under such
      terms.

      Regards,
      Bill Herrin


      --
      William D. Herrin ................ herrin at dirtside.com? bill at herrin.us
      3005 Crane Dr. ...................... Web: <http://bill.herrin.us/>
      Falls Church, VA 22042-3004


      ------------------------------

      Message: 4
      Date: Sat, 30 Apr 2011 20:43:29 -0400
      From: "Mike Burns" <mike at nationwideinc.com>
      To: "Stephen Sprunk" <stephen at sprunk.org>,      "Owen DeLong"
             <owen at delong.com>
      Cc: arin-ppml at arin.net
      Subject: Re: [arin-ppml] ARIN / Microsoft press release regarding IP
             addressTransfers
      Message-ID: <7B6110E30D2E40CDA7E10BCB85E290B7 at video>
      Content-Type: text/plain; charset="utf-8"

      >If you can provide examples of transfers you both do and don't wish to allow, I'll be happy to come up with wording to express your intent.  As it stands, though, I >don't understand your (or anyone else's) intent well enough to try.

      >S

      Steve,

      Here is why I call BS on the claim that these transfers comply with policy:

      "Such transferred number resources may only be received under RSA by organizations that are within the ARIN region and can demonstrate the need for such resources, as a single aggregate, in the exact amount which they can justify under current ARIN policies."

      That is the text. The comma between resources and "as a single aggregate" can be read to cause the "as a single aggregate" clause to apply to either the verb phrase "be received" or the verb phrase "can demonstrate."

      But how would anybody demonstrate a need for multiple netblocks anyway?
      Isn't the need ALWAYS determined as a single aggregate?

      Regards,

      Mike



       ----- Original Message -----
       From: Stephen Sprunk
       To: Owen DeLong
       Cc: arin-ppml at arin.net
       Sent: Saturday, April 30, 2011 8:27 PM
       Subject: Re: [arin-ppml] ARIN / Microsoft press release regarding IP addressTransfers


       On 16-Apr-11 02:19, Owen DeLong wrote:

         On Apr 15, 2011, at 9:53 PM, Stephen Sprunk wrote:

           On 15-Apr-11 19:00, Matthew Kaufman wrote:

             The adopted policies (if they are using the "relatively new policy" as alluded to in the release) require the transfer of *a single aggregate*.


           Not quite.  NRPM 8.3 only requires the receiver "demonstrate the need for such resources, as a single aggregate", not that a single aggregate be transferred.

         ... I do not believe that Stephen's interpretation below matches the meaning or the intent of the policy as I understand it. ...

       I don't think it does either, for the record.  However, this points out how bad wording has left us in a situation where we're not sure what the policy text means--much less whether we agree with it.


         I do agree that your interpretation would be a syntactically  and grammatically valid construction, but, I believe it is contextually nonsensical and not the intended meaning of the words.


         If anyone has a suggestion for making the actual intent more clear, I am open to suggestions and would support making an editorial correction for clarity.

       If you can provide examples of transfers you both do and don't wish to allow, I'll be happy to come up with wording to express your intent.  As it stands, though, I don't understand your (or anyone else's) intent well enough to try.

       S


      --
      Stephen Sprunk         "God does not play dice."  --Albert Einstein
      CCIE #3723         "God is an inveterate gambler, and He throws the
      K5SSS        dice at every possible opportunity." --Stephen Hawking


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    -- 


    Rudi Daniel
    danielcharles consulting
    1-784 498 8277






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