[arin-ppml] ARIN-prop-147 Set Transfer Need to 24 months and Clarify Exception

[Matthew Kaufman]

On May 2, 2011, at 2:48 PM, Owen DeLong wrote:

> I do not support the proposal as written.
> 
> First, I don't see a benefit to the community from adding 8.2 to the
> exemption. 8.2 is for transferring resources already in use as a
> result of M&A and as such should not require any sort of exemption
> or time period specification of any type.

> The resources should already
> have justified need and be in use at the time of transfer.

Addresses involved in an 8.2 transfer are not necessarily "already in use". The source organization may have a considerable number of legacy addresses and/or have recently qualified for addresses based on a needs justification that is no longer applicable... therefore the new organization must re-qualify.

If they are to re-qualify, it doesn't make sense that they be forced to justify only a 3-month supply simply because the free pool is low or empty.

> Adding
> a 24 month time frame for speculative need only enhances the
> opportunities for fraudulent transfers and abuse.

It also has other benefits, but perhaps these proposals should be split so we can debate them separately.

> 
> Second, I think there was value in preserving the 12 month horizon
> for transfers in that the shortening of the horizon to three months
> was for the purpose of limiting the extent to which a single organization
> could "shut out" their competitors by collecting a twelve month supply
> of addresses right as several of them ran out. No such protection makes
> sense in the transfer market.

Nor does it make sense in the M&A transfer context, but you just argued the other way above.


> However, expanding policy to a 24
> month horizon makes no more sense for transfers than it would have
> for allocations.

Transfers require considerably more work on the part of two non-ARIN parties. 

Furthermore, the uncertainty of the IPv4 market makes the inability to acquire additional space that is justified, albeit over a longer interval, a serious problem... how can you get investment for something that you intend to build over the next 2 years if you can only get the first year of space now via transfer and the second one is totally dependent on whether or not there even IS a seller down the road... as opposed to just ponying up the cash now and getting enough space that you can make it all the way to when IPv6 really works for your application.

There are also potential benefits to aggregation. See my justification statements.

Matthew Kaufman

> 
> Owen
> 
> On May 2, 2011, at 11:00 AM, ARIN wrote:
> 
>> ARIN-prop-147 Set Transfer Need to 24 months and Clarify Exception
>> 
>> ARIN received the following policy proposal and is posting it to the
>> Public Policy Mailing List (PPML) in accordance with the Policy
>> Development Process.
>> 
>> The ARIN Advisory Council (AC) will review the proposal at their next
>> regularly scheduled meeting (if the period before the next regularly
>> scheduled meeting is less than 10 days, then the period may be extended
>> to the subsequent regularly scheduled meeting). The AC will decide how
>> to utilize the proposal and announce the decision to the PPML.
>> 
>> The AC invites everyone to comment on the proposal on the PPML,
>> particularly their support or non-support and the reasoning
>> behind their opinion. Such participation contributes to a thorough
>> vetting and provides important guidance to the AC in their deliberations.
>> 
>> Draft Policies and Proposals under discussion can be found at:
>> https://www.arin.net/policy/proposals/index.html
>> 
>> The ARIN Policy Development Process can be found at:
>> https://www.arin.net/policy/pdp.html
>> 
>> Mailing list subscription information can be found
>> at: https://www.arin.net/mailing_lists/
>> 
>> Regards,
>> 
>> Communications and Member Services
>> American Registry for Internet Numbers (ARIN)
>> 
>> 
>> ## * ##
>> 
>> 
>> ARIN-prop-147 Set Transfer Need to 24 months and Clarify Exception
>> 
>> Proposal Originator: Matthew Kaufman
>> 
>> Proposal Version: 1
>> 
>> Date: 2 May 2011
>> 
>> Proposal type: new
>> 
>> Policy term: permanent
>> 
>> Policy statement:
>> 
>> Change section 4.2.4.4 content as follows:
>> 
>> Replace:
>> "This reduction does not apply to resources received via section 8.3. An
>> organization receiving a transfer under section 8.3 may continue to
>> request up to a 12-month supply of IP addresses."
>> 
>> With:
>> "This reduction does not apply to resources received via transfer. An
>> organization receiving a transfer under section 8 may request up to a
>> 24-month supply of IP addresses."
>> 
>> Rationale:
>> 
>> The exception should apply to transfers under 8.2 as well as 8.3 (and
>> any future transfer policies).
>> 
>> Due to the complexity of the financial transaction that may be
>> involved and the associated budgeting on the part of the receiving
>> organization, 24 months is a more reasonable amount of forecast need to
>> allow to be fulfilled via the transfer process.
>> 
>> Potential benefit to address aggregation by allowing fewer larger
>> transfers sooner.
>> 
>> Timetable for implementation: immediate
>> 
>> 
>> _______________________________________________
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> 
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