[arin-ppml] NRPN 8.2 & 2.3

Jeffrey Lyon jeffrey.lyon at blacklotus.net
Mon May 2 19:34:21 EDT 2011


On Mon, May 2, 2011 at 6:25 PM, Owen DeLong <owen at delong.com> wrote:

>
> On May 2, 2011, at 12:57 PM, Mike Burns wrote:
>
> >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.
>
>
> Yes... It is.
>
> Stewardship simply means different things pre- and post-exhaust.
>
>
> No, it does not.
>
> 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 is a dependable system because without the needs
> basis,
> you open up the potential for a new class of organization... The speculator
> who wants to come in, use vast financial resources to acquire all addresses
> priced below some threshold he believes to be viable and then wait until
> the market desire for the resource exceeds that price (potentially by a
> wide
> margin). This delays the availability of addresses to a wider set of
> justified
> need while increasing the price without benefit to the community.
>
> The only entitiy that gains in this environment is the speculator. Everyone
> else
> loses.
>
> That is, regardless of what else you may think, in my mind an obvious
> abandonment
> of the responsibility of stewardship.
>
> 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.
>
>
>
> I agree with you that is the case.
>
> 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.
>
>
> While it is nonsensical, I have found that the law is often nonsensical in
> its
> interpretation of plain English. The supreme court has somehow managed
> to interpret the plain English of the first amendment to include the
> ability
> to bankroll a campaign by a corporation as a form of protected free speech.
> To me, this seems completely nonsensical.
>
> So, we can't rule out a nonsensical interpretation and we need to write
> language that cannot be nonsensically interpreted.
>
> Owen
>
> Regards,
> Mike
>
>
>
>
> ----- Original Message -----
> *From:* Owen DeLong <owen at delong.com>
> *To:* Rudolph Daniel <rudi.daniel at gmail.com>
> *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<http://www.facebook.com/pages/Kingstown-Saint-Vincent-and-the-Grenadines/DanielCharles/153611257984774>
> **1-784 498 8277<http://www.facebook.com/pages/Kingstown-Saint-Vincent-and-the-Grenadines/DanielCharles/153611257984774>
> *
> *
> *
>
>
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>


Owen,

Would you be in support of an open exchange if there were basic controls in
place to lockout speculators?

-- 

Jeffrey Lyon, Leadership Team
jeffrey.lyon at blacklotus.net | http://www.blacklotus.net
Black Lotus Communications - AS32421
First and Leading in DDoS Protection Solutions
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