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

Owen DeLong owen at delong.com
Mon May 2 17:48:43 EDT 2011

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

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


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 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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