[arin-ppml] ARIN-prop-146 Clarify Justified Need for Transfers

Matthew Kaufman matthew at matthew.at
Tue May 3 22:58:03 EDT 2011

On 5/3/2011 7:46 PM, John Springer wrote:
> Hi Mathew,
> Thank you for the response(s), but I remain unpersuaded.
> More comments inline.

More responses inline.

> On Tue, 3 May 2011, Matthew Kaufman wrote:
>> On 5/3/2011 3:33 PM, John Springer wrote:
>>> I oppose proposal ARIN-prop-146.
>>> Comments inline.
>>> On Tue, 3 May 2011, Owen DeLong wrote:
>>>> On May 2, 2011, at 9:22 PM, Matthew Kaufman wrote:
>>>>> On 5/2/2011 8:47 PM, Owen DeLong wrote:
>>>>>> Welcome to the post-run-out world. Why should we let you acquire 
>>>>>> more space now and deny that
>>>>>> space to someone else who has justified need now?
>>>>> Because I can afford it and have taken the time to find a seller.
>>>>> Or were you planning on enacting price controls on the market as 
>>>>> well?
>>>> No, I think justified need is the only required control on the 
>>>> market. I don't see a need for price
>>>> controls, but, I do see a need to ensure that people like you do 
>>>> not get excessive address
>>>> space just because you have greater financial resources vs. others 
>>>> who need it now, but
>>>> have lesser financial resources.
>>> <bows to Owen>
>>> I see a need to ensure that people who have greater resources do not 
>>> get more additional address space than others who also need it, but 
>>> have lesser resources.
> OK, I responded to a comment, not a proposal or a thread. My bad. Still.
>>> Basically, what is being proposed here, stripped of a lot of heat 
>>> and light is an environment where more resources is a much better 
>>> advantage than currently.
>>> Who wouldn't want that?
>> I don't have a problem with justified need for transfers. I *do* have 
>> a problem with creating large sets of people who can't even *use* 
>> transfers to fulfill their needs because the 3-month limit *they* are 
>> subject to is a lot different operationally than the 12-month limit 
>> the rest of the transfer recipients are subject to.
>> I do not see how someone can operate a business that will still need 
>> IPv4 addresses in order to function and yet be limited to only 
>> getting three months at a time via transfer when their competitors 
>> are allowed to get 12 months at a time via transfer.
> Not still need, need for the first time.
> According to your subsequent comment to Marty: "The people this policy 
> change protects currently have no IPv4 space (as if they did they'd be 
> processed under the policy which does have the 12-month exemption), 
> but will need to acquire some after ARIN runout."

Them *and* the folks who haven't had ARIN space for a full 12 months 
prior to when runout happens. This proposal gives both of those cases 
the same benefit when it comes to acquiring space via transfer that 
those who've had space from ARIN for >12 months at runout have... the 
ability to transfer a full 12 months worth of justified space, if they 
can find a seller and afford the price.

> People who have no IPv4 space, but will need to acquire some after 
> ARIN runout. This is exceptional advocacy. It also seems like a self 
> limiting problem. I am not sure whether giving them 12 months instead 
> of 3 will help that. ???

It helps in that 12 (or 24) months might be enough to get through the 
IPv6 transition. 3 is most certainly not. And the volatility of the 
transfer market means that those who are unable to get more than a 3 
month supply are at a vast disadvantage, as opposed to pre-runout when 
it is simply a bit of extra paperwork.

> In any case, why on earth would you answer the question "Why should we 
> let you acquire more space now and deny that space to someone else..." 
> (meaning someone just now needing IPV4 space versus someone already in 
> the business) with "Because I can afford it and have taken the time to 
> find a seller." Some of us here on PPML, (eternally vituperated), 
> puzzled by wording and motive, wait until discussion seems to resolve 
> upon something that galvanizes us, to respond. I don't think in my 
> case you did your cause any favors with that response. I believe now 
> that I misunderstood at least the context of your statements. Would 
> you please do me the favor to identify, if you will, what party 
> getting into the IPV4 business after ARIN runout, other than 
> speculators, deserves favors such as this?

Any party that wishes to offer services to both the IPv4 and IPv6 
Internet who wasn't holding space for at least 12 months prior to runout 
(see below for the details).

>> Sure... back when there was a free pool, making them jump through the 
>> extra hoops every 3 months to show that they're doing the right thing 
>> makes (some) sense... but once there isn't, every time they get space 
>> might be their last.
> While I admit that my initial opposition to this was based on a 
> completely unprecedented <grin> misunderstanding, now that I think I 
> am clear(er) I am still opposed. Give bigger chunks of scarce IPV4 
> space to _NEW_ entrants simply "Because I can afford it and have taken 
> the time to find a seller."? Insufficient information, at best.

The proposal simply makes the justification required (12 months) 
identical for both new entrants (which includes folks who are getting 
space any time up to 12 months before ARIN runout) and those who have 
held ARIN space for more than 12 months already. That simply establishes 
WHO is allowed to bid for HOW MUCH space and then hopefully acquire it 
via the transfer market.

As it stands, "new entrants" will be at a disadvantage in bidding for 
address space *even if they can afford it and have taken the time to 
find a seller* because they will only be allowed to bid for and transfer 
space that meets three months of future need, and then they're forced 
back to the transfer market then... as opposed to their competitors who 
have been around for 12 months or more at runout, who are able to bid 
for and transfer space that meets 12 (or 24, if my other proposal 
passes) months of space requirements... which might be long enough that 
they never need to come back to the transfer market again.

In no way does it "give bigger chunks of scarce IPv4 space to new 
entrants"... they get to bid for space exactly the way everyone else 
does. What it eliminates is "forcing new entrants to take much smaller 
chunks of scarce IPv4 space via transfer simply because they're new" 
which I believe is equivalent to "makes the transfer market nearly 
useless for new entrants because the odds of being able to come back in 
three months and get more space is so uncertain as to pose a business 
risk too large for their investors".

Matthew Kaufman

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