[arin-ppml] ARIN-prop-151 Limiting needs requirements for IPv4transfers

[Mike Burns]

Hi Owen,

First, thanks to Daniel for suggesting changes to Prop-151.

Clearly there is a consensus for allowing out of region transfers, that much
is clear.

But the devil is in the details, and I think that post-Philadelphia
discussion on this list served to point out potential pitfalls of 2011-1,
one of which was the danger of a raid on the free pool driven by pecuniary
interests.

Because once Inter-RIR transfers are allowed, a real demand for transferred
addresses will exist for the first time, MS/Nortel notwithstanding.

Prop-151 seeks to recognize the bald facts of human greed and deal with them
proactively to protect the free pool in two ways.

First, it prevents the selling of addresses from anybody who has received an
allocation from the free pool in the prior 12 months. This would serve as a
check against those who would seek to receive allocations of free addresses
with the intent of selling them in the transfer market.

Second, it caps needs-free transfers at the size of a /12, which Owen
helpfully points out is just 1/4096th of unicast space. With a cap like this
in place, cornering the market is not feasible and total potential profits
are limited, making this kind of speculation unsound because the high risk
of speculating in this market can not be outweighed by oversized returns.

And Prop-151 seeks to recognize what Owen and others fear, that people will
see monetary value in IPv4 addresses, and will act accordingly.  That means
in addition to greed, IPv4 address value will naturally cause people to use
this valuable resource efficiently, to an extent that ARIN justification
policies simply can not match.  My own opinion, based on the size of
allocated but unrouted address space (less the smidgen used only internally)
is that there is a great deal of efficiency still to be wrung out of the
pool of prior ARIN allocations, not to mention the pool of legacy space.
Whether or not you agree, it is axiomatic that valuable assets are used more
efficiently than free ones.

And speaking of legacy space, this proposal would recognize what ARIN
lawyers are trying to tell us, namely that ARIN's legal position insofar as
restricting legacy space transfers is weak. ARIN can certainly refuse to
book these transfers, but it is by no means certain, legally, that ARIN has
any right to block them.  I believe ARIN counsel recognizes the difficulty
and expense involved in trying to either prevent transfers of legacy space
or revoking/reclaiming it.

By allowing all transfers to be needs-free, we remove an artificial and
un-needed market restraint whose existence will only serve to drive
transfers off the books, with Whois accuracy diminished.

We take the first steps towards supporting a viable, open, transparent, and
global market for IPv4 addresses which is the best method of ensuring Whois
accuracy, aligning ARIN policy with the legal realities of property law,
equalizing regional exhaust dates, and discharging our conservationist
duties as stewards of the free pool.

I simply remind you of where this proposal started. It was seeking to answer
the question "What would have happened in the MS/Nortel deal had not MS
justified the transfer to ARIN?"
Please consider the situation we will be in when this inevitably occurs.  My
fear is that legally, the deal would be done.  Whois would be ignored or
replaced by a private registry. Addresses revoked and reissued would subject
ARIN to lawsuits. A breakdown in Whois could lead to ITU becoming more
invasive.  If we stand in defiance of a free, open, and transparent market
we will be creating a black market.

I support the policy.

Regards,
Mike






-----Original Message----- 
From: Owen DeLong
Sent: Tuesday, November 22, 2011 7:53 PM
To: Alexander, Daniel
Cc: arin-ppml at arin.net (arin-ppml at arin.net)
Subject: Re: [arin-ppml] ARIN-prop-151 Limiting needs requirements for
IPv4transfers

I still oppose the policy. This policy is still a speculators dream and will
have
negative impacts on the proper and reasonable management of IPv4 address
space by removing the needs-basis for any amount of transfers up to an
aggregate
/12 (more than 1/4096th of total IPv4 unicast space).

Worse, this would actually prevent inter-RIR transfers out of the ARIN
region as it
is currently worded below.

Owen

On Nov 22, 2011, at 2:37 PM, Alexander, Daniel wrote:

> Hello PPML,
>
> Some changes are being considered in the text of prop-151, and I would
> like to solicit some feedback. The modifications are summarized below
> along with the resulting text. Given the conversations surrounding 2011-1,
> it seems like a good time to continue the discussion with this text.
>
> Thanks,
> Dan Alexander
>
>
> Changes to the original text:
>
> - Removed the suggestions to altering the text of the RSA.
>
> - Removed the section regarding "Conditions on the IPv4 address block".
>
> - Removed the condition of space being administered by ARIN to open the
> possibility of inter-RIR transfers.
>
> - Moved the minimum transfer size requirement down to remaining
> conditions.
>
>
> Resulting text:
>
>
> Replace Section 8.3 with
>
> 8.3 ARIN will process and record IPv4 address transfer requests.
>
> Conditions on source of the transfer:
>
> * The source entity must be the current rights holder of the
> IPv4 address resources, and not be involved in any dispute as to
> the status of those resources.
>
> * The source entity will be ineligible to receive any further IPv4
> address allocations or assignments from ARIN for a period of 12
> months after the transfer, or until the exhaustion of ARIN's
> IPv4 space, whichever occurs first.
>
> * The source entity must not have received an allocation from
> ARIN for the 12 months prior to the transfer.
>
> * The minimum transfer size is a /24
>
>
> Conditions on recipient of the transfer:
>
> * The recipient entity must be a current ARIN account holder.
>
> * The recipient must sign an RSA with ARIN.
>
> * The recipient entity of the transferred resources will be subject
> to current ARIN policies. In particular, in any subsequent ARIN
> IPv4 address allocation request, the recipient will be required
> to account for the efficient utilization of all IPv4 address
> space held, including all transferred resources.
>
> * If the recipient has already received the equivalent of a /12
> of addresses in the prior 12 months, the recipient must
> demonstrate the need for additional resources in the exact amount
> which they can justify under current ARIN policies.
>
> * The minimum transfer size is a /24
>
>
> and add to the NRPM Section 12:
>
> 10. ARIN will not use utilization as a measure of policy compliance
> for addresses transferred under 8.3.
>
>
>
>
> _______________________________________________
> PPML
> You are receiving this message because you are subscribed to
> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> http://lists.arin.net/mailman/listinfo/arin-ppml
> Please contact info at arin.net if you experience any issues.

_______________________________________________
PPML
You are receiving this message because you are subscribed to
the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
Unsubscribe or manage your mailing list subscription at:
http://lists.arin.net/mailman/listinfo/arin-ppml
Please contact info at arin.net if you experience any issues.

-----Original Message----- 
From: Owen DeLong
Sent: Tuesday, November 22, 2011 7:53 PM
To: Alexander, Daniel
Cc: arin-ppml at arin.net (arin-ppml at arin.net)
Subject: Re: [arin-ppml] ARIN-prop-151 Limiting needs requirements for 
IPv4transfers

I still oppose the policy. This policy is still a speculators dream and will 
have
negative impacts on the proper and reasonable management of IPv4 address
space by removing the needs-basis for any amount of transfers up to an 
aggregate
/12 (more than 1/4096th of total IPv4 unicast space).

Worse, this would actually prevent inter-RIR transfers out of the ARIN 
region as it
is currently worded below.

Owen

On Nov 22, 2011, at 2:37 PM, Alexander, Daniel wrote:

> Hello PPML,
>
> Some changes are being considered in the text of prop-151, and I would
> like to solicit some feedback. The modifications are summarized below
> along with the resulting text. Given the conversations surrounding 2011-1,
> it seems like a good time to continue the discussion with this text.
>
> Thanks,
> Dan Alexander
>
>
> Changes to the original text:
>
> - Removed the suggestions to altering the text of the RSA.
>
> - Removed the section regarding "Conditions on the IPv4 address block".
>
> - Removed the condition of space being administered by ARIN to open the
> possibility of inter-RIR transfers.
>
> - Moved the minimum transfer size requirement down to remaining
> conditions.
>
>
> Resulting text:
>
>
> Replace Section 8.3 with
>
> 8.3 ARIN will process and record IPv4 address transfer requests.
>
> Conditions on source of the transfer:
>
> * The source entity must be the current rights holder of the
> IPv4 address resources, and not be involved in any dispute as to
> the status of those resources.
>
> * The source entity will be ineligible to receive any further IPv4
> address allocations or assignments from ARIN for a period of 12
> months after the transfer, or until the exhaustion of ARIN's
> IPv4 space, whichever occurs first.
>
> * The source entity must not have received an allocation from
> ARIN for the 12 months prior to the transfer.
>
> * The minimum transfer size is a /24
>
>
> Conditions on recipient of the transfer:
>
> * The recipient entity must be a current ARIN account holder.
>
> * The recipient must sign an RSA with ARIN.
>
> * The recipient entity of the transferred resources will be subject
> to current ARIN policies. In particular, in any subsequent ARIN
> IPv4 address allocation request, the recipient will be required
> to account for the efficient utilization of all IPv4 address
> space held, including all transferred resources.
>
> * If the recipient has already received the equivalent of a /12
> of addresses in the prior 12 months, the recipient must
> demonstrate the need for additional resources in the exact amount
> which they can justify under current ARIN policies.
>
> * The minimum transfer size is a /24
>
>
> and add to the NRPM Section 12:
>
> 10. ARIN will not use utilization as a measure of policy compliance
> for addresses transferred under 8.3.
>
>
>
>
> _______________________________________________
> PPML
> You are receiving this message because you are subscribed to
> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> http://lists.arin.net/mailman/listinfo/arin-ppml
> Please contact info at arin.net if you experience any issues.

_______________________________________________
PPML
You are receiving this message because you are subscribed to
the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
Unsubscribe or manage your mailing list subscription at:
http://lists.arin.net/mailman/listinfo/arin-ppml
Please contact info at arin.net if you experience any issues.