[arin-ppml] 2011-1 dissent Was: Re: ARIN-2011-1: ARINInter-RIRTransfers - Last Call

[Owen DeLong]

On Oct 24, 2011, at 4:58 PM, Jimmy Hess wrote:

> On Mon, Oct 24, 2011 at 5:03 PM, John Curran <jcurran at arin.net> wrote:
>> Bill -
>>  It's actually simpler than that... These "independent" entities
>>  with limited history are actually valid address recipients.
>>  We do our best to unveil companies which are entirely shell
>>  companies (and effectively deduplicate requests) but as long as
> 
> I think the premise was the entities wouldn't be "shell companies"
> strictly speaking,
> even though their ultimate owners formed them  knowing the companies' business
> plan would ultimately lead them to needing IP addresses,  which could
> then become
> so valuable due to Inter-RIR transfer and  offshore value of IP addresses,
> that the companies might be scrapped for a quick profit due to the
> value of their IP addresses.
> 
>>  I agree that presently this new entrant "loophole" could
>>  potentially be exacerbated by an InterRIR transfer policy;
>>  I just wanted to  make it clear that it may also be a serious
>>  problem as we approach in-region depletion in general.
> 
> There is a way we could avoid InterRIR transfer policy exacerbating this...
> ARIN could allow applicants from _any_  service region  to apply for
> resources from the free pool,
> via a  inter-RIR  "cross application" deal.
> 
I like the idea in general, but, I believe it would require global policy and/or
a modification of the ICP-2 document which I think is infeasible in the time
remaining in the free pool.

> By that,  I mean  ARIN could adopt a policy permitting resources from
> the ARIN free pool to be allocated to an applicant in any other
> region,  and  after approval, the resources would automatically be
> transferred to the local RIR on the applicant's behalf,   provided
> that other region also adopted the same policy.
> 

I believe this would be contrary to the current ICP-2 document and would
also create interesting financial, legal, and language problems.

> 
> Then there would be no point of abusing the Inter-RIR transfer
> process,  as the applicants in the
> other  region could simply make their application with ARIN and  meet
> the justified need
> requirements under ARIN's criteria.
> 

As I said, I like the idea in principle, but, I don't think it can be implemented
within the current global policy framework.

Owen