[arin-ppml] Transfers by non-legacy address holders and perceived risk of reclamation

[John Curran]

On Sep 1, 2011, at 5:31 PM, William Herrin wrote:

> At no time in the history of the Internet number registry system have
> we had 0 addresses available to issue. The process evolves with the
> conditions it encounters.

I am all for evolution. Please suggest policy changes as you desire
to reflect the new conditions.

>>  You've asserted a binary end-state where ARIN is either "to enforce
>>  efficient utilization" or is to disregard utilization it altogether,
>>  and this does not reflect reality of any point in history of the
>>  Internet number registry system.
> 
> Respectfully, that is not a correct analysis. ARIN and its
> predecessors have been charged with enforcing efficient utilization
> from the inception.

You assert that the registries have been charged with enforcing 
efficient utilization with respect to already issued allocations?
(as opposed to at the time of the registry issuing address space?)

> But don't take my word for it.
> 
> NRPM 4.2.2 "Organizations [...] must satisfy the following
> requirements: [...] Demonstrate efficient use of IP address space
> allocations"
> 
> NRPM 4.2.4.1 "ISPs must have efficiently utilized all previous allocations"

Both of these are when ARIN is processing a request for address space,
and indeed, we validate the utilization of all previous allocations.

> etc. etc. The phrase "efficient utilization" appears in the NRPM a
> full dozen times. Synonymous phrases appear more.

You might want elaborate on those "etc. etc." cases, as your 
assertion is that ARIN has an ongoing proactive responsibility
to enforce efficiency in existing allocations, ie. one that can
not be met via passive mechanisms such as a transfer market; a 
duty that requires "audits and revocation" of existing allocations. 
Both of the above NRPM references are with respect to the making 
of new allocations and do not support your point.

Thanks!
/John

John Curran
President and CEO
ARIN