[arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified Transfers

[Kevin Kargel]

My issue with this is that it treats ARIN members unfairly.  If we should
eliminate needs requirements for any part of IP address allocation then we
should eliminate needs requirements for *all* allocations, not just
transfers for profit.  

All of the arguments here apply to regular allocations as much as they do to
transfer allocations.  This does not mean it is a good idea.  

I strongly oppose this proposal.  

Kevin Kargel

 

> -----Original Message-----
> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On
> Behalf Of ARIN
> Sent: Thursday, February 16, 2012 4:54 PM
> To: arin-ppml at arin.net
> Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on
> 8.3 Specified Transfers
> 
> ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified
> Transfers
> 
> 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-165 Eliminate Needs-Based Justification on 8.3 Specified
> Transfers
> 
> Proposal Originator: Jeff Mehlenbacher
> 
> Proposal Version: 1
> 
> Date: 16 February 16 2012
> 
> Proposal type: Modify
> 
> Policy term: Permanent
> 
> Policy statement:
> 
> Current Policy Statement:
> 8.3. Transfers to Specified Recipients
> In addition to transfers under section 8.2, IPv4 number resources within
> the ARIN region may be released to ARIN by the authorized resource
> holder, in whole or in part, for transfer to another specified
> organizational recipient. Such transferred number resources may only be
> received under RSA by organizations that are within the ARIN region and
> can demonstrate the need for such resources in the amount which they can
> justify under current ARIN policies showing how the addresses will be
> utilized within 24 months.
> 
> Proposed Policy Statement
> 8.3. Transfers to Specified Recipients
> In addition to transfers under section 8.2, IPv4 number resources within
> the ARIN region may be released to ARIN by the authorized resource
> holder, in whole or in part, for transfer to another specified
> organizational recipient. Such transferred number resources may only be
> received under RSA by organizations that are within the ARIN region and
> requires that an Officer Attestation be provided confirming the
> transferred number resources will be applied to enable current or
> planned business models.
> 
> Rationale:
> 
> Current policy acts as a major impediment to freeing up unused IPv4
> address and constrains trade in a free market economy. If a Company
> receives Board approval to spend between $11.25 and $12.00 per IP, this
> should suggest the business case is justified for the acquiring
> organization. The role of ARIN should be to encourage the freeing of
> IPv4 addresses that will otherwise remain dormant in the hands of
> companies who have no incentive to transfer them.
> 
> The objective of the Specified Transfer market should be to a) encourage
> source Companies to transfer their unused blocks thereby increasing
> supply of IPv4 address and b) encourage recipient Companies to acquire
> sufficient IPv4 addresses to support business plans rather than
> depleting the free pool.
> 
> Current policy of demonstrating need for specified transfers, be it
> based on 12 months or now 24 months, does not provide sufficient
> incentive for organizations to acquire unused IPv4 addresses in a
> financial transaction. Companies recognize they must still endure the
> rigors of the justification process regardless of free allocation or
> specified transfer.making it very difficult to justify a financial
> transaction when specified transfers will still be assessed by exactly
> the same techniques and algorithms applied for approval of free resources.
> 
> Eliminating needs-based justification has many benefits so long as all
> transactions continue to flow through ARIN for ratification:
> 
> a) Buyer executive attestation will ensure the IP's are being used for
> business purposes. Failure to be truthful could result in punitive
> measures against corporate officers, and is a risk an officer would not
> be likely to take
> 
> b) Source Companies have an active market and financial incentive to
> transfer unused IPv4 blocks to Companies with need
> 
> c) IPv4 number resources will not be scarce if adequate incentive exists
> for Buyers to acquire unused blocks through specified transfer
> 
> d) Many Buyers express hesitation that confidential business plans must
> be disclosed through the justification process-no such disclosure would
> be required (under NDA or otherwise)
> 
> e) Legacy blocks will come under RSA in ever increasing numbers
> 
> f) Improves the accuracy, utility and value of the ARIN address registry
> 
> g) Effectively kills the black or gray IPv4 transfer market guaranteeing
> ARIN's custodianship over number resources
> 
> h) Encourages source Companies to free up resources and recipient
> Companies to actively acquire available IPv4 blocks thereby eliminating
> speculation because supply is abundant. Only when a resource is truly
> scarce does capricious consumption (stockpiling) occur
> 
> i) The Free resource pool is best applied to small or new ISPs while
> medium to large corporations with greater financial wherewithal are
> encouraged to participate in specified transfers to acquire larger IPv4
> blocks
> 
> Timetable for implementation: Immediate
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