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

[David Farmer]

The policy refers to "business models";

"Officer Attestation be provided confirming the transferred number 
resources will be applied to enable current or planned business models."

Is it the author's intent that this can be any business model?  Or, is 
this intended be to limited to a business model that requires addresses 
for the deployment of operational networks?  I ask because; Acquiring 
addresses for resale or simply to corner the market on addresses are a 
potential business models.  If the intent is to not allow these last two 
business models then maybe this could be an interesting way to find 
consensus to remove needs-basis from the current policy.

But, if the intent is to include the last two business models then I'm 
not sure we are going to find consensus within the community for this 
policy and I probably oppose this policy.

However, If the intent is to allow only business models that "need 
addresses to deploy operational networks" then; I'm not sure I support 
this policy yet, but it is definitely an interesting idea, and probably 
worthy of discussion.

On 2/16/12 16:54 CST, ARIN wrote:
> 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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David Farmer               Email:farmer at umn.edu
Networking & Telecommunication Services
Office of Information Technology
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