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

[Peter Bui]

I oppose this proposal as written.

On Thu, Feb 16, 2012 at 2:54 PM, ARIN <info at arin.net> wrote:

> 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<https://www.arin.net/policy/proposals/index.html>
>
> The ARIN Policy Development Process can be found at:
> https://www.arin.net/policy/**pdp.html<https://www.arin.net/policy/pdp.html>
>
> Mailing list subscription information can be found
> at: https://www.arin.net/mailing_**lists/<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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