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

[John Santos]

+1

Also opposed.

Isn't "making lots of money by cornering the IPv4 address market" also
a "business purpose"?

On Thu, 16 Feb 2012, CJ Aronson wrote:

> I am opposed to this policy.  For as long as ARIN has existed this
> community has been very vocal in supporting the needs basis for
> address allocations and assignments.  I have no reason to believe that
> this position has changed.
> 
> ----Cathy
> 
> On Thu, Feb 16, 2012 at 3:54 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
> >
> > 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
> > _______________________________________________
> > PPML
> > You are receiving this message because you are subscribed to
> > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> > Unsubscribe or manage your mailing list subscription at:
> > http://lists.arin.net/mailman/listinfo/arin-ppml
> > Please contact info at arin.net if you experience any issues.
> _______________________________________________
> PPML
> You are receiving this message because you are subscribed to
> the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> http://lists.arin.net/mailman/listinfo/arin-ppml
> Please contact info at arin.net if you experience any issues.
> 
> 

-- 
John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539