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

[Sweeting, John]

On 2/16/12 10:32 PM, "Astrodog" <astrodog at gmail.com> wrote:

>On Thu, Feb 16, 2012 at 6:27 PM, John Santos <JOHN at egh.com> wrote:
>> +1
>>
>> Also opposed.
>>
>> Isn't "making lots of money by cornering the IPv4 address market" also
>> a "business purpose"?
>
>Support.
>
>I believe the concern about speculation with IP addresses is fairly
>overblown. If an entity were to attempt such a move, it would induce
>more efficent usage among existing users, so that they could sell
>portions of their space (or avoid purchasing additional address
>space). This carries with it a very large risk that the addresses such
>an entity purchased would become nearly worthless, either due to
>oversupply as large address space holders sold off their space, or due
>to IPv6 migration and more efficent utilization due to the short term
>increased cost driving demand for the addresses down over longer
>periods of time.
>
>It is unlikely, given these concerns, that such an endevour would be
>attempted on a large scale or that such an attempt would have any
>significant impact on long term "pricing" of IPv4 addresses.
>
>The positives with such an approach are significant, though, as it
>greatly reduces the time and effort required on the part of both
>parties, as well as ARIN, to effect such a transfer, making it much
>easier for IP addresses to go to those entities who will use them.

So what is the harm in asking them to share how they will be using them?
Is it your belief that just makes it "too hard"?


>
>The situation, as things stand today, appears to involve companies
>deciding to arrainge such a transfer, then trying to back in to a
>justification under 8.3.
>
>--- Harrison

Just wondering, do you know of any organizations today that face that
situation?

>
>> 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 transferŠmaking
>>>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 IP¹s 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
>>> > ARIN¹s 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:
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>>> Please contact info at arin.net if you experience any issues.
>>>
>>>
>>
>> --
>> John Santos
>> Evans Griffiths & Hart, Inc.
>> 781-861-0670 ext 539
>>
>> _______________________________________________
>> PPML
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