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

David Bucciero d.bucciero at wwpass.com
Fri Feb 17 10:33:01 EST 2012


I am new to ARIN having received our ASN, IPv4 & IPv6 only a week or so 
ago. I appreciated the scrutiny for ASN & IPv4 but not for IPv6 as I 
feel it is too early to scrutinize IPv6.

I would be opposed to this proposal as currently written.

Best regards,
Dave

On 2/16/12 5:54 PM, ARIN 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
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-- 
*David L. Bucciero* WWPass Logo
*IT Director*  |  WWPass Corporation
5 Bedford Farms Drive, Bedford, New Hampshire 03110
1.603.782.0319

d.bucciero at wwpass.com <="" a=""> <http://www.wwpass.com/>wwpass.com 
<http://www.wwpass.com/>
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