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

Kevin Kargel kkargel at polartel.com
Thu Feb 16 18:06:00 EST 2012


My issue with this is that it treats ARIN members unfairly.  If we should
eliminate needs requirements for any part of IP address allocation then we
should eliminate needs requirements for *all* allocations, not just
transfers for profit.  

All of the arguments here apply to regular allocations as much as they do to
transfer allocations.  This does not mean it is a good idea.  

I strongly oppose this proposal.  

Kevin Kargel

 

> -----Original Message-----
> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On
> Behalf Of ARIN
> Sent: Thursday, February 16, 2012 4:54 PM
> To: arin-ppml at arin.net
> Subject: [arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justification on
> 8.3 Specified Transfers
> 
> 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
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