[arin-ppml] ARIN-2011-11 and ARIN-2011-12 - Last Call

[Michael Sinatra]

On 01/12/12 14:35, William Herrin wrote:
> On Wed, Jan 11, 2012 at 6:16 PM, David Farmer<farmer at umn.edu>  wrote:
>> There are still two days left in the formal last call period for
>> ARIN-2011-11 and ARIN-2011-12.  If you have any feedback for the AC
>> regarding these two Draft Policies please get it in soon.
>>>
>>>> ARIN-2011-11: Clarify Justified Need for Transfers
>>>> ARIN-2011-12: Set Transfer Need to 24 months
>
> The 3-month "need" period is based on folks dipping in to a nearly
> empty "free" pool. Transfers are not "free." I'd hate to see a nascent
> transfer market choked by a rule that wasn't meant for it.
>
> Please consider this a statement of SUPPORT for both proposals.

The 3-month need only applies to the ARIN free pool, not to 8.3 
transfers, as NRPM Section 4.2.4.4 notes.  8.3 transfers already get a 
12-month need window.

The difference in the two need windows further distorts the market for 
IP addresses, unnecessarily inflating transfer market prices.  It also 
prolongs the pathological situation where ARIN has a large free pool 
relative to other regions, presents the impression (wrongly, I agree) 
that ARIN is hoarding IP resources, and it places unnecessary burdens on 
ISPs attempting to legitimately get IP address space.  Any concern that 
the ARIN pool would be raided by out-of-region entities is both a 
product of the current situation that shouldn't be prolonged and 
something which can be mitigated by placing time limits on transfers of 
recently-acquired address space.

The free pool should match the transfer pool, and the free pool need 
should be liberalized, rather than the transfer pool being made more 
strict.  As long as there are free addresses, ARIN should not attempt to 
protect them by giving incentives to use the transfer market and 
disincentives to come to ARIN for IPv4 resources.

Until there is an effort to normalize the free pool and transfer 
policies, I can't support 2011-12, which would only increase the current 
distortions.

michael