[arin-ppml] Prop-151: Limiting needs requirements for IPv4 transfers

[Alexander, Daniel]

On 1/23/12 3:09 PM, "William Herrin" <bill at herrin.us> wrote:

>On Mon, Jan 23, 2012 at 9:22 AM, Alexander, Daniel
><Daniel_Alexander at cable.comcast.com> wrote:
>> Thank you for clarifying your point. If I understand you correctly,
>>needs
>> requirements should be consistent across all regions for inter-RIR
>> transfers to be equitable to those within the ARIN region. To achieve
>>this
>> parity, you feel it is more appropriate to define requirements through
>> global policy, and not through local pressures exerted on another RIR.
>
>Hi Dan,
>
>That, OR set local policy so that any unavoidable unfairness is
>weighted to favor recipients in the originating region.
>
>> You
>> also mention on the other end, that ARIN could race to the bottom and
>> reduce it's requirements to match all the other regions, but that may
>>be a
>> premature approach.
>
>There's a persuasive argument to be made that the cost per IPv4
>address is likely to be high enough that money alone will be
>sufficient to assure efficient utilization. That would allow us to
>withdraw the other controls. IF that proves to be the case, the the
>only remaining objection to an interregion transfer policy would be
>the lack of a reciprocity requirement. Under 2011-1, the receiving RIR
>is not required to have a policy which permits ARIN registrants to
>receive transfers from that RIR's region.
>
>However, persuasive though the argument is I'm not yet sold on the
>idea that dollars alone get the job done. I'd prefer to wait and see
>what happens when the free pool is finally empty before taking that
>step.

[DA] I'm not sold either, but I think the hold requirements that are
incorporated into 151 should help mitigate this problem. One suggestion
that has also been raised is whether the hold requirement should be
applied to transfers, in addition to allocations, or assignments from the
free pool. I haven't gotten a feel yet for what people think about a
change like that.

>
>
>> A concern I have is that a global needs review proposal would take years
>> to work through. I would also assume that it is not operationally
>> sustainable having ARIN vet all requests both in and out of region. Do
>>you
>> think these are fair assumptions
>
>Given that we've been trying to create a global policy for address
>reallocation for several years and have thus far failed, I think the
>first assumption is a safe one.
>
>The latter assumption doesn't ring entirely true. ARIN regularly vets
>requests from entities which have not previously interacted with ARIN.
>How is asking them to vet a request for a transfer out-region
>meaningfully more onerous?

[DA] The concern was more about volume than complexity. Staffing, expense,
etc.

>
>> Is there a middle ground or
>> alternative you would find acceptable in a proposal that did not define
>> the policies of another RIR?
>
>If anyone came up with a viable middle ground, I missed it in the
>noise. Maybe something like having the recipient RIR make the
>evaluation, but expect the RIR to apply the strictest merge of both
>RIR's recipient policies. Make that application a condition of the
>policy being deemed compatible.

[DA] This circles back to my concern of scalability, or what is practical.
If ARIN reviews all requests, the staff would likely have to scale up to
accommodate. This would have cost implications that would have to be
sorted out, outside of policy, but this could be an option.

[DA] To have the recipient RIR applying the strictest merge of both
policies, we would be expecting the staff of all the other RIR to become
proficient in the practices of ARIN Registration Services. I think that
crosses a line of what is reasonable for implementation.

[DA] I would be curious to hear from others whether the conditions of the
recipient RIR are a sufficient review or that they agree with Bill that
this is a bad direction.

[DA] While not perfect, the other consideration comes through the passage
of 2011-11 and/or 2011-12. If ARIN's requirement review for transfers is
increased to 12 or 24 months, than everyone's requirements may be at a
state of strictness that could be considered acceptable. Would a 24 month
window on transfers be enough to overcome your objection to the
recipient's RIR performing the review?


>
>Sort of like what happens in U.S. Courts: a large dollar lawsuit in
>state court can be removed to federal court when the parties are from
>different states. But when that happens, the federal court follows
>state law instead of federal law.
>
>Regards,
>Bill Herrin
>
>
>
>-- 
>William D. Herrin ................ herrin at dirtside.com  bill at herrin.us
>3005 Crane Dr. ...................... Web: <http://bill.herrin.us/>
>Falls Church, VA 22042-3004