[arin-ppml] ARIN-prop-176 Increase Needs-Based Justification to 60 months on 8.3 Specified Transfers

[Michael Sinatra]

A few months ago, I floated the idea of extending the time horizon for 
8.3 transfers to 36 months.  The only comment I got back was an AC 
member (possibly speaking for himself only) making the valid point that 
we should see how things go at 24 months.  I agreed at the time.

2011-12 extended the needs window to 24 months and it was implemented 
just about four and a half months ago.  Given the short timeframe, I am 
having a hard time understanding the rationale for the proposal; 
specifically how the 24-month window creates significant uncertainty, 
or, more importantly, how we know it to be so.  I am sure that a 
registered STLS Facilitator like Jeff has a better window into that 
issue that I do, but I can't imagine it's a good enough window to draw 
such a conclusion.

(It's worth noting that at my most recent job, I was hired on to a 
24-month contract, with no guarantee of re-appointment at the time of my 
hiring.  Contrary to the implications of the rationale, 24-month time 
horizons appear to be quite frequent in free markets.)

Opposed as written.

michael

On 06/26/12 11:46, ARIN wrote:
> ARIN-prop-176 Increase Needs-Based Justification to 60 months 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-176 Increase Needs-Based Justification to 60 months on 8.3
> Specified Transfers
>
> Proposal Originator: Jeff Mehlenbacher
>
> Proposal Version: 1
>
> Date: 26 June 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
> 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 60 months.
>
> Rationale:
> The IPv4 transfer market is a necessary vehicle to effectively
> reallocate from those with excess to those with need. The ARIN community
> has spoken regarding the importance of maintaining a needs-based
> justification system for all 8.3 Specified Transfers. However, 24 months
> need is far too short a planning horizon for potential buyers
> contemplating a significant financial transaction which ensures business
> continuity.
>
> For both sellers and buyers, increasing from 24 to 60 months promotes
> considerably more certainty for transaction approval. Such certainty has
> been repeatedly expressed as the single greatest requirement for
> allocating human (business, legal, administrative) and financial
> resources in a legitimate transfer process.
>
> Timetable for implementation: Immediate
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