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

Wed Jun 27 16:30:13 EDT 2012

Then I assume you'll be reclaiming all unused resources (legacy or
otherwise) as "the goal of ARIN policy is to see that addresses are held
by those that have justified need."  Didn't we just go through that pain
on the PPML?

The horses have left the barn Owen.  There is an active transfer market.
 Eliminating 8.3 just means ARIN will no longer be part of the process
and the registry will be further eroded over time.  The objective should
be to encourage companies to participate by making the process as
pain-free as possible while still maintaining ARIN involvement in
transfers of number resources.

Jeff Mehlenbacher

-------- Original Message --------
Subject: Re: [arin-ppml] ARIN-prop-176 Increase Needs-Based
Justification to 60 months on 8.3 Specified Transfers
From: Owen DeLong <owen at delong.com>
Date: Wed, June 27, 2012 4:14 pm
To: <jeffmehlenbacher at ipv4marketgroup.com>
Cc: michael+ppml at burnttofu.net, arin-ppml at arin.net

The concern is not about the speed of free pool depletion (at least from
my
perspective). Afterall, we're talking about transfers -- addresses which
by
definition are already not part of the free pool.

However, the goal of ARIN policy is also not to optimize for your
particular
business model. The goal of ARIN policy is to see that addresses are
held
by those that have justified need.

A 60 month justified need for a resource as constrained as IPv4 is
simply
will not further that policy goal and will, in fact, be contrary to it.

24 months is bad enough. As others have said, 24 months was a bad
compromise. I'm sure we will, indeed, continue to see a flurry of these
proposals to extend the time line in the interests of commerce. This is,
in fact, part of the problem set which has led me to generally oppose
having a paid transfer market and which led me to vehemently oppose
having one outside of the exigent circumstances of IPv4 runout.

As a trial balloon...

How many would support the following proposal if I were to submit it:

Type: modify
Policy statement:

Delete section 8.3 from the NRPM

Owen

On Jun 27, 2012, at 12:56 PM, <jeffmehlenbacher at ipv4marketgroup.com>
wrote:

> Appreciate the background Michael. In the past twelve months, we have
> had over 300 communications with potential buyers and sellers of IPv4
> address blocks. There was dissatisfaction with 12 months justification
> for 8.3 and on February 10, 2012, when 24 months was introduced, it was
> met with a collective "shrug of the shoulders" by the prospective buyer
> community in ARIN region. This is what we hear with a very high degree
> of consistency:
> 
> From prospective buyers--they are loath to continue going back to the
> ARIN trough every 90-days seeking another allocation and having to
> justify said...but they are equally loath to participate in a specified
> transfer and compound technical involvement with legal, business,
> administrative involvement only to receive a 2 year supply--and--receive
> the added privilege of paying for the benefit of a transfer and
> undergoing exactly the same scrutiny for justification of an unused IPv4
> block. They would rather seek a larger block with a 100% measure of
> certainty that said will be approved based on 60 months allocation. One
> effort, one time--five years of business continuity and thus the ability
> to focus on managing growth.
> 
> From sellers (majority are legacy /16 holders)--it has become
> increasingly obvious to each that full transfer of their /16 in one
> transaction is possible, but rare. There is a rather narrow market of
> companies that could justify such a block size over 24
> months--particularly when free allocations to most of these companies
> still abound. So sellers are dissatisfied with 24 months because they
> are often forced to split /16s (for example) into a /17 and two /18s. 
> If a /16 is split into a /17 and two /18s—you are talking about the
> seller applying 3x the technical, business, administrative and legal
> effort to transfer unused resources. Sellers therefore would be more
> receptive to engaging in specified transfers if the buyer market was
> broadened via 60 month need. This enables a much higher probability the
> entire block could be transferred at one time thus making sellers of
> unused IPs much more likely to enter the specified transfer market.
> 
> If ARIN adopts a 60 month justification period on 8.3 specified
> transfers, I simply do not believe it will materially affect the speed
> at which the free pool is or isn't depleted. There will be those
> companies that elect to systematically apply for resources every 90 days
> and those companies with financial wherewithal will be much more
> inclined to participate in 8.3 specified transfers.
> 
> 
> Jeff Mehlenbacher
> IPv4 Market Group
> Email: jeffmehlenbacher at ipv4marketgroup.com
> 
> 
> Date: Tue, 26 Jun 2012 18:11:17 -0700
> From: Michael Sinatra <michael+ppml at burnttofu.net>
> To: arin-ppml at arin.net
> Subject: Re: [arin-ppml] ARIN-prop-176 Increase Needs-Based
> Justification to 60 months on 8.3 Specified Transfers
> Message-ID: <4FEA5DB5.6060108 at burnttofu.net>
> Content-Type: text/plain; charset=ISO-8859-1; format=flowed
> 
> 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
> 
> 
> 
> 
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