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

[Alexander, Daniel]

Jeff,

One of the primary justifications used during the debate of 8.3 transfers
claimed that transfers would put underutilized resources to use. By
stretching the period to five years, we start trading one underutilized
resource holder for another. This is a contradiction to the claimed
benefits that everyone was supposed to accept who objected to these
transactions. 

No sooner than section 8.3 was created the policies came in to expand the
timeframes. The timeframes have already been expanded before having any
data as to the benefits or consequences of the changes that have been
made. While I don't claim to know what the magic number should be, I think
this change would be irresponsible at this time, based only on the
speculations made on this mailing list.

I'm opposed to this proposal.

Dan Alexander
Speaking as myself


On 6/27/12 3:56 PM, "jeffmehlenbacher at ipv4marketgroup.com"
<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
>
>
>
>
>_______________________________________________
>PPML
>You are receiving this message because you are subscribed to
>the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
>Unsubscribe or manage your mailing list subscription at:
>http://lists.arin.net/mailman/listinfo/arin-ppml
>Please contact info at arin.net if you experience any issues.