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

[jeffmehlenbacher at ipv4marketgroup.com]

I understand your desire to sit tight and assess statistical evidence
before suggesting a longer justification period is required. My concern
with such a strategy is the decided lack of comprehensive transfer
market data.  We have only the ARIN Specified Transfer Listing Service
(STLS) and ARIN Statistics on 8.3 transfers (# Requested / # Completed).
 Is there another source you would consider useful to assess the
appropriateness of extending the 24 months justification period?

The STLS would suggest there is no market at all.  In 2012, there was an
update in February (a Facilitator was added) and two updates in June (a
Facilitator was removed and another added).  The last and only Seeker
(Needer/Buyer) was December 2011 and it was a post-facto pre-approval of
a public transaction in progress.  Only two Listers (Sellers) have ever
posted since November 2010...the most recent Lister being October 2011. 
It may be safe to say the STLS is a vehicle that doesn't attract
interest and thus cannot be used as a reliable statistical measure for
the purpose of monitoring the appropriateness of the current
justification period.  Now, if we implemented 60 months justification
for a 1-year period and monitored uptake on the STLS for
Listers/Seekers, that might be evidence that longer justification
periods a) bring unused resources (listers) to market and b) bring
organizations with need (seekers) forward.

ARIN Statistics on 8.3 transfers further suggests the market is far from
vibrant: 24 requested in 2011; 12 requested 2012 year-to-date.  The
issue with these statistics is the limited insight one can glean.  Yes,
the number of completed transfers is published but it is a running total
and doesn't correspond directly, on a month to month basis, with the
number of transfers requested.  Further, we do not know anything about
the recipient organizations including block size requested, previous
ARIN customer or new ISP, ISP or End-User, size of last allocation from
the free pool...and most importantly, whether 24 months was too short a
window to obtain transfer approval.

So what statistical evidence will constitute success or failure of the
current 24-month justification period? 

Jeff Mehlenbacher
IPv4 Market Group
Email: jeffmehlenbacher at ipv4marketgroup.com




-------- 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 9:55 pm
To: Scott Leibrand <scottleibrand at gmail.com>
Cc: jeffmehlenbacher at ipv4marketgroup.com, arin-ppml at arin.net


On Jun 27, 2012, at 1:43 PM, Scott Leibrand wrote:

On Wed, Jun 27, 2012 at 1:14 PM, Owen DeLong <owen at delong.com> wrote:
 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.


I would agree that this is the goal we're trying to optimize for.


 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.


I agree that with a 60 month justified need threshold we do have a risk
of organizations will acquire more space than they have immediate need
for, and that the addresses will not be in use for some time after
they're transferred.  However, there is another case we need to be sure
not to ignore.  If organizations holding (and not using) legacy space
are disinclined to transfer it due to ARIN's restrictions, then those
addresses will not be in use (or held by those that have justified need)
either.


I'm not sure that 60 months is the right threshold at this time, but I
do think we need to figure out how to balance the incentive for address
holders to release space to those with justified need against the
possibility that organizations will acquire more addresses than they
have immediate need for.


-Scott



Let's let 24 months sink in long enough to have real data before we try
to push the line significantly farther in what I consider to be the
wrong direction.


Owen