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

[Owen DeLong]

On Jun 28, 2012, at 3:05 AM, <jeffmehlenbacher at ipv4marketgroup.com> wrote:

> 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?

I consider that adequate. (primarily the latter and not the former).


> 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.

The fact that transfers have been completed would suggest that there is
a market at a time when rational policy would render one irrelevant or
at least nearly non-existant. So long as there is a free pool, policy which
makes transfers more attractive is contrary to the good of the community.

Judging anything about specified transfers and policy effect therein is
premature until after free pool runout.

> 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.

Far from vibrant is the desired and rational state prior to runout as far as
I am concerned, so I am not seeing the problem. I realize this doesn't
necessarily help your business model, but, I think it is in line with the
intent of the community. The market is currently competing against
essentially free allocations and assignments (after all, you have to pay
registration fees after you transfer through the market anyway, so,
there's no price advantage there). This means that the only advantage
to purchasing through the market at this time is the convenience of
a longer allocation or assignment period.

This should result in a small and lack-luster market until free pool
exhaustion and as near as I can tell, the result is in line with that
intent.

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

Let's see what the transfer statistics look like 6-12 months after ARIN
free pool exhaustion. At that point, if there are still not many transfers,
then I will accept that 8.3 is not working as intended. Until that time,
I would argue that increasing the number of transfers by skewing
policy to give undue advantage to market transfers over free pool
allocations/assignments is contrary to good stewardship.

Owen