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

[Cameron Byrne]

On Jun 28, 2012 4:17 AM, "Owen DeLong" <owen at delong.com> wrote:
>
>
> 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
>
>

+1 to Owen's comments.

Opposed to 176.

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