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

[sandrabrown at ipv4marketgroup.com]

It is out of line that a member of the ARIN AC would attack the business
model of IPv4 Market Group in this forum.  All Jeff Mehlenbacher has
done is propose a policy.  He does not sit in conflict on the AC where
he votes on policies that affect his business.  And that is what most AC
members do every day.

May I make a suggestion that any member of the AC who is remotely in
conflict on an issue should recuse themselves from voting or opining on
an issue.  Consider the case of Owen, whose company would benefit from a
faster conversion to IPV6, and whose attitudes on policy suggest he
would not like to see IPv4 made more readily available:
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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
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If we wait another 24 months while companies clamor for IPv4, whose
company would that benefit, Owen?  Is this an unbiased opinion?  Don't
you think you should recuse yourself or perhaps step down from the AC
for espousing an opinion that benefits your company and does not benefit
the community at large?
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And Mr Dan Alexander, how can you have an opinion on needing IPv4
addresses, when the ARIN clearly took care of its own in 2010?  How can
someone from Comcast possibly speak as myself?  Are you offering to
recuse yourself from Comcast for the 30 minutes you look at ARIN stuff? 
Did you recuse yourself from ARIN when Comcast was granted the large
allocation in 2010?
 
http://www.internetgovernance.org/2010/11/02/arin-grants-comcast-ipv4-mega-allocation/
 
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I'm opposed to this proposal.

Dan Alexander
Speaking as myself

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I think the ARIN AC and Board should consider conflict of interest
situations and when it is appropriate and not appropriate to voice an
opinion and to vote on issues in front of the Board.  And I would not be
saying this if the business model of our company was not attacked by a
member of the ARIN AC in this forum - totally inappropriate behavior
even for a body that has members in constant conflict and is above
normal business ethics.
 
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I think it's time the silent minority scolded the AC for this bad
behavior.    Your support in suggesting that the AC members not vote on
issues where they self-benefit, would be a great help to a free market
internet.

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Secondly, I am highly critical of ARIN, the ARIN AC, and the ARIN Board,
for not understanding their most important function and purpose with
respect to legacy addresses.  If you truly want to protect and safeguard
the Internet, consider the following:
 
The most important function ARIN can provide with respect to legacy
resources is an accurate registry. Failure to do this jeopardizes the
financial and social safety of the internet. 

Current ARIN policies in fact do not ensure an accurate registry and
thus do not support a safe Internet. 

Today many legacy address holders do not have contracts with ARIN. The
prudent ones avoid contracts with ARIN because they correctly recognize
legacy addresses will ultimately be worth more than non legacy addresses
on the open market. 

A /16 seller typically complies with ARIN policy in selling because it
is not worth the relatively small sale proceeds to risk ARIN’s threat
of court action, even though there is little likelihood that ARIN would
prevail in court. A larger block seller is not afraid of the court costs
or of losing in court, but may fear the stigma of publicity. 

When a legacy IP holder chooses not to comply with ARIN policies,
problems begin, because the IP holder also dodges the registry update
step. When there is no corresponding registry to reflect these
transactions, it opens the door for ISPs to receive other announcement
requests without ARIN registrations and then hijacking and misuse
becomes easier. Over time, as the ARIN registry has less relevance, the
registry becomes meaningless as a tool to determine who has permission
to use IPs and then control becomes more ad hoc. It is then that I
believe that financial and possibly social misuse of ips will become
more common. 

The ARIN AC should realize that while it may never face a legal
challenge for the reasons outlined two paragraphs ago, it does have a
social responsibility. IP sales are now common. The right thing to do
would be to:

1) cease to attempt to govern resources over which ARIN has no legal
right. RIPE and APNIC don't govern legacy resources and the precedent
they set should be followed by ARIN. 
2) Allow transfers of otherwise dormant resources with no needs
justifications so long as the recipient organizations can be classified
as an ISP or end user per the NRPM (there I even threw in some
ARIN-ese). Otherwise they sit unused and no one benefits. If you don't
stop needs justifications on these blocks, too many of these
transactions go underground. 
3). If you just don't get it, as clearly Owen and others don't want to
(apparently speaking only as themselves?), a 60 month justification
period is a poor compromise. 24 months won't keep a transaction from
going underground. We see that today as legitimate buyers approach us
and then disappear after they learn from us that they fail the ARIN
prequalification. 

So while the ARIN’s AC policy making rules are fine in a bubble, the
real world is not a bubble. IPs have escalating value, and many IPs will
be used by entities not listed in ARIN’s registry. I do not see how
ARIN can reclaim a valued resource from a company that is profiting from
it, especially when sister RIR’s, RIPE and APNIC, do not make similar
claims. As the ARIN registry becomes more inaccurate within the current
ARIN policies, then it will continue to become easier and easier for
highjacking and misuse. 

And I have not even spoken to Milton's free market arguments, which by
the way, are absolutely correct.  The ARIN policies are like wage and
price controls gone mad.  

Sandra Brown