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

[David Farmer]

On 6/28/12 05:05 CDT, 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?

While I'm not sure we can sit tight either, I do understand the desire 
for more information.  For those of you who think we need to extend the 
justification window, this is why I suggested that some modeling or 
other or other predictive analysis would be useful.  For those of you 
who say we should sit tight, the earliest this can go into effect is 
around the end of the year.  But more likely this is going to take more 
than one policy cycle, so realistically we're talking about this being 
implemented this time next year, or maybe even longer.  So I wold like 
to start the conversation now, its going to take time to build the 
necessary consensus.

> 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?

I think it was important to get the market started, I believe the change 
to 24 months was important for that to happen.  If we had tried for 36 
months last fall, we still might be arguing about it  Going for 24 
months last fall I believe got the market rolling.  However, with there 
still being a significant free pool it doesn't greatly concern me that 
we are not see an extremely vibrant market just yet.  I think it is good 
to start off slow, but we needed to get things started.  So from that 
point of view 24 months has been successful.  This is why I supported 24 
months as a first step.

I believe that a next step is needed, I'm not sure if that is 36, 48, or 
60 months, or the exact timing, now (6 months), soon (12 month), or a 
little longer (18 to 24 months) out, but I do think we will need a next 
step and it is important to start the discussion now.  I also think we 
should even consider other options like a triggered policy, maybe when 
the free pool gets to some level (say one /8) then go to 36, 48, or 60 
months.  Remember predictability is what people are looking for, this is 
why I believe even if you don't agree we should change it yet, you 
should want to start the conversation.

Believe it or not I believe we are making progress.  We (the community) 
have decided we need transfers, that we want to maintain justified need, 
and the need window is probably the primary knob that we can make 
adjustments with.  These are all good things, and I think we are 
building a win-win scenario here.  Even though IPv4 run-out might look 
like a zero-sum game, the Internet is not, remember Metcalfe's law.

http://en.wikipedia.org/wiki/Metcalfe%27s_law

No one here has absolute authority here, even ARIN, but no one has an 
absolute right to do as they please and ignore everyone else either, or 
we all loose, because that would kill the network effect we are all 
benefiting from.  Therefore, we have to keep working together, and we do 
so because the network effect tells us it is in our own self interest to 
do so.  The most important thing I ask both extremes to do is stop 
attacking each other and focus your efforts on persuading the rest of us 
on the.

So as I've said, I'm skeptical of 60 months, but think a next step is 
necessary.  I would like a constructive conversion on;  How fare the 
next step should be, 36, 48, or 60 all seem like logical options;  And, 
when now (6 months), 12, 18, or 24 months out, or maybe triggered.  Are 
there other that make sense?  What do you think?

Thanks.

-- 
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David Farmer               Email:farmer at umn.edu
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota	
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