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

Fri Jun 29 09:00:25 EDT 2012

Hello Tom,

Thank you for weighing in on this proposal.  Please permit me to preface
my statistical suggestions with a couple of points:

1.  I neither suggested it was valid to wait for statistical evidence
before considering the merit of extending the window for justification
nor did I suggest the current statistics available through ARIN were
sufficient to evaluate the appropriateness of the current justification
window.  Two other AC Members suggested that would be a sensible
approach.  I do not believe published statistical tables currently
exists to support such an assessment and it's perhaps a deferral
strategy on behalf of those individuals opposed to the policy proposal.

2.  My proposal is founded on the very simple principle: reallocating an
organization's unused IPv4 blocks to a legitimate ISP or End User via an
ARIN-approved 8.3 Specified Transfer is a good thing for the community
and should be made as painless as possible.  60 months justification
promotes a much, much higher degree of certainty to enter into an 8.3
transfer and thus all parties (sellers and buyers) will be more willing
to participate.  Unused IPv4 blocks are revitalized, the registry is
more accurate, etc.

Having said that Tom, I believe statistics that might lead the community
to a better understanding of what has transpired the last 17 months
under 8.3 are readily available.  They simply are not published by ARIN.
 What we know with certainty is how many 8.3 transfers have been
requested, and how many have been completed.  We do not understand the
one to one relationship of request and approval/rejection because it's a
rolling monthly total.  I believe that before we attempt to use any
statistics we should understand the data elements that are captured, the
accuracy, and the utility to evaluate such things as whether the 24
month justification window is appropriate.  I would suggest the
following data elements (not a comprehensive list) are captured but
currently not published...if Mutual NDA's prohibit said, it's really a
matter of modifying said Mutual NDA to ensure that generic data may be
collected and published:

1.  Date of Request for 8.3 Specified Transfer
2.  Status of Transferring Block (Legacy, LRSA, RSA)
3.  Size of Block (/16, /17, etc.)
4.  Source SIC Code
5.  Recipient NRPM Definition: ISP or End User
6.  Recipient Customer Status with ARIN: Customer or Non-Customer
7.  If ARIN Customer, date and size of last allocation from the free
pool
8.  Current percent utilization of existing blocks
9.  Number of Justification re-submissions for transfer
10. Approval or Rejection decision
11. Approval or Rejection rationale (codes 1-?)
11. Date of Approval or Rejection
12. Facilitator Involvement (yes/no)
13. Price paid (US$)

I'm surely missing a half dozen other data elements that are captured
during an 8.3 but my point is, there is considerable data...will it
support the notion that 24 months is the correct window?  Very loosely
at best, but it would assist all interested parties in better
understanding the 8.3 transfer market.  Publishing price however is
going to be an entirely separate debate isn't it?  I quietly muse at all
that would suggest 60 months will permit speculation or hoarding. 
Really?  What are you speculating on in the absence of known prices and
continuous updates?  If however, prices are published, now you have the
basis to speculate as is the case in every open market system (real
estate, stock market, etc.).

As for other well-established markets, I have thoughts but would suggest
there are individuals who participate on the PPML better qualified to
suggest objective models for assessment purposes. 

Jeff Mehlenbacher

-------- Original Message --------
Subject: Re: [arin-ppml] ARIN-prop-176 Increase Needs-Based
Justification to 60 months on 8.3 Specified Transfers
From: Tom Vest <tvest at eyeconomics.com>
Date: Thu, June 28, 2012 11:59 am
To: <jeffmehlenbacher at ipv4marketgroup.com>
<jeffmehlenbacher at ipv4marketgroup.com>
Cc: Daniel_Alexander at Cable.Comcast.com, arin-ppml at arin.net

Hi Jeff, 

Out of curiosity, could you suggest ( at min.) one set of data that
would be sufficient, in your view, to determine the appropriateness of
a(ny) IP number resource transfer market, under current or any other
imaginable policy criteria? How would you define "appropriateness" and
what sort of data would you need to make such a judgment? 

If this question seems too abstract, perhaps you could point us to some
other, well-established market that demonstrably satisfies its own
"appropriateness" criteria based on "objective" data that is, if not
publicly available, at least available to some disinterested
"appropriateness evaluators"? 

Thanks, 

Tom Vest

On Jun 28, 2012, at 6:25 AM, <jeffmehlenbacher at ipv4marketgroup.com>
<jeffmehlenbacher at ipv4marketgroup.com> wrote:

> <snip> I have a real concern that the body of data available for assessment is neither comprehensive
> nor focused on dictating success or failure of the current 24 month
> justification period. I would be interested in understanding what data
> will be monitored to determine the appropriateness of current policy for
> 8.3s.
> 
> Thanks!
> 
> Jeff Mehlenbacher
> 
> 
> Date: Thu, 28 Jun 2012 08:11:24 +0000
> From: "Alexander, Daniel" <Daniel_Alexander at Cable.Comcast.com>
> To: "arin-ppml at arin.net" <arin-ppml at arin.net>
> Subject: Re: [arin-ppml] ARIN-prop-176 Increase Needs-Based
> Justification to 60 months on 8.3 Specified Transfers
> Message-ID:
> <B64177493F39BA4A81233AA84B50049E5A2BA30E at PACDCEXMB12.cable.comcast.com>
> 
> Content-Type: text/plain; charset="Windows-1252"
> 
> Jeff,
> 
> One of the primary justifications used during the debate of 8.3
> transfers
> claimed that transfers would put underutilized resources to use. By
> stretching the period to five years, we start trading one underutilized
> resource holder for another. This is a contradiction to the claimed
> benefits that everyone was supposed to accept who objected to these
> transactions.
> 
> No sooner than section 8.3 was created the policies came in to expand
> the
> timeframes. The timeframes have already been expanded before having any
> data as to the benefits or consequences of the changes that have been
> made. While I don't claim to know what the magic number should be, I
> think
> this change would be irresponsible at this time, based only on the
> speculations made on this mailing list.
> 
> I'm opposed to this proposal.
> 
> Dan Alexander
> Speaking as myself
> 
> 
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