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

Fri Jun 29 11:06:43 EDT 2012

As I previously told you Owen, we are asked once per week by a
prospective buyer or seller how these transactions can be accommodated
without enduring the rigors of justification.  When we identify the
risks for both buyers and sellers alike, they go quiet.  You wonder
where they go don't you?  I have a pretty good idea they simply seek
alternative means and providers.  So it's not fear mongering to suggest
people will disregard the registry.  Some do.  I cannot quantify it
because we neither endorse nor monitor.

Correct, as we are debating transfers you are correct to point out free
allocations in APNIC are needs-based.

Jeff Mehlenbacher

-------- Original Message --------
Subject: Re: [arin-ppml] ARIN-prop-176 Increase Needs-Based
Justification to 60 months on 8.3 Specified Transfers
From: Owen DeLong <owen at delong.com>
Date: Fri, June 29, 2012 10:38 am
To: <jeffmehlenbacher at ipv4marketgroup.com>
Cc: "Blecker, Christoph" <christoph.blecker at ubc.ca>, 
"arin-ppml at arin.net" <arin-ppml at arin.net>

On Jun 29, 2012, at 7:06 AM, <jeffmehlenbacher at ipv4marketgroup.com>
wrote:

> I also left out the part about the rational, open-minded postings by
> many members of the community suggesting it was worth
> considering...particularly where legacy resources not under contract are
> concerned. The opposition to the proposal was too often centered around
> the belief that speculating / hoarding / stock-piling and other
> fear-monger issues would be the result. Again, until such time as the
> market matures and statistical insight is available (particularly price
> per IP), we need not worry about speculation and capricious consumption.
> It's a sucker bet.
> 

Fear monger issues like the claim that people will disregard the
registry
system if we don't buckle under and remove policy preserving needs
basis?

Allowing the market to devolve into speculation and hoarding is the
sucker bet in my opinion.

> I don't think outright elimination of needs assessment on specified
> transfers should be swept under the rug permanently Owen. Things
> change. It wasn't so long ago that the APNIC community--one that is
> considerably larger and more complex than ARIN--had no needs-based
> justification (pre-October 2011). Needs-based justification was
> (re)introduced by APNIC only to enable a compatible needs-based policy
> with ARIN for inter-RIR transfer policy implementation.
> 

Nobody is sweeping it under the rug. We hauled it out into the light
and disinfected it in the court of public opinion.

Actually, I don't know to what extent you participated in or watched
the debate in the APNIC community, but, I do not agree with your
characterization. Yes, ARIN policy was a factor in the debate, but,
to claim it was the ONLY factor supporting adding needs basis to
APNIC transfer policy is specious.

Further, APNIC retained needs basis for all allocations/assignments
from the free pool. It was only ever removed for transfers, so claiming
that APNIC had no needs-based justification is also false. They had
no needs-based justification for transfers.

Owen

> Jeff Mehlenbacher
> 
> 
> 
> -------- Original Message --------
> Subject: Re: [arin-ppml] ARIN-prop-176 Increase Needs-Based
> Justification to 60 months on 8.3 Specified Transfers
> From: Owen DeLong <owen at delong.com>
> Date: Fri, June 29, 2012 9:20 am
> To: <jeffmehlenbacher at ipv4marketgroup.com>
> Cc: "Blecker, Christoph" <christoph.blecker at ubc.ca>, 
> "arin-ppml at arin.net" <arin-ppml at arin.net>
> 
> Jeff leaves out that the proposal was also rejected by tremendous
> opposition
> on PPML and in the show of hands at the PPM prior to the AC's rejection.
> 
> I don't know who advised him it was "too radical too soon". I would say
> that
> elimination of needs basis is simply not something the community wants
> to
> embrace. Given history, I expect that to be unlikely to change unless
> and
> until the makeup of the community is sufficiently tilted away from those
> interested
> in managing and operating networks and more towards those looking to
> extract value from the circulation of addresses and other derivatives.
> 
> Owen
> 
> On Jun 29, 2012, at 6:10 AM, <jeffmehlenbacher at ipv4marketgroup.com>
> wrote:
> 
>> Christoph,
>> 
>> Fear not, we are not dancing around the issue by proposing 60 months. 
>> On February 16th 2012, I submitted a policy proposal for the elimination
>> of needs-based assessment on 8.3 specified transfers. The policy
>> proposal read as follows:
>> 
>> 8.3. Transfers to Specified Recipients
>> In addition to transfers under section 8.2, IPv4 number resources within
>> the ARIN region may be released to ARIN by the authorized resource
>> holder, in whole or in part, for transfer to another specified
>> organizational recipient. Such transferred number resources may only be
>> received under RSA by organizations that are within the ARIN region and
>> requires that an Officer Attestation be provided confirming the
>> transferred number resources will be applied to enable current or
>> planned business models.
>> 
>> The proposal was rejected by a vote of 10-3 by the AC. I was advised
>> that changing the 24 months to an outright elimination was too radical
>> too soon.
>> 
>> Jeff Mehlenbacher
>> 
>> -------- Original Message --------
>> Subject: RE: [arin-ppml] ARIN-prop-176 Increase Needs-Based
>> Justification to 60 months on 8.3 Specified Transfers
>> From: "Blecker, Christoph" <christoph.blecker at ubc.ca>
>> Date: Thu, June 28, 2012 2:18 pm
>> To: "'jeffmehlenbacher at ipv4marketgroup.com'"
>> <jeffmehlenbacher at ipv4marketgroup.com>
>> Cc: "arin-ppml at arin.net" <arin-ppml at arin.net>
>> 
>>> -----Original Message-----
>>> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On
>>> Behalf Of jeffmehlenbacher at ipv4marketgroup.com
>>> Sent: June-28-12 6:37 AM
>>> To: Owen DeLong
>>> Cc: arin-ppml at arin.net
>>> Subject: Re: [arin-ppml] ARIN-prop-176 Increase Needs-Based Justification to
>>> 60 months on 8.3 Specified Transfers
>>> 
>>> Owen, I appreciate your continued concern for the health of our business
>>> model. However, your suggestion to wait for the free pool to run out
>>> (http://www.potaroo.net/tools/ipv4/index.html) and then wait another
>>> 6-12 months to view partial statistics within ARIN and ignore all other
>>> statistical evidence outside of ARIN's statistical capture isn't
>>> terribly compelling is it? Projecting free pool depletion and adding
>>> your outer limit of another 12 months might suggest we not touch 8.3
>>> justification duration until sometime 2014. One might be accused of
>>> "head in the sand" thinking if the community embraced such a position
>>> while inter-RIR transfers are afoot between ARIN and APNIC in July 2012
>>> followed by ARIN and RIPE in September 2012.
>>> 
>>> Again, in the here and now, I state based on our extensive dialogue with
>>> prospective buyers that there can be two categories of planners: those
>>> that will systematically continue to go to the 90-day well for free
>>> allocations and those, that if properly motivated by increasing the
>>> justification from 24 months to 60 months, will enter the 8.3 Specified
>>> Transfer market under ARIN policy. If efficiently allocating unused
>>> IPv4 legacy resources via policy improvements on 8.3 specified transfers
>>> prolongs IPv4 utilization and defers IPv6 adoption, I empathize only
>>> with the people and organizations who base their business models on
>>> evangelistic trumpeting of all things IPv6 and comment on IPv4 transfer
>>> policy proposals on that basis.
>>> 
>>> Jeff Mehlenbacher
>> 
>> Hi Jeff,
>> I'm wondering if it's possible to provide an idea of what a reasonable
>> IPv4 usage forecast for 60 months in the future looks like? With things
>> like IPv6 uptake and such, the major concern is that networks can't
>> reasonably plan what things will look like 5 years from now. Unless this
>> is the case, perhaps it would be better not to dance around the issue
>> and propose removing the needs-based requirement from 8.3 transfers all
>> together.
>> 
>> Without more details on what a reasonable 60-month IPv4 usage forecast
>> looks like, I cannot support the proposal as written.
>> 
>> Best regards,
>> 
>> --
>> Christoph Blecker
>> The University of British Columbia
>> 
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