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

[David Farmer]

On 6/29/12 17:14 CDT, Owen DeLong wrote:
>
> Sent from my iPad
>
> On Jun 29, 2012, at 5:13 PM, David Farmer <farmer at umn.edu> wrote:
>> On 6/29/12 10:06 CDT, jeffmehlenbacher at ipv4marketgroup.com wrote:
>>> 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.
>>
>> We need to find middle ground here guys.
>>
>
> 24 months _IS_ middle ground. Continuing to negotiate for half-way to infinity in an iterative process is a perversion of Zeno's paradox designed to effectively achieve infinity over time.
>
> Calling for iterative middle ground is equivalent to calling for infinity.

I agree with that, however the above didn't say anything about 60 
months.  We all need to practice a little more active listening. I'm 
referring to what he is really asking for, or more precisely what he is 
being asked for;

"we are asked once per week by a prospective buyer or seller how these 
transactions can be accommodated without enduring the rigors of 
justification."

>> Jeff, and others,
>>
>> Needs justifications are not going to go away, so stop asking for the community to make it go away, its not going to happen.
>>
>> However, on the flip side,
>>
>> Owen, and others
>>
>> The community does need to find way of simplifying the process and make needs justification less of a burden if transfers are going to work the way we need them too.  If we don't then people will find a way around the process.  Owen, you're fond of John Gilmore's quote about the "Internet routing around damage," well if our policies create damage they will get routed around too and that's not fear mongering.
>
> True, but at 24 months, I am not convinced we are creating damage. (other than the damage caused by the extended dichotomy between free pool justification and transfer justification periods). Going to 36 months or 60 months would only exacerbate that damage.
>
>
>> So trying to think outside the box here, what if we created some special rules that simplified demonstrating operational need for smaller transfers but still fundamentally kept reasonable needs justifications in place overall.
>
> I'm amenable to discussing that. It sounds reasonable on the surface. However, I don't find it terribly difficult to justify operational need for a smaller allocation/assignment and I believe that the bar for operational need for a transfer is identical to that for an allocation/assignment.

What you and I think is difficult or not is honestly irrelevant, I here 
this complaint all the time.  Not just through Jeff

>> - Allow any organization to receive a transfer of an unaggregated /24, that the original assignment was a single class C or a /24 that is not part of a larger range of addresses held by the same organization originating the transfer, on the condition that the recipient puts it into operational use within 6 month and they cannot receive another such transfer for 24 months without demonstrating justified need.
>
> I would be OK with that if they can show that it is at least 50% utilized within 6 months and not merely routed.

I was thinking routed and actual devices using it, no particular 
utilization level, but with a contractual claw-back for failure to meet 
the requirement.  If you want a waiver from the normal process you 
better meet your commitments.

The intent here is to facilitate getting old unused Class C's into use.

>> - Allow any organization to receive a transfer of up to 50% of their current holdings or /16 which is ever is smaller on the condition that the recipient puts it into operational use within 6 month and they cannot receive another such transfer for 24 months without demonstrating justified need.
>
> I could accept this with the same caveat above if it were limited to /20.

The intent here is to facilitate getting old unused Class B's into use.

>> - All transfers larger than /16 require demonstrating justified need with a window of 24 or maybe 36 months.
>
> 24 months, yes. (current policy already). 36 months, uh, no. See my above concern about damage.

I'm fine with 24, if we find can loosen up for the smaller stuff, the 
big guys have the technical and legal staff, and financial resources to 
make it work.  But, I completely believe that requiring both financial 
resources and rigorous justification maybe asking to much.

I also believe we can't eliminate justified need, to prevent market 
power plays, but no one is going to corner the market with a /16.

>> This probably needs work on the details, but is something like this a workable compromise?
>
> Within the constraints I described above, perhaps.
>
> Owen
>

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