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

[Jimmy Hess]

On 6/29/12, Milton L Mueller <mueller at syr.edu> wrote:
> oops. You may not realize it, but you just admitted that there is no such
> thing as "the community." You've observed that the people involved here fall
> into a variety of different groupings with different interests - legacy
> holders, speculators, prospective buyers who "want more resources than they
> can justify," and others, good guys like you and Hurricane and Comcast.

Let's be really really clear.  The ARIN community consists of
Internet Service Providers and network operators,  that require
number resources for the purpose of connecting their networks
together,  using IP, and require the WHOIS service to help coordinate
with other networks, for reliable connectivity, and minimal network
abuse.    If you're anyone else, you are not a member of the community
that it's ARIN's job to provide services to.

If you happen to by coincidence  be both a speculator AND an ISP, or
both a prospective buyer, and the operator of a network.

Then you are a member of the community,  but your special interests or
roles as "speculator",   "prospective buyer",  "academic", or
whatever,  have nothing to do with the community, and should be left
at home.

Although you're certainly allowed to share your opinions and views,
you should ensure that you disclose any special financial or personal
interest you have.

And ARIN in providing proper stewardship of the resources,  should be ensuring
that factions except "network operator"' organizations (and network end user)
organizations'   are not being served,

Especially not at the expense of ISPs and network end users  best interests
specifically in those roles.

And that should be true,  even if  non-Network operator  factions
become more numerous
on PPML and policy meetings,   due to the fact the financial
incentive,  might encourage
more aggressive participation,  in order to manipulate policy.

ARIN should be sure to recognize and reject any manipulation efforts of that
nature that are not in the interest of the specific  community ARIN
exists to serve.



> As my previous message indicated, I have a very strong suspicion that the 24
> month period is arbitrary and has no more or less support than 60 months or
> 12 months or 6 months. But since you are saying that the data does not

The 24 month period is surely an arbitrary number that was chosen, but there
was some agreement to, but the contention that it  is no more/less
supported than 60 months  is wrong.


> Tell me: what _kind_ of data would indicate to you that a change is
> warranted? Would it be something like a yield curve for address blocks?

There are three things that all need to be shown simultaneously,
before there's any reason to believe the justification period is too
short:

1. Proof of an unmet need for IP addresses in the region, for the
purpose of actually running networks, per the RFC2050 criteria;  there
must be organizations actively seeking resources who are not getting
them,  because there are not enough resources offered by specified
transfer.

2. Lack of interest by organizations seeking IPv4 resources through
specified transfer
OR  organizations that have unused resources leaving them idle and
neither returning
to ARIN nor offering by specified transfer  (an actual showing that
organizations really are not participating in the transfer market due
to the inefficiency caused by the requirement  that they execute
multiple transfers instead of just one).


3.   That there is no  equally expensive, less expensive, or more
familiar/convenient source of IP addresses than specified transfer.
Until (3) is met, there is no possible data that will show that a
longer justification period is suitable, justified, necessary, or
appropriate.

For example:  as long as there are free pool resources  available at
similar cost,  Transfer is a less attractive option,  because  direct
allocation from a pool is adequate,  and with a high likelihood
provides  "Virgin"   IP addresses   that have never been allocated
before, and probably aren't on blacklists.

Also, as long as there is still a free pool,  organizations in the
ARIN region  that have dealt with ARIN in the past are likely to
continue to make their additional resource requests  through ARIN,
because they have dealt with ARIN in the past,  there is a degree of
familiarity and trust.

Transfer resources must be significantly less expensive, before many
organizations will consider taking on added risk of dealing with
potentially unfamiliar third parties,  and lengthening the process of
getting their resources. They may even prefer to acquire other orgs
altogether,  and perform 8.2 transfers instead.

As long as there is a free pool, the data is expected to be skewed,
and therefore
unreliable.


-- 
-JH