[arin-ppml] ARIN-prop-204 Removing Needs Test from Small IPv4 Transfers (Sandra Brown)

[sandrabrown at ipv4marketgroup.com]

Support.

I have been discussing the topic of reducing need with Andrew Dul and
Owen DeLong at and since ARIN33 in Chicago.  I too had reached the
conclusion that the right approach was for reduction of needs
justification for /16 and smaller, so I am very pleased to support this
proposal.  

Small businesses and ARIN staff should not be wasting their time on
needs justification of IPv4 addresses for /16 and smaller.  

ARIN should not be determining whether a small business needs a /16 or
smaller in order to conduct its business.  This is up to the business,
not a pseudo-governmental authority, such as ARIN.

The historical rationale for needs justification was to prevent
hoarding.

As David Huberman said, a small number of companies get MOST of the IP's
via the free pool.  In other words, the ARIN needs justification process
allows a small number of large companies to get a boatload of free IP's.
 But I talk to medium sized and small companies every day that cannot
get small blocks out of the free pool through the ARIN process.  The
needs justification process just does not work for them.

In THIS proposal we are talking about paid for transfers only.  The fact
there is a dollar amount attached to the transfer, is one impediment to
hoarding.

BUT:  With the limitation of the transfer size to a /16 or smaller, it
would take a lot of transfers to hoard.  It would take 256 transfers to
stockpile a /8.  This is the 2nd means to prevent hoarding.  Most
companies wanting that many IP's would simply do needs justification. 
With the ARIN affidavit by a company officer already needed for an 8.3
or 8.4 transfer, this is a 3rd deterrent to hoarding.  4thly the very
wide distribution of the IPv4 address pool is a deterrent to hoarding,
as it would take agreements and purchases from a vast number of
suppliers, each willing to transfer a vast number of /16's, for
significant hoarding to take place.  There is no danger of hoarding with
this proposal.

Most significantly, it will start to bring ARIN Region into the global
IPv4 internet age, where the RIPE community is leaving North America in
its dust.  RIPE NCC realized it would better support small business by
removing impediments such as needs justification.  This is ARIN region's
opportunity for North Americans to catch up and allow our small internet
and telco businesses to be competitive and thrive. 

Sandra Brown
IPv4 Market Group