[arin-ppml] ARIN-prop-204 Removing Needs Test from Small IPv4 Transfers

[sandrabrown at ipv4marketgroup.com]

I would like to address Mr. Herrin's questions below.

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Message: 2
Date: Wed, 30 Apr 2014 17:39:03 -0400
From: William Herrin <bill at herrin.us>
To: John Springer <springer at inlandnet.com>
Cc: "arin-ppml at arin.net" <arin-ppml at arin.net>
Subject: Re: [arin-ppml] ARIN-prop-204 Removing Needs Test from Small
 IPv4 Transfers (fwd)
Message-ID:
 <CAP-guGVxkHBOdL6VKAGwB7Z=SRr0RzaQQ6K5gsnAaq-gVkjzvg at mail.gmail.com>
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On Tue, Apr 29, 2014 at 1:35 AM, John Springer <springer at inlandnet.com>
wrote:
> ARIN-prop-204 Removing Needs Test from Small IPv4 Transfers
>
> Policy statement:
> Change the language in NRPM 8.3 after Conditions on the recipient of the
> transfer: from "The recipient must demonstrate the need for up to a 24-month
> supply of IP address resources under current ARIN policies and sign an RSA."
> to "For transfers larger than a /16 equivalent, the recipient must
> demonstrate the need for up to a 24-month supply of IP address resources
> under current ARIN policies and sign an RSA."

How would we go about assessing whether such changes prove harmful or
helpful? 
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1.  There was the interesting statistic that 11 companies get x% (need
David to restate) from the free pool.
meaning that the free pool is not going to the vast number of small
businesses in North America, even though
all statistics show them to be the largest employers.
2.  There is the interesting discussion on this very PPML of the case of
 Derek Calanchini who can't get IPv4 addresses with current ARIN rules. 
I hear these stories every week.  I'm sure ARIN staff could tell you
these stories and give you metrics, if they tracked them.
3.  It will not touch the free pool, and if anything, will cause more
transfers of previously allocated IP's, not free ARIN IP's, and
therefore, could cause the ARIN free pool to last longer.
4.  Transfer stats are currently very low.  ARIN staff publish these. 
Simply watch how they trend over time to assess change.
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What metrics does ARIN collect under this policy which can be
analyzed and presented here so we can consider expanding it to larger
transfers? 
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1.  Publishes all transfers (and there are not very many of them today).
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Does no justification mean no documentation?
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1.  8.3 and 8.4 still require affidavits and "proof of ownership".
2.  Still require a transfer fee.
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What makes you think /16 is the right place to start testing this
idea? 
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1.  Will cover, in my estimation, and I'm sure ARIN staff can tell you
more accurately, 95-99% of transfers.
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Traditionally /24 was the last no-justification request
accepted. Why is that not the right place to start testing a new
no-justification regime?
_________________________________________________________________________________________________________________
1.  We proposed no needs 2 years ago and got push back that the time was
not right.  A lot has changed since then.  RIPE has implemented no need.
 North America is being left behind by Europe.  It is a serious problem
when pseudo-government tells you whether you can buy IP's in North
America, but your competitors are free to buy IP's in Europe.  North
America is supposed to be the leading free market in the world, but
apparently not in the internet space.  

2.  A /24 is only 256 IP's.  This is, and ARIN staff can confirm this,
probably 30-40 % of all ARIN requests.  In my transfer world, it is more
like 10% of requests, and frankly, we don't do /24 requests because they
are too small.  To be worthwhile, it has to be a meaningful size range. 
A /16 is about 25% of our transfer requests.

I have not heard a valid reason to oppose a /16  no needs policy:
- not hoarding
- not lack of control

I have heard FUD - fear, uncertainty and doubt.  I have heard lack of
understanding, thinking it applied to the free pool, but it does not.  

I have not heard a valid REASON to deny this policy:  This policy will
help small and medium sized business in the US, Canada and the
Caribbean.  

Sandra Brown
IPv4 Market Group
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For now I OPPOSE the proposal as written but I'd like to hear more.

Regards,
Bill Herrin