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

Mike Burns mike at nationwideinc.com
Wed Apr 30 17:26:36 EDT 2014

As the author of the proposal, I would also like to indicate that I chose 
/16 for many of the reasons elucidated by Sarah below.
But I wanted that number to be a topic of discussion on the list and I am 
certainly amenable to a change of this number.
Thank you Owen, for proposing a different size and a limited duration as 
something you could perhaps support.

All the small buyers we see seem to be in a much more desperate need than 
the parties transacting in /16s and higher.
We are seeing that users can't get addresses from upstream providers.
I think this is because the upstream providers are unable to tighten the 
screws to get to 80%  utilization, otherwise they would get more from the 
free pool.
Whatever the reason, with this simple addition of a clause in two lines of 
the NRPM we solve many problems without risking any dangers of market 
Also of note regarding the illustration of the difficulties in hoarding with 
this limitation which Sandra provided, there is still the limit of one 
transfer per year.
So a series of transfers is precluded.

Mike Burns

-----Original Message----- 
From: sandrabrown at ipv4marketgroup.com
Sent: Wednesday, April 30, 2014 4:55 PM
To: arin-ppml at arin.net
Subject: Re: [arin-ppml] ARIN-prop-204 Removing Needs Test from Small IPv4 
Transfers (Sandra Brown)


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

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

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

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
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