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

Mike Burns mike at iptrading.com
Wed Apr 30 18:41:04 EDT 2014

> How would we go about assessing whether such changes prove harmful or
> helpful? What metrics does ARIN collect under this policy which can be
> analyzed and presented here so we can consider expanding it to larger
> transfers? Does no justification mean no documentation?
> What makes you think /16 is the right place to start testing this
> idea? Traditionally /24 was the last no-justification request
> accepted. Why is that not the right place to start testing a new
> no-justification regime?
> For now I OPPOSE the proposal as written but I'd like to hear more.
> Regards,
> Bill Herrin

Hi Bill,

I chose /16 as a starting point for negotiations because it is a common size 
I see in the brokerage business.

Removing the needs test serves many purposes. One that I have considered is 
the possibility for an Inter-RIR policy with RIPE.
I think this change at least lays the groundwork for that. I believe that a 
"compatible needs-based policy" would be a match for RIPE up to the point 
where ARIN needs tests would apply, since RIPEs needs test for transfers is 
less rigorous than ARIN's currently. But if ARIN drops the needs test up to 
a certain size, my hope is that the ARIN would recognize that the policies 
are now compatible for transfers lower than that certain size. I understand 
your reluctance to expose the remains of the free pool to possible predation 
through rinse-repeat allocations and sales, but the one per year allowance 
inhibits that, and we don't expect the free pool to be there much more than 
a year from now anyway.

Of course it also answers the needs of those who can't get addresses from 
their upstreams but don't qualify for the /20 minimum, without applying any 
additional draw on the free pool, but instead utilizing already allocated 
but unused space. We had a customer call today on just this issue. He has an 
acute need for a /24. His upstream has imposed a limit of 128 addresses. 
What can he do? He can acquire a shell corp with a /24 but those are few and 
far between. Absent that, what are his options? Answer is, he can lease the 
addresses or engage in an out-of-policy legacy transfer, both of which 
affect Whois accuracy negatively.

You ask how we can assess the effects of this policy, and I am not sure. 
Perhaps a count of small blocks transferred? If that increases, can we 
ascribe any rise to this policy? Probably not. Aborted 8.2 transfers don't 
apply. Maybe a count of aborted 8.3 transfers and 8.4 transfers?

Granted that it will be difficult to assess the impact of this policy beyond 
the anectodal hallelujahs from those who have been unable to secure 
addresses under current policy. But more important to me is the 
identification and assessment of potential downsides or risks. Are there any 
downsides or risks which you feel are important to address?

Would you support this policy if it were of limited duration and a smaller 
size, as Owen suggested?


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