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

Andrew Dul andrew.dul at quark.net
Wed Apr 30 22:05:31 EDT 2014

On 4/30/2014 6:40 PM, Scott Leibrand wrote:
> On Apr 30, 2014, at 5:04 PM, Andrew Dul <andrew.dul at quark.net
> <mailto:andrew.dul at quark.net>> wrote:
>> On 4/30/2014 4:50 PM, Scott Leibrand wrote:
>>>> On Apr 30, 2014, at 4:45 PM, Andrew Dul <andrew.dul at quark.net> wrote:
>>>>> On 4/30/2014 1:55 PM, sandrabrown at ipv4marketgroup.com wrote:
>>>>> 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.
>>>> It seems trivial to me to divide a /8 into /16s or any other smaller
>>>> block so I could transfer it without doing the needs justification.  I
>>>> could write a script for the transfer templates and just send them off. 
>>>> Once the legwork for the first transfer is complete, the rest should
>>>> just flow right through.  Nothing I see in the current text or policy
>>>> prevents someone from taking a larger block and slicing it up to get
>>>> under the /16 limit.  Since most of the brokers are out speculating that
>>>> these blocks have significant value it seems clear that if the large
>>>> players need them they will just be paying a staff person a few extra
>>>> hours to manage this overhead.
>>> Current transfer policy operates on the *recipient* of the transfer. It requires that they meet their need with a single block, and prevents repeated transfers to circumvent that. 
>> Conditions on recipient of the transfer:
>>   * 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.
>>   * The resources transferred will be subject to current ARIN policies.
>> Scott, I don't see any restrictions on the recipient that would
>> prevent them from receiving multiple blocks...where do you see that?
> It's hiding in 4.1.8: 
> Repeated requests, in a manner that would circumvent 4.1.6, are not
> allowed: an organization may only receive one allocation, assignment,
> or transfer every 3 months, but ARIN, at its sole discretion, may
> waive this requirement if the requester can document a change in
> circumstances since their last request that could not have been
> reasonably foreseen at the time of the original request, and which now
> justifies additional space. 
Fair enough, but one could also argue that 4.1.8 doesn't apply to
transfers because the whole section is about ARIN issued space, not
transfer obtained space.  They key is how ARIN would implement the
proposed policy, which will happen latter in the staff assessment after
the proposal is a draft policy.


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