[arin-ppml] Draft Policy ARIN-2014-14: Removing Needs Test from Small IPv4 Transfers

[David Farmer]

First, While this policy has a clearly formed problem statement, I don't 
support fixing the perceived problem and do not agree it is even a real 
problem.

Then, the proposed solution to this none problem is "removing needs 
testing" for small IPv4 transfers.  I can not support the concept of 
removing needs testing, that is a line I'm not willing to cross.

However, some of the ideas for this policy come from comments I've made. 
  But, for some reason those ideas are spun around to eliminate need, 
instead of redefining need, which I think can gain community consensus.

I support a fundamental reexamination and redefinition of what justified 
need means in a post (or nearly post) free pool world.  But, 
fundamentally there has to be need involved, the definition for that 
need may look radically different than what we have used for the last 20 
years or so.

I support redefining justified need for the transfer of a /24 and up to 
a /20 as justified by an officer attestation that the resources are 
needed for use on a operational network within 6 months and a 
willingness to expend financial resources necessary to acquire the IPv4 
resources on the transfer market.  However, this is only one small part 
of the reexamination and redefinition of justified need that is 
necessary, but is seems like a reasonable bit size chunk to start with.

Some may argue that is the same thing that this policy does, and I must 
disagree;  This policy wants to eliminate needs justification, granted 
only for small transfers.  But it eliminates need none the less.

Where as what I'm suggesting fundamental redefines and simplifies what 
justified need means in a post (or nearly post) free pool world for 
small transfers, but does not eliminate need.  Granted, I'm talking 
about a fairly low bar being set.  But there is a bar and it's not as 
low as some may think.  The fact that IPv4 resources have to be acquired 
on the transfer market is accounted for as part of the demonstration of 
need, this is a real constraint for most organizations.  Furthermore, 
the officer attestation requirement provides organizational commitment 
that resources are going to be used and not just stockpiled.

I think the real problem this solves is failure of slow start when there 
is no free pool to prime the pump.

So, unfortunately while this policy is at least partially based on my 
suggestion, I can not support the problem statement given, nor can I 
support the policy as written.  Therefore, I suggest abandoning this 
problem statement and policy, and starting over with a problem statement 
focused on a different issue and not focusing on the elimination of need 
at a solution.

On 5/16/14, 15:20 , ARIN wrote:
> On 15 May 2014 the ARIN Advisory Council (AC) accepted "ARIN-prop-204
> Removing Needs Test from Small IPv4 Transfers" as a Draft Policy.
>
> Draft Policy ARIN-2014-14 is below and can be found at:
> https://www.arin.net/policy/proposals/2014_14.html
>
> You are encouraged to discuss the merits and your concerns of Draft
> Policy 2014-14 on the Public Policy Mailing List.
>
> The AC will evaluate the discussion in order to assess the conformance
> of this draft policy with ARIN's Principles of Internet Number Resource
> Policy as stated in the PDP. Specifically, these principles are:
>
>    * Enabling Fair and Impartial Number Resource Administration
>    * Technically Sound
>    * Supported by the Community
>
> The ARIN Policy Development Process (PDP) can be found at:
> https://www.arin.net/policy/pdp.html
>
> Draft Policies and Proposals under discussion can be found at:
> https://www.arin.net/policy/proposals/index.html
>
> Regards,
>
> Communications and Member Services
> American Registry for Internet Numbers (ARIN)
>
>
> ## * ##
>
>
> Draft Policy ARIN-2014-14
> Removing Needs Test from Small IPv4 Transfers
>
> Date: 16 May 2014
>
> Problem Statement:
>
> ARIN staff, faced with a surge in near-exhaust allocations and
> subsequent transfer requests and a requirement for team review of these,
> is spending scarce staff time on needs testing of small transfers. This
> proposal seeks to decrease overall ARIN processing time through
> elimination of that needs test.
>
> 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 or for
> recipients who have completed a needs-free transfer in the prior year,
> 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."
>
> Change the language in the third bullet point in NRPM 8.4 after
> Conditions on the recipient of the transfer: from "Recipients within the
> ARIN region must demonstrate the need for up to a 24-month supply of
> IPv4 address space." to "For transfers larger than a /16 equivalent or
> for recipients who have completed a needs-free transfer in the prior
> year, recipients in the ARIN region must demonstrate the need for up to
> a 24-month supply of IP address resources under current ARIN policies
> and sign an RSA."
>
> Comments:
>
> Needs testing has been maintained for transfers largely because the
> community wishes to ensure protection against hoarding and speculation
> in the IPv4 market. This proposal seeks a middle ground between the
> elimination of needs tests for transfers altogether, and the continuance
> of needs tests for every transfer. This should help ARIN staff to reduce
> transfer processing time, since most transfers have been smaller than /16.
>
> Timetable for implementation: Immediate

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David Farmer               Email: farmer at umn.edu
Office of Information Technology
University of Minnesota
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