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

[John Springer]

Hi David,

On Tue, 17 Jun 2014, David Farmer wrote:

> 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.

You mean the problem of delays in resource request processing time as 
suggested by Leslie and seemingly confirmed by others?  Please share the 
information that you have that contradicts this.

> 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.

Why not? Because it is a line? Why?

> 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.

Happens all the time. People have the right to spin. That some other 
proposal might gain consensus is not a valid argument against the current 
proposal. Cum hoc ergo propter hoc, probably

> 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.

First sentence, thank you for that good idea. Second sentence, Why? What 
gives you the right to say? To just declare and make it be so. State the 
reason.

> 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.

About .03%. Accurate numbers coming. A useless gesture. Symbolism.

> 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.

Argument through tautology. No one is disputing that this policy seeks to 
eliminate needs basis for small transfers. Please show your work. State 
the reason for your disagreement. Don't go in circles. Please.

> 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.

Possibly a good idea, but not a _REASON_ for not doing this.

> Granted, I'm talking about a fairly 
> low bar being set.

No danger of tripping. A piece of tape on the floor.

> But there is a bar and it's not as low as some may think.

This will require evidence, I think. I'll have some coming as soon as I 
stop being interrupted.

> 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.

Not even a policy proposal, just the suggestion of one and it is an 
argument against 2014-14? No.

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

Starting to see a pattern? Something that happened before is not evidence 
of causation. post hoc ergo propter hoc.

> 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.

Everybody gets to change their mind. However unless you provide logical 
_REASONS_, your stance may be acknowledged and then not taken into 
account, by fair minded people who wish to have a logic based discussion.
Clearly you _FEEL_ strongly. As Lee Howard would say, that does not make 
you more persuasive. Reasons will do that.

John Springer

> 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
>
> -- 
> ================================================
> David Farmer               Email: farmer at umn.edu
> Office of Information Technology
> University of Minnesota
> 2218 University Ave SE     Phone: 1-612-626-0815
> Minneapolis, MN 55414-3029  Cell: 1-612-812-9952
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