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

Sun Jun 22 09:56:10 EDT 2014

Milton,

On Sun, Jun 22, 2014 at 6:21 AM, Milton L Mueller <mueller at syr.edu> wrote:
> David
> I don't think an intransigent attitude toward retaining needs testing is justified by anything you have cited here or elsewhere.

None of the folks who support needs-testing are being intransigent.
Most have signaled a willingness to compromise.

RIPE has basically eliminated needs assessment, see this article for
an assessment of the results:
> http://www.internetgovernance.org/2014/06/20/baby-steps-and-big-differences-in-address-transfer-market/
>
> In economics there is the concept of transaction costs. Needs testing is a transaction cost in both free pool allocations and market transfers. If the transactions costs are too high, it is a barrier to transactions happening at all. Basically, it means that you don't spend $5,000 worth of staff time and transacting parties' time to effectuate a transfer that may be worth $4,000 or even $6,000.
>
> I think the case that's being made here is that for small transfers, the cost of a full-fledged needs assessment is simply not worth the trouble, as it is disproportionately large relative to the value of the overall transaction.  For the smaller transactions, which cannot really pose threats of hoarding and speculation, the value the community gains from imposing traditional needs assessment criteria is pretty minimal compared to the natural form of rationing you are going to get from the market price for the number block.

As David said:

"I don't support fixing the perceived problem and do not agree it is
even a real problem."

"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..."

Do you have evidence from Registration Services that it is a "real problem"?

The data you provide on the link above doesn't show this at all.

-- 
Cheers,

McTim
"A name indicates what we seek. An address indicates where it is. A
route indicates how we get there."  Jon Postel

p.s. the Metropole lobby does a smashing High Tea

>
>
>> -----Original Message-----
>> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net]
>> On Behalf Of David Farmer
>> Sent: Tuesday, June 17, 2014 7:21 PM
>> To: ARIN PPML
>> Subject: Re: [arin-ppml] Draft Policy ARIN-2014-14: Removing Needs Test
>> from Small IPv4 Transfers
>>
>> 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
>>
>> --
>> ================================================
>> 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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