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

[jeffmehlenbacher at ipv4marketgroup.com]

In February 2012, I authored an ARIN policy proposal to eliminate any
needs-based justification on paid transfers.  It was not adopted
obviously.  Interestingly, the RIPE NCC adopted policy to remove
needs-based justification on paid transfers in February 2014.  With the
benefit of two plus years facilitating transfers in ARIN, APNIC and RIPE
regions since my original policy proposal, I would still prefer ARIN
remove all needs analysis on paid transfers rather than compromising on
a /16 maximum transfer without demonstrated need but only ONCE per year.
 It seems to me such a compromise is intended solely to appease rather
than doing what is right for ARIN region businesses that shortly, may
have no recourse but to enter the transfer market to obtain IPv4
resources that ARIN can no longer supply regardless of whether or not
need is demonstrated.  While it has only been a few months since RIPE
region buyers have not been directed to demonstrate need in order to
obtain transfer approval, I can tell the ARIN community one thing with
certainty: the requested block sizes we receive may or may not be larger
than truly "needed", but once market pricing is applied based on the
most recent transfers completed, a /18 block request may quickly be
modified by the prospective buyer to a /19 if the cost/benefit cannot be
realized for their business within acceptable timelines.  It is not
about demonstrating justified need to the RIR, it is about balancing
expense with the need to maintain business continuity and accommodating
growth forecasts.  The market has an interesting correction mechanism
without RIR resources being applied to interrogate need regardless of
block size requested/desired.  If the ARIN community is concerned about
speculation and hoarding with no needs assessment, I would invite you to
review the RIPE transfer market statistics paying particular attention
to block size (with or without need):
http://www.ripe.net/lir-services/resource-management/ipv4-transfers/table-of-transfers.


So for those ARIN region companies that will have impending requirements
for IPv4 resources based on previous allocations (consumption) and
future growth, now is the time for you to weigh in with a position on
the PPML.  If you believe paying for transferred IPv4 resources with an
officer attestation is sufficient justification in order to obtain
blocks that inevitably, ARIN can no longer distribute, your comments
would be most meaningful .


Jeff Mehlenbacher
IPv4 Market Group