[arin-ppml] Draft Policy ARIN-2014-20: Transfer Policy Slow Start and Simplified Needs Verification

[Milton L Mueller]

After reviewing both 2014-20 and 2014-14, I think Mike Burns is correct. 2014-20 (Transfer policy slow start...) is an attempt to simplify and automate needs assessments for transfers. But 2014-14 (Removing needs test for small transfers) is a much cleaner and simpler way of doing that. I see 2014-20 adding complexity in certain cases and tripping over itself in an attempt to simplify. All this talk of forward-looking projections vs retrospective measures of utilization, of 50% vs. 80%, are simply adding new exceptions, potential loopholes and complexity to the needs testing regime. 

If I am not mistaken, RIPE has already passed an exemption from needs testing for small transfers and the world has not come to an end. We need to take much more seriously the extent to which ARIN will be in the business of handling market-based ip address transfers for the next 10 years. 

--MM

> -----Original Message-----
> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On
> Behalf Of Mike Burns
> Sent: Thursday, September 18, 2014 12:50 PM
> To: John Curran; David Huberman
> Cc: arin-ppml at arin.net
> Subject: Re: [arin-ppml] Draft Policy ARIN-2014-20: Transfer PolicySlow Start
> and Simplified Needs Verification
> 
> Present transfer policy will effectively preclude new entrants from obtaining any
> IPv4 address space via transfer (unless they can somehow first get resources
> allocated from their upstream ISPs during this time of increasing scarcity), so
> continued thinking and discussion on solutions would indeed be prudent.
> 
> Thanks!
> /John
> 
> 
> 
> Yet another reason to support 2014-14, the simple solution to many problems.
> 2014-14 solves virtually all the problems being presented in the context of 2014-
> 20, does so in verbally economic terms, and contains within it protections
> against market manipulations in the form of the limit of a single /16 transferred
> needs-free per year per recipient.
> 
> No problems with 80% of last versus aggregate, no problems with TPIA, no
> problems with slow-start, no problems with MDN, no problems with upstream
> scarcity, no problems with section 4 versus section 8. No issues of NRPM bloat,
> no need to change section 4, no problems with minimum sizes. Plus it has the
> benefit of reducing the gap between legacy and RSA-space rights and reduces
> the risk of out-of-policy transfers which detriment Whois accuracy, and
> increases the likelihood of Interregional transfers with RIPE. Finally it allows us
> to stop with the deck-chair arranging and pay more attention to
> IPv6 policy.
> 
> Regards
> Mike Burns
> 
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