[arin-ppml] reverse COE statement

Tue Sep 23 12:48:29 EDT 2014

Dear Kevin,

The needs test has several flaws when operating in the new market environment.
It worked okay, not great, for the free-pool environment.
But now there are forces which were absent from the free pool environment which are working on network operators.
These forces will tend towards policy avoidance, and there are several methods of avoidance which reduce Whois accuracy.
In addition, the needs test creates an additional barrier for small entrants such as yourself and absolutely prevents a first allocation via transfer.

Your attitude seems to be that those problems are acceptable so as to reduce the likelihood of larger problems inherent to a commodity market.

Could you please provide a scenario in which the passage of one of the proposals seeking to address the new reality will lead to these larger problems?

In particular, 2014-14 seeks to address this situation through the limited removal of needs testing for a /16 or less, once per year per recipient.
Should that proposal pass, what in your mind would be the downside risk? Perhaps if we can identify that risk, we can address it.

For example, there is the fear that nefarious actors would spin up separate organizations and use them to get around the limits of 2014-14.
Perhaps there is a way to allow ARIN staff the power to identify and protect against this through some definition of related organizations?

For another example, there are many who feel a /16 is not small, and would provide a great enough opportunity for hoarding by enough separate organizations  that it could affect the overall transfer marketplace. Would you consider a smaller block size more appropriate to minimize this risk? Owen has suggested a /20, temporarily.

As ARIN gets to the dregs of the free pool, staff will be busy team-reviewing every allocation, and there is a long tail of unaggregatable /24s, more than a thousand. Since every applicant will get only a /24 and be told to come back in three months, we can easily foresee ARIN staff being very busy. My reading of policy also finds that in our current Phase IV, team review has to happen to transfers, too. Maybe John Curran can confirm or deny this? I could be mistaken.

But if that is indeed the case and ARIN staff is very busy, response times will decay. ARIN already posted a warning to that effect on their website. Should this slowdown materialize, is this the kind of support of network operators you think is ARIN’s proper role?  Would you consider a change to policy which required organizations attest to their need for a small block rather than involve ARIN staff in review? If so, is there a maximum block size for which you would accept attestation in lieu of staff review? What about how much team review of /24s costs the community, as we consider funding, is that a worthy investment?

I read you as concerned about the impact of the profit motive on the IPv4 allocation process, but surely you understand that the genie is out of the bottle in that regard, and ARIN will register a block to a needy porn site that pays more than a needy community workshop? So the needs test does not prevent those with more money from outbidding those with less. Those with more money will get the space.  What the needs test does is prevent hoarding by those who seek to buy without need, as we define need. I think that it is incumbent on you to go beyond lamenting the profit motive and the commodity market as problematic, and actually provide a scenario which could be damaging to network operators should a limited removal of needs-testing be implemented.

Finally, as should be expected of every organization, you wish to leverage the system that exists to your benefit. 
Here is my advice: go to ARIN under immediate need and tell them you plan to stop the NATTING, then get your /24.
ARIN does not require you to NAT. In the stewardship community’s expressed wisdom, conserving addresses in this way reduces your justifiable need for IPv4.
Perversely, you are being punished for your conservation, although I am sure your NAT is functioning perfectly for you.

Regards,
Mike Burns

From: Kevin Kargel 
Sent: Tuesday, September 23, 2014 11:44 AM
To: arin-ppml at arin.net 
Subject: [arin-ppml] reverse COE statement

I should point out that the strength of my convictions on the discussion of needs assessment impacts me negatively on a personal level.  I am in a position where I would love to get a /24 for my own use, personally and business.  Unfortunately I would not pass the needs requirement.  I could present about 40 IP addresses that are currently NATed, with some small future growth projection.  That would not – in my understanding – pass muster for an allocation under the current rules.  I will in the near future be changing locations and providers for that network and a portable IP block would be most handy.

I honestly do not believe that eliminating needs tests would be good for society.  

If needs tests were eliminated all that would be left in my way would be the money hurdle, which presents a relatively low bar to vault.  

Don’t get me wrong, if needs tests are eliminated over my objections I will be at the front of the line with my application.  I see nothing wrong with legitimately leveraging the system that exists.  

I know it would be trivial as a network operator to game the system for a /24, I just don’t want to do it that way.  

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