[arin-ppml] 2014-14
Rudolph Daniel
rudi.daniel at gmail.com
Wed Sep 24 13:47:14 EDT 2014
Re: David's
>>>2014-14 would work nicely.
-get a "free" 8.3 transfer up to a /16
-anything more requires strict needs basis <mechanism TBD>
-throw in a clause that ARIN has the right to refuse if it believes the
free transfer is not being made in good faith because of speculation and
multiple >>>OrgIDs..end quote.
+1 on the above ..from data offerings and knowledge gleamed so far.
But a free /16...as opposed to a smaller one..??
RD
skype: rudidaniel
On Sep 24, 2014 9:49 AM, <arin-ppml-request at arin.net> wrote:
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> Today's Topics:
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> 1. Re: Draft Policy ARIN-2014-20: Transfer Policy Slow Start and
> Simplified Needs Verification (Matthew Kaufman)
> 2. Hoarding and speculation (was: Re: Draft Policy ARIN-2014-20:
> Transfer Policy Slow Start and Simplified Needs Verification)
> (John Curran)
> 3. Re: Draft Policy ARIN-2014-20: Transfer Policy Slow Start and
> Simplified Needs Verification (Mike Burns)
> 4. Re: ARIN-2014-20 and current future looking needs assessment
> (Martin Hannigan)
> 5. Re: Hoarding and speculation (was: Re: Draft Policy
> ARIN-2014-20: Transfer Policy Slow Start and Simplified Needs
> Verification) (David Huberman)
>
>
> ----------------------------------------------------------------------
>
> Message: 1
> Date: Tue, 23 Sep 2014 19:50:53 -0700
> From: Matthew Kaufman <matthew at matthew.at>
> To: David Huberman <David.Huberman at microsoft.com>
> Cc: "arin-ppml at arin.net List \(arin-ppml at arin.net\)"
> <arin-ppml at arin.net>
> Subject: Re: [arin-ppml] Draft Policy ARIN-2014-20: Transfer Policy
> Slow Start and Simplified Needs Verification
> Message-ID: <DE1F8AB3-4A29-4288-BAD1-187AEAE935D3 at matthew.at>
> Content-Type: text/plain; charset=us-ascii
>
> Speculators and hoarders could already be locking up space via contracts
> that aren't even transfers (yet)... And yet I haven't seen much of that
> going on either. In fact, offers to buy or lease (or any other contract
> regarding) space are coming in less often than a year ago, if anything.
>
> Matthew Kaufman
>
> (Sent from my iPhone)
>
> > On Sep 23, 2014, at 7:45 PM, David Huberman <
> David.Huberman at microsoft.com> wrote:
> >
> > John wrote:
> >
> >> A transfer policy mechanism which allows receipt up to a limit based on
> >> current holdings provides far more certainty for those who wish to plan
> >> for the future, as they can go to market knowing precisely that limit.
> >
> > What is the virtue of a limit?
> >
> > It's not the prevention of speculation and hoarding. Those will always
> > happen outside the view of ARIN policy. Speculators and hoarders will
> > buy blocks on the open market and simply not engage ARIN because
> > there's no reason to. Contract law makes it trivial to ignore ARIN.
> >
> > It's not conservation - there is no such thing as conservation in IPv4.
> > 85% of the address space ARIN issued over the last 10 years went
> > to less than 20 companies. (At a significant penalty, I might add, to
> > the little guys and especially new entrants, who got screwed in ARIN
> > policy for 17 years.)
> >
> > Before anyone answers this, please ensure you're knowledgeable about
> > the IPv4 market today. I am. I characterize it as VERY robust. Tons of
> > supply, with new suppliers showing up every month. Outside of China,
> > prices are low; it's a buyer's market. There's no speculation that I can
> > find, short of a one-off speculator who is a well-known fraudster. There
> > is certainly hoarding by the larger companies, but ARIN policy today
> > isn't stopping that, and no policy passed here can stop that. Think about
> > that last sentence carefully. ARIN policy is powerless to stop hoarding.
> >
> > So how do we write policy that helps the non-big guys? By removing
> > artificial policy barriers that require lots of paperwork with ARIN
> beyond
> > simply, "I bought this /20 from this company, please update Whois".
> >
> > ARIN's job should simply be to verify the seller is the bona fide
> registrant,
> > and that the seller agrees to the transfer, and that the buyer signs an
> > RSA and pays whatever fees are necessary to cover the costs of the
> > transaction processing.
> >
> > Let's simplify ARIN processes, make ARIN policy fit the REALITY of
> > network operations in a post-exhaustion world, and move on with
> > talking about RPKI, DNSSEC, IPv6 and other actually important things
> > that will shape our future.
> >
> > David
> > _______________________________________________
> > PPML
> > You are receiving this message because you are subscribed to
> > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> > Unsubscribe or manage your mailing list subscription at:
> > http://lists.arin.net/mailman/listinfo/arin-ppml
> > Please contact info at arin.net if you experience any issues.
>
>
> ------------------------------
>
> Message: 2
> Date: Wed, 24 Sep 2014 11:54:38 +0000
> From: John Curran <jcurran at arin.net>
> To: David Huberman <David.Huberman at microsoft.com>
> Cc: "arin-ppml at arin.net List \(arin-ppml at arin.net\)"
> <arin-ppml at arin.net>
> Subject: [arin-ppml] Hoarding and speculation (was: Re: Draft Policy
> ARIN-2014-20: Transfer Policy Slow Start and Simplified Needs
> Verification)
> Message-ID: <06449011-DCD9-4C6C-84A3-1F125D431200 at arin.net>
> Content-Type: text/plain; charset="us-ascii"
>
> On Sep 23, 2014, at 10:45 PM, David Huberman <David.Huberman at microsoft.com>
> wrote:
>
> > What is the virtue of a limit?
> >
> > It's not the prevention of speculation and hoarding. Those will always
> > happen outside the view of ARIN policy.
> > ...
> > Before anyone answers this, please ensure you're knowledgeable about
> > the IPv4 market today. I am.
> > ...
> > There's no speculation that I can find, short of a one-off speculator
> > who is a well-known fraudster.
> > ...
> > ARIN's job should simply be to verify the seller is the bona fide
> registrant,
> > and that the seller agrees to the transfer, and that the buyer signs an
> > RSA and pays whatever fees are necessary to cover the costs of the
> > transaction processing.
>
> David -
>
> You describe an interesting "present state", and presuming it is
> well-informed, it is probably extracting and making explicit some
> points in your worldview before continuing the discussion.
>
> You indicate -
>
> 1) Hoarding and speculation can happen outside of ARIN's view
>
> This is almost certainly the case, as parties always free
> to contract for future behavior, including a party ceding
> its ability to transfer address rights to any other party.
>
> 2) A limit on the size of transfers cannot meaningfully deter
> hoarding, due to point #1 above.
>
> 3) A limit on the size of transfers cannot meaningfully deter
> speculation, due to point #1 above.
>
> 4) Hoarding does occur, but there is no meaningful speculation
> that you can find.
>
> By "hoarding", I believe that you mean parties obtaining
> right to number resources in anticipation of future need
> to make use of them, as opposed to "speculation" whereby
> one obtains rights in anticipation of financial gain.
>
> If you are correct above, it does raise the question of "why
> isn't there abundant & apparent speculation going on today?"
>
> It can't be for lack of interest; investment firms will speculate
> on nearly anything that has good potential to beat the market.
> I've had investment firms ask about the 'rules and regulations'
> that apply to transfers of IP address rights for this very reason.
>
> The various policy merits of allowing hoarding or speculation are
> not mine to argue; that is for the community to ponder through the
> policy development process. However, you propose that we simplify
> ARIN processes and make ARIN policy fit reality; effectively that
> ARIN's job should simply be to verify the seller is the bona fide
> registrant and that parties agree to the transfer.
>
> If community does as you suggest, both hoarding and speculation
> become readily available, and this represents a significant change
> from the present state as described by your worldview. A change
> which simply formalized the present state that you describe would
> not enable speculation, since you do not view that as abundant in
> the present system. The difference between the two outcomes comes
> down to whether or not the buyer is obtaining the resources in
> anticipation of future need or simply financial gain, i.e. is the
> buyer of the rights to the addresses a bona fide network operator.
>
> I'll assert that the present system is actually rather unfavorable
> to speculation; parties that seek to obtain the rights to address
> blocks without the real potential for future use are run a very risk
> of ending up in violation of policy and with impaired investments
> as a result. More specifically, your postulate [#3] above to the
> effect that a limit on the size of transfers cannot meaningfully
> deter speculation is likely not valid - the limit does indeed deter
> speculation today, as having to qualify eventually against needs-
> based limit requires the party to actually operate a network (or
> risk total loss of the investment, likely beyond the risk profile
> of the vast majority of potential investors.)
>
> Unless you are advocating for a policy shift to enable speculation,
> simplification of ARIN policy towards your "present reality" needs
> to be more than simply verifying that the seller is the bona fide
> registrant and that parties agree to the transfer; in particular,
> verification that the recipient is a bona fide network operator
> would also be required. That is an aspect presently implied in the
> needs-based limit on the size of an address rights transfer, but
> that element could be made explicit and retained, if limit itself
> is otherwise undesirable in your view.
>
> Interesting discussion - Thank you!
> /John
>
> John Curran
> President and CEO
> ARIN
>
>
>
>
>
>
>
>
>
> ------------------------------
>
> Message: 3
> Date: Wed, 24 Sep 2014 07:52:52 -0400
> From: "Mike Burns" <mike at iptrading.com>
> To: "David Huberman" <David.Huberman at microsoft.com>, "John Curran"
> <jcurran at arin.net>
> Cc: arin-ppml at arin.net
> Subject: Re: [arin-ppml] Draft Policy ARIN-2014-20: Transfer Policy
> Slow Start and Simplified Needs Verification
> Message-ID: <D94590F128074A84AB76B5BDC495C573 at ncsscfoipoxes4>
> Content-Type: text/plain; format=flowed; charset="iso-8859-1";
> reply-type=original
>
> Hi list,
>
> +1 to what David wrote.
>
> I would say it is a buyer's market, there are more sellers than buyers.
> Also demand for transfer IPv4 is not as high as demand for free pool IPv4
> in
> the previous years.
> I believe this is due to companies being a litle more efficient internally.
> And there have been some fairly large CGN deployments as well.
>
> I see no evidence of speculation in transfers, even in RIPE after they
> effectively dropped needs tests for transfers.
> That last sentence should provide relief for those who have expressed this
> fear and expectation.
>
> I wouldn't call it robust yet, as there are still too few buyers.
>
> I agree that ARIN should become a lightweight registry service for IPv4,
> concentrating on our primary stewardship goal of registration and avoiding
> policy which works against accurate registration in the name of
> conservation
> which is already provided by the natural forces of a market.
>
> This will be cheaper for ARIN, easier for everyone to understand, consonant
> with property law, result in faster transfers, a more accurate registry,
> less verbose NRPM, reduce corruption potential, and free us for policy
> development in other areas.
>
> Regards,
>
> Mike
>
>
>
>
>
>
> ----- Original Message -----
> From: "David Huberman" <David.Huberman at microsoft.com>
> To: "John Curran" <jcurran at arin.net>
> Cc: <arin-ppml at arin.net>
> Sent: Tuesday, September 23, 2014 10:45 PM
> Subject: Re: [arin-ppml] Draft Policy ARIN-2014-20: Transfer Policy Slow
> Start and Simplified Needs Verification
>
>
> > John wrote:
> >
> >> A transfer policy mechanism which allows receipt up to a limit based on
> >> current holdings provides far more certainty for those who wish to plan
> >> for the future, as they can go to market knowing precisely that limit.
> >
> > What is the virtue of a limit?
> >
> > It's not the prevention of speculation and hoarding. Those will always
> > happen outside the view of ARIN policy. Speculators and hoarders will
> > buy blocks on the open market and simply not engage ARIN because
> > there's no reason to. Contract law makes it trivial to ignore ARIN.
> >
> > It's not conservation - there is no such thing as conservation in IPv4.
> > 85% of the address space ARIN issued over the last 10 years went
> > to less than 20 companies. (At a significant penalty, I might add, to
> > the little guys and especially new entrants, who got screwed in ARIN
> > policy for 17 years.)
> >
> > Before anyone answers this, please ensure you're knowledgeable about
> > the IPv4 market today. I am. I characterize it as VERY robust. Tons of
> > supply, with new suppliers showing up every month. Outside of China,
> > prices are low; it's a buyer's market. There's no speculation that I can
> > find, short of a one-off speculator who is a well-known fraudster. There
> > is certainly hoarding by the larger companies, but ARIN policy today
> > isn't stopping that, and no policy passed here can stop that. Think about
> > that last sentence carefully. ARIN policy is powerless to stop hoarding.
> >
> > So how do we write policy that helps the non-big guys? By removing
> > artificial policy barriers that require lots of paperwork with ARIN
> beyond
> > simply, "I bought this /20 from this company, please update Whois".
> >
> > ARIN's job should simply be to verify the seller is the bona fide
> > registrant,
> > and that the seller agrees to the transfer, and that the buyer signs an
> > RSA and pays whatever fees are necessary to cover the costs of the
> > transaction processing.
> >
> > Let's simplify ARIN processes, make ARIN policy fit the REALITY of
> > network operations in a post-exhaustion world, and move on with
> > talking about RPKI, DNSSEC, IPv6 and other actually important things
> > that will shape our future.
> >
> > David
> > _______________________________________________
> > PPML
> > You are receiving this message because you are subscribed to
> > the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
> > Unsubscribe or manage your mailing list subscription at:
> > http://lists.arin.net/mailman/listinfo/arin-ppml
> > Please contact info at arin.net if you experience any issues.
> >
>
>
>
> ------------------------------
>
> Message: 4
> Date: Wed, 24 Sep 2014 14:27:44 +0200
> From: Martin Hannigan <hannigan at gmail.com>
> To: Owen DeLong <owen at delong.com>
> Cc: "arin-ppml at arin.net" <arin-ppml at arin.net>
> Subject: Re: [arin-ppml] ARIN-2014-20 and current future looking needs
> assessment
> Message-ID:
> <CAMDXq5P_ySx9aC5Kkfyq93ry3MfGr1dnNUA5DgO7Rg4gmF=
> YJQ at mail.gmail.com>
> Content-Type: text/plain; charset=ISO-8859-1
>
> On Wed, Sep 24, 2014 at 1:59 AM, Owen DeLong <owen at delong.com> wrote:
> > You have always been able to get space from ARIN based on forward-looking
> > business cases, but it has been limited.
> >
> > This applies to both free pool and transfers equally, though free pool
> being
> > limited to a 3-month window now for ISPs makes "forward" a little less
> > useful.
>
>
> Business plan is a useless term in this context. My earlier point
> which may not have been clear was that ARIN is not qualified to
> evaluate a business plan let alone compare my business plan to a
> competitors and make judgements as to what my (or their) need is. If
> they did do such a thing, it would be problematic. The three month
> window is a market limit not so much of a business limit unless ARIN
> unevenly applies the policies (which in my own view, they do).
>
> So with that said, yes, I agree, it applies to both free pool and
> transfer requests.
>
>
> >
> > I would venture that most end-user initial allocations are based on at
> least
> > somewhat forward-looking projections.
>
> All submissions regardless of who submits them follow this theme. You
> tell ARIN what you want. They guess if its credible or not, then
> assign what you need or figure out what policy to use to avoid
> fulfilling the request.
>
>
>
> Best,
>
> -M<
>
>
> ------------------------------
>
> Message: 5
> Date: Wed, 24 Sep 2014 14:48:40 +0000
> From: David Huberman <David.Huberman at microsoft.com>
> To: John Curran <jcurran at arin.net>
> Cc: "arin-ppml at arin.net" <arin-ppml at arin.net>
> Subject: Re: [arin-ppml] Hoarding and speculation (was: Re: Draft
> Policy ARIN-2014-20: Transfer Policy Slow Start and
> Simplified Needs
> Verification)
> Message-ID:
> <
> dd33d38ad67b4bcea4ac0ecba4fbd3c6 at DM2PR03MB398.namprd03.prod.outlook.com>
>
> Content-Type: text/plain; charset="us-ascii"
>
> I think John's message, with its new info that speculators call him
> regularly to learn the rules, leads to a fairly straightforward conclusion:
>
> 2014-14 would work nicely.
>
> -get a "free" 8.3 transfer up to a /16
> -anything more requires strict needs basis <mechanism TBD>
> -throw in a clause that ARIN has the right to refuse if it believes the
> free transfer is not being made in good faith because of speculation and
> multiple OrgIDs
>
> This makes life easy for non-big guys.
>
> It deters speculation.
>
> It keeps needs basis for those with all the money.
>
> What's the counter argument against 2014-14?
>
> David R Huberman
> Microsoft Corporation
> Principal, Global IP Addressing
>
> ________________________________________
> From: John Curran <jcurran at arin.net>
> Sent: Wednesday, September 24, 2014 4:54:38 AM
> To: David Huberman
> Cc: arin-ppml at arin.net List (arin-ppml at arin.net)
> Subject: Hoarding and speculation (was: Re: [arin-ppml] Draft Policy
> ARIN-2014-20: Transfer Policy Slow Start and Simplified Needs Verification)
>
> On Sep 23, 2014, at 10:45 PM, David Huberman <David.Huberman at microsoft.com>
> wrote:
>
> > What is the virtue of a limit?
> >
> > It's not the prevention of speculation and hoarding. Those will always
> > happen outside the view of ARIN policy.
> > ...
> > Before anyone answers this, please ensure you're knowledgeable about
> > the IPv4 market today. I am.
> > ...
> > There's no speculation that I can find, short of a one-off speculator
> > who is a well-known fraudster.
> > ...
> > ARIN's job should simply be to verify the seller is the bona fide
> registrant,
> > and that the seller agrees to the transfer, and that the buyer signs an
> > RSA and pays whatever fees are necessary to cover the costs of the
> > transaction processing.
>
> David -
>
> You describe an interesting "present state", and presuming it is
> well-informed, it is probably extracting and making explicit some
> points in your worldview before continuing the discussion.
>
> You indicate -
>
> 1) Hoarding and speculation can happen outside of ARIN's view
>
> This is almost certainly the case, as parties always free
> to contract for future behavior, including a party ceding
> its ability to transfer address rights to any other party.
>
> 2) A limit on the size of transfers cannot meaningfully deter
> hoarding, due to point #1 above.
>
> 3) A limit on the size of transfers cannot meaningfully deter
> speculation, due to point #1 above.
>
> 4) Hoarding does occur, but there is no meaningful speculation
> that you can find.
>
> By "hoarding", I believe that you mean parties obtaining
> right to number resources in anticipation of future need
> to make use of them, as opposed to "speculation" whereby
> one obtains rights in anticipation of financial gain.
>
> If you are correct above, it does raise the question of "why
> isn't there abundant & apparent speculation going on today?"
>
> It can't be for lack of interest; investment firms will speculate
> on nearly anything that has good potential to beat the market.
> I've had investment firms ask about the 'rules and regulations'
> that apply to transfers of IP address rights for this very reason.
>
> The various policy merits of allowing hoarding or speculation are
> not mine to argue; that is for the community to ponder through the
> policy development process. However, you propose that we simplify
> ARIN processes and make ARIN policy fit reality; effectively that
> ARIN's job should simply be to verify the seller is the bona fide
> registrant and that parties agree to the transfer.
>
> If community does as you suggest, both hoarding and speculation
> become readily available, and this represents a significant change
> from the present state as described by your worldview. A change
> which simply formalized the present state that you describe would
> not enable speculation, since you do not view that as abundant in
> the present system. The difference between the two outcomes comes
> down to whether or not the buyer is obtaining the resources in
> anticipation of future need or simply financial gain, i.e. is the
> buyer of the rights to the addresses a bona fide network operator.
>
> I'll assert that the present system is actually rather unfavorable
> to speculation; parties that seek to obtain the rights to address
> blocks without the real potential for future use are run a very risk
> of ending up in violation of policy and with impaired investments
> as a result. More specifically, your postulate [#3] above to the
> effect that a limit on the size of transfers cannot meaningfully
> deter speculation is likely not valid - the limit does indeed deter
> speculation today, as having to qualify eventually against needs-
> based limit requires the party to actually operate a network (or
> risk total loss of the investment, likely beyond the risk profile
> of the vast majority of potential investors.)
>
> Unless you are advocating for a policy shift to enable speculation,
> simplification of ARIN policy towards your "present reality" needs
> to be more than simply verifying that the seller is the bona fide
> registrant and that parties agree to the transfer; in particular,
> verification that the recipient is a bona fide network operator
> would also be required. That is an aspect presently implied in the
> needs-based limit on the size of an address rights transfer, but
> that element could be made explicit and retained, if limit itself
> is otherwise undesirable in your view.
>
> Interesting discussion - Thank you!
> /John
>
> John Curran
> President and CEO
> ARIN
>
>
>
>
>
>
>
>
>
> ------------------------------
>
> _______________________________________________
> ARIN-PPML mailing list
> ARIN-PPML at arin.net
> http://lists.arin.net/mailman/listinfo/arin-ppml
>
> End of ARIN-PPML Digest, Vol 111, Issue 60
> ******************************************
>
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