[arin-ppml] 2014-14

Steven Ryerse SRyerse at eclipse-networks.com
Wed Sep 24 14:54:23 EDT 2014


I agree – this is an improvement from current policy. +1

Steven Ryerse
President
100 Ashford Center North, Suite 110, Atlanta, GA  30338
770.656.1460 - Cell
770.399.9099- Office

[Description: Description: Eclipse Networks Logo_small.png]℠ Eclipse Networks, Inc.
        Conquering Complex Networks℠

From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of Rudolph Daniel
Sent: Wednesday, September 24, 2014 1:47 PM
To: arin-ppml at arin.net
Subject: Re: [arin-ppml] 2014-14


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<mailto:arin-ppml-request at arin.net>> wrote:
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Today's Topics:

   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<mailto:matthew at matthew.at>>
To: David Huberman <David.Huberman at microsoft.com<mailto:David.Huberman at microsoft.com>>
Cc: "arin-ppml at arin.net<mailto:arin-ppml at arin.net> List \(arin-ppml at arin.net<mailto:arin-ppml at arin.net>\)"
        <arin-ppml at arin.net<mailto: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<mailto: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<mailto: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<mailto:ARIN-PPML at arin.net>).
> Unsubscribe or manage your mailing list subscription at:
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> Please contact info at arin.net<mailto: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<mailto:jcurran at arin.net>>
To: David Huberman <David.Huberman at microsoft.com<mailto:David.Huberman at microsoft.com>>
Cc: "arin-ppml at arin.net<mailto:arin-ppml at arin.net> List \(arin-ppml at arin.net<mailto:arin-ppml at arin.net>\)"
        <arin-ppml at arin.net<mailto: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<mailto: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<mailto: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<mailto:mike at iptrading.com>>
To: "David Huberman" <David.Huberman at microsoft.com<mailto:David.Huberman at microsoft.com>>,    "John Curran"
        <jcurran at arin.net<mailto:jcurran at arin.net>>
Cc: arin-ppml at arin.net<mailto: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<mailto:David.Huberman at microsoft.com>>
To: "John Curran" <jcurran at arin.net<mailto:jcurran at arin.net>>
Cc: <arin-ppml at arin.net<mailto: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<mailto: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<mailto: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<mailto:hannigan at gmail.com>>
To: Owen DeLong <owen at delong.com<mailto:owen at delong.com>>
Cc: "arin-ppml at arin.net<mailto:arin-ppml at arin.net>" <arin-ppml at arin.net<mailto: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<mailto: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<mailto: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<mailto:David.Huberman at microsoft.com>>
To: John Curran <jcurran at arin.net<mailto:jcurran at arin.net>>
Cc: "arin-ppml at arin.net<mailto:arin-ppml at arin.net>" <arin-ppml at arin.net<mailto: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<mailto: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<mailto:jcurran at arin.net>>
Sent: Wednesday, September 24, 2014 4:54:38 AM
To: David Huberman
Cc: arin-ppml at arin.net<mailto:arin-ppml at arin.net> List (arin-ppml at arin.net<mailto: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<mailto: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









------------------------------

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