[arin-ppml] Draft Policy ARIN-2014-18: SimplifyingMinimumAllocations and Assignments

Mike Burns mike at iptrading.com
Wed Sep 3 14:25:38 EDT 2014

Hi Owen,

"Needs testing is not merely a vehicle to save the remaining free pool. If 
that were true, then we would not have subjected the transfer policies to 
needs testing."

Prior to the 12 month waiting period for transfers which was implemented in 
2012, needs testing was *indeed* required to save the remaining free pool. 
Otherwise applicants would receive an allocation, sell it to re-establish 
their need, and get another allocation.  No bogus ORGs needed. Even before 
addresses could be openly sold, needs testing of transfers was required to 
avoid the draining of the free pool through needs-based allocations, then 
transfers to a non-needing party, rinse and repeat. This is why I believe 
needs testing was applied to transfers in RFC2050, not due to any principle 
which required registry stewards to arbitrate transfers in the absence of a 
free pool and the presence of a natural conserving factor- price.

I am opposed to 2014-18. Now that the minimums have dropped to /24, one of 
the barriers to very small applicants has been removed. Although I am 
against need-testing of transfers, I am in favor of continued needs-testing 
free pool allocations, even the lowly /24s.

Mike Burns

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