[arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

Thu Sep 24 17:11:38 EDT 2015

Owen,

if someone needs an IPv4 transfer and wants to use our brokerage firm, 
believe me we will be happy to assist them and help them get what they 
need (regardless of whether the needs-based criteria is still in the 
policy or not). Off course, we will do everything to respect the 
policies of (all of) the RIRs while helping our customers get what they 
want.

An unrestricted transfer market may increase the number of transfers we 
broker - that's true, but in the end 'the money' (you call it profits) 
will be the same. The number of available (read: unused and ready to be 
transferred) IP addresses will not change, we (the brokers) will broker 
them regardless of who the buyer is. What will change is the correct 
registration (in place of the contracts hidden in a drawer in a lawyer's 
office).

There is almost a /12 unmet (read: justified) on the ARIN waiting list.. 
in 2.5 months. We won't probably be able to keep up with the number of 
companies receiving approvals from ARIN, so.. no I have worries about 
our 'profits'. What I worry about is that, maybe, those that have the 
funds will buy the resources and not keep a proper registration because 
either the policy is too restrictive to them, their employee has not 
succeeded in convincing the ARIN staff or their future usage plans were 
maybe not clear enough.

Again, from my experience (we've brokered more than a /11 in the 2 years 
since our company exists) if someone has the money for it and wants it, 
they will get it .

regards,
elvis

On 24/09/15 23:37, Owen DeLong wrote:
> Of course your position wouldn’t have anything to do with the profits you stand to make from an unrestricted transfer market.
>
> Owen
>
>> On Sep 24, 2015, at 13:12 , Elvis Daniel Velea <elvis at velea.eu> wrote:
>>
>> Hi Owen,
>>
>> On 24/09/15 22:09, Owen DeLong wrote:
>>> Short answer: NO
>>>
>>> Longer answer:
>>>
>>> Finance alone does not reflect all community values. Eliminating needs-based evaluation for transfers
>>> will foster an environment open to speculation and other artifice used to maximize the monetization of
>>> address resources without providing the benefit to the community of maximizing utilization.
>> The environment open to speculation already exists, a needs-based criteria will not stop the ones that want to speculate. Keeping needs-based criteria in policy will only drive (keep some of the) transfers underground (ie: futures contracts, all kind of financial artifices). I actually believe the needs-based criteria removal will benefit the community by eliminating a barrier in the correct registration of the transfers (resources) in the registry (and whois).
>>
>> The allocation era has passed, ARIN should just be a shepherd and record the transfers (and do the allocation exercise twice per year, when the IANA allocates the few crumbs remaining). From my experience and observations, if someone needs the IP addresses and has the money to pay for them I am sure that they will not be stopped by ARIN's needs-base criteria...
>>> In fact, I believe that eliminating needs-basis will likely cause actual utilization to be reduced in the
>>> long run in favor of financial manipulation.
>> I dare to disagree. From where I am standing, the removal of needs-basis criteria from the RIPE Region has increased utilization of the resources transferred through the IPv4 marketplace.
>> Additionally, the removal of the needs-basis criteria has increased the number of transfers, showing that the marketplace works and is useful to hundreds (or even thousands) of companies from the region.
>>
>> I am not saying that the ARIN community should copy what the RIPE community has done. I am just saying that if something is working and it's usability is proven, it is rather strange to see some saying the opposite as an argument against the removal of the needs-based criteria.
>>> Owen
>> cheers,
>> elvis
>>>> On Sep 24, 2015, at 11:55 , Leif Sawyer <lsawyer at gci.com> wrote:
>>>>
>>>> Now that we've reached the magic ZERO in the free pool, what does the community
>>>> think about this new draft policy?
>>>>
>>>> Should ARIN begin the process of streamlining the IPv4 policy so that it is
>>>> geared more toward the transfer market, and remove "need" as a criteria in
>>>> certain sections of the NRPM to increase the database accuracy?
>>>>
>>>>
>>>> -----Original Message-----
>>>> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of ARIN
>>>> Sent: Wednesday, September 23, 2015 12:54 PM
>>>> To: arin-ppml at arin.net
>>>> Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
>>>>
>>>> Draft Policy ARIN-2015-9
>>>> Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
>>>>
>>>> On 17 September 2015 the ARIN Advisory Council (AC) accepted
>>>> "ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks" as a Draft Policy.
>>>>
>>>> Draft Policy ARIN-2015-9 is below and can be found at:
>>>> https://www.arin.net/policy/proposals/2015_9.html
>>>>
>>>> You are encouraged to discuss the merits and your concerns of Draft Policy 2015-9 on the Public Policy Mailing List.
>>>>
>>>> The AC will evaluate the discussion in order to assess the conformance of this draft policy with ARIN's Principles of Internet Number Resource Policy as stated in the PDP. Specifically, these principles are:
>>>>
>>>>     * Enabling Fair and Impartial Number Resource Administration
>>>>     * Technically Sound
>>>>     * Supported by the Community
>>>>
>>>> The ARIN Policy Development Process (PDP) can be found at:
>>>> https://www.arin.net/policy/pdp.html
>>>>
>>>> Draft Policies and Proposals under discussion can be found at:
>>>> https://www.arin.net/policy/proposals/index.html
>>>>
>>>> Regards,
>>>>
>>>> Communications and Member Services
>>>> American Registry for Internet Numbers (ARIN)
>>>>
>>>>
>>>> ## * ##
>>>>
>>>> Draft Policy ARIN-2015-9
>>>> Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
>>>>
>>>> Date: 23 September 2015
>>>>
>>>> Problem statement:
>>>>
>>>> The current policies in NRPM sections 8.2, 8.3, and 8.4 regarding transfer of IPv4 netblocks from one organization to another are currently a hindrance in ensuring database accuracy. In practice, ARIN staff are utilizing those polices to refuse to complete database updates which would reflect an accurate transfer of control / utilization of netblocks in cases where ARIN doesn't agree that the recipient organization has need, or more often where the recipient organization bypasses the ARIN registry entirely in order to secure the needed IPv4 netblocks in a more timely fashion directly from the current holder.
>>>> Additionally, the 8.1 introduction section includes a perceived "threat"
>>>> of reclaim which serves as a hindrance to long-term resource holders approaching ARIN with database updates when transferring resources. The result is that the data visible in ARIN registry continues to become more inaccurate over time.
>>>>
>>>> Policy statement:
>>>>
>>>> This proposal is for the following language changes in the respective NRPM sections in order to eliminate all needs-based evaluation for the respective transfer type, and allow transfers to be reflected in the database as they occur following an agreement of transfer from the resource provider to the recipient.
>>>>
>>>> Section 8.1 Principles:
>>>>
>>>> - Strike the 3rd paragraph which begins with "Number resources are issued, based on justified need, to organizations. . ." since it mostly reiterates other sections of ARIN policy. All transfers are subjected to those policies, as called out in 8.2, 8.3, 8.4. Additionally, removing this paragraph removes the perceived "threat" of reclaim which serves as a hindrance to long-term resource holders approaching ARIN with database updates, since in practice ARIN has not been forcibly reclaiming IP resources assigned to "failed businesses."
>>>>
>>>> Section 8.2 Mergers and Acquisitions:
>>>>
>>>> - Change the 4th bullet from:
>>>>
>>>> "The resources to be transferred will be subject to ARIN policies."
>>>>
>>>> to:
>>>>
>>>> "The resources to be transferred will be subject to ARIN policies, excluding any policies related to needs-based justification or inspection of current or future utilization rate."
>>>>
>>>> - Remove entirely the last paragraph which reads "In the event that number resources of the combined organizations are no longer justified under ARIN policy at the time ARIN becomes aware of the transaction, through a transfer request or otherwise, ARIN will work with the resource holder(s) to return or transfer resources as needed to restore compliance via the processes outlined in current ARIN policy."
>>>>
>>>> Section 8.3 Transfers between Specified Recipients within the ARIN Region:
>>>>
>>>> - Change the first bullet under "Conditions on recipient of the transfer" from:
>>>>
>>>> "The recipient must demonstrate the need for up to a 24-month supply of IP address resources under current ARIN policies and sign an RSA."
>>>>
>>>> to:
>>>>
>>>> "The recipient must sign an RSA."
>>>>
>>>> - Change the 2nd bullet under "Conditions on recipient of the transfer"
>>>> from:
>>>>
>>>> "The resources to be transferred will be subject to ARIN policies."
>>>>
>>>> to:
>>>>
>>>> "The resources to be transferred will be subject to ARIN policies, excluding any policies related to needs-based justification or inspection of current or future utilization rate."
>>>>
>>>> Section 8.4 Inter-RIR Transfers to Specified Recipients:
>>>>
>>>> - Change the introductory language from:
>>>>
>>>> "Inter-regional transfers may take place only via RIRs who agree to the transfer and share reciprocal, compatible, needs-based policies."
>>>>
>>>> to:
>>>>
>>>> "Inter-regional transfers may take place only via RIRs who agree to the transfer and share reciprocal, compatible, policies."
>>>>
>>>> - Change the 2nd bullet under "Conditions on recipient of the transfer"
>>>> from:
>>>>
>>>> "Recipients within the ARIN region will be subject to current ARIN policies and sign an RSA for the resources being received."
>>>>
>>>> to:
>>>>
>>>> "Recipients within the ARIN region will be subject to current ARIN policies, excluding any policies related to needs-based justification or inspection of current or future utilization rate, and sign an RSA for the resources being received."
>>>>
>>>> - Remove entirely the 3rd bullet under "Conditions on recipient of the transfer" which reads "Recipients within the ARIN region must demonstrate the need for up to a 24-month supply of IPv4 address space."
>>>>
>>>> Comments:
>>>>
>>>> a.	Timetable for implementation: Immediate
>>>>
>>>> b.	Anything else
>>>>
>>>> As the "free pool" for 4 of the 5 world's RIRs (APNIC, RIPE, LACNIC, and
>>>> ARIN) has now been exhausted, networks in need of additional IPv4 addresses have shifted away from the practice of receiving them from the RIR's resource pool. Instead, networks in need are seeking out current holders of IPv4 resources who are willing to transfer them in order to fulfil that need. Accordingly, the RIR's primary responsibility vis-à-vis IPv4 netblock governance has shifted from "allocation" to "documentation." In other words, the focus must move away from practicing conservation and fair distribution (e.g. following guidelines set forth in RFC2050) to ensuring an accurate registry database of which organization is utilizing a given netblock as a result of transfers which occur between organizations.
>>>>
>>>> The RIPE registry can be used as a reference of one which has evolved over the past couple years to shift their focus away from conservation/allocation and towards database accuracy. IPv4 netblock transfers within that RIR consist merely of validating authenticity of the parties requesting a transfer. Provided the organizations meet the basic requirement of RIR membership, and that the transferring organization has the valid authority to request the transfer, the transaction completes without any "needs-based" review.
>>>>
>>>>
>>>> _______________________________________________
>>>> 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.
>>>> _______________________________________________
>>>> 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.
>>> _______________________________________________
>>> 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.
>> _______________________________________________
>> 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.