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

Fri Sep 25 07:23:45 EDT 2015

Hi Owen,

On 25/09/15 09:23, Owen DeLong wrote:
> It’s not ARIN’s mission to prevent profits nor did I say it was.
>
> My point is that Elvis support for removing policy is strongly influenced by the potential windfall he stands to reap while not actually providing
> any internet services in the process if the policy is changed as he wishes.
Please stop implying what influences my beliefs. I doubt you can read my 
mind.

I already said it several times that regardless of the outcome, there 
are plenty of organizations that have already received 'pre-approvals' 
and helping at least those will fill up my plate.. What do you mean we 
do not provide an internet service? We offer various services, not just 
the brokerage part.
> As yo pointed out, many folks make a profit on various INETERNET SERVICES. Elvis, OTOH is not in the internet services business. He’s strictly
> an address broker.
What do you mean by 'not in the internet services business' ? I think 
you are starting to be rude and would like to ask you to back off a bit.
We offer various services to our customers: IP management, LIR 
management, audits, Sponsoring LIR services (RIPE Region), IPv6 
migration support, etc...
> It would be sort of like Realtors arguing against transfer taxes on real estate. An argument based solely in greed rather than any actual concern for the common good.
Again, you are just guessing why I am commenting on this policy 
proposal. As an ex-RIR employee, I've told you (and others) several 
times that I still want to do the right thing for the community. I have 
already made several policy proposals in the RIPE Region (one recently 
accepted by the community) and I am active in APNIC and now ARIN...

Owen, last time we discussed you said that you understand the need of 
brokers and while a few years back you did not agree with us existing, 
now you are no longer against... I see personal attacks in the two 
e-mails you sent and I don't understand where these come from.

Owen, please stop guessing what my business does and why I participate 
in the discussions. I doubt this is what an ARIN AC member should do..

regards,
Elvis

PS: I could have registered to the mailing list with my work e-mail 
address if all I wanted to do is to profit from my position on this (and 
other) policy proposals discussions. These messages are sent on my 
behalf and may or may not be the point of view of the company I work for
>
> Owen
>
>> On Sep 24, 2015, at 13:53 , Steven Ryerse <SRyerse at eclipse-networks.com> wrote:
>>
>> Many folks make a profit on various Internet services in this Region. ARIN was created to further the Internet and not stifle it.  Nowhere do I see that it is part of ARIN's mission to somehow prevent profits via policies. Appears to me to be all about the haves keeping the have nots from obtaining resources.  :-(
>>
>> Steven Ryerse
>> President
>> 100 Ashford Center North, Suite 110, Atlanta, GA  30338
>> 770.656.1460 - Cell
>> 770.399.9099- Office
>>
>> ℠ Eclipse Networks, Inc.
>>                      Conquering Complex Networks℠
>>
>> -----Original Message-----
>> From: arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] On Behalf Of Owen DeLong
>> Sent: Thursday, September 24, 2015 4:37 PM
>> To: elvis at velea.eu
>> Cc: arin-ppml at arin.net
>> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
>>
>> 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.
>> _______________________________________________
>> 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.