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

[Brian Jones]

I find Bill's proposal an interesting middle ground approach. I do not
believe completely eliminating needs-based justification for addresses is
the correct thing to do.

--
Brian

On Fri, Sep 25, 2015 at 4:05 PM, Bill Buhler <bill at tknow.com> wrote:

> Having watched this for the last couple of years let me make a couple of
> observations / one proposal:
>
>
>
> There seems to be a lot of fear on both sides of this debate, on the needs
> test side there seems to be a complete fear of monopolization of the IP
> address space by those with deep pockets.
>
>
>
> On the other side there seem to be a couple of thoughts:
>
>
>
> 1.       It’s a market, markets work best when freed from constraints
> that increase the complexity of non-harmful transactions, and that allowing
> companies to more freely exchange IP resources is not harmful.
>
> 2.        Not liking to justify future and current operations to a third
> party / fear of rejection by this process.
>
>
>
> I may not have encapsulated both arguments well, and these have been
> hashed over again and again for the last few years. So what is different
> today? ARIN has allocated every last resource from the free pool, and has a
> long waiting list.
>
>
>
> So what if we strike a compromise? What if some restrictions were put on
> allocation size and frequency without a needs test and left only the truly
> large or frequent transactions to do it. Something like this:
>
>
>
> Every legal entity can obtain up to a /22 from the transfer market every
> year, in up to two transactions. They may not transfer these resources out
> of their network within twelve months. Each legal entity has to occupy a
> unique address (suite level) from any other entity in the ARIN database.
>
>
>
> All transfers larger than a /22 need to have needs based justification
> done based on the current model.
>
>
>
>
>
> If you wanted to speculate, you would need to spin-up dozens of entities
> all with unique mailstops, and you would have to camp on the addresses for
> a year. Meanwhile the small end users and ISPs could obtain up to a /22 of
> a resource that with a lot of careful use of NAT would support a fairly
> large public network.
>
>
>
> Best regards,
>
>
>
> Bill Buhler
>
>
>
> *From:* arin-ppml-bounces at arin.net [mailto:arin-ppml-bounces at arin.net] *On
> Behalf Of *Steven Ryerse
> *Sent:* Friday, September 25, 2015 11:48 AM
> *To:* Owen DeLong
>
> *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
>
>
>
> Owens comment from below:
>
> “2. To the extent that there is supply, anyone who needs addresses can get
> them already. Needs-based evaluation does not prevent those with need from
> getting addresses… It prevents those without need from getting them.”
>
>
>
> Owen’s comment is absolutely false!!!!!  It allows large organizing who
> request resources to get what they need or something smaller.  It allows
> medium size organizations who request resources to get what they need or
> something smaller.  It allows small organizations who request resources to
> get what they need or nothing, and there is no other source to get
> resources if ARIN rejects a request, but the open market which Owen and
> others seem to wish did not exist!
>
>
>
> It is time to fix this inequity and removing needs tests would be a big
> help to small organizations who really need resources!
>
>
>
> *Steven Ryerse*
>
> *President*
>
> *100 Ashford Center North, Suite 110, Atlanta, GA  30338*
>
> *770.656.1460 <770.656.1460> - Cell*
>
> *770.399.9099 <770.399.9099>- Office*
>
>
>
> [image: 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
> <arin-ppml-bounces at arin.net>] *On Behalf Of *Owen DeLong
> *Sent:* Friday, September 25, 2015 1:24 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
>
>
>
>
>
> On Sep 25, 2015, at 04:42 , Elvis Daniel Velea <elvis at velea.eu> wrote:
>
>
>
> Hi Richard,
>
> On 25/09/15 06:46, Richard J. Letts wrote:
>
> b)
> There is no definitive outcome from the policy change, which makes me feel
> that it's not worth changing -- the problem statement argument is weak at
> best.
>
> the outcome is that everyone that will need IP addresses will be able to
> get them. Isn't that quite definitive and clear?
>
>
>
> Sure, except it isn’t actually an outcome of the proposal on many levels:
>
>
>
> 1. The proposal does nothing to guarantee a supply of addresses or even
> increase the supply.
>
> 2. To the extent that there is supply, anyone who needs addresses can get
> them already. Needs-based evaluation does not prevent those with need from
> getting addresses… It prevents those without need from getting them.
>
> 3. The definitive outcome from the policy change, if there is such, is
> that those without need will now be more easily able to acquire addresses,
> potentially preventing those with need from acquiring them.
>
>
>
>
> It is potentially enabling organizations with more money than need gain
> more resources, potentially at the expense of non-profit and educational
> organizations who might not be able to raise cash for additional IPv4 space
> [or equipment to support a transition to IPv6].
>
> So, you think that in today's market the non-profit/educational
> organizations will have the chance at getting some of the IP space from the
> market? And if the needs-based barrier is removed, they will no longer have
> that chance?
> Everyone knows that the IP address is now an asset and is worth a buck.
> Who do you think will say: I'll give it for free to this educational
> organization (because they have proven the need to ARIN) instead of giving
> it for money to this commercial entity (that may or may not have a
> demonstrated need need for it).
>
>
>
> Contrary to your statement, there have been addresses returned to ARIN and
> there have been organizations who chose to transfer addresses to those they
> found worthy rather than maximize the monetization of those addresses.
>
>
>
> OTOH, having a policy like this in place certainly makes it easier to
> manipulate the market to maximize the price.
>
>
>
> I think we need to wake up. Keeping needs-based criteria in the policy
> will only cause SOME transfers to be driven underground and block some
> others.
>
>
>
> I think claiming that those of us who believe needs-based criteria is
> still useful are asleep is unwarranted.
>
>
>
> Changing policy just to (potentially) improve the accuracy of a database
> seems not worth the (potential) risk.
>
> The change of the accuracy of the registry is already proven in the RIPE
> region. I would say it's not just potential, it is real and visible.
>
>
>
> Please provide the metrics on which you base this assertion. How was
> RIPE-NCC accuracy measured prior to the policy change and to what extent
> was it improved as a result of this policy change. What mechanism was used
> to determine that the measured increase in accuracy was the result of the
> particular policy abandoning needs-based evaluation?
>
>
>
> Owen
>
>
>
>
> Richard
>
> regards,
> Elvis
>
>
> ________________________________________
> From: arin-ppml-bounces at arin.net <arin-ppml-bounces at arin.net> on behalf
> of Dani Roisman <droisman at softlayer.com>
> Sent: Thursday, September 24, 2015 6:20 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
>
> | Date: Wed, 23 Sep 2015 16:53:59 -0400
> | From: ARIN <info at arin.net>
> | 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
> | Message-ID: <56031167.1010007 at arin.net>
> | Content-Type: text/plain; charset=utf-8; format=flowed
> |
> | 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
>
> Greetings,
>
> There has been some stimulating dialog about the merits of 2015-9.  I'd
> like to ask that in addition to any overall support or lack thereof, you
> also review the policy language and comment specifically on the changes
> proposed:
> a) For those of you generally in support of this effort, are there any
> refinements to the changes made which you think will improve this should
> these policy changes be implemented?
> b) For those of you generally opposed to this effort, are there any
> adjustments to the policy changes which, if implemented, would gain your
> support?
>
> --
> Dani Roisman
> _______________________________________________
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