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

Mon Sep 28 21:36:28 EDT 2015

Bill, 

Great compromise proposal. 

Can you clarify your point b) -- why limit the number of inbound transfers to reach n size in a ? 

Thanks, 
Mark 

From: "Bill Buhler" <bill at tknow.com> 
To: "owen" <owen at delong.com> 
Cc: arin-ppml at arin.net 
Sent: Monday, September 28, 2015 12:59:30 PM 
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 

OK, how about this: 

Small end users and ISPs are allowed to obtain IPv4 address blocks without a needs test as long as the following criteria are met: 

a. The total size of their ARIN allocations at any time of the process does not exceed a /20 if a ISP or /22 for an end user. 

b. They cannot purchase IP address from the transfer market more than three total times to reach this size, including the initial operation. 

c. None of the addresses purchased can be transferred to any other entity for twenty-four months following the date of the last transfer. 

d. If the company ceases operations within the twenty-four month window the addresses are automatically transferred to the ARIN free pool. After that period of time regular transfer rights exist. 

e. All subsequent allocations / transfers require regular needs testing after the initial twenty-four month allocation window. 

f. Eligible entities for this policy consist of ISPs and End users who have a unique physical address in the ARIN region at the suite level. Meaning if two companies share the same suite they are not eligible to both have ARIN allocations. 

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

I believe that meets all of your concerns. I would prefer companies get everything they think they will need in one operation, but I don’t want to have fear drive them into buying the max amount just in case. 

Best regards, 

Bill Buhler 

From: Owen DeLong [mailto:owen at delong.com] 
Sent: Monday, September 28, 2015 1:09 PM 
To: Bill Buhler 
Cc: Adam Thompson; 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 28, 2015, at 11:50 , Bill Buhler < bill at tknow.com > wrote: 

Thanks Owen for your thoughts, it sounds to me like we are getting a lot closer to a compromise, would this be a sufficient circuit breaker: 

Small end users and ISPs are allowed initial and follow up transfers up to a /20 for ISPs or /22 for end users from the market. These transfers can be conducted in no more than three operations over a 24 month period. None of the transferred addresses can be transferred to another entity for twenty-four months following the date of the last transfer. If the company ceases operations within that twenty-four month window the addresses automatically become property of ARIN and are placed in the free pool. After that period of time regular transfer rights exist. 

Property is a loaded term in this context. 

I would be OK with the proposal, but we would need to change “automatically become property of...” to “are automatically returned to the ARIN free pool”. 

Also, you’re still allowing “follow up” transfers without needs testing. So there’s ambiguity as to whether you mean follow-ups up to a total holding of (/20,/22) or if you mean there’s a new (/20,/22) followup cycle each 24 months. 

The former would be acceptable to me. The latter would not. 

All subsequent allocations / transfers require regular needs testing. 

Eligible entities for this policy consist of ISPs and End users who have a unique physical address in the ARIN region at the suite level. Meaning if two companies share the same suite they are not eligible to both have ARIN allocations. 

BQ_BEGIN

My reasoning of allowing follow up transfers is within the first two years, but not allowing transfers out for twenty-four months from the last transfer is it encourages companies to go for a small initial allocation rather than buying their max possible size initially knowing that they next time they will need to go through needs testing. 

BQ_END

I don’t see any reason to worry about this in the transfer market. We allow for a 24 month need, so there’s no overall advantage IMHO to facilitating a smaller initial transfer and allowing subsequent transfers without need, but if people feel this is useful, I can live with it. Personally, I think it just encourages fragmentation of the routing table without providing a tangible benefit. 

Owen 

Any thoughts? 

Bill Buhler 

From: arin-ppml-bounces at arin.net [ mailto:arin-ppml-bounces at arin.net ] On Behalf Of Owen DeLong 
Sent: Monday, September 28, 2015 11:11 AM 
To: Adam Thompson 
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 

I’m not going to support anything that provides a blanket exemption from needs basis. 

I will support a change which allows an initial allocation/assignment/transfer of a minimal block of addresses (up to a /22 for an end-user or up to a /20 for an ISP seems reasonable to me) so long as it also includes anti-flip protections and some language preventing spinning up related party entities strictly for address acquisition. 

I believe this would address most of the concerns expressed (other than those seeking to eliminate needs basis altogether). 

Owen 

BQ_BEGIN

On Sep 26, 2015, at 19:48 , Adam Thompson < athompso at athompso.net > wrote: 

At this point, I support anything that looks like a compromise so we can get *any* change in policy at all... So this looks like a decent compromise to me. Yes, it'll have to be revisited in a couple of years' time; yes, the specifics probably aren't perfect. The community can change those. The policy can even be written such that ARIN staff can change them independently (although this doesn't seem to be a popular model). 
Insisting on perfection is just hamstringing the entire service region... both the speculators *and* legitimate users. 
-Adam 

On September 26, 2015 8:47:46 PM CDT, Brian Jones < bjones at vt.edu > wrote: 

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 - Cell 

770.399.9099 - Office 

℠ Eclipse Networks, Inc. 

Conquering Complex Networks ℠ 

From: arin-ppml-bounces at arin.net [ mailto: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 

BQ_BEGIN

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: 
BQ_BEGIN

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. 

BQ_END

the outcome is that everyone that will need IP addresses will be able to get them. Isn't that quite definitive and clear? 

BQ_END

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. 

BQ_BEGIN

BQ_BEGIN

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]. 

BQ_END

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). 

BQ_END

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. 

BQ_BEGIN

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. 

BQ_END

I think claiming that those of us who believe needs-based criteria is still useful are asleep is unwarranted. 

BQ_BEGIN

BQ_BEGIN

Changing policy just to (potentially) improve the accuracy of a database seems not worth the (potential) risk. 

BQ_END

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. 

BQ_END

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 

BQ_BEGIN

BQ_BEGIN

Richard 

BQ_END

regards, 
Elvis 
BQ_BEGIN

________________________________________ 
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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