[arin-ppml] Thoughts on 2015-7

[Jason Schiller]

I oppose as written.

I opposed ARIN-2015-3 and I oppose this draft policy on the same grounds.
I support simplifying some transfers and keeping the more complicated old
rules for others in general...

However, the policy as written requires no real, tangible, and verifiable
claim.  Without such a check justified need for transfers simply becomes a
2 year future looking projection, and with sufficient arm waving an easy
end run around justified need.

I could certainly get on board if there were some other tangible and
verifiable claim to show there was a real commitment to use half the
address space within two years.

I choose Scott's email to reply to because I like his approach in general.

1. Make an agreement to acquire addresses in the quantity you believe you
need.
2. If that agreement brings your total address holdings to less than 2x
your current or 24-month projected usage, get easy approval for the
transfer from ARIN under the Simplified requirements for demonstrated need
for IPv4 transfers defined in this draft policy.
3. Skip the LOA and ongoing legal stuff.
4. Use the addresses.

I would suggest a slight modification and a slight clarification.

1. Make an agreement to acquire addresses in the quantity you believe you
need.
2. If that agreement brings your total address holdings to less than 2x
your current holdings
    And your current holdings are > 80% utilized in aggregate and no less
that 50% per resource,
    then you qualify for a simplified transfer.
3. You can still qualify for a two year supply under the current
unsimplified policy
    You can get twice your last year's run rate
    if your current holding are > 80% utilization in aggregate and no less
that 50% per resource,
4. Sign an RSA
5. Use the addresses

Note: sources of a transfer still:
- must be the current (dispute free) registered holder of the IPv4 address
space
- must not have received a transfer, allocation or assignment from ARIN in
the last year
  (not including M&A)
- minimum /24


Neither Scott's nor my approach here deal with organizations that have no
resources.

I (and MJ) tried a more complicated version of this as ARIN-2014-20.

Scott, do you want to consider my (friendly) amendment and draft some text?

Do you want to consider what to do for organizations with no resources?


___Jason


On Mon, Oct 5, 2015 at 4:30 PM, Scott Leibrand <scottleibrand at gmail.com>
wrote:

> I believe we should make it easy to:
>
> 1. Make an agreement to acquire addresses in the quantity you believe you
> need.
> 2. If that agreement brings your total address holdings to less than 2x
> your current or 24-month projected usage, get easy approval for the
> transfer from ARIN under the Simplified requirements for demonstrated
> need for IPv4 transfers defined in this draft policy.
> 3. Skip the LOA and ongoing legal stuff.
> 4. Use the addresses.
>
> -Scott
>
> On Mon, Oct 5, 2015 at 1:07 PM, Martin Hannigan <hannigan at gmail.com>
> wrote:
>
>>
>>
>> On Mon, Oct 5, 2015 at 3:29 PM, Scott Leibrand <scottleibrand at gmail.com>
>> wrote:
>>
>>> Reducing the burden on ARIN staff is not part of the problem statement
>>> for this proposal (though it might be a side effect, depending on how they
>>> implement it).  The main goal here is to reduce the administrative burden
>>> on organizations who need to acquire IPv4 space via transfer.  That burden
>>> may actually be higher for smaller entities who don't have experience with
>>> and processes in place for jumping through ARIN's hoops.
>>>
>>> I don't think this policy would have much impact on the ability of large
>>> well-funded entities to purchase as much address space as they like.
>>> Currently, those organizations simply write a contract that gives them full
>>> rights to the address space they're buying, and allows them to transfer the
>>> space with ARIN whenever they are ready to put it into use on their network
>>> (or can otherwise pass ARIN's needs justification tests).
>>>
>>>
>>>
>>
>> Let me give you a real world example.
>>
>> 1. Buy rights to use addresses in any quantity you believe you need
>> 2. Use those addresses as you need them, assuming the agreement you made
>> with the party works properly
>> 3. Get an LOA from the documented owner
>> 4. Bypass ARIN entirely
>> 5. Use the addresses.
>>
>> How do you think we should solve that problem?
>>
>>
>> Best,
>>
>> -M<
>>
>>
>>
>>
>
>
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-- 
_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com|571-266-0006
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