[arin-ppml] Thoughts on 2015-7

[Scott Leibrand]

Thanks for the constructive suggestions.  Let me see (inline below) if I
understand exactly what you're saying.

On Wed, Feb 10, 2016 at 9:31 PM, Jason Schiller <jschiller at google.com>
wrote:

> 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.
>

So if I understand correctly, you're suggesting that we reinstate the >80%
overall and 50% per-resource utilization requirements for simplified
transfers, but once an organization has met that threshold, they can
qualify for a simplified transfer that will get them up to 2x their current
holdings?  (You removed "or 24-month projected usage".)

The proposed text as written ("IPv4 transfer recipients must demonstrate
(and an officer of the requesting organization must attest) that they will
use at least 50% of their aggregate IPv4 addresses (including the requested
resources) on an operational network within 24 months.") is more liberal
than that on two counts: 1) it does not include any requirement for
utilization level of current resources, and 2) it allows the transfer of
resources up to 2x the 24-month projection (as attested by an officer).  I
understand your objection to 2), but can you clarify why you think 1) is
problematic?

I would like to get more feedback from others here on PPML as to how
comfortable we are trusting officer attestations of forward-looking
projections, plus the need to shell out real hard cash for any space
obtained, as a limit on any fraudulent or anticompetitive behavior.

*If* a lot of people are uncomfortable with trusting officer-attested
forward-looking projections, then another middle ground would be to simply
limit simplified transfers to 2x current holdings.  I think that would be
sufficient for most organizations, and any for whom RSA section 4 is a
better option can of course elect to use that, as you mentioned in your #3
below.  It would also address your desire for a "tangible and verifiable
claim to show there was a real commitment to use half the address space
within two years", because they would actually be required to demonstrate
use of half the resulting address space holdings before they qualify for
the simplified transfer at all.

Thoughts?

-Scott


> 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<
>>>
>>>
>>>
>>>
>>
>>
>> _______________________________________________
>> 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.
>>
>
>
>
> --
> _______________________________________________________
> Jason Schiller|NetOps|jschiller at google.com|571-266-0006
>
>
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-ppml/attachments/20160210/68d40671/attachment.htm>