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

Fri Feb 19 00:20:02 EST 2016

I have a question. Our small ISP company is losing a /22 and a /23 we 
were reallocated years
ago. The company sold and now is requiring us to give these back. This was
unexpected. We did not see that coming and by the time we got the news 
and started
the process to directly acquire IPv4 ARIN was out.

My question is: if we justify a certain IP Block maybe a /21 or /22. Is 
it true if we acquire
them a /24 at a time we have to wait 12 months before we can get the 
next transfer
approved? and have to pay another $500 for each /24 we get transferred 
in. So if we are lucky to find a legacy owner, I have been told by ARIN 
that they need proof of the company
from the secretary of state. Back in the 80's and 90's fictitious names 
did not have to
be registered by most states especially in the case of a sole 
proprietorship or a
small corporation using an unregistered DBA. This seems to be the case 
of acquiring
and trying to transfer legacy IP Blocks in to ARIN. We were required to 
get a new ORG-ID
because the dba we were using at the time of the re-allocation wasn't 
registered with the state.
It was perfectly legal at the time the ORG-ID was issued. This is the 
biggest obstacle
I have had. I am scared to acquire Legacy Resources because ARIN 
threatens to
claw them back if I try to transfer and register them. The big companies 
have lawyers that
can fight the ARIN policies and win, we do not.

If I am misunderstanding the transfer system please clue me in. This is 
extremely
expensive for a small ISP like us. I see both sides of the proposal as 
detrimental
to small ISP's. We are currently having to re-IP 8 /24's to a /27. Very 
hard to do!

I want what ever it takes to transfer in resources up to the 
justification amount.
It might take 1 year maybe 10 years and not be charged on every /24 up to
our justification..

IPv6 direct allocations were supposed to get a $500 direct allocation by 
now.
A $500 direct allocation of IPv6 would help but we have to find enough IPv4
to stay in business. Currently our fiber provider can provide IPv6 to our
rural area.

Please help me understand the bureaucracy that ARIN is?

Thanks
Paul McNary
McNary Computer Services

On 2/18/2016 10:50 PM, Randy Carpenter wrote:
> So, you are saying that you need addresses, but can't justify it? I keep hearing the argument and it makes no sense.
>
> I manage the IP networks of a bunch of small ISPs. I have never had an issue with justifying their needs. There certainly are instances where it would be nice to have some more space to have more flexibility and for future needs. But, we can't justify the actual need, so we shouldn't get the space. Others have a need and can justify it, therefore they should be able to get it.
>
> Making it trivial to get space would lead to those who do *not* need it getting it because they can, which will reduce the amount of space available to those who actually need it.
>
> I oppose vehemently.
>
> thanks,
> -Randy
>
>
> ----- On Feb 18, 2016, at 11:07 PM, Steven Ryerse SRyerse at eclipse-networks.com wrote:
>
>> Milton is right! We are one of those small ISPs and the deck is stacked against
>> us on purpose by larger organizations. It is time to move on and stop arranging
>> the deck chairs on the IPv4 Titanic like other regions have. It’s 2016 not
>> 2001. I support this policy!
>>
>>
>>
>>
>>
>>
>> Steven Ryerse
>>
>> President
>>
>> 100 Ashford Center North, Suite 110, Atlanta, GA 30338
>>
>> www.eclipse-networks.com
>>
>> 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 Mueller, Milton L
>> Sent: Thursday, February 18, 2016 10:47 PM
>> To: Jason Schiller <jschiller at google.com>
>> Cc: ARIN PPML <arin-ppml at arin.net>
>> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based
>> evaluation for Section 8.2 and 8.3 transfers of IPv4 netblocks
>>
>>
>>
>>
>>
>>
>>
>> Really. Am I going to have to be the first to point out the irony of Google
>> employees complaining that companies with "deep pockets" and "the most
>> profitable services" will dominate the address market if we make minor
>> relaxations of need assessments?
>>
>>
>>
>> What's wrong with this picture? Think, folks.
>>
>>
>>
>> Isn't it obvious that companies like Google are in a very good position to get
>> the addresses they want - via less than transparent market mechanisms such as
>> options contracts and acquisitions? And isn't it possible that they might be
>> trying to prevent smaller companies from participating in the market by
>> throwing up artificial barriers?
>>
>>
>>
>> All this talk of "fairness" overlooks the fact that it's more fair to have
>> simple, transparent bidding and less bureaucracy. Smaller bidders can easily
>> afford smaller chunks of numbers, and they benefit from the reduced
>> administrative burden and delays associated with pointless and restrictive
>> needs assessments. When I hear smaller ISPs who need addresses making Jason's
>> arguments, I might take them seriously. Until then, no.
>>
>>
>>
>> --MM
>>
>>
>>
>> From: arin-ppml-bounces at arin.net < arin-ppml-bounces at arin.net > on behalf of
>> Jason Schiller < jschiller at google.com >
>>
>>
>> Sent: Thursday, February 18, 2016 3:11 PM
>> To: Vaughn Thurman - Swift Systems
>> Cc: ARIN PPML
>> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based
>> evaluation for Section 8.2 and 8.3 transfers of IPv4 netblocks
>>
>>
>>
>>
>>
>> +1 to what MCTim, Owen, and Vaughn said.
>>
>>
>>
>>
>>
>> In general I oppose transfers with no need.
>>
>>
>>
>>
>>
>> If there are "networks in need of additional IPv4 addresses", surely they should
>> be able to show this, in accord with long standing practice.
>>
>>
>>
>>
>>
>> I'd rather us not move to a situation which enables/encourages speculation and
>> profit taking (or rent-seeking if you will) in re: IP resource distribution.
>>
>>
>>
>>
>>
>> I'd also rather not encourage one competitor in a business segment to be able to
>> better stockpile addresses and for that to become a competitive advantage
>>
>>
>> against other providers in the space. Additionally if this is done in a wide
>> enough scale it can sufficiently lengthen wide spread IPv6 adoption.
>>
>>
>>
>>
>>
>> This policy would also allow for companies with the deepest pockets and the most
>> profitable services to concentrate IPv4 space. I'm not sure that is more "fair"
>>
>>
>> than the pre-existing framework for "fair".
>>
>>
>>
>>
>>
>> __Jason
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>> On Thu, Feb 18, 2016 at 2:32 PM, Vaughn Thurman - Swift Systems <
>> vaughn at swiftsystems.com > wrote:
>>
>>
>>
>>
>> +1
>>
>> Sent from my mobile device, please forgive brevity and typos.
>>
>>
>>
>> On Feb 18, 2016, at 2:16 PM, Owen DeLong < owen at delong.com > wrote:
>>
>>
>>
>>
>>
>> +1 — McTim said it very well.
>>
>>
>>
>>
>>
>> Owen
>>
>>
>>
>>
>>
>>
>>
>>
>> On Feb 18, 2016, at 10:34 , McTim < dogwallah at gmail.com > wrote:
>>
>>
>>
>>
>>
>> I am opposed.
>>
>>
>>
>>
>>
>> If there are " networks in need of additional IPv4 addresses", surely they
>> should be able to show this, in accord with long standing practice.
>>
>>
>>
>>
>>
>> I'd rather us not move to a situation which enables/encourages speculation and
>> profit taking (or rent-seeking if you will) in re: IP resource distribution.
>>
>>
>>
>>
>>
>> Regards,
>>
>>
>>
>>
>>
>> McTim
>>
>>
>>
>>
>>
>>
>>
>>
>> On Tue, Feb 16, 2016 at 7:12 PM, Leif Sawyer < lsawyer at gci.com > wrote:
>>
>>
>>
>> Good afternoon -
>>
>> Based on feedback from Montreal as well as internal discussions, I've reworked
>> this policy.
>> AC members and ARIN staff are looking for additional feedback, as well as your
>> position in terms
>> of supporting or opposing this draft policy.
>>
>> We'll be discussing this policy, as well as any feedback provided on this week's
>> AC teleconference,
>> so I'm very appreciative of your input.
>>
>> Thanks,
>>
>> Leif Sawyer
>> Shepherd - ARIN-2015-9
>>
>> NRPM section 8: https://www.arin.net/policy/nrpm.html#eight
>>
>> Most current draft policy text follows:
>> --
>>
>> Draft Policy ARIN-2015-9
>> Eliminating needs-based evaluation for Section 8.2 and 8.3 transfers of IPv4
>> netblocks
>> Original Date: 23 September 2015
>> Updated: 16 February, 2016
>>
>> Problem statement:
>> The current needs-based evaluation language in NRPM sections 8.2 and 8.3,
>> regarding transfer of IPv4
>> netblocks from one organization to another, may cause a recipient organization
>> to bypass the ARIN
>> registry entirely in order to secure the needed IPv4 netblocks in a more timely
>> fashion directly from the
>> current holder. The result is that the data visible in ARIN registry may become
>> more inaccurate over
>> time.
>>
>> Policy statement:
>> This proposal eliminates all needs-based evaluation language for sections 8.2
>> and 8.3, allowing
>> 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 fragment from the 3rd paragraph which reads
>> ", based on justified need,"
>> so the resulting text reads
>> "Number resources are issued to organizations, not to individuals representing
>> those organizations."
>> 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."
>>
>> - Strike the final paragraph which begins "In the event that number resources of
>> the combined organizations are no longer justified under 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."
>>
>> Comments:
>> a. Timetable for implementation: Immediate
>> b. Anything else
>> As the "free pool" for 4 of the 5 world's RIR's (APNIC, RIPE, LACNIC, and ARIN)
>> have 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 fulfill that
>> need. Accordingly, the RIR's
>> primary responsibility vis-à-vis IPv4 netblock governance has shifted from
>> "allocation" to ensuring an
>> accurate registry database.
>>
>> 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
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>>
>>
>>
>>
>>
>>
>>
>>
>> --
>>
>>
>> Cheers,
>>
>> McTim
>> "A name indicates what we seek. An address indicates where it is. A route
>> indicates how we get there." Jon Postel
>>
>>
>> _______________________________________________
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>>
>>
>>
>>
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>>
>>
>> --
>>
>>
>> _______________________________________________________
>>
>>
>> Jason Schiller|NetOps| jschiller at google.com |571-266-0006
>>
>>
>>
>>
>> _______________________________________________
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