[arin-ppml] Draft Policy ARIN-2016-5: Post-IPv4-Free-Pool-Depletion Transfer Policy

[Brett Frankenberger]

On Wed, Jun 22, 2016 at 11:15:58AM -0500, Scott Leibrand wrote:
> On Wed, Jun 22, 2016 at 11:00 AM, Mike Burns <mike at iptrading.com> wrote:
> 
> > Hi Andrew,
> >
> > I have a couple of questions about the policy proposal.
> >
> >  On Section 8.5.2 Operational Use.
> >
> > First, why is this section even in there, does it serve some particular
> > purpose?
> >
> 
> It prevents financial speculators, who have no operational use for the
> addresses, from acquiring them for speculative purposes.

If that's the intent, I think it would better to make "operational
network" part of the actual requirements, rather than have a general
"ARIN transfers for the purposes of use on an operational network"
platitude, and then interpret that as a condition of transfer rather
than a general statement of a goal we consider worthy.

For example, for an entity wanting to get a /24 under 8.5.4, ARIN would
first validate that the organization had no existing direct assignments
or allocations, but then what?  How would they implement 8.5.2?  Ask
"do you plan to use this on an operational network"?  Request officer
attestation as to plans to use the /24 on an operational network?  Do
nothing and approve the transfer on the theory that the requester is on
his honor to abide by 8.5.2 even without being asked about it?  Approve
the transfer unless ARIN had some specific reason to believe that the
proposed transfer was for the purposes of financial speculation? 
Something else?

As for 8.5.5, would 8.5.2 be of any effect given that documentation is
already required.  (Is 8.5.2 the thing that would allow ARIN to reject
documention along the lines of "we will, within 24 months, make use of
the transferred space for the purposes of financial speculation"?  That
seems like overkill; before run-out, ARIN didn't need something like
8.5.2 to reject requests for free-pool assignments that came in with a
justification of "financial speculation" -- I don't know that they
ever received such, but I'm sure they would have rejected it had they
received such.)

If we want ARIN to impose an operational network requirement, we should
be clear what that means. 

All that said, I support the goals of this proposal.  I agree that
8.5.2 is non- or poorly- operative (but keeping it would not cause me
to drop my support for the proposal), and have no opinion on Owen's
proposal to do it in section 4 rather than 8, but I support the
elimination of justification for the first /24, and the proposed 8.5.5
requirements for subsequent or larger tansfers.  I note that it's
possible that there will be small free-pool assignments made going
forward, so doing this in section 4, as opposed to section 8, is not a
purely editorial change.

(Proposed sections referenced above are quoted below for reference.)

    8.5.2. Operational Use

    ARIN allocates or assigns blocks of IP addresses to organizations via
    transfer solely for the purpose of use on an operational network.
      
    8.5.4. Initial block
        
    Organizations without direct assignments or allocations from ARIN
    qualify for transfer of an initial block of ARIN's minimum transfer size.

    8.5.5. Block size

    Organizations may qualify for the transfer of a larger initial block,
    or an additional block, by providing documentation to ARIN which details
    the use of at least 50% of the requested block size within 24 months. An
    officer of the organization shall attest to the documentation provided to
    ARIN.

     --  Brett