[arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2 and 8.3 transfers of IPv4 netblocks
Owen DeLong
owen at delong.com
Tue Mar 1 17:11:12 EST 2016
In most of the rest of the world, attempting to purchase a supply of addresses to prevent your competitors from gaining access to them would be considered an anti-trust issue and would likely face prosecution.
In the US (I’m not sure about the rest of the ARIN region), it would likely be viewed as shrewd business practice.
That’s the difference.
Owen
> On Feb 18, 2016, at 21:28 , Steven Ryerse <SRyerse at eclipse-networks.com> wrote:
>
> Loosening up the policies is working fine in other regions. What justification do you really have to not do it here?? In case you don't know, brokers are doing a brisk business in IPv4 blocks outside of ARIN, and every time one sells the database gets less accurate. All of the arguments about cornering the market or whatever are not happening in other regions and there is no reason why our region is somehow different.
>
> With runout we now just have policies to prevent IPv4 runout that has already happened. Isn't it time for this Region to join the rest of the world we used to lead?
>
>
> 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℠
>
> -----Original Message-----
> From: Randy Carpenter [mailto:rcarpen at network1.net]
> Sent: Thursday, February 18, 2016 11:50 PM
> To: Steven Ryerse <SRyerse at eclipse-networks.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
>
>
> 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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