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

Wed Mar 2 15:13:50 EST 2016

Obviously Milton doesn’t share that opinion per his comments below and neither do I.

Steven Ryerse
President
100 Ashford Center North, Suite 110, Atlanta, GA  30338
770.656.1460 - Cell
770.399.9099- Office

[Description: Description: Eclipse Networks Logo_small.png]℠ Eclipse Networks, Inc.
        Conquering Complex Networks℠

From: Owen DeLong [mailto:owen at delong.com]
Sent: Tuesday, March 1, 2016 5:00 PM
To: Steven Ryerse <SRyerse at eclipse-networks.com>
Cc: Mueller, Milton L <milton at gatech.edu>; Jason Schiller <jschiller at google.com>; 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

This policy is an example of rearranging the IPv4 deck chairs.

So your statement is not consistent with your support of the policy.

Owen

On Feb 18, 2016, at 20:07 , Steven Ryerse <SRyerse at eclipse-networks.com<mailto: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<http://www.eclipse-networks.com/>
770.656.1460 - Cell
770.399.9099- Office

<image001.jpg>℠ Eclipse Networks, Inc.
        Conquering Complex Networks℠

From: arin-ppml-bounces at arin.net<mailto: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<mailto:jschiller at google.com>>
Cc: ARIN PPML <arin-ppml at arin.net<mailto: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<mailto:arin-ppml-bounces at arin.net> <arin-ppml-bounces at arin.net<mailto:arin-ppml-bounces at arin.net>> on behalf of Jason Schiller <jschiller at google.com<mailto: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<mailto: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<mailto:owen at delong.com>> wrote:
+1 — McTim said it very well.

Owen

On Feb 18, 2016, at 10:34 , McTim <dogwallah at gmail.com<mailto: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<mailto: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.

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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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--
_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com<mailto:jschiller at google.com>|571-266-0006

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