[arin-ppml] Thoughts on 2015-7

Tue Mar 8 14:01:24 EST 2016

I haven't seen any progress on this and though I would bump the thread...

The problem as I understand it is that transfers are hard, and you cannot
predict what you will get approved for.

In my simplified approach, an organization should easily know how much
address space they are holding, and if it will pass the simple test of:
1. is each aggregate more than 50% in use
2. is all my IP space more that 80% in use.

And they know they can complete one or more transfers up to doubling over
the next two years.

comments in line

__Jason

On Thu, Feb 11, 2016 at 1:09 AM, Scott Leibrand <scottleibrand at gmail.com>
wrote:

> 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".)
>

Yes.  from a simplified perspective...
if you have space and it is efficiently utilized (over 80% on average, and
not block less than 50%)
then you are pre-approved to make one or more transfers within a two year
window,
up to doubling your current holdings

You can re-verify efficient use at any time, and get a new two year window
to to make one or more transfers
up to doubling your current holdings.

The un-simple process is still an avenue.

There probably needs to be some accommodation for a simple process for
non-address holders.

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

-- 
_______________________________________________________
Jason Schiller|NetOps|jschiller at google.com|571-266-0006
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