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<TITLE>Re: [arin-ppml] Draft Policy 2009-1: Transfer Policy ? Revised andforwarded to the Board</TITLE>
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<FONT FACE="Calibri, Verdana, Helvetica, Arial"><SPAN STYLE='font-size:11pt'>A few more bits of information. One reason that the AC moved this proposal forward was that 2008-6 was already approved and set to be implemented on June 1 so the issue was already there. I believe it was accepted that the AC would make further review and come up with a proposal that would deal with this impact. Also a point to note is that this policy must be recertified at the next Public Policy Meeting since it went through the Emergency Policy process. <BR>
<BR>
<BR>
On 5/4/09 3:00 PM, "Leo Bicknell" <<a href="bicknell@ufp.org">bicknell@ufp.org</a>> wrote:<BR>
<BR>
</SPAN></FONT><BLOCKQUOTE><FONT FACE="Calibri, Verdana, Helvetica, Arial"><SPAN STYLE='font-size:11pt'>In a message written on Mon, May 04, 2009 at 12:21:01PM -0400, Member Services wrote:<BR>
> The ARIN Advisory Council (AC) met on 29 April 2009 and decided to send<BR>
> a revised version of 2009-1 to the Board for their consideration:<BR>
<BR>
This policy isn't in "last-call" per se, but given the PDP process<BR>
I feel this is the only appropriate time for me to make these<BR>
remarks.<BR>
<BR>
I am a member of the Advisory Council, speaking only for myself.<BR>
During the various reviews and discussions the Advisory Council<BR>
performs after the meeting a particular aspect of this policy was<BR>
brought to (most of?) the AC's attention. I would like to bring<BR>
it to the community's attention as well. I did not write notes on<BR>
this at the time, so I am doing this from memory. If I get it<BR>
wrong, I hope someone corrects me.<BR>
<BR>
Billy has a /16, and he's using it for dial up services which is<BR>
not paying the bills anymore.<BR>
<BR>
Suzie wants a /16 for her hot new social networking experiment.<BR>
<BR>
Billy and Suzie find each other and agree to transfer Billy's /16<BR>
to Suzie under the result of 2008-6 + 2009-1.<BR>
<BR>
Billy goes to ARIN and says "Here's a /16, please give it to Suzie."<BR>
<BR>
Suzie goes to ARIN and says, "I'm here for Billy's /16". In the<BR>
process, ARIN checks Suzie's justification, and realizes Suzie can<BR>
only justify a /18.<BR>
<BR>
My understanding of the current interpretation of 2008-6 + 2009-1<BR>
is that ARIN would give Suzie a /18, and keep a /18 and /17 in the<BR>
free pool.<BR>
<BR>
Billy has given up his /16, and Suzie only got a /18 of it.<BR>
<BR>
This ends up being an artifact of the legal requirement that transfers<BR>
must occur through ARIN. My own personal view on how this would<BR>
work prior to finding this out was if Suzie couldn't receive Billy's<BR>
/16 for any reason, Billy would retain the /16. Thus my surprise,<BR>
and I'm wondering if this isn't a surprise for others in the<BR>
community.<BR>
<BR>
The recommended "fix", is that Suzie will be able to "pre-qualify",<BR>
that is go to ARIN with all of her paperwork and get approved for<BR>
a /18 before Billy and Suzie do a deal, so Suzie knows this will<BR>
not happen.<BR>
<BR>
I think this ends up being bad for three distinct reasons:<BR>
<BR>
Technically:<BR>
<BR>
This causes deaggregation. In the example given a /16 was turned into<BR>
a /17 and two /18's. However, because a /17 and /18 are both now in<BR>
the free pool they may be further subdivided into /20's (or smaller,<BR>
in some cases).<BR>
<BR>
Business:<BR>
<BR>
It is likely Billy and Suzie exchanged something of value during this<BR>
transaction to make it happen. Suzie has now "overpaid" for her /18,<BR>
and is likely to demand a refund from Billy, or challenge ARIN's<BR>
stance she can only justify a /18, or both. Billy, of course, isn't<BR>
going to want to give a refund as he is out the entire /16, but he may<BR>
also be unhappy at ARIN for only approving her for a /18. It sounds<BR>
like a good way to get all the parties in a transaction unhappy.<BR>
<BR>
But also, it opens up an interesting fraud. Alice could go to Billy<BR>
and offer to buy the /16 for a hundred million dollars. Billy gets<BR>
so excited over the idea of retiring from the dial up business that<BR>
he takes the deal. Alice gives him a fake check, and Billy fills out<BR>
the ARIN paperwork.<BR>
<BR>
But you see, it is a fake check, and Alice had no intention of ever<BR>
justifying the addresses to ARIN. Billy figures out two weeks later<BR>
the check is fake from the bank, but he's already released the addresses<BR>
to ARIN and can't get them back. What's Alice's motivation? Well,<BR>
her alter-ego Janice is sitting near the front of the line of folks<BR>
waiting for space to end up in the free pool. Good for her, a /16<BR>
just showed up.<BR>
<BR>
But really this is all added risk, and what business wants to<BR>
participate in a system with extra risk?<BR>
<BR>
Politically:<BR>
<BR>
This interpretation of the policy is likely to affect the most<BR>
vulnerable the most. The savvy folks who are doing all sorts of<BR>
transfers are reading this post on PPML now, and will understand<BR>
the pitfalls of the system and work around these issues by doing<BR>
things like prequalifing.<BR>
<BR>
This issue is much more likely to trip up the "one time" casual<BR>
transferor or transferee who last delt with ARIN in 1999 and<BR>
doesn't do this as a day job anymore. They are the ones who will<BR>
accidently encounter this situation.<BR>
<BR>
Personally, I think ARIN should not let this happen. The simplest<BR>
fix I have come up with is to require Suzie to fill out the recipient<BR>
paperwork first. Billy should not be able to designate a recipient<BR>
without having some assurance that end of the transaction is already<BR>
approved from ARIN. This could be as simple as Suzie giving Billy<BR>
the ticket number under which Suzie was approved, and Billy having<BR>
to provide that ticket number to release resources. In this way<BR>
an exact match could be insured, eliminating all of the problems<BR>
listed above.<BR>
<BR>
The AC obviously moved this proposal on; so this was not seen as a<BR>
show-stopper issue by the majority of the AC. At a minimum, I<BR>
wanted to get the issue out to the community so if nothing is changed<BR>
the community is aware of the issue and will be able to avoid it.<BR>
I would hope this would end up documented on the ARIN web site in<BR>
fairly clear language as well; but given the accelerated timetable<BR>
for this proposal I didn't want to wait for that to occur first.<BR>
<BR>
--<BR>
Leo Bicknell - <a href="bicknell@ufp.org">bicknell@ufp.org</a> - CCIE 3440<BR>
PGP keys at <a href="http://www.ufp.org/~bicknell/">http://www.ufp.org/~bicknell/</a><BR>
<BR>
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