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<DIV dir=ltr align=left><SPAN class=473004219-04052009><FONT face=Arial
color=#0000ff size=2>AC had no need to make further policy to deal with the
impact since 2008-6 had an</FONT></SPAN></DIV>
<DIV dir=ltr align=left><SPAN class=473004219-04052009><FONT face=Arial
color=#0000ff size=2>automatic sunset. The entire point of the sunset in
2008-6 was to see what the</FONT></SPAN></DIV>
<DIV dir=ltr align=left><SPAN class=473004219-04052009><FONT face=Arial
color=#0000ff size=2>unintended consequences would be and the only way to find
them out was to</FONT></SPAN></DIV>
<DIV dir=ltr align=left><SPAN class=473004219-04052009><FONT face=Arial
color=#0000ff size=2>implement the policy and see what happened. I think
most people expected that</FONT></SPAN></DIV>
<DIV dir=ltr align=left><SPAN class=473004219-04052009><FONT face=Arial
color=#0000ff size=2>after a year or so of 2008-6 that, armed with the knowledge
learned from the</FONT></SPAN></DIV>
<DIV dir=ltr align=left><SPAN class=473004219-04052009><FONT face=Arial
color=#0000ff size=2>experiment, we would write a much more comprehensive policy
that would</FONT></SPAN></DIV>
<DIV dir=ltr align=left><SPAN class=473004219-04052009><FONT face=Arial
color=#0000ff size=2>supersede 2008-6. The sunset was a deadline that
guaranteed this would</FONT></SPAN></DIV>
<DIV dir=ltr align=left><SPAN class=473004219-04052009><FONT face=Arial
color=#0000ff size=2>happen.</FONT></SPAN></DIV>
<DIV dir=ltr align=left><SPAN class=473004219-04052009><FONT face=Arial
color=#0000ff size=2></FONT></SPAN> </DIV>
<DIV dir=ltr align=left><SPAN class=473004219-04052009><FONT face=Arial
color=#0000ff size=2>Ted</FONT></SPAN></DIV><BR>
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style="PADDING-LEFT: 5px; MARGIN-LEFT: 5px; BORDER-LEFT: #0000ff 2px solid; MARGIN-RIGHT: 0px">
<DIV class=OutlookMessageHeader lang=en-us dir=ltr align=left>
<HR tabIndex=-1>
<FONT face=Tahoma size=2><B>From:</B> arin-ppml-bounces@arin.net
[mailto:arin-ppml-bounces@arin.net] <B>On Behalf Of </B>John
Sweeting<BR><B>Sent:</B> Monday, May 04, 2009 12:28 PM<BR><B>To:</B> Leo
Bicknell; arin ppml<BR><B>Subject:</B> Re: [arin-ppml] Draft Policy 2009-1:
Transfer Policy ? Revisedandforwarded to the Board<BR></FONT><BR></DIV>
<DIV></DIV>
<P><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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