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I am new to ARIN having received our ASN, IPv4 & IPv6 only a
week or so ago. I appreciated the scrutiny for ASN & IPv4 but
not for IPv6 as I feel it is too early to scrutinize IPv6.<br>
<br>
I would be opposed to this proposal as currently written.<br>
<br>
Best regards,<br>
Dave<br>
<br>
On 2/16/12 5:54 PM, ARIN wrote:
<blockquote cite="mid:4F3D891C.6060507@arin.net" type="cite">ARIN-prop-165
Eliminate Needs-Based Justification on 8.3 Specified Transfers
<br>
<br>
ARIN received the following policy proposal and is posting it to
the
<br>
Public Policy Mailing List (PPML) in accordance with the Policy
<br>
Development Process.
<br>
<br>
The ARIN Advisory Council (AC) will review the proposal at their
next
<br>
regularly scheduled meeting (if the period before the next
regularly
<br>
scheduled meeting is less than 10 days, then the period may be
extended
<br>
to the subsequent regularly scheduled meeting). The AC will decide
how
<br>
to utilize the proposal and announce the decision to the PPML.
<br>
<br>
The AC invites everyone to comment on the proposal on the PPML,
<br>
particularly their support or non-support and the reasoning
<br>
behind their opinion. Such participation contributes to a thorough
<br>
vetting and provides important guidance to the AC in their
deliberations.
<br>
<br>
Draft Policies and Proposals under discussion can be found at:
<br>
<a class="moz-txt-link-freetext" href="https://www.arin.net/policy/proposals/index.html">https://www.arin.net/policy/proposals/index.html</a>
<br>
<br>
The ARIN Policy Development Process can be found at:
<br>
<a class="moz-txt-link-freetext" href="https://www.arin.net/policy/pdp.html">https://www.arin.net/policy/pdp.html</a>
<br>
<br>
Mailing list subscription information can be found
<br>
at: <a class="moz-txt-link-freetext" href="https://www.arin.net/mailing_lists/">https://www.arin.net/mailing_lists/</a>
<br>
<br>
Regards,
<br>
<br>
Communications and Member Services
<br>
American Registry for Internet Numbers (ARIN)
<br>
<br>
<br>
## * ##
<br>
<br>
<br>
ARIN-prop-165 Eliminate Needs-Based Justification on 8.3 Specified
Transfers
<br>
<br>
Proposal Originator: Jeff Mehlenbacher
<br>
<br>
Proposal Version: 1
<br>
<br>
Date: 16 February 16 2012
<br>
<br>
Proposal type: Modify
<br>
<br>
Policy term: Permanent
<br>
<br>
Policy statement:
<br>
<br>
Current Policy Statement:
<br>
8.3. Transfers to Specified Recipients
<br>
In addition to transfers under section 8.2, IPv4 number resources
within the ARIN region may be released to ARIN by the authorized
resource holder, in whole or in part, for transfer to another
specified organizational recipient. Such transferred number
resources may only be received under RSA by organizations that are
within the ARIN region and can demonstrate the need for such
resources in the amount which they can justify under current ARIN
policies showing how the addresses will be utilized within 24
months.
<br>
<br>
Proposed Policy Statement
<br>
8.3. Transfers to Specified Recipients
<br>
In addition to transfers under section 8.2, IPv4 number resources
within the ARIN region may be released to ARIN by the authorized
resource holder, in whole or in part, for transfer to another
specified organizational recipient. Such transferred number
resources may only be received under RSA by organizations that are
within the ARIN region and requires that an Officer Attestation be
provided confirming the transferred number resources will be
applied to enable current or planned business models.
<br>
<br>
Rationale:
<br>
<br>
Current policy acts as a major impediment to freeing up unused
IPv4 address and constrains trade in a free market economy. If a
Company receives Board approval to spend between $11.25 and $12.00
per IP, this should suggest the business case is justified for the
acquiring organization. The role of ARIN should be to encourage
the freeing of IPv4 addresses that will otherwise remain dormant
in the hands of companies who have no incentive to transfer them.
<br>
<br>
The objective of the Specified Transfer market should be to a)
encourage source Companies to transfer their unused blocks thereby
increasing supply of IPv4 address and b) encourage recipient
Companies to acquire sufficient IPv4 addresses to support business
plans rather than depleting the free pool.
<br>
<br>
Current policy of demonstrating need for specified transfers, be
it based on 12 months or now 24 months, does not provide
sufficient incentive for organizations to acquire unused IPv4
addresses in a financial transaction. Companies recognize they
must still endure the rigors of the justification process
regardless of free allocation or specified transfer…making it very
difficult to justify a financial transaction when specified
transfers will still be assessed by exactly the same techniques
and algorithms applied for approval of free resources.
<br>
<br>
Eliminating needs-based justification has many benefits so long as
all transactions continue to flow through ARIN for ratification:
<br>
<br>
a) Buyer executive attestation will ensure the IP’s are being used
for business purposes. Failure to be truthful could result in
punitive measures against corporate officers, and is a risk an
officer would not be likely to take
<br>
<br>
b) Source Companies have an active market and financial incentive
to transfer unused IPv4 blocks to Companies with need
<br>
<br>
c) IPv4 number resources will not be scarce if adequate incentive
exists for Buyers to acquire unused blocks through specified
transfer
<br>
<br>
d) Many Buyers express hesitation that confidential business plans
must be disclosed through the justification process—no such
disclosure would be required (under NDA or otherwise)
<br>
<br>
e) Legacy blocks will come under RSA in ever increasing numbers
<br>
<br>
f) Improves the accuracy, utility and value of the ARIN address
registry
<br>
<br>
g) Effectively kills the black or gray IPv4 transfer market
guaranteeing ARIN’s custodianship over number resources
<br>
<br>
h) Encourages source Companies to free up resources and recipient
Companies to actively acquire available IPv4 blocks thereby
eliminating speculation because supply is abundant. Only when a
resource is truly scarce does capricious consumption (stockpiling)
occur
<br>
<br>
i) The Free resource pool is best applied to small or new ISPs
while medium to large corporations with greater financial
wherewithal are encouraged to participate in specified transfers
to acquire larger IPv4 blocks
<br>
<br>
Timetable for implementation: Immediate
<br>
_______________________________________________
<br>
PPML
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<br>
</blockquote>
<br>
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