<html><head></head><body>Based on "the perfect is the enemy of the good", I figure it's worth going ahead with this.<br>
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If it turns out to be a disaster, the policy can be revised in... what's the minimum, 6 months? And there are ways to mitigate its impact during that time if necessary.<br>
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Much as mentioned in the policy statement, we're working with estimates and guesses, not verifiable facts. This will at least generate some verifiable facts.<br>
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I'm equally certain it will need revision/tweaking at some point fairly soon.<br>
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-Adam<br><br><div class="gmail_quote">On February 24, 2015 2:04:42 PM CST, Owen DeLong <owen@delong.com> wrote:<blockquote class="gmail_quote" style="margin: 0pt 0pt 0pt 0.8ex; border-left: 1px solid rgb(204, 204, 204); padding-left: 1ex;">
<pre class="k9mail">I do not oppose the policy as written. I’m not sure I support it, but if we want to conduct such an experiment, then I believe this policy provides adequate protections and limitations on the scope of the experiment.<br /><br />Owen<br /><br /><blockquote class="gmail_quote" style="margin: 0pt 0pt 1ex 0.8ex; border-left: 1px solid #729fcf; padding-left: 1ex;"> On Feb 24, 2015, at 09:17 , ARIN <info@arin.net> wrote:<br /> <br /> ARIN-2014-14 has been revised. This draft policy is open for discussion<br /> on this mailing list.<br /> <br /> ARIN-2014-14 is below and can be found at:<br /> <a href="https://www.arin.net/policy/proposals/2014_14.html">https://www.arin.net/policy/proposals/2014_14.html</a><br /> <br /> Regards,<br /> <br /> Communications and Member Services<br /> American Registry for Internet Numbers (ARIN)<br /> <br /> <br /> ## * ##<br /> <br /> <br /> Draft Policy ARIN-2014-14<br /> Needs Attestation for some IPv4 Transfers<br /> <b
r />
Date: 24 Feb 2015<br /> <br /> Problem Statement:<br /> <br /> The process of 'needs testing' or 'needs basis' allocation has evolved<br /> over the history of the Internet registry system. The earliest number<br /> resource policy required that an operator intend to use the number<br /> resources on an operational Internet Protocol network before the<br /> resource would be registered to an organization. Organizations were<br /> assigned either a Class A, B, or C block roughly depending on the<br /> organization's size. With the implementation of CIDR, additional 'needs<br /> testing' was done to right size allocations to fit organizations. These<br /> testing requirements continued to evolve under various organizations<br /> prior to the RIRs inception and then later formally under the RIR's<br /> policy development process.<br /> <br /> In the 2000s, ARIN began a systematic "trust but verify" process for<br /> IPv4 requests. This was necessary due to both IPv4 address
registration<br /> hijackings in ARIN Whois and the accelerated amount of systematic fraud<br /> being perpetrated on ARIN.<br /> <br /> As IPv4 exhaustion occurred, some RIRs have reconsidered the necessity<br /> of some of the needs testing requirements and implemented policies<br /> which reduced the requirements on organizations to show need or<br /> utilization for some transfer transactions with the RIR.<br /> <br /> The cost of performing a needs assessment and auditing of this<br /> information vs. the public benefit of restricting allocations to<br /> specifically qualified organizations has been noted by some<br /> organizations to be out of alignment. The ability to predict future use<br /> toward a 24-month utilization rate can also be challenging for some<br /> organizations and relies on projections and estimates rather than<br /> verifiable facts. Thus, the current needs testing requirements may be<br /> more than is necessary and desirable for small transfers.
This
policy<br /> seeks to reduce the complexity of transfers by removing the utilization<br /> needs testing requirement and replacing it with a needs attestation by<br /> a corporate officer.<br /> <br /> Additionally, other requirements are placed around the 'needs<br /> attestation only' requirement to reduce the Number Resource Community's<br /> concern that this type of policy could be abused for speculation or<br /> hording. Furthermore, the policy includes a sunset clause to limit the<br /> total number of transfers under this policy proposal. This sunset is<br /> intended to force the community to reexamine the success or failure of<br /> the practices contained in this policy proposal.<br /> <br /> Policy statement:<br /> <br /> Section 8.3<br /> <br /> Replace the 'Conditions on recipient of the transfer' with<br /> the following conditions.<br /> <br /> Conditions on recipient of the transfer:<br /> <br /> The organization must sign an RSA.<br /> <br /> The resources
transferred will be subject to current ARIN policies.<br /> <br /> In addition, the recipient must meet one of the following requirements<br /> sets:<br /> <br /> 1. The organization must demonstrate the need for up to a 24-month<br /> supply of IP address resources under current ARIN policies.<br /> <br /> OR<br /> <br /> 1.The organization, its parent(s), or subsidiary organizations, must<br /> not have received IPv4 address resources, via transfer, within the past 12 months.<br /> <br /> 2.An officer of the organization must attest that the IPv4 address<br /> block is needed for and will be used on an operational network.<br /> <br /> 3.The maximum transfer size is /20.<br /> <br /> 4.Fewer than 5,000 needs attestation transfers have occurred.<br /> <br /> <br /> Section 8.4<br /> <br /> Replace the 'Conditions on recipient of the transfer' with<br /> the following conditions.<br /> <br /> Conditions on recipient of the transfer:<br /> <br /> The conditions on a recipient
outside of the ARIN region will be<br /> defined by the policies of the receiving RIR.<br /> <br /> Recipients within the ARIN region will be subject to current ARIN<br /> policies and sign an RSA for the resources being received.<br /> <br /> The minimum transfer size is a /24.<br /> <br /> In addition, the recipient must meet one of the following requirements<br /> sets:<br /> <br /> 1. The organization must demonstrate the need for up to a 24-month<br /> supply of IP address resources under current ARIN policies.<br /> <br /> OR<br /> <br /> 1.The organization, its parent(s), or subsidiary organizations, must<br /> not have received IPv4 address resources, via transfer, within the past 12 months.<br /> <br /> 2.An officer of the organization must attest that the IPv4 address<br /> block is needed for and will be used on an operational network.<br /> <br /> 3.The maximum transfer size is /20.<br /> <br /> 4.Fewer than 5,000 needs attestation transfers have occurred.<br
/> <br
/> Comments:<br /> <br /> Timetable for implementation: Immediate<br /><hr /><br /> PPML<br /> You are receiving this message because you are subscribed to<br /> the ARIN Public Policy Mailing List (ARIN-PPML@arin.net).<br /> Unsubscribe or manage your mailing list subscription at:<br /> <a href="http://lists.arin.net/mailman/listinfo/arin-ppml">http://lists.arin.net/mailman/listinfo/arin-ppml</a><br /> Please contact info@arin.net if you experience any issues.<br /></blockquote><br /><hr /><br />PPML<br />You are receiving this message because you are subscribed to<br />the ARIN Public Policy Mailing List (ARIN-PPML@arin.net).<br />Unsubscribe or manage your mailing list subscription at:<br /><a href="http://lists.arin.net/mailman/listinfo/arin-ppml">http://lists.arin.net/mailman/listinfo/arin-ppml</a><br />Please contact info@arin.net if you experience any issues.</pre></blockquote></div><br>
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