<div dir="ltr">I am opposed. <div><br></div><div>If there are "<span style="font-size:12.8px">networks in need of additional IPv4 addresses", surely they should be able to show this, in accord with long standing practice. </span></div><div><span style="font-size:12.8px"><br></span></div><div><span style="font-size:12.8px">I'd rather us not move to a situation which enables/encourages speculation and profit taking (or rent-seeking if you will) in re: IP resource distribution.</span></div><div><span style="font-size:12.8px"><br></span></div><div><span style="font-size:12.8px">Regards,</span></div><div><span style="font-size:12.8px"><br></span></div><div><span style="font-size:12.8px">McTim</span></div><div><span style="font-size:12.8px"><br></span></div></div><div class="gmail_extra"><br><div class="gmail_quote">On Tue, Feb 16, 2016 at 7:12 PM, Leif Sawyer <span dir="ltr"><<a href="mailto:lsawyer@gci.com" target="_blank">lsawyer@gci.com</a>></span> wrote:<br><blockquote class="gmail_quote" style="margin:0 0 0 .8ex;border-left:1px #ccc solid;padding-left:1ex">Good afternoon -<br>
<br>
Based on feedback from Montreal as well as internal discussions, I've reworked this policy.<br>
AC members and ARIN staff are looking for additional feedback, as well as your position in terms<br>
of supporting or opposing this draft policy.<br>
<br>
We'll be discussing this policy, as well as any feedback provided on this week's AC teleconference,<br>
so I'm very appreciative of your input.<br>
<br>
Thanks,<br>
<br>
Leif Sawyer<br>
Shepherd - ARIN-2015-9<br>
<br>
NRPM section 8: <a href="https://www.arin.net/policy/nrpm.html#eight" rel="noreferrer" target="_blank">https://www.arin.net/policy/nrpm.html#eight</a><br>
<br>
Most current draft policy text follows:<br>
--<br>
<br>
Draft Policy ARIN-2015-9<br>
Eliminating needs-based evaluation for Section 8.2 and 8.3 transfers of IPv4 netblocks<br>
Original Date: 23 September 2015<br>
Updated: 16 February, 2016<br>
<br>
Problem statement:<br>
The current needs-based evaluation language in NRPM sections 8.2 and 8.3, regarding transfer of IPv4<br>
netblocks from one organization to another, may cause a recipient organization to bypass the ARIN<br>
registry entirely in order to secure the needed IPv4 netblocks in a more timely fashion directly from the<br>
current holder. The result is that the data visible in ARIN registry may become more inaccurate over<br>
time.<br>
<br>
Policy statement:<br>
This proposal eliminates all needs-based evaluation language for sections 8.2 and 8.3, allowing<br>
transfers to be reflected in the database as they occur following an agreement of transfer from the<br>
resource provider to the recipient.<br>
<br>
Section 8.1 Principles:<br>
- Strike the fragment from the 3rd paragraph which reads<br>
", based on justified need, "<br>
so the resulting text reads<br>
"Number resources are issued to organizations, not to individuals representing those organizations."<br>
Section 8.2 Mergers and Acquisitions:<br>
- Change the 4th bullet from:<br>
"The resources to be transferred will be subject to ARIN policies."<br>
to:<br>
"The resources to be transferred will be subject to ARIN policies, excluding any policies related to needs-based justification."<br>
<br>
- Strike the final paragraph which begins "In the event that number resources of the combined organizations are no longer justified under ARIN policy ..."<br>
<br>
Section 8.3 Transfers between Specified Recipients within the ARIN Region:<br>
- Change the first bullet under "Conditions on recipient of the transfer" from:<br>
"The recipient must demonstrate the need for up to a 24-month supply of IP address resources under current ARIN policies and sign an RSA."<br>
to:<br>
"The recipient must sign an RSA."<br>
<br>
- Change the 2nd bullet under "Conditions on recipient of the transfer" from:<br>
"The resources to be transferred will be subject to ARIN policies."<br>
to:<br>
"The resources to be transferred will be subject to ARIN policies, excluding any policies related to needs-based justification."<br>
<br>
Comments:<br>
a. Timetable for implementation: Immediate<br>
b. Anything else<br>
As the "free pool" for 4 of the 5 world's RIR's (APNIC, RIPE, LACNIC, and ARIN) have now been<br>
exhausted, networks in need of additional IPv4 addresses have shifted away from the practice of<br>
receiving them from the RIR's resource pool. Instead, networks in need are seeking out current holders<br>
of IPv4 resources who are willing to transfer them in order to fulfill that need. Accordingly, the RIR's<br>
primary responsibility vis-à-vis IPv4 netblock governance has shifted from "allocation" to ensuring an<br>
accurate registry database.<br>
<br>
The RIPE registry can be used as a reference of one which has evolved over the past couple years to<br>
shift their focus away from conservation/allocation and towards database accuracy. IPv4 netblock<br>
transfers within that RIR consist merely of validating authenticity of the parties requesting a transfer.<br>
Provided the organizations meet the basic requirement of RIR membership, and that the transferring<br>
organization has the valid authority to request the transfer, the transaction completes without any<br>
"needs-based" review.<br>
<br>
_______________________________________________<br>
PPML<br>
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</blockquote></div><br><br clear="all"><div><br></div>-- <br><div class="gmail_signature">Cheers,<br><br>McTim<br>"A name indicates what we seek. An address indicates where it is. A route indicates how we get there." Jon Postel</div>
</div>