Amen!  ARIN's raison d'être is to allocate resources.  

Steven Ryerse
President
100 Ashford Center North, Suite 110, Atlanta, GA  30338
770.656.1460 - Cell
770.399.9099- Office

℠ Eclipse Networks, Inc.
                     Conquering Complex Networks℠

-----Original Message-----
From: [email protected] [mailto:[email protected]] On Behalf 
Of [email protected]
Sent: Wednesday, April 30, 2014 4:56 PM
To: [email protected]
Subject: Re: [arin-ppml] ARIN-prop-204 Removing Needs Test from Small 
IPv4Transfers (Sandra Brown)

Support.

I have been discussing the topic of reducing need with Andrew Dul and Owen 
DeLong at and since ARIN33 in Chicago.  I too had reached the conclusion that 
the right approach was for reduction of needs justification for /16 and 
smaller, so I am very pleased to support this proposal.  

Small businesses and ARIN staff should not be wasting their time on needs 
justification of IPv4 addresses for /16 and smaller.  

ARIN should not be determining whether a small business needs a /16 or smaller 
in order to conduct its business.  This is up to the business, not a 
pseudo-governmental authority, such as ARIN.

The historical rationale for needs justification was to prevent hoarding.

As David Huberman said, a small number of companies get MOST of the IP's via 
the free pool.  In other words, the ARIN needs justification process allows a 
small number of large companies to get a boatload of free IP's.
 But I talk to medium sized and small companies every day that cannot get small 
blocks out of the free pool through the ARIN process.  The needs justification 
process just does not work for them.

In THIS proposal we are talking about paid for transfers only.  The fact there 
is a dollar amount attached to the transfer, is one impediment to hoarding.

BUT:  With the limitation of the transfer size to a /16 or smaller, it would 
take a lot of transfers to hoard.  It would take 256 transfers to stockpile a 
/8.  This is the 2nd means to prevent hoarding.  Most companies wanting that 
many IP's would simply do needs justification. 
With the ARIN affidavit by a company officer already needed for an 8.3 or 8.4 
transfer, this is a 3rd deterrent to hoarding.  4thly the very wide 
distribution of the IPv4 address pool is a deterrent to hoarding, as it would 
take agreements and purchases from a vast number of suppliers, each willing to 
transfer a vast number of /16's, for significant hoarding to take place.  There 
is no danger of hoarding with this proposal.

Most significantly, it will start to bring ARIN Region into the global
IPv4 internet age, where the RIPE community is leaving North America in its 
dust.  RIPE NCC realized it would better support small business by removing 
impediments such as needs justification.  This is ARIN region's opportunity for 
North Americans to catch up and allow our small internet and telco businesses 
to be competitive and thrive. 

Sandra Brown
IPv4 Market Group
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