On Jun 4, 2014, at 8:16 AM, Mike Burns <[email protected]> wrote:

> Hi Blake,
> 
> We can be wistful for the lack of progress of RPKI or the fact that addresses 
> are regularly routed for customers who are not the Whois registrants, but we 
> are powerless to change those things, community-wide.
> 
> We are a community of private network operators for the most part. We are 
> stakeholders tasked primarily with maintaining a registry of uniqueness of IP 
> addresses. We need to ask ourselves whether the purported benefits of 
> maintaining a needs-test for every change of registrant in Whois is worth the 
> risk to the registry and the expenditure of fungible ARIN staff resources.
> 
> I elucidated one such risk, which is the risk of un-registered acquisitions 
> of shell corporations which are incentivized by the lack of a needs test. 
> John Curran acknowledged this risk.
> 
> I offered an example of one of the few publicly demonstrable cases of this in 
> Whois, related to the public information surrounding the Microsoft/Nortel 
> deal. I am aware of many more but can not disclose them.
> 
> People seek to frame this issue as if it were this question: "Should we 
> change the rules just because some people will break them?"
> 
> My answer to that is yes, of course we should, unless the rule provides some 
> overriding benefit.
> 
> So my question for the community is "What is the benefit we realize by 
> insisting on ARIN team review of every single transfer, down to /24, and is 
> it worth ARIN ticket time delay and the risk of decreased Whois accuracy?”

The benefit is preserving addresses on a fair basis for those who actually have 
legitimate and quasi-immediate use for them.

Yes, this benefit is worth the ARIN ticket time and delay.

There has not yet been any actual evidence presented to show that the risk to 
whois accuracy is any greater without this proposal than it is with it. Those 
that would ignore ARIN policy to effectuate a transfer are just as likely IMHO 
to ignore whois as not.

> And secondarily, what size of un-needs tested transfer would be an acceptable 
> balance between the benefits of the needs test and the costs of the needs 
> test?

/24 seems like a perfectly reasonable balancing point to me. I’d be willing to 
conduct an experiment on a temporary basis at /20 for a limited time (12 
months).

Owen


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