Your proposed language is clearer in the context of policy development, but would lack clarity when placed in the NRPM as “this requirement” becomes somewhat ambiguous.
Hi Owen, It should be read not as “this requirement” but as “this requirement set”. Maybe it should read: In addition, the recipient must meet one of the following requirement-sets: ... 4.Fewer than 5,000 transfers have completed under this requirement-set ? Or the two requirement sets might be labeled clearly as the “Needs-tested” option and the “Needs-attested” option. This comports with the current language of Line 4. But so long as it is clear to everyone who considers the proposal I am fine with the current language. Regards, Mike From: Owen DeLong [mailto:[email protected]] Sent: Thursday, March 12, 2015 1:55 PM To: Mike Burns Cc: [email protected]; [email protected] Subject: Re: [arin-ppml] Draft Policy ARIN-2014-14: Needs Attestation for some IPv4 Transfers - Revised Mike, Your proposed language is clearer in the context of policy development, but would lack clarity when placed in the NRPM as “this requirement” becomes somewhat ambiguous. Owen On Mar 12, 2015, at 08:08 , Mike Burns <[email protected] <mailto:[email protected]> > wrote: On 2/24/2015 9:17 AM, ARIN wrote: ARIN-2014-14 has been revised. This draft policy is open for discussion on this mailing list. ARIN-2014-14 is below and can be found at: https://www.arin.net/policy/proposals/2014_14.html Regards, Communications and Member Services American Registry for Internet Numbers (ARIN) ## * ## Draft Policy ARIN-2014-14 Needs Attestation for some IPv4 Transfers Date: 24 Feb 2015 Problem Statement: The process of 'needs testing' or 'needs basis' allocation has evolved over the history of the Internet registry system. The earliest number resource policy required that an operator intend to use the number resources on an operational Internet Protocol network before the resource would be registered to an organization. Organizations were assigned either a Class A, B, or C block roughly depending on the organization's size. With the implementation of CIDR, additional 'needs testing' was done to right size allocations to fit organizations. These testing requirements continued to evolve under various organizations prior to the RIRs inception and then later formally under the RIR's policy development process. In the 2000s, ARIN began a systematic "trust but verify" process for IPv4 requests. This was necessary due to both IPv4 address registration hijackings in ARIN Whois and the accelerated amount of systematic fraud being perpetrated on ARIN. As IPv4 exhaustion occurred, some RIRs have reconsidered the necessity of some of the needs testing requirements and implemented policies which reduced the requirements on organizations to show need or utilization for some transfer transactions with the RIR. The cost of performing a needs assessment and auditing of this information vs. the public benefit of restricting allocations to specifically qualified organizations has been noted by some organizations to be out of alignment. The ability to predict future use toward a 24-month utilization rate can also be challenging for some organizations and relies on projections and estimates rather than verifiable facts. Thus, the current needs testing requirements may be more than is necessary and desirable for small transfers. This policy seeks to reduce the complexity of transfers by removing the utilization needs testing requirement and replacing it with a needs attestation by a corporate officer. Additionally, other requirements are placed around the 'needs attestation only' requirement to reduce the Number Resource Community's concern that this type of policy could be abused for speculation or hording. Furthermore, the policy includes a sunset clause to limit the total number of transfers under this policy proposal. This sunset is intended to force the community to reexamine the success or failure of the practices contained in this policy proposal. Policy statement: Section 8.3 Replace the 'Conditions on recipient of the transfer' with the following conditions. Conditions on recipient of the transfer: The organization must sign an RSA. The resources transferred will be subject to current ARIN policies. In addition, the recipient must meet one of the following requirements sets: 1. The organization must demonstrate the need for up to a 24-month supply of IP address resources under current ARIN policies. OR 1.The organization, its parent(s), or subsidiary organizations, must not have received IPv4 address resources, via transfer, within the past 12 months. 2.An officer of the organization must attest that the IPv4 address block is needed for and will be used on an operational network. 3.The maximum transfer size is /20. 4.Fewer than 5,000 needs attestation transfers have occurred. Section 8.4 Replace the 'Conditions on recipient of the transfer' with the following conditions. Conditions on recipient of the transfer: The conditions on a recipient outside of the ARIN region will be defined by the policies of the receiving RIR. Recipients within the ARIN region will be subject to current ARIN policies and sign an RSA for the resources being received. The minimum transfer size is a /24. In addition, the recipient must meet one of the following requirements sets: 1. The organization must demonstrate the need for up to a 24-month supply of IP address resources under current ARIN policies. OR 1.The organization, its parent(s), or subsidiary organizations, must not have received IPv4 address resources, via transfer, within the past 12 months. 2.An officer of the organization must attest that the IPv4 address block is needed for and will be used on an operational network. 3.The maximum transfer size is /20. 4.Fewer than 5,000 needs attestation transfers have occurred. Comments: Timetable for implementation: Immediate _______________________________________________ PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected] <mailto:[email protected]> ). Unsubscribe or manage your mailing list subscription at: http://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected] <mailto:[email protected]> if you experience any issues. Hi Andrew, I think it would be clearer if the line: 4.Fewer than 5,000 needs attestation transfers have occurred. Was changed to: 4. Fewer than 5,000 transfers under this requirement set have completed. But I would support it with the current language. The maximum number of addresses which could be transferred in aggregate under this policy is 1.25 /8 equivalents. And at the current rate of transfers this would take years. Does anybody still fear damaging market manipulation could occur under this policy? Regards, Mike Burns <http://iptrading.com/> IPTrading.com _______________________________________________ PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ( <mailto:[email protected]> [email protected]). Unsubscribe or manage your mailing list subscription at: <http://lists.arin.net/mailman/listinfo/arin-ppml> http://lists.arin.net/mailman/listinfo/arin-ppml Please contact <mailto:[email protected]> [email protected] if you experience any issues.
_______________________________________________ PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]). Unsubscribe or manage your mailing list subscription at: http://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected] if you experience any issues.
