Of course your position wouldn’t have anything to do with the profits you stand 
to make from an unrestricted transfer market.

Owen

> On Sep 24, 2015, at 13:12 , Elvis Daniel Velea <[email protected]> wrote:
> 
> Hi Owen,
> 
> On 24/09/15 22:09, Owen DeLong wrote:
>> Short answer: NO
>> 
>> Longer answer:
>> 
>> Finance alone does not reflect all community values. Eliminating needs-based 
>> evaluation for transfers
>> will foster an environment open to speculation and other artifice used to 
>> maximize the monetization of
>> address resources without providing the benefit to the community of 
>> maximizing utilization.
> The environment open to speculation already exists, a needs-based criteria 
> will not stop the ones that want to speculate. Keeping needs-based criteria 
> in policy will only drive (keep some of the) transfers underground (ie: 
> futures contracts, all kind of financial artifices). I actually believe the 
> needs-based criteria removal will benefit the community by eliminating a 
> barrier in the correct registration of the transfers (resources) in the 
> registry (and whois).
> 
> The allocation era has passed, ARIN should just be a shepherd and record the 
> transfers (and do the allocation exercise twice per year, when the IANA 
> allocates the few crumbs remaining). From my experience and observations, if 
> someone needs the IP addresses and has the money to pay for them I am sure 
> that they will not be stopped by ARIN's needs-base criteria...
>> In fact, I believe that eliminating needs-basis will likely cause actual 
>> utilization to be reduced in the
>> long run in favor of financial manipulation.
> I dare to disagree. From where I am standing, the removal of needs-basis 
> criteria from the RIPE Region has increased utilization of the resources 
> transferred through the IPv4 marketplace.
> Additionally, the removal of the needs-basis criteria has increased the 
> number of transfers, showing that the marketplace works and is useful to 
> hundreds (or even thousands) of companies from the region.
> 
> I am not saying that the ARIN community should copy what the RIPE community 
> has done. I am just saying that if something is working and it's usability is 
> proven, it is rather strange to see some saying the opposite as an argument 
> against the removal of the needs-based criteria.
>> 
>> Owen
> cheers,
> elvis
>> 
>>> On Sep 24, 2015, at 11:55 , Leif Sawyer <[email protected]> wrote:
>>> 
>>> Now that we've reached the magic ZERO in the free pool, what does the 
>>> community
>>> think about this new draft policy?
>>> 
>>> Should ARIN begin the process of streamlining the IPv4 policy so that it is
>>> geared more toward the transfer market, and remove "need" as a criteria in
>>> certain sections of the NRPM to increase the database accuracy?
>>> 
>>> 
>>> -----Original Message-----
>>> From: [email protected] [mailto:[email protected]] On 
>>> Behalf Of ARIN
>>> Sent: Wednesday, September 23, 2015 12:54 PM
>>> To: [email protected]
>>> Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
>>> evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
>>> 
>>> Draft Policy ARIN-2015-9
>>> Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers 
>>> of IPv4 netblocks
>>> 
>>> On 17 September 2015 the ARIN Advisory Council (AC) accepted
>>> "ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3, and 
>>> 8.4 transfers of IPv4 netblocks" as a Draft Policy.
>>> 
>>> Draft Policy ARIN-2015-9 is below and can be found at:
>>> https://www.arin.net/policy/proposals/2015_9.html
>>> 
>>> You are encouraged to discuss the merits and your concerns of Draft Policy 
>>> 2015-9 on the Public Policy Mailing List.
>>> 
>>> The AC will evaluate the discussion in order to assess the conformance of 
>>> this draft policy with ARIN's Principles of Internet Number Resource Policy 
>>> as stated in the PDP. Specifically, these principles are:
>>> 
>>>    * Enabling Fair and Impartial Number Resource Administration
>>>    * Technically Sound
>>>    * Supported by the Community
>>> 
>>> The ARIN Policy Development Process (PDP) can be found at:
>>> https://www.arin.net/policy/pdp.html
>>> 
>>> Draft Policies and Proposals under discussion can be found at:
>>> https://www.arin.net/policy/proposals/index.html
>>> 
>>> Regards,
>>> 
>>> Communications and Member Services
>>> American Registry for Internet Numbers (ARIN)
>>> 
>>> 
>>> ## * ##
>>> 
>>> Draft Policy ARIN-2015-9
>>> Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers 
>>> of IPv4 netblocks
>>> 
>>> Date: 23 September 2015
>>> 
>>> Problem statement:
>>> 
>>> The current policies in NRPM sections 8.2, 8.3, and 8.4 regarding transfer 
>>> of IPv4 netblocks from one organization to another are currently a 
>>> hindrance in ensuring database accuracy. In practice, ARIN staff are 
>>> utilizing those polices to refuse to complete database updates which would 
>>> reflect an accurate transfer of control / utilization of netblocks in cases 
>>> where ARIN doesn't agree that the recipient organization has need, or more 
>>> often where the recipient organization bypasses the ARIN registry entirely 
>>> in order to secure the needed IPv4 netblocks in a more timely fashion 
>>> directly from the current holder.
>>> Additionally, the 8.1 introduction section includes a perceived "threat"
>>> of reclaim which serves as a hindrance to long-term resource holders 
>>> approaching ARIN with database updates when transferring resources. The 
>>> result is that the data visible in ARIN registry continues to become more 
>>> inaccurate over time.
>>> 
>>> Policy statement:
>>> 
>>> This proposal is for the following language changes in the respective NRPM 
>>> sections in order to eliminate all needs-based evaluation for the 
>>> respective transfer type, and allow transfers to be reflected in the 
>>> database as they occur following an agreement of transfer from the resource 
>>> provider to the recipient.
>>> 
>>> Section 8.1 Principles:
>>> 
>>> - Strike the 3rd paragraph which begins with "Number resources are issued, 
>>> based on justified need, to organizations. . ." since it mostly reiterates 
>>> other sections of ARIN policy. All transfers are subjected to those 
>>> policies, as called out in 8.2, 8.3, 8.4. Additionally, removing this 
>>> paragraph removes the perceived "threat" of reclaim which serves as a 
>>> hindrance to long-term resource holders approaching ARIN with database 
>>> updates, since in practice ARIN has not been forcibly reclaiming IP 
>>> resources assigned to "failed businesses."
>>> 
>>> Section 8.2 Mergers and Acquisitions:
>>> 
>>> - Change the 4th bullet from:
>>> 
>>> "The resources to be transferred will be subject to ARIN policies."
>>> 
>>> to:
>>> 
>>> "The resources to be transferred will be subject to ARIN policies, 
>>> excluding any policies related to needs-based justification or inspection 
>>> of current or future utilization rate."
>>> 
>>> - Remove entirely the last paragraph which reads "In the event that number 
>>> resources of the combined organizations are no longer justified under ARIN 
>>> policy at the time ARIN becomes aware of the transaction, through a 
>>> transfer request or otherwise, ARIN will work with the resource holder(s) 
>>> to return or transfer resources as needed to restore compliance via the 
>>> processes outlined in current ARIN policy."
>>> 
>>> Section 8.3 Transfers between Specified Recipients within the ARIN Region:
>>> 
>>> - Change the first bullet under "Conditions on recipient of the transfer" 
>>> from:
>>> 
>>> "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."
>>> 
>>> to:
>>> 
>>> "The recipient must sign an RSA."
>>> 
>>> - Change the 2nd bullet under "Conditions on recipient of the transfer"
>>> from:
>>> 
>>> "The resources to be transferred will be subject to ARIN policies."
>>> 
>>> to:
>>> 
>>> "The resources to be transferred will be subject to ARIN policies, 
>>> excluding any policies related to needs-based justification or inspection 
>>> of current or future utilization rate."
>>> 
>>> Section 8.4 Inter-RIR Transfers to Specified Recipients:
>>> 
>>> - Change the introductory language from:
>>> 
>>> "Inter-regional transfers may take place only via RIRs who agree to the 
>>> transfer and share reciprocal, compatible, needs-based policies."
>>> 
>>> to:
>>> 
>>> "Inter-regional transfers may take place only via RIRs who agree to the 
>>> transfer and share reciprocal, compatible, policies."
>>> 
>>> - Change the 2nd bullet under "Conditions on recipient of the transfer"
>>> from:
>>> 
>>> "Recipients within the ARIN region will be subject to current ARIN policies 
>>> and sign an RSA for the resources being received."
>>> 
>>> to:
>>> 
>>> "Recipients within the ARIN region will be subject to current ARIN 
>>> policies, excluding any policies related to needs-based justification or 
>>> inspection of current or future utilization rate, and sign an RSA for the 
>>> resources being received."
>>> 
>>> - Remove entirely the 3rd bullet under "Conditions on recipient of the 
>>> transfer" which reads "Recipients within the ARIN region must demonstrate 
>>> the need for up to a 24-month supply of IPv4 address space."
>>> 
>>> Comments:
>>> 
>>> a.  Timetable for implementation: Immediate
>>> 
>>> b.  Anything else
>>> 
>>> As the "free pool" for 4 of the 5 world's RIRs (APNIC, RIPE, LACNIC, and
>>> ARIN) has now been exhausted, networks in need of additional IPv4 addresses 
>>> have shifted away from the practice of receiving them from the RIR's 
>>> resource pool. Instead, networks in need are seeking out current holders of 
>>> IPv4 resources who are willing to transfer them in order to fulfil that 
>>> need. Accordingly, the RIR's primary responsibility vis-à-vis IPv4 netblock 
>>> governance has shifted from "allocation" to "documentation." In other 
>>> words, the focus must move away from practicing conservation and fair 
>>> distribution (e.g. following guidelines set forth in RFC2050) to ensuring 
>>> an accurate registry database of which organization is utilizing a given 
>>> netblock as a result of transfers which occur between organizations.
>>> 
>>> The RIPE registry can be used as a reference of one which has evolved over 
>>> the past couple years to shift their focus away from 
>>> conservation/allocation and towards database accuracy. IPv4 netblock 
>>> transfers within that RIR consist merely of validating authenticity of the 
>>> parties requesting a transfer. Provided the organizations meet the basic 
>>> requirement of RIR membership, and that the transferring organization has 
>>> the valid authority to request the transfer, the transaction completes 
>>> without any "needs-based" review.
>>> 
>>> 
>>> _______________________________________________
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>> _______________________________________________
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> 
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