Hi Bill, Interesting proposal. I will note that RIPE allowed a /22 to each new LIR without a needs test, and enterprising individuals began spinning up LIRs just to get that /22 only to transfer or sell it immediately.
In our case, though, the buyers will be paying market price for the addresses, not getting nearly free ones from ARIN. So I doubt we would see people spinning up ARIN organizations just to get around the needs test. If they wanted to get around the needs test, there are many options already available for that at much lower expense. Steven is right, there was a proposal last year to allow non-needs tested transfers up to a certain size, one per year. Maybe it should be dusted off. Regards, Mike From: [email protected] [mailto:[email protected]] On Behalf Of Bill Buhler Sent: Friday, September 25, 2015 4:06 PM To: Steven Ryerse <[email protected]>; Owen DeLong <[email protected]> Cc: [email protected] Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks Having watched this for the last couple of years let me make a couple of observations / one proposal: There seems to be a lot of fear on both sides of this debate, on the needs test side there seems to be a complete fear of monopolization of the IP address space by those with deep pockets. On the other side there seem to be a couple of thoughts: 1. It’s a market, markets work best when freed from constraints that increase the complexity of non-harmful transactions, and that allowing companies to more freely exchange IP resources is not harmful. 2. Not liking to justify future and current operations to a third party / fear of rejection by this process. I may not have encapsulated both arguments well, and these have been hashed over again and again for the last few years. So what is different today? ARIN has allocated every last resource from the free pool, and has a long waiting list. So what if we strike a compromise? What if some restrictions were put on allocation size and frequency without a needs test and left only the truly large or frequent transactions to do it. Something like this: Every legal entity can obtain up to a /22 from the transfer market every year, in up to two transactions. They may not transfer these resources out of their network within twelve months. Each legal entity has to occupy a unique address (suite level) from any other entity in the ARIN database. All transfers larger than a /22 need to have needs based justification done based on the current model. If you wanted to speculate, you would need to spin-up dozens of entities all with unique mailstops, and you would have to camp on the addresses for a year. Meanwhile the small end users and ISPs could obtain up to a /22 of a resource that with a lot of careful use of NAT would support a fairly large public network. Best regards, Bill Buhler From: [email protected] <mailto:[email protected]> [mailto:[email protected]] On Behalf Of Steven Ryerse Sent: Friday, September 25, 2015 11:48 AM To: Owen DeLong Cc: [email protected] <mailto:[email protected]> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks Owens comment from below: “2. To the extent that there is supply, anyone who needs addresses can get them already. Needs-based evaluation does not prevent those with need from getting addresses… It prevents those without need from getting them.” Owen’s comment is absolutely false!!!!! It allows large organizing who request resources to get what they need or something smaller. It allows medium size organizations who request resources to get what they need or something smaller. It allows small organizations who request resources to get what they need or nothing, and there is no other source to get resources if ARIN rejects a request, but the open market which Owen and others seem to wish did not exist! It is time to fix this inequity and removing needs tests would be a big help to small organizations who really need 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℠ From: [email protected] <mailto:[email protected]> [mailto:[email protected]] On Behalf Of Owen DeLong Sent: Friday, September 25, 2015 1:24 PM To: [email protected] <mailto:[email protected]> Cc: [email protected] <mailto:[email protected]> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks On Sep 25, 2015, at 04:42 , Elvis Daniel Velea <[email protected] <mailto:[email protected]> > wrote: Hi Richard, On 25/09/15 06:46, Richard J. Letts wrote: b) There is no definitive outcome from the policy change, which makes me feel that it's not worth changing -- the problem statement argument is weak at best. the outcome is that everyone that will need IP addresses will be able to get them. Isn't that quite definitive and clear? Sure, except it isn’t actually an outcome of the proposal on many levels: 1. The proposal does nothing to guarantee a supply of addresses or even increase the supply. 2. To the extent that there is supply, anyone who needs addresses can get them already. Needs-based evaluation does not prevent those with need from getting addresses… It prevents those without need from getting them. 3. The definitive outcome from the policy change, if there is such, is that those without need will now be more easily able to acquire addresses, potentially preventing those with need from acquiring them. It is potentially enabling organizations with more money than need gain more resources, potentially at the expense of non-profit and educational organizations who might not be able to raise cash for additional IPv4 space [or equipment to support a transition to IPv6]. So, you think that in today's market the non-profit/educational organizations will have the chance at getting some of the IP space from the market? And if the needs-based barrier is removed, they will no longer have that chance? Everyone knows that the IP address is now an asset and is worth a buck. Who do you think will say: I'll give it for free to this educational organization (because they have proven the need to ARIN) instead of giving it for money to this commercial entity (that may or may not have a demonstrated need need for it). Contrary to your statement, there have been addresses returned to ARIN and there have been organizations who chose to transfer addresses to those they found worthy rather than maximize the monetization of those addresses. OTOH, having a policy like this in place certainly makes it easier to manipulate the market to maximize the price. I think we need to wake up. Keeping needs-based criteria in the policy will only cause SOME transfers to be driven underground and block some others. I think claiming that those of us who believe needs-based criteria is still useful are asleep is unwarranted. Changing policy just to (potentially) improve the accuracy of a database seems not worth the (potential) risk. The change of the accuracy of the registry is already proven in the RIPE region. I would say it's not just potential, it is real and visible. Please provide the metrics on which you base this assertion. How was RIPE-NCC accuracy measured prior to the policy change and to what extent was it improved as a result of this policy change. What mechanism was used to determine that the measured increase in accuracy was the result of the particular policy abandoning needs-based evaluation? Owen Richard regards, Elvis ________________________________________ From: [email protected] <mailto:[email protected]> <[email protected] <mailto:[email protected]> > on behalf of Dani Roisman <[email protected] <mailto:[email protected]> > Sent: Thursday, September 24, 2015 6:20 PM To: [email protected] <mailto:[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 | Date: Wed, 23 Sep 2015 16:53:59 -0400 | From: ARIN <[email protected] <mailto:[email protected]> > | To: [email protected] <mailto:[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 | Message-ID: <[email protected] <mailto:[email protected]> > | Content-Type: text/plain; charset=utf-8; format=flowed | | 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 Greetings, There has been some stimulating dialog about the merits of 2015-9. I'd like to ask that in addition to any overall support or lack thereof, you also review the policy language and comment specifically on the changes proposed: a) For those of you generally in support of this effort, are there any refinements to the changes made which you think will improve this should these policy changes be implemented? b) For those of you generally opposed to this effort, are there any adjustments to the policy changes which, if implemented, would gain your support? -- Dani Roisman _______________________________________________ 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. _______________________________________________ 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. _______________________________________________ PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ( <mailto:[email protected]> [email protected]). 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