The RIPE issue related directly to the price of IP addresses being doled out 
needs-free to each LIR.
The price then was the fees paid to RIPE plus any fees incurred in creating the 
new LIR business entity.
The net price was still far lower than the price for a /22 on the transfer 
market.
It was the price difference that drove the policy work-arounds in RIPE.
This is not an issue we face because our incentives are not misaligned.

Because we know RIPE offers needs-free transfers, it was not the needs 
requirement that drove this practice.
It was the profit incentive derived from policy conditions.

Likewise here in North America policy conditions work to provide incentive for 
off-the-books transfers.
As RIPE changed their policy to meet these real world conditions, ARIN should 
do the same and get rid of needs testing  because it provides a disincentive 
for properly recording the transfer.


Regards,
Mike

----- Original Message ----- 
  From: Andrew Dul 
  To: [email protected] 
  Sent: Friday, September 25, 2015 6:17 PM
  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


  One might want to be reminded about what happened in the RIPE region when 
they allowed organizations to obtain /22 blocks by just opening a new LIR.  

  There are lots of threads in the RIPE mailing-list that you can go read 
through if you desire.  Here is a link to the outcome, a policy that restricts 
block flipping.

  https://www.ripe.net/participate/policies/proposals/2015-01

  Yes, a /24 is not a /22, but if you decide that an organization can just come 
and get a free block, people will find ways to abuse the system.  This doesn't 
apply in the ARIN region now, because our free pool is empty, but still we can 
see what happens when incentives are misaligned in resource allocation.

  Andrew

  On 9/25/2015 1:07 PM, Steven Ryerse wrote:

    So explain to me how anyone can corner the market on IPv4 blocks when they 
can only get one /24 per year without going thru your needs testing.  They have 
to pay ARIN for them every year so in 3 years they can get up to 3 /24’s as 
long as they are willing to pay for them every year they have them.  If they 
stop paying they lose the resources.



    This is a miniscule amount of resources, and I respectfully submit it would 
not appreciably change the availability of resources for anyone. It hasn’t in 
other regions as Elvis pointed out.  It would however make a big difference to 
small Organizations and level the playing field. 



    We are not far apart conceptually but we are far apart in what actually 
happens.  



    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: Owen DeLong [mailto:[email protected]] 
    Sent: Friday, September 25, 2015 3:46 PM
    To: Steven Ryerse <[email protected]>
    Cc: Mike Winters <[email protected]>; [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



    Your proposal was to allow anyone to get a /24 per year whether they needed 
anything or not.



    I am not opposed to a policy which would allow organizations with lesser 
need to obtain a minimum size block (/24 or /48) if the potential for abuse can 
be adequately addressed.



    By abuse, I mean, for example, the creation of entities with minimalist 
infrastructure strictly for the sake of qualifying for addresses.



    I’m all for the local bakery to be able to get a /24 to support their 3 
cash registers, a router, and a few menu board displays.



    However, I’m not for VPNs-R-US being able to create 1024 entities each of 
which owns an SRX-100 and qualifies for a /24 on that basis.



    I don’t think resource policy should substantially change in a post-runout 
world and nothing said so far gives me any reason to believe there is benefit 
to the community from doing so.



    This isn't about miserly blocking of allocations for future theoretical 
use. This is about trying to make sure that organizations with need have the 
best chance of getting resources they need that we can provide. Allowing 
organizations without need to hoard addresses is contrary to that goal.



    Interestingly, we seem to have the same goal but radically different 
opinions on how best to achieve it.



    Owen



      On Sep 25, 2015, at 12:32 , Steven Ryerse <[email protected]> 
wrote:



      I would probably agree with your comment that neither of the above really 
helps anyone and probably creates a host of other issues. I would probably not 
advocate them either but they would be more fair that the policies in place 
now. 



      Of course the easy fix is to allow Organizations of any size to easily 
get the Minimum size block which I believe is now a /24 and that would go a 
long way towards fixing the problem.  I put forth just that policy change 
proposal a while back with a limit of one block per year for small 
organizations and that Policy Proposal was summarily dumped by folks with 
Owen’s views.



      My preference is to allow organizations to more easily get resources in 
this post Run-Out world, rather than to somehow try to miserly block 
allocations in the hope of saving them for some unknown future use.  



      I appreciate your attempt to be constructive.



      Steven Ryerse

      President

      100 Ashford Center North, Suite 110, Atlanta, GA  30338

      770.656.1460 - Cell

      770.399.9099- Office



      <image001.jpg>℠ Eclipse Networks, Inc.

              Conquering Complex Networks℠



      From: Mike Winters [mailto:[email protected]] 
      Sent: Friday, September 25, 2015 3:03 PM
      To: Steven Ryerse <[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



      That’s an interesting take on the “inequity”…



      However, there is a fundamental flaw with your “inequity” situation.  If 
there is not enough addresses for a small organization to get them, then nobody 
would get them.

      They will eventually rise to the top just like everyone else, ergo no 
inequity.



      Assuming for a moment your argument is correct and not seriously flawed, 
then arguing that letting people who don’t need addresses get addresses is 
silly since it would only exacerbate the problem.

      It seems the best way to “fix this inequity” that you describe would be 
to either:

      a)      not let larger organizations accept smaller allocations; or

      b)      make everyone take smaller allocations; or

      c)       let ARIN allocate smaller blocks (really bad idea); or

      d)      some crazy combination of the above



      Neither of the above really helps anyone and probably creates a host of 
other issues.

      To be clear, I am not advocating any of the above.



      Mike





      From: [email protected] [mailto:[email protected]] On 
Behalf Of Steven Ryerse
      Sent: Friday, September 25, 2015 1:48 PM
      To: Owen DeLong
      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



      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



      <image001.jpg>℠ Eclipse Networks, Inc.

              Conquering Complex Networks℠



      From: [email protected] [mailto:[email protected]] On 
Behalf Of Owen DeLong
      Sent: Friday, September 25, 2015 1:24 PM
      To: [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





        On Sep 25, 2015, at 04:42 , Elvis Daniel Velea <[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] <[email protected]> on 
behalf of Dani Roisman <[email protected]>
          Sent: Thursday, September 24, 2015 6:20 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

          | Date: Wed, 23 Sep 2015 16:53:59 -0400
          | From: ARIN <[email protected]>
          | 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
          | Message-ID: <[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
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