I am writing on behalf of the ARIN AC to seek additional input from the 
community regarding how (or if) we should proceed with ARIN-2015-8.

The feedback received at ARIN 36 and in subsequent AC discussions has been very 
mixed and there is no community consensus for the proposal in its present form.

Some of the main points made at ARIN 36 and the subsequent AC meeting were:


1.     Orgs should not be able to by-pass the fee structures and other policy 
consequences of being classified as ISPs, and the draft policy would facilitate 
this type of by-pass;

2.     Some of those who shared the concern in point 1. said that they would 
still support allowing Orgs to SWIP to themselves (and possibly to related 
Orgs) to facilitate geolocation and this will be even more important in an IPv6 
environment where assigned address blocks are much bigger and so often not used 
at one location;

3.     ARIN already allows RWHOIS to be used by End-Users, which leads to the 
question of whether this avenue should be foreclosed, End-User SWIPs should be 
allowed or the status quo should be left in place;

4.     Should End-Users who want to be able to re-assign records simply be 
required to become ISPs?

5.     Should the ISP/End-User distinction be eliminated (which is a bigger 
discussion outside the scope of the current problem statement)?

6.     If the ISP/End-User fee distinction were eliminated, would there still 
be opposition to the draft policy?

7.     To what extent is there value or do problems get created if End-Users 
can SWIP (i.e., improving the accuracy of database information vs. possibly 
facilitating a "grey market" where the true registered users of numbering 
resources are not known)? and

8.     Does the problem statement need to be reformulated, and if so, how?

If you would like to see further work on this policy, please let us at the AC 
know what form you think that work should take. If you think the policy should 
be abandonded altogether we would like to know that as well.

Thank you.

Chris

Christian S. Tacit,
Tacit Law

P.O. Box 24210 RPO Hazeldean
Kanata, Ontario
K2M 2C3 Canada

Tel: +1 613 599 5345
Fax: +1 613 248 5175
E-mail: [email protected]

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