Obviously Milton doesn’t share that opinion per his comments below and neither
do I.
Steven Ryerse
President
100 Ashford Center North, Suite 110, Atlanta, GA 30338
770.656.1460 - Cell
770.399.9099- Office
[Description: Description: Eclipse Networks Logo_small.png]℠ Eclipse Networks,
Inc.
Conquering Complex Networks℠
From: Owen DeLong [mailto:[email protected]]
Sent: Tuesday, March 1, 2016 5:00 PM
To: Steven Ryerse <[email protected]>
Cc: Mueller, Milton L <[email protected]>; Jason Schiller
<[email protected]>; ARIN PPML <[email protected]>
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based
evaluation for Section 8.2 and 8.3 transfers of IPv4 netblocks
This policy is an example of rearranging the IPv4 deck chairs.
So your statement is not consistent with your support of the policy.
Owen
On Feb 18, 2016, at 20:07 , Steven Ryerse
<[email protected]<mailto:[email protected]>> wrote:
Milton is right! We are one of those small ISPs and the deck is stacked
against us on purpose by larger organizations. It is time to move on and stop
arranging the deck chairs on the IPv4 Titanic like other regions have. It’s
2016 not 2001. I support this policy!
Steven Ryerse
President
100 Ashford Center North, Suite 110, Atlanta, GA 30338
www.eclipse-networks.com<http://www.eclipse-networks.com/>
770.656.1460 - Cell
770.399.9099- Office
<image001.jpg>℠ Eclipse Networks, Inc.
Conquering Complex Networks℠
From: [email protected]<mailto:[email protected]>
[mailto:[email protected]] On Behalf Of Mueller, Milton L
Sent: Thursday, February 18, 2016 10:47 PM
To: Jason Schiller <[email protected]<mailto:[email protected]>>
Cc: ARIN PPML <[email protected]<mailto:[email protected]>>
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based
evaluation for Section 8.2 and 8.3 transfers of IPv4 netblocks
Really. Am I going to have to be the first to point out the irony of Google
employees complaining that companies with "deep pockets" and "the most
profitable services" will dominate the address market if we make minor
relaxations of need assessments?
What's wrong with this picture? Think, folks.
Isn't it obvious that companies like Google are in a very good position to get
the addresses they want - via less than transparent market mechanisms such as
options contracts and acquisitions? And isn't it possible that they might be
trying to prevent smaller companies from participating in the market by
throwing up artificial barriers?
All this talk of "fairness" overlooks the fact that it's more fair to have
simple, transparent bidding and less bureaucracy. Smaller bidders can easily
afford smaller chunks of numbers, and they benefit from the reduced
administrative burden and delays associated with pointless and restrictive
needs assessments. When I hear smaller ISPs who need addresses making Jason's
arguments, I might take them seriously. Until then, no.
--MM
From: [email protected]<mailto:[email protected]>
<[email protected]<mailto:[email protected]>> on behalf of
Jason Schiller <[email protected]<mailto:[email protected]>>
Sent: Thursday, February 18, 2016 3:11 PM
To: Vaughn Thurman - Swift Systems
Cc: ARIN PPML
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based
evaluation for Section 8.2 and 8.3 transfers of IPv4 netblocks
+1 to what MCTim, Owen, and Vaughn said.
In general I oppose transfers with no need.
If there are "networks in need of additional IPv4 addresses", surely they
should be able to show this, in accord with long standing practice.
I'd rather us not move to a situation which enables/encourages speculation and
profit taking (or rent-seeking if you will) in re: IP resource distribution.
I'd also rather not encourage one competitor in a business segment to be able
to better stockpile addresses and for that to become a competitive advantage
against other providers in the space. Additionally if this is done in a wide
enough scale it can sufficiently lengthen wide spread IPv6 adoption.
This policy would also allow for companies with the deepest pockets and the
most profitable services to concentrate IPv4 space. I'm not sure that is more
"fair"
than the pre-existing framework for "fair".
__Jason
On Thu, Feb 18, 2016 at 2:32 PM, Vaughn Thurman - Swift Systems
<[email protected]<mailto:[email protected]>> wrote:
+1
Sent from my mobile device, please forgive brevity and typos.
On Feb 18, 2016, at 2:16 PM, Owen DeLong
<[email protected]<mailto:[email protected]>> wrote:
+1 — McTim said it very well.
Owen
On Feb 18, 2016, at 10:34 , McTim
<[email protected]<mailto:[email protected]>> wrote:
I am opposed.
If there are "networks in need of additional IPv4 addresses", surely they
should be able to show this, in accord with long standing practice.
I'd rather us not move to a situation which enables/encourages speculation and
profit taking (or rent-seeking if you will) in re: IP resource distribution.
Regards,
McTim
On Tue, Feb 16, 2016 at 7:12 PM, Leif Sawyer
<[email protected]<mailto:[email protected]>> wrote:
Good afternoon -
Based on feedback from Montreal as well as internal discussions, I've
reworked this policy.
AC members and ARIN staff are looking for additional feedback, as well as your
position in terms
of supporting or opposing this draft policy.
We'll be discussing this policy, as well as any feedback provided on this
week's AC teleconference,
so I'm very appreciative of your input.
Thanks,
Leif Sawyer
Shepherd - ARIN-2015-9
NRPM section 8: https://www.arin.net/policy/nrpm.html#eight
Most current draft policy text follows:
--
Draft Policy ARIN-2015-9
Eliminating needs-based evaluation for Section 8.2 and 8.3 transfers of
IPv4 netblocks
Original Date: 23 September 2015
Updated: 16 February, 2016
Problem statement:
The current needs-based evaluation language in NRPM sections 8.2 and 8.3,
regarding transfer of IPv4
netblocks from one organization to another, may cause a recipient organization
to bypass the ARIN
registry entirely in order to secure the needed IPv4 netblocks in a more timely
fashion directly from the
current holder. The result is that the data visible in ARIN registry may become
more inaccurate over
time.
Policy statement:
This proposal eliminates all needs-based evaluation language for sections 8.2
and 8.3, allowing
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 fragment from the 3rd paragraph which reads
", based on justified need, "
so the resulting text reads
"Number resources are issued to organizations, not to individuals representing
those organizations."
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."
- Strike the final paragraph which begins "In the event that number resources
of the combined organizations are no longer justified under 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."
Comments:
a. Timetable for implementation: Immediate
b. Anything else
As the "free pool" for 4 of the 5 world's RIR's (APNIC, RIPE, LACNIC, and ARIN)
have 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 fulfill that
need. Accordingly, the RIR's
primary responsibility vis-à-vis IPv4 netblock governance has shifted from
"allocation" to ensuring an
accurate registry database.
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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--
Cheers,
McTim
"A name indicates what we seek. An address indicates where it is. A route
indicates how we get there." Jon Postel
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PPML
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PPML
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--
_______________________________________________________
Jason
Schiller|NetOps|[email protected]<mailto:[email protected]>|571-266-0006
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