Hi Scott,

 

I would support the policy even with 8.5.2, having registered my concerns.

 

I would support it more if 8.5.2 was removed, and transfer needs were 
determined under the already-operative NRPM 1.2 text calling for efficient 
distribution to organizations who have a technical need for the addresses in 
support of operational networks. We shouldn’t copy bits of operational text and 
stick them in every section simply to afford convenience to those who can’t be 
bothered to find them in section 1.

 

Let an officer attest to the fact that they need the addresses in support of an 
operational network, fine.  The real functional attestation of need is the 
corporation paying for the addresses and that won’t change.

 

So I would encourage simplification via the removal of 8.5.2 on the basis that 
it goes beyond 1.2 through the use of the word “solely”, which will lead to 
confusion with buyers who either don’t yet have an operational network, or 
buyers who are buying for strictly planning purposes.

 

Regards,

Mike

 

 

 

 

 

 

 

From: Scott Leibrand [mailto:[email protected]] 
Sent: Friday, June 24, 2016 10:22 AM
To: Mike Burns <[email protected]>; Michael Peddemors 
<[email protected]>; John Curran <[email protected]>
Cc: [email protected]
Subject: RE: [arin-ppml] Draft Policy ARIN-2016-5: 
Post-IPv4-Free-Pool-Depletion Transfer Policy

 

I am assuming we'll need to tighten up this language to make it more 
operational: specifically requiring attestation of operational use, not just 
making a general statement about ARIN only issuing space to operational 
networks. Would that help address your concern? If so, let's revisit after 
Andrew and I and the AC shepherds figure out the exact revision we want there, 
unless you have any specific suggestions for language we should consider. 

-Scott

 

_____________________________
From: Mike Burns <[email protected] <mailto:[email protected]> >
Sent: Friday, June 24, 2016 9:17 AM
Subject: RE: [arin-ppml] Draft Policy ARIN-2016-5: 
Post-IPv4-Free-Pool-Depletion Transfer Policy
To: Scott Leibrand <[email protected] <mailto:[email protected]> >, 
Michael Peddemors <[email protected] <mailto:[email protected]> >, 
John Curran <[email protected] <mailto:[email protected]> >
Cc: <[email protected] <mailto:[email protected]> >



Hi Scott,

 

I see the harm in the inclusion of non-operational text which seems to put into 
the NRPM something like a specific community expression against financial 
speculation which I think is not necessary. This inclusion could end up being a 
Trojan horse for future policy which could hinge on the assumption that the 
ARIN community had made this overt expression.

 

As I said I support the intent of simplifying the transfer policy but I don’t 
think 8.5.2 is necessary in light of NRPM 1.2 Conservation:  Conservation of 
these common number spaces requires that Internet number resources be 
efficiently distributed to those organizations who have a technical need for 
them in support of operational networks.

 

 

On the assumption that we don’t want wasted or non-op verbiage in the NRPM, why 
is this section required?

 

Regards,

Mike

 

 

 

 

 

 

From: Scott Leibrand [mailto:[email protected]] 
Sent: Friday, June 24, 2016 10:09 AM
To: Mike Burns <[email protected] <mailto:[email protected]> >; Michael 
Peddemors <[email protected] <mailto:[email protected]> >; John 
Curran <[email protected] <mailto:[email protected]> >
Cc: [email protected] <mailto:[email protected]> 
Subject: Re: [arin-ppml] Draft Policy ARIN-2016-5: 
Post-IPv4-Free-Pool-Depletion Transfer Policy

 

Mike,

 

I think you're misunderstanding the intent here. This very simple "operational 
use" clause, that doesn't interfere with *any* legitimate transfers, is all 
that should be needed to prevent financial speculation, and allow us to 
dramatically simplify the needs test, or even remove it entirely in some cases 
(like the /24 for new entrants). Unless you see some actual harm that the 
clause would do, please just consider it "insurance" against an unlikely event 
that some people are concerned about, so we can move on to actually simplifying 
the rest of the policy. 

-Scott

 

 

On Fri, Jun 24, 2016 at 8:59 AM -0500, "Mike Burns" <[email protected] 
<mailto:[email protected]> > wrote:

 
 
   I do believe such a provision would have significant teeth with respect to 
inhibiting
   IP address blocks as a viable large scale investment opportunity.   While 
those 
   of questionable repute may want work around such provisions, it would be 
rather
   difficult to establish a formal vehicle (i.e. fund) for investment in IP 
resource blocks 
   based on a requirement for the necessary representations and the associated 
risk 
   of loss of the entire investment in cases of fraud.   Other than that 
circumstance, 
   I agree that it would be fairly straightforward for most operating companies 
to make
   reasonable representations based on anticipated needs without significant 
concern.
 
Thanks!
/John
 
 
Now the boogeyman has morphed into a hypothetical formal investment fund for 
IPv4 addresses. Despite zero evidence of anybody buying addresses and then 
reselling them for profit, we are asked to include this non-operational chaff 
in the NRPM. Despite an atomized supply, despite anti-flip provisions, despite 
IPv6 in the offing.  I wonder again what is keeping this fictional investment 
fund from opening a RIPE LIR and buying all they want? 
 
For what it's worth, there are active buyers today seeking to acquire millions 
of addresses which they desperately need for their operational networks and 
planned growth. Guess what, despite having the largest warchests around, they 
can't find sellers capable of meeting their needs. Why do you think a fund 
would have any more luck? Where is your evidence that 8.5.2 would have 
significant teeth regarding its inhibiting effect on viable large scale 
investments in ipv4? Is this just your opinion?
 
John, people can have different views on whether IP blocks should be treated as 
other commodities, and thus hedged, invested in, or speculated on. There is no 
need to cast aspersions on those who have this view, and your language about 
"questionable repute" goes beyond policy advice and veers into policy 
partisanship.
 
Regards,
Mike
 
 
 
 
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