Oppose

I have no problem with the idea of getting rid of the waiting list part of the proposal.

I do have a problem with an auction, as I think it will cause lots of issues when ARIN revokes resources, because it certainly will be alleged that "ARIN did it for the money", as has already been discussed, and will make any legal action a lot more costly. The Board choosing to use auction proceeds for legal costs would be like pouring gasoline on a fire, and I note that the Board could choose to spend auction proceeds in this fashion, since how to spend the proceeds is totally under their control.

Rather than an auction, I propose putting the returns in the 4.10 Dedicated IPv4 Block to Facilitate IPv6 Deployment. This pool is limited to a /24 maximum. This use would also promote IPv6 use.

This would leave the marketplace as the only source of IPv4 addresses greater than a /24. It would also effectively limit any "free" addresses to smaller players.

If we are giving out "Free" addresses at ARIN, why not impose a condition that the addresses so provided be used as part of IPv6 deployment?

Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Thu, 20 Jun 2019, Alyssa Moore wrote:

Hi folks,

Trying to do a temperature check here. If you're following this thread,
please indicate whether you support or oppose this draft policy.

On Mon, Jun 17, 2019 at 11:42 AM David Farmer <[email protected]> wrote:



On Sun, Jun 16, 2019 at 2:50 PM Mueller, Milton L <[email protected]>
wrote:

OK, I???ve read it, and here is my reaction:



This policy requires legal comment. ARIN???s Articles and Bylaws do not
specifically prohibit ARIN from monetizing returned or revoked resources by
selling those resources into the transfer market



So point #1 is that this proposed policy does not violate any articles or
bylaws.



Today, ARIN does not financially benefit in any material way from such
revocations. Adoption of this policy would for the first time allow the
party in a contested revocation situation to argue that ARIN seeks to
financially benefit. Avoiding that concern is also significant.



I am totally unimpressed with this argument. If ARIN revokes addresses
for nonpayment it is financially benefiting from the revocation is it not?
It is basically taking them back because it is not getting paid.



If ARIN ???gets paid??? by selling the numbers into the transfer market what
is the difference exactly?


Referring to the waiting list policy, the Draft Policy says, "this policy
provides valuable number resources essentially for free".

Yes, ARIN currently financially benefits, but currently, that benefit is
at a level of cost recovery, "essentially for free" as stated above.
Whereas, if ARIN were to dispose of resources using the market, the level
of financial benefit is likely to be orders of magnitude larger.
Furthermore, if this wasn't the case, then the impact on the market and the
potential for fraud supposedly created by the waiting list, that the draft
policy proposes to mitigate, wouldn't exist in the first place.

In short, "what is the difference", probably, several orders of magnitude
in the level of financial benefit involved. Where the financial motivations
from simple "cost recovery" can probably be summarily dismissed by the
court. Whereas the potential financial motivations, that one might even
call a windfall, from market-based transactions probably at least needs to
be examined and evaluated by the court, and probably wouldn't be summarily
dismissed. The outcome of the two situations might be the same in the end,
but the level of effort involved defending and the level of risk of an
adverse ruling, are not the same at all.

More generally, ARIN participating in the market seems distasteful and
counter to its overall mission, but doesn't directly violate its Articles
and Bylaws.

That said that doesn't mean ARIN can't implement the policy, but these
risks need to be evaluated when compared to other alternatives being
considered, along with the possible benefits this policy could have as well.

--
===============================================
David Farmer               Email:[email protected]
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota
2218 University Ave SE        Phone: 612-626-0815
Minneapolis, MN 55414-3029   Cell: 612-812-9952
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