IE ARIN would be a competitor in a marketplace for which it holds a monopoly.




Orin Roberts 
IP PROVISIONING
Bell Canada


-----Original Message-----
From: ARIN-PPML <[email protected]> On Behalf Of [email protected]
Sent: June-20-19 12:57 PM
To: ARIN-PPML List <[email protected]>
Subject: [EXT]Re: [arin-ppml] ARIN-2019-7: Elimination of the Waiting List 
(was:Re: Looking for final show of support on revised Advisory Council 
Recommendation Regarding NRPM 4.1.8. Unmet Requests

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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