Hi Owen,

Thanks for spurring conversation on this proposal.

In my experience those who frequently want to acquire a small block to renumber 
into are holders of much-larger blocks who can realize higher prices if they 
sell their much-larger block intact. The market is rewarding larger block sizes 
with higher unit prices these days.

But how can they justify the small block they need to renumber into, since they 
usually have many more addresses than they are currently using?

The workaround of a second ORG made it easier for the second ORG to acquire 
space, as it had none.

But if we just adopt this policy language, the problem of the acquisition of 
the smaller block remains.
I would likely advise my clients to choose the workaround.

Actually I think the policy intention is good but it should be implemented in a 
different way.
Recipients of  8.3 or 8.4 transfers can choose an option which avoids any 
needs-test in exchange for a promise to transfer out eight times the number 
received within a year. Only one option can be active at a time. These 
Recipients would be excluded from current source restrictions.

I think the policy needs to consider the justification problem for recipients 
of the small block they need to renumber into, in addition to the exclusion of 
these companies from the source restrictions, or it only provides half the 
reason to avoid the workaround.

(Also I think there should be no needs-tests or source-restrictions as 
conservation is provided by price and address turnover is not a BAD THING. 😉)

Regards,
Mike




-----Original Message-----
From: ARIN-PPML <[email protected]> On Behalf Of Owen DeLong
Sent: Tuesday, December 15, 2020 2:38 PM
To: arin-ppml <[email protected]>
Subject: [arin-ppml] ARIN-2020-6: Allowance for IPv4 Allocation “Swap” 
Transactions via 8.3 Specified Transfers and 8.4 Inter-RIR Transfers

Dear ARIN community,

We (the AC, and specifically the proposal shepherds) need to solicit some 
additional feedback in order to better know the community’s desire with regards 
to this policy. Specifically, we’d like to ask the following questions:

1a.     Do you feel that we should place an upper limit on the size of the 
smaller block
        received in the process?

1b.     If so, what should that upper limit be?

2.      Do you support limits on the time period allowed for renumbering?

        2a. If so, how long?

        2b. If so, what consequences should there be for exceeding the time 
limit?

3.      Should any additional restrictions or prohibitions be placed on use of 
waitlist
        space in these transactions?

        3a. Restrictions on waitlist providing the smaller block?

        3b. Restrictions on waitlist space being transferred out?

4.      Do you support the policy as currently written?

5.      If not, would you support it with the changes suggested in your answers 
above?

Thanks for your attention to this matter,

Owen DeLong
ARIN AC

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