Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Owen DeLong]

> On Oct 6, 2015, at 6:45 PM, Jason Schiller <jschil...@google.com> wrote:
> 
> Before we started mucking around with lowering the minimum size block, it was 
> a /20 for ISPs (/22 for multi-homed ISPs). /20 became the defacto ISP slow 
> start.  Post 2014-13, it was reduced for to a /24 as the minimum for ISPs, 
> but the slow start initial block was between a /24 and a /20 at the ISP's 
> request. 
> 
> For end users it was /20 or /24 for multi-homed.
> 
> https://www.arin.net/policy/proposals/2014_13.html 
> <https://www.arin.net/policy/proposals/2014_13.html>
> 
> Slow start of between /24 and /20 is consistent with automatic transfer 
> pre-approval for ISPs holding no IPv4 addresses, or for ISPs whose IPv4 
> holding are at or above 80% used, and have no previous history in the past 
> year to support a larger transfer.
> 
> We have never had a slow start for end-users, but could imagine a block 
> between /24 and /22 as the right size based on the fact that most assignments 
> are within that size, and it lines up with other region's soft landing.
> 
> Anti 2 year flip / revert to ARIN free pool is a good provision.
> 
> I have a few more thoughts for this policy.
> 
> 1. At any time, an org can opt to revert back to justified need based on 
> their past 3-12 months (the org chooses the window size) run rate they can 
> get a two year supply.
> 

I think that is implicit in the policy as it would get incorporated into the 
NRPM. Do you believe it needs to be made more explicit?

It certainly is in line with my understanding of the author’s intent as well as 
my own.

> [this is useful for orgs growing at faster than the slow start size] 
> 
> 2. Orgs disolved due to corporate restructuring less than 24 months after 
> creation can keep their IP space if they meet traditional needs justification.

Do you mean that the space could be transferred to the parent organization in 
this case?

I would oppose such a provision because I believe it is quite ripe for abuse.

If not, then how, exactly, would you see this working? An org which is 
dissolved no longer exists to keep their IP space, so who is actually keeping 
it in this case?

Owen

> 
> ___Jason
> 
> 
> On Wed, Sep 30, 2015 at 10:42 PM, Owen DeLong <o...@delong.com 
> <mailto:o...@delong.com>> wrote:
> Dani,
> 
> In fairness to Bill, I think he may also have chosen them because I suggested 
> that those would be boundaries I would consider livable.
> 
> I believe they represent a good size to guarantee that small organizations 
> are not shut out of the transfer market based on size, but still ensure that 
> need assessment is preserved in order to prevent acquisition of addresses 
> without intended use thereof.
> 
> While a /20 is a fair quantity of addresses (4096), it’s a pretty small 
> number of customers for an ISP in most cases and I think anything smaller 
> would be somewhat punitive.
> 
> It does also line up well with transfer history and other ARIN data about 
> small-ish organizations and address issuance over the last several years.
> 
> Owen
> 
>> On Sep 30, 2015, at 03:52 , Dani Roisman <drois...@softlayer.com 
>> <mailto:drois...@softlayer.com>> wrote:
>> 
>> Hi Bill,
>>  
>> I’m interested to learn how you came up with the below proposed netblock 
>> sizes “/20 if a ISP or /22 for an end user” ?  Is there data behind that?  
>> If not, does it make sense to ask ARIN to supply data regarding sizes of 
>> transfers which have occurred in the past 12 - 18 months?
>>  
>> --
>> Dani Roisman
>>  
>> 
>> From: "Bill Buhler" <b...@tknow.com<mailto:b...@tknow.com 
>> <mailto:b...@tknow.com%3cmailto:b...@tknow.com>>>
>> To: "owen" <o...@delong.com<mailto:o...@delong.com 
>> <mailto:o...@delong.com%3cmailto:o...@delong.com>>>
>> Cc: arin-ppml@arin.net<mailto:arin-ppml@arin.net 
>> <mailto:arin-ppml@arin.net%3cmailto:arin-ppml@arin.net>>
>> Sent: Monday, September 28, 2015 12:59:30 PM
>> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
>> evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
>>  
>> OK, how about this:
>>  
>> Small end users and ISPs are allowed to obtain IPv4 address blocks without a 
>> needs test as long as the following criteria are met:
>>  
>>  
>> a.   The total size of their ARIN allocations at any time of the process 
>> does not exceed a /20 if a ISP or /22 for an end user.
>>  
>> b.  They cannot purchase IP address from the transfer market mor

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Jason Schiller]

Before we started mucking around with lowering the minimum size block, it
was a /20 for ISPs (/22 for multi-homed ISPs). /20 became the defacto ISP
slow start.  Post 2014-13, it was reduced for to a /24 as the minimum for
ISPs, but the slow start initial block was between a /24 and a /20 at the
ISP's request.

For end users it was /20 or /24 for multi-homed.

https://www.arin.net/policy/proposals/2014_13.html

Slow start of between /24 and /20 is consistent with automatic transfer
pre-approval for ISPs holding no IPv4 addresses, or for ISPs whose IPv4
holding are at or above 80% used, and have no previous history in the past
year to support a larger transfer.

We have never had a slow start for end-users, but could imagine a block
between /24 and /22 as the right size based on the fact that most
assignments are within that size, and it lines up with other region's soft
landing.

Anti 2 year flip / revert to ARIN free pool is a good provision.

I have a few more thoughts for this policy.

1. At any time, an org can opt to revert back to justified need based on
their past 3-12 months (the org chooses the window size) run rate they can
get a two year supply.

[this is useful for orgs growing at faster than the slow start size]

2. Orgs disolved due to corporate restructuring less than 24 months after
creation can keep their IP space if they meet traditional needs
justification.

___Jason


On Wed, Sep 30, 2015 at 10:42 PM, Owen DeLong <o...@delong.com> wrote:

> Dani,
>
> In fairness to Bill, I think he may also have chosen them because I
> suggested that those would be boundaries I would consider livable.
>
> I believe they represent a good size to guarantee that small organizations
> are not shut out of the transfer market based on size, but still ensure
> that need assessment is preserved in order to prevent acquisition of
> addresses without intended use thereof.
>
> While a /20 is a fair quantity of addresses (4096), it’s a pretty small
> number of customers for an ISP in most cases and I think anything smaller
> would be somewhat punitive.
>
> It does also line up well with transfer history and other ARIN data about
> small-ish organizations and address issuance over the last several years.
>
> Owen
>
> On Sep 30, 2015, at 03:52 , Dani Roisman <drois...@softlayer.com> wrote:
>
> Hi Bill,
>
> I’m interested to learn how you came up with the below proposed netblock
> sizes “/20 if a ISP or /22 for an end user” ?  Is there data behind that?
> If not, does it make sense to ask ARIN to supply data regarding sizes of
> transfers which have occurred in the past 12 - 18 months?
>
> --
> Dani Roisman
>
> 
> From: "Bill Buhler" <b...@tknow.com<mailto:b...@tknow.com>>
> To: "owen" <o...@delong.com<mailto:o...@delong.com>>
> Cc: arin-ppml@arin.net<mailto:arin-ppml@arin.net>
> Sent: Monday, September 28, 2015 12:59:30 PM
> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based
> evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
>
> OK, how about this:
>
> Small end users and ISPs are allowed to obtain IPv4 address blocks without
> a needs test as long as the following criteria are met:
>
>
> a.   The total size of their ARIN allocations at any time of the
> process does not exceed a /20 if a ISP or /22 for an end user.
>
> b.  They cannot purchase IP address from the transfer market more than
> three total times to reach this size, including the initial operation.
>
> c.   None of the addresses purchased can be transferred to any other
> entity for twenty-four months following the date of the last transfer.
>
> d.  If the company ceases operations within the twenty-four month
> window the addresses are automatically transferred to the ARIN free pool.
> After that period of time regular transfer rights exist.
>
> e.  All subsequent allocations / transfers require regular needs
> testing after the initial twenty-four month allocation window.
>
> f.Eligible entities for this policy consist of ISPs and End users
> who have a unique physical address in the ARIN region at the suite level.
> Meaning if two companies share the same suite they are not eligible to both
> have ARIN allocations.
>
> ---
>
> I believe that meets all of your concerns. I would prefer companies get
> everything they think they will need in one operation, but I don?t want to
> have fear drive them into buying the max amount just in case.
>
> Best regards,
>
> Bill Buhler
>
> ___
> PPML
> You are receiving this message because you are subscribed to
> the ARIN Public Policy Mailing Lis

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[John Curran]

On Sep 30, 2015, at 12:40 PM, Dani Roisman 
> wrote:

That’s just billing buckets then, not really based on actual transfer activity. 
 Maybe it will help to look at more relevant data?

ARIN staff watching - could you point me to any published statistics for 
transfers over the past 18 months, or if not could you generate them and share? 
 I’m thinking this is a good start:

1)  Number of transfers requests for each block size for 8.3 and 8.4 
transfers which completed.  e.g. “/20 = qty 15, /19 = qty 5, /18 = qty 10”

The list of transfers completed is available online here -


2)  Number of transfers requests for each block size for 8.3 and 8.4 
transfers which were closed without completion, specifically where need was not 
met

This may not be possible, but we will see what statistics are available
regarding transfers not completed (the reason that “specifically where
need not met” may not be meaningful is because such requests often
close due to prolonged lack of response while awaiting documentation
or because they’re closed by the original requester but not otherwise
distinguished, etc.)

/John

John Curran
President and CEO
ARIN



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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[John Curran]

On Sep 30, 2015, at 1:15 PM, John Curran 
> wrote:

On Sep 30, 2015, at 12:40 PM, Dani Roisman 
> wrote:

That’s just billing buckets then, not really based on actual transfer activity. 
 Maybe it will help to look at more relevant data?

ARIN staff watching - could you point me to any published statistics for 
transfers over the past 18 months, or if not could you generate them and share? 
 I’m thinking this is a good start:

1)  Number of transfers requests for each block size for 8.3 and 8.4 
transfers which completed.  e.g. “/20 = qty 15, /19 = qty 5, /18 = qty 10”

The list of transfers completed is available online here -


2)  Number of transfers requests for each block size for 8.3 and 8.4 
transfers which were closed without completion, specifically where need was not 
met

This may not be possible, but we will see what statistics are available
regarding transfers not completed (the reason that “specifically where
need not met” may not be meaningful is because such requests often
close due to prolonged lack of response while awaiting documentation
or because they’re closed by the original requester but not otherwise
distinguished, etc.)

Unfortunately, we do not have any readily-available way to correlate the
not-completed tickets with intended block size.  We do have overall
transfer ticket closure statistics available.

8.3 / 8.2 Ticket statistics to date -

153  8.3 tickets closed
106  completed (69%)
  37  withdrawn (24%)
4  duplicate (3%)
3  abandoned (2%)
3  closed for another reason (2%)

   82 8.2 tickets closed
   68 completed (83%)
   12 withdrawn (15%)
 1 duplicate (1%)
 1 other (1%)

If one presumes that demonstration of need is a more significant concern
for 8.3 transfers (generalization, but plausible) _and_ that there was no
other significant factor (lots of hand-waving at this point), then there is a
9% withdrawal rate (and potentially 2% abandoned rate)  that one might
bravely attribute to the consequences of needs-assessment.

/John

John Curran
President and CEO
ARIN

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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Bill Buhler]

Dani,

Do you have a particular reason to want to dive into the stats? I looked at 
them but see no way to easily separate the requests between those that would 
qualify for this (those that have a no or a very small IP allocation), and 
those of larger entities. I did run out the transfers and found the following:

Size

Transfers

% Overall

% <=

/10

1

0.72%

100%

/11

3

2.17%

99.28%

/12

5

3.62%

97.10%

/13

2

1.45%

93.48%

/14

7

5.07%

92.03%

/15

7

5.07%

86.96%

/16

15

10.87%

81.88%

/17

6

4.35%

71.01%

/18

8

5.80%

66.67%

/19

11

7.97%

60.87%

/20

16

11.59%

52.90%

/21

9

6.52%

41.30%

/22

14

10.14%

34.78%

/23

12

8.70%

24.64%

/24

21

15.22%

15.94%

/25

1

0.72%

0.72%


Average block size: 19.20
Median block size: 20
Standard Deviation: 3.792

So we can see that /24 is the most popular allocation size, and ~ 50% of all 
transfer activity is for a /20 or smaller block. What I can't see without a lot 
of WHOIS work, is what the size of the entities are that transferred the 
smaller blocks. I suspect even if they had been subject to this policy change a 
large majority would still fall under the needs test provisions.

Best regards,

Bill Buhler

From: Dani Roisman [mailto:drois...@softlayer.com]
Sent: Wednesday, September 30, 2015 10:40 AM
To: Bill Buhler; arin-ppml@arin.net
Subject: RE: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

That's just billing buckets then, not really based on actual transfer activity. 
 Maybe it will help to look at more relevant data?

ARIN staff watching - could you point me to any published statistics for 
transfers over the past 18 months, or if not could you generate them and share? 
 I'm thinking this is a good start:


1)  Number of transfers requests for each block size for 8.3 and 8.4 
transfers which completed.  e.g. "/20 = qty 15, /19 = qty 5, /18 = qty 10"

2)  Number of transfers requests for each block size for 8.3 and 8.4 
transfers which were closed without completion, specifically where need was not 
met

I'm only asking for 8.3 and 8.4 because 8.2 doesn't have the same type of needs 
demonstration burden (only as usage demonstration).

Thanks.


Dani Roisman

From: Bill Buhler [mailto:b...@tknow.com]
Sent: Wednesday, September 30, 2015 09:35
To: Dani Roisman <drois...@softlayer.com<mailto:drois...@softlayer.com>>; 
arin-ppml@arin.net<mailto:arin-ppml@arin.net>
Subject: RE: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

Based on the ARIN fee table of ISP classification:

/20 is the max allocation size of a X-Small ISP

/22 is the max allocation size of a XX-Small End User.

So there is a slight bias towards small ISPs, but they are in less of a 
position to leverage NAT.

Thanks,

Bill Buhler

From: Dani Roisman [mailto:drois...@softlayer.com]
Sent: Wednesday, September 30, 2015 4:52 AM
To: arin-ppml@arin.net<mailto:arin-ppml@arin.net>; Bill Buhler
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks


Hi Bill,



I'm interested to learn how you came up with the below proposed netblock sizes 
"/20 if a ISP or /22 for an end user" ?  Is there data behind that?  If not, 
does it make sense to ask ARIN to supply data regarding sizes of transfers 
which have occurred in the past 12 - 18 months?



--

Dani Roisman





From: "Bill Buhler" 
<b...@tknow.com<mailto:b...@tknow.com<mailto:b...@tknow.com%3cmailto:b...@tknow.com>>>

To: "owen" 
<o...@delong.com<mailto:o...@delong.com<mailto:o...@delong.com%3cmailto:o...@delong.com>>>

Cc: 
arin-ppml@arin.net<mailto:arin-ppml@arin.net<mailto:arin-ppml@arin.net%3cmailto:arin-ppml@arin.net>>

Sent: Monday, September 28, 2015 12:59:30 PM

Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks



OK, how about this:



Small end users and ISPs are allowed to obtain IPv4 address blocks without a 
needs test as long as the following criteria are met:





a.   The total size of their ARIN allocations at any time of the process 
does not exceed a /20 if a ISP or /22 for an end user.



b.  They cannot purchase IP address from the transfer market more than 
three total times to reach this size, including the initial operation.



c.   None of the addresses purchased can be transferred to any other entity 
for twenty-four months following the date of the last transfer.



d.  If the company ceases operations within the twenty-four month window 
the addresses are automatically transferred to the ARIN free pool. After that 
period of time regular transfer rights ex

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Richard J. Letts]

Where did the 9% come from? Should that not be 24%?

Either way, if we were talking about houses then many of us realize that if the 
number of bidders on property who had the cash (but not the need) were 10 or 
25% larger, then you might expect the value of the property to be higher. The 
same is true with any inelastic good. I have no idea what the price elasticity 
of IP address space is, but I’m going to suggest that it’s very inelastic given 
the lack of alternatives (IPv6 is an alternative, but it has other costs 
associated with it)

I have not seen an argument that this policy will not increase the price of 
IPv4 addresses for people who have needs, and I can’t see that is a good thing.

Richard Letts


From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On Behalf 
Of John Curran
Sent: 30 September 2015 12:29 PM
To: Dani Roisman <drois...@softlayer.com>
Cc: arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

On Sep 30, 2015, at 1:15 PM, John Curran 
<jcur...@arin.net<mailto:jcur...@arin.net>> wrote:

Unfortunately, we do not have any readily-available way to correlate the
not-completed tickets with intended block size.  We do have overall
transfer ticket closure statistics available.

8.3 / 8.2 Ticket statistics to date -

153  8.3 tickets closed
106  completed (69%)
  37  withdrawn (24%)
4  duplicate (3%)
3  abandoned (2%)
3  closed for another reason (2%)

   82 8.2 tickets closed
   68 completed (83%)
   12 withdrawn (15%)
 1 duplicate (1%)
 1 other (1%)

If one presumes that demonstration of need is a more significant concern
for 8.3 transfers (generalization, but plausible) _and_ that there was no
other significant factor (lots of hand-waving at this point), then there is a
9% withdrawal rate (and potentially 2% abandoned rate)  that one might
bravely attribute to the consequences of needs-assessment.

/John

John Curran
President and CEO
ARIN

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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Dani Roisman]

Hi Bill,



I'm interested to learn how you came up with the below proposed netblock sizes 
"/20 if a ISP or /22 for an end user" ?  Is there data behind that?  If not, 
does it make sense to ask ARIN to supply data regarding sizes of transfers 
which have occurred in the past 12 - 18 months?



--

Dani Roisman





From: "Bill Buhler" 
<b...@tknow.com<mailto:b...@tknow.com<mailto:b...@tknow.com%3cmailto:b...@tknow.com>>>

To: "owen" 
<o...@delong.com<mailto:o...@delong.com<mailto:o...@delong.com%3cmailto:o...@delong.com>>>

Cc: 
arin-ppml@arin.net<mailto:arin-ppml@arin.net<mailto:arin-ppml@arin.net%3cmailto:arin-ppml@arin.net>>

Sent: Monday, September 28, 2015 12:59:30 PM

Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks



OK, how about this:



Small end users and ISPs are allowed to obtain IPv4 address blocks without a 
needs test as long as the following criteria are met:





a.   The total size of their ARIN allocations at any time of the process 
does not exceed a /20 if a ISP or /22 for an end user.



b.  They cannot purchase IP address from the transfer market more than 
three total times to reach this size, including the initial operation.



c.   None of the addresses purchased can be transferred to any other entity 
for twenty-four months following the date of the last transfer.



d.  If the company ceases operations within the twenty-four month window 
the addresses are automatically transferred to the ARIN free pool. After that 
period of time regular transfer rights exist.



e.  All subsequent allocations / transfers require regular needs testing 
after the initial twenty-four month allocation window.



f.Eligible entities for this policy consist of ISPs and End users who 
have a unique physical address in the ARIN region at the suite level. Meaning 
if two companies share the same suite they are not eligible to both have ARIN 
allocations.



---



I believe that meets all of your concerns. I would prefer companies get 
everything they think they will need in one operation, but I don?t want to have 
fear drive them into buying the max amount just in case.



Best regards,



Bill Buhler

___
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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Owen DeLong]

Dani,

In fairness to Bill, I think he may also have chosen them because I suggested 
that those would be boundaries I would consider livable.

I believe they represent a good size to guarantee that small organizations are 
not shut out of the transfer market based on size, but still ensure that need 
assessment is preserved in order to prevent acquisition of addresses without 
intended use thereof.

While a /20 is a fair quantity of addresses (4096), it’s a pretty small number 
of customers for an ISP in most cases and I think anything smaller would be 
somewhat punitive.

It does also line up well with transfer history and other ARIN data about 
small-ish organizations and address issuance over the last several years.

Owen

> On Sep 30, 2015, at 03:52 , Dani Roisman <drois...@softlayer.com> wrote:
> 
> Hi Bill,
>  
> I’m interested to learn how you came up with the below proposed netblock 
> sizes “/20 if a ISP or /22 for an end user” ?  Is there data behind that?  If 
> not, does it make sense to ask ARIN to supply data regarding sizes of 
> transfers which have occurred in the past 12 - 18 months?
>  
> --
> Dani Roisman
>  
> 
> From: "Bill Buhler" <b...@tknow.com<mailto:b...@tknow.com 
> <mailto:b...@tknow.com%3cmailto:b...@tknow.com>>>
> To: "owen" <o...@delong.com<mailto:o...@delong.com 
> <mailto:o...@delong.com%3cmailto:o...@delong.com>>>
> Cc: arin-ppml@arin.net<mailto:arin-ppml@arin.net 
> <mailto:arin-ppml@arin.net%3cmailto:arin-ppml@arin.net>>
> Sent: Monday, September 28, 2015 12:59:30 PM
> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
> evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
>  
> OK, how about this:
>  
> Small end users and ISPs are allowed to obtain IPv4 address blocks without a 
> needs test as long as the following criteria are met:
>  
>  
> a.   The total size of their ARIN allocations at any time of the process 
> does not exceed a /20 if a ISP or /22 for an end user.
>  
> b.  They cannot purchase IP address from the transfer market more than 
> three total times to reach this size, including the initial operation.
>  
> c.   None of the addresses purchased can be transferred to any other 
> entity for twenty-four months following the date of the last transfer.
>  
> d.  If the company ceases operations within the twenty-four month window 
> the addresses are automatically transferred to the ARIN free pool. After that 
> period of time regular transfer rights exist.
>  
> e.  All subsequent allocations / transfers require regular needs testing 
> after the initial twenty-four month allocation window.
>  
> f.Eligible entities for this policy consist of ISPs and End users who 
> have a unique physical address in the ARIN region at the suite level. Meaning 
> if two companies share the same suite they are not eligible to both have ARIN 
> allocations.
>  
> ---
>  
> I believe that meets all of your concerns. I would prefer companies get 
> everything they think they will need in one operation, but I don?t want to 
> have fear drive them into buying the max amount just in case.
>  
> Best regards,
>  
> Bill Buhler
>  
> ___
> PPML
> You are receiving this message because you are subscribed to
> the ARIN Public Policy Mailing List (ARIN-PPML@arin.net 
> <mailto:ARIN-PPML@arin.net>).
> Unsubscribe or manage your mailing list subscription at:
> http://lists.arin.net/mailman/listinfo/arin-ppml 
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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Bill Buhler]

Based on the ARIN fee table of ISP classification:

/20 is the max allocation size of a X-Small ISP

/22 is the max allocation size of a XX-Small End User.

So there is a slight bias towards small ISPs, but they are in less of a 
position to leverage NAT.

Thanks,

Bill Buhler

From: Dani Roisman [mailto:drois...@softlayer.com]
Sent: Wednesday, September 30, 2015 4:52 AM
To: arin-ppml@arin.net; Bill Buhler
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks


Hi Bill,



I'm interested to learn how you came up with the below proposed netblock sizes 
"/20 if a ISP or /22 for an end user" ?  Is there data behind that?  If not, 
does it make sense to ask ARIN to supply data regarding sizes of transfers 
which have occurred in the past 12 - 18 months?



--

Dani Roisman





From: "Bill Buhler" 
<b...@tknow.com<mailto:b...@tknow.com<mailto:b...@tknow.com%3cmailto:b...@tknow.com>>>

To: "owen" 
<o...@delong.com<mailto:o...@delong.com<mailto:o...@delong.com%3cmailto:o...@delong.com>>>

Cc: 
arin-ppml@arin.net<mailto:arin-ppml@arin.net<mailto:arin-ppml@arin.net%3cmailto:arin-ppml@arin.net>>

Sent: Monday, September 28, 2015 12:59:30 PM

Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks



OK, how about this:



Small end users and ISPs are allowed to obtain IPv4 address blocks without a 
needs test as long as the following criteria are met:





a.   The total size of their ARIN allocations at any time of the process 
does not exceed a /20 if a ISP or /22 for an end user.



b.  They cannot purchase IP address from the transfer market more than 
three total times to reach this size, including the initial operation.



c.   None of the addresses purchased can be transferred to any other entity 
for twenty-four months following the date of the last transfer.



d.  If the company ceases operations within the twenty-four month window 
the addresses are automatically transferred to the ARIN free pool. After that 
period of time regular transfer rights exist.



e.  All subsequent allocations / transfers require regular needs testing 
after the initial twenty-four month allocation window.



f.Eligible entities for this policy consist of ISPs and End users who 
have a unique physical address in the ARIN region at the suite level. Meaning 
if two companies share the same suite they are not eligible to both have ARIN 
allocations.



---



I believe that meets all of your concerns. I would prefer companies get 
everything they think they will need in one operation, but I don?t want to have 
fear drive them into buying the max amount just in case.



Best regards,



Bill Buhler

___
PPML
You are receiving this message because you are subscribed to
the ARIN Public Policy Mailing List (ARIN-PPML@arin.net).
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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Dani Roisman]

That's just billing buckets then, not really based on actual transfer activity. 
 Maybe it will help to look at more relevant data?

ARIN staff watching - could you point me to any published statistics for 
transfers over the past 18 months, or if not could you generate them and share? 
 I'm thinking this is a good start:


1)  Number of transfers requests for each block size for 8.3 and 8.4 
transfers which completed.  e.g. "/20 = qty 15, /19 = qty 5, /18 = qty 10"

2)  Number of transfers requests for each block size for 8.3 and 8.4 
transfers which were closed without completion, specifically where need was not 
met

I'm only asking for 8.3 and 8.4 because 8.2 doesn't have the same type of needs 
demonstration burden (only as usage demonstration).

Thanks.


Dani Roisman

From: Bill Buhler [mailto:b...@tknow.com]
Sent: Wednesday, September 30, 2015 09:35
To: Dani Roisman <drois...@softlayer.com>; arin-ppml@arin.net
Subject: RE: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

Based on the ARIN fee table of ISP classification:

/20 is the max allocation size of a X-Small ISP

/22 is the max allocation size of a XX-Small End User.

So there is a slight bias towards small ISPs, but they are in less of a 
position to leverage NAT.

Thanks,

Bill Buhler

From: Dani Roisman [mailto:drois...@softlayer.com]
Sent: Wednesday, September 30, 2015 4:52 AM
To: arin-ppml@arin.net<mailto:arin-ppml@arin.net>; Bill Buhler
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks


Hi Bill,



I'm interested to learn how you came up with the below proposed netblock sizes 
"/20 if a ISP or /22 for an end user" ?  Is there data behind that?  If not, 
does it make sense to ask ARIN to supply data regarding sizes of transfers 
which have occurred in the past 12 - 18 months?



--

Dani Roisman





From: "Bill Buhler" 
<b...@tknow.com<mailto:b...@tknow.com<mailto:b...@tknow.com%3cmailto:b...@tknow.com>>>

To: "owen" 
<o...@delong.com<mailto:o...@delong.com<mailto:o...@delong.com%3cmailto:o...@delong.com>>>

Cc: 
arin-ppml@arin.net<mailto:arin-ppml@arin.net<mailto:arin-ppml@arin.net%3cmailto:arin-ppml@arin.net>>

Sent: Monday, September 28, 2015 12:59:30 PM

Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks



OK, how about this:



Small end users and ISPs are allowed to obtain IPv4 address blocks without a 
needs test as long as the following criteria are met:





a.   The total size of their ARIN allocations at any time of the process 
does not exceed a /20 if a ISP or /22 for an end user.



b.  They cannot purchase IP address from the transfer market more than 
three total times to reach this size, including the initial operation.



c.   None of the addresses purchased can be transferred to any other entity 
for twenty-four months following the date of the last transfer.



d.  If the company ceases operations within the twenty-four month window 
the addresses are automatically transferred to the ARIN free pool. After that 
period of time regular transfer rights exist.



e.  All subsequent allocations / transfers require regular needs testing 
after the initial twenty-four month allocation window.



f.Eligible entities for this policy consist of ISPs and End users who 
have a unique physical address in the ARIN region at the suite level. Meaning 
if two companies share the same suite they are not eligible to both have ARIN 
allocations.



---



I believe that meets all of your concerns. I would prefer companies get 
everything they think they will need in one operation, but I don?t want to have 
fear drive them into buying the max amount just in case.



Best regards,



Bill Buhler

___
PPML
You are receiving this message because you are subscribed to
the ARIN Public Policy Mailing List (ARIN-PPML@arin.net).
Unsubscribe or manage your mailing list subscription at:
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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Bill Buhler]

I wanted to allow some growth before needs analysis became necessary (but 
prevent way overestimating need), but prevent the customer from getting a /24 
every month as needed and greatly increasing the fragmentation of the routing 
table.

From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On Behalf 
Of Mark Mahle
Sent: Monday, September 28, 2015 7:36 PM
To: arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

Bill,

Great compromise proposal.

Can you clarify your point b)  -- why limit the number of inbound transfers to 
reach n size in a ?

Thanks,
Mark


From: "Bill Buhler" <b...@tknow.com<mailto:b...@tknow.com>>
To: "owen" <o...@delong.com<mailto:o...@delong.com>>
Cc: arin-ppml@arin.net<mailto:arin-ppml@arin.net>
Sent: Monday, September 28, 2015 12:59:30 PM
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

OK, how about this:

Small end users and ISPs are allowed to obtain IPv4 address blocks without a 
needs test as long as the following criteria are met:


a.   The total size of their ARIN allocations at any time of the process 
does not exceed a /20 if a ISP or /22 for an end user.

b.  They cannot purchase IP address from the transfer market more than 
three total times to reach this size, including the initial operation.

c.   None of the addresses purchased can be transferred to any other entity 
for twenty-four months following the date of the last transfer.

d.  If the company ceases operations within the twenty-four month window 
the addresses are automatically transferred to the ARIN free pool. After that 
period of time regular transfer rights exist.

e.  All subsequent allocations / transfers require regular needs testing 
after the initial twenty-four month allocation window.

f.Eligible entities for this policy consist of ISPs and End users who 
have a unique physical address in the ARIN region at the suite level. Meaning 
if two companies share the same suite they are not eligible to both have ARIN 
allocations.


---

I believe that meets all of your concerns. I would prefer companies get 
everything they think they will need in one operation, but I don’t want to have 
fear drive them into buying the max amount just in case.

Best regards,

Bill Buhler

From: Owen DeLong [mailto:o...@delong.com]
Sent: Monday, September 28, 2015 1:09 PM
To: Bill Buhler
Cc: Adam Thompson; arin-ppml@arin.net<mailto:arin-ppml@arin.net>
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks


On Sep 28, 2015, at 11:50 , Bill Buhler <b...@tknow.com<mailto:b...@tknow.com>> 
wrote:

Thanks Owen for your thoughts, it sounds to me like we are getting a lot closer 
to a compromise, would this be a sufficient circuit breaker:

Small end users and ISPs are allowed initial and follow up transfers up to a 
/20 for ISPs or /22 for end users from the market. These transfers can be 
conducted in no more than three operations over a 24 month period. None of the 
transferred addresses can be transferred to another entity for twenty-four 
months following the date of the last transfer. If the company ceases 
operations within that twenty-four month window the addresses automatically 
become property of ARIN and are placed in the free pool. After that period of 
time regular transfer rights exist.

Property is a loaded term in this context.

I would be OK with the proposal, but we would need to change “automatically 
become property of...” to “are automatically returned to the ARIN free pool”.

Also, you’re still allowing “follow up” transfers without needs testing. So 
there’s ambiguity as to whether you mean follow-ups up to a total holding of 
(/20,/22) or if you mean there’s a new (/20,/22) followup cycle each 24 months.

The former would be acceptable to me. The latter would not.


All subsequent allocations / transfers require regular needs testing.

Eligible entities for this policy consist of ISPs and End users who have a 
unique physical address in the ARIN region at the suite level. Meaning if two 
companies share the same suite they are not eligible to both have ARIN 
allocations.


My reasoning of allowing follow up transfers is within the first two years, but 
not allowing transfers out for twenty-four months from the last transfer is it 
encourages companies to go for a small initial allocation rather than buying 
their max possible size initially knowing that they next time they will need to 
go through needs testing.

I don’t see any reason to worry about this in the transfer market. We allow for 
a 24 month need, so there’s no overall advantage IMHO

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Owen DeLong]

> On Sep 28, 2015, at 11:50 , Bill Buhler <b...@tknow.com> wrote:
> 
> Thanks Owen for your thoughts, it sounds to me like we are getting a lot 
> closer to a compromise, would this be a sufficient circuit breaker:
>  
> Small end users and ISPs are allowed initial and follow up transfers up to a 
> /20 for ISPs or /22 for end users from the market. These transfers can be 
> conducted in no more than three operations over a 24 month period. None of 
> the transferred addresses can be transferred to another entity for 
> twenty-four months following the date of the last transfer. If the company 
> ceases operations within that twenty-four month window the addresses 
> automatically become property of ARIN and are placed in the free pool. After 
> that period of time regular transfer rights exist.

Property is a loaded term in this context.

I would be OK with the proposal, but we would need to change “automatically 
become property of...” to “are automatically returned to the ARIN free pool”.

Also, you’re still allowing “follow up” transfers without needs testing. So 
there’s ambiguity as to whether you mean follow-ups up to a total holding of 
(/20,/22) or if you mean there’s a new (/20,/22) followup cycle each 24 months.

The former would be acceptable to me. The latter would not.


> All subsequent allocations / transfers require regular needs testing.
>  
> Eligible entities for this policy consist of ISPs and End users who have a 
> unique physical address in the ARIN region at the suite level. Meaning if two 
> companies share the same suite they are not eligible to both have ARIN 
> allocations.

>  
> My reasoning of allowing follow up transfers is within the first two years, 
> but not allowing transfers out for twenty-four months from the last transfer 
> is it encourages companies to go for a small initial allocation rather than 
> buying their max possible size initially knowing that they next time they 
> will need to go through needs testing.

I don’t see any reason to worry about this in the transfer market. We allow for 
a 24 month need, so there’s no overall advantage IMHO to facilitating a smaller 
initial transfer and allowing subsequent transfers without need, but if people 
feel this is useful, I can live with it. Personally, I think it just encourages 
fragmentation of the routing table without providing a tangible benefit.

Owen

>  
> Any thoughts?
>  
> Bill Buhler
>  
> From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On 
> Behalf Of Owen DeLong
> Sent: Monday, September 28, 2015 11:11 AM
> To: Adam Thompson
> Cc: arin-ppml@arin.net
> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
> evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
>  
> I’m not going to support anything that provides a blanket exemption from 
> needs basis.
>  
> I will support a change which allows an initial 
> allocation/assignment/transfer of a minimal block of addresses (up to a /22 
> for an end-user or up to a /20 for an ISP seems reasonable to me) so long as 
> it also includes anti-flip protections and some language preventing spinning 
> up related party entities strictly for address acquisition.
>  
> I believe this would address most of the concerns expressed (other than those 
> seeking to eliminate needs basis altogether).
>  
> Owen
>  
> On Sep 26, 2015, at 19:48 , Adam Thompson <athom...@athompso.net 
> <mailto:athom...@athompso.net>> wrote:
>  
> At this point, I support anything that looks like a compromise so we can get 
> *any* change in policy at all... So this looks like a decent compromise to 
> me. Yes, it'll have to be revisited in a couple of years' time; yes, the 
> specifics probably aren't perfect. The community can change those. The policy 
> can even be written such that ARIN staff can change them independently 
> (although this doesn't seem to be a popular model).
> Insisting on perfection is just hamstringing the entire service region... 
> both the speculators *and* legitimate users.
> -Adam
> 
> 
> On September 26, 2015 8:47:46 PM CDT, Brian Jones <bjo...@vt.edu 
> <mailto:bjo...@vt.edu>> wrote:
> I find Bill's proposal an interesting middle ground approach. I do not 
> believe completely eliminating needs-based justification for addresses is the 
> correct thing to do.
> 
> --
> Brian
>  
> On Fri, Sep 25, 2015 at 4:05 PM, Bill Buhler <b...@tknow.com 
> <mailto:b...@tknow.com>> wrote:
> Having watched this for the last couple of years let me make a couple of 
> observations / one proposal:
>  
> There seems to be a lot of fear on both sides of this debate, on the needs 
> test side there seems to be a complete fear of

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Bill Buhler]

OK, how about this:

Small end users and ISPs are allowed to obtain IPv4 address blocks without a 
needs test as long as the following criteria are met:


a.   The total size of their ARIN allocations at any time of the process 
does not exceed a /20 if a ISP or /22 for an end user.

b.  They cannot purchase IP address from the transfer market more than 
three total times to reach this size, including the initial operation.

c.   None of the addresses purchased can be transferred to any other entity 
for twenty-four months following the date of the last transfer.

d.  If the company ceases operations within the twenty-four month window 
the addresses are automatically transferred to the ARIN free pool. After that 
period of time regular transfer rights exist.

e.  All subsequent allocations / transfers require regular needs testing 
after the initial twenty-four month allocation window.

f.Eligible entities for this policy consist of ISPs and End users who 
have a unique physical address in the ARIN region at the suite level. Meaning 
if two companies share the same suite they are not eligible to both have ARIN 
allocations.


---

I believe that meets all of your concerns. I would prefer companies get 
everything they think they will need in one operation, but I don’t want to have 
fear drive them into buying the max amount just in case.

Best regards,

Bill Buhler

From: Owen DeLong [mailto:o...@delong.com]
Sent: Monday, September 28, 2015 1:09 PM
To: Bill Buhler
Cc: Adam Thompson; arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks


On Sep 28, 2015, at 11:50 , Bill Buhler <b...@tknow.com<mailto:b...@tknow.com>> 
wrote:

Thanks Owen for your thoughts, it sounds to me like we are getting a lot closer 
to a compromise, would this be a sufficient circuit breaker:

Small end users and ISPs are allowed initial and follow up transfers up to a 
/20 for ISPs or /22 for end users from the market. These transfers can be 
conducted in no more than three operations over a 24 month period. None of the 
transferred addresses can be transferred to another entity for twenty-four 
months following the date of the last transfer. If the company ceases 
operations within that twenty-four month window the addresses automatically 
become property of ARIN and are placed in the free pool. After that period of 
time regular transfer rights exist.

Property is a loaded term in this context.

I would be OK with the proposal, but we would need to change “automatically 
become property of...” to “are automatically returned to the ARIN free pool”.

Also, you’re still allowing “follow up” transfers without needs testing. So 
there’s ambiguity as to whether you mean follow-ups up to a total holding of 
(/20,/22) or if you mean there’s a new (/20,/22) followup cycle each 24 months.

The former would be acceptable to me. The latter would not.



All subsequent allocations / transfers require regular needs testing.

Eligible entities for this policy consist of ISPs and End users who have a 
unique physical address in the ARIN region at the suite level. Meaning if two 
companies share the same suite they are not eligible to both have ARIN 
allocations.


My reasoning of allowing follow up transfers is within the first two years, but 
not allowing transfers out for twenty-four months from the last transfer is it 
encourages companies to go for a small initial allocation rather than buying 
their max possible size initially knowing that they next time they will need to 
go through needs testing.

I don’t see any reason to worry about this in the transfer market. We allow for 
a 24 month need, so there’s no overall advantage IMHO to facilitating a smaller 
initial transfer and allowing subsequent transfers without need, but if people 
feel this is useful, I can live with it. Personally, I think it just encourages 
fragmentation of the routing table without providing a tangible benefit.

Owen



Any thoughts?

Bill Buhler

From: arin-ppml-boun...@arin.net<mailto:arin-ppml-boun...@arin.net> 
[mailto:arin-ppml-boun...@arin.net] On Behalf Of Owen DeLong
Sent: Monday, September 28, 2015 11:11 AM
To: Adam Thompson
Cc: arin-ppml@arin.net<mailto:arin-ppml@arin.net>
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

I’m not going to support anything that provides a blanket exemption from needs 
basis.

I will support a change which allows an initial allocation/assignment/transfer 
of a minimal block of addresses (up to a /22 for an end-user or up to a /20 for 
an ISP seems reasonable to me) so long as it also includes anti-flip 
protections and some language preventing spinning up related party entities 
strictly for address acquisition.

I believe this would address most o

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Owen DeLong]

I’m not going to support anything that provides a blanket exemption from needs 
basis.

I will support a change which allows an initial allocation/assignment/transfer 
of a minimal block of addresses (up to a /22 for an end-user or up to a /20 for 
an ISP seems reasonable to me) so long as it also includes anti-flip 
protections and some language preventing spinning up related party entities 
strictly for address acquisition.

I believe this would address most of the concerns expressed (other than those 
seeking to eliminate needs basis altogether).

Owen

> On Sep 26, 2015, at 19:48 , Adam Thompson <athom...@athompso.net> wrote:
> 
> At this point, I support anything that looks like a compromise so we can get 
> *any* change in policy at all... So this looks like a decent compromise to 
> me. Yes, it'll have to be revisited in a couple of years' time; yes, the 
> specifics probably aren't perfect. The community can change those. The policy 
> can even be written such that ARIN staff can change them independently 
> (although this doesn't seem to be a popular model).
> Insisting on perfection is just hamstringing the entire service region... 
> both the speculators *and* legitimate users.
> -Adam
> 
> 
> On September 26, 2015 8:47:46 PM CDT, Brian Jones <bjo...@vt.edu> wrote:
> I find Bill's proposal an interesting middle ground approach. I do not 
> believe completely eliminating needs-based justification for addresses is the 
> correct thing to do.
> 
> --
> Brian
> 
> On Fri, Sep 25, 2015 at 4:05 PM, Bill Buhler <b...@tknow.com 
> <mailto:b...@tknow.com>> wrote:
> Having watched this for the last couple of years let me make a couple of 
> observations / one proposal:
> 
>  
> 
> There seems to be a lot of fear on both sides of this debate, on the needs 
> test side there seems to be a complete fear of monopolization of the IP 
> address space by those with deep pockets.
> 
>  
> 
> On the other side there seem to be a couple of thoughts:
> 
>  
> 
> 1.   It’s a market, markets work best when freed from constraints that 
> increase the complexity of non-harmful transactions, and that allowing 
> companies to more freely exchange IP resources is not harmful.
> 
> 2.Not liking to justify future and current operations to a third 
> party / fear of rejection by this process.
> 
>  
> 
> I may not have encapsulated both arguments well, and these have been hashed 
> over again and again for the last few years. So what is different today? ARIN 
> has allocated every last resource from the free pool, and has a long waiting 
> list.
> 
>  
> 
> So what if we strike a compromise? What if some restrictions were put on 
> allocation size and frequency without a needs test and left only the truly 
> large or frequent transactions to do it. Something like this:
> 
>  
> 
> Every legal entity can obtain up to a /22 from the transfer market every 
> year, in up to two transactions. They may not transfer these resources out of 
> their network within twelve months. Each legal entity has to occupy a unique 
> address (suite level) from any other entity in the ARIN database.
> 
>  
> 
> All transfers larger than a /22 need to have needs based justification done 
> based on the current model.
> 
>  
> 
>  
> 
> If you wanted to speculate, you would need to spin-up dozens of entities all 
> with unique mailstops, and you would have to camp on the addresses for a 
> year. Meanwhile the small end users and ISPs could obtain up to a /22 of a 
> resource that with a lot of careful use of NAT would support a fairly large 
> public network.
> 
>  
> 
> Best regards,
> 
>  
> 
> Bill Buhler
> 
>  
> 
> From: arin-ppml-boun...@arin.net <mailto:arin-ppml-boun...@arin.net> 
> [mailto:arin-ppml-boun...@arin.net <mailto:arin-ppml-boun...@arin.net>] On 
> Behalf Of Steven Ryerse
> Sent: Friday, September 25, 2015 11:48 AM
> To: Owen DeLong
> 
> 
> Cc: arin-ppml@arin.net <mailto:arin-ppml@arin.net>
> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
> evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
> 
>  
> 
> Owens comment from below:
> 
> “2. To the extent that there is supply, anyone who needs addresses can get 
> them already. Needs-based evaluation does not prevent those with need from 
> getting addresses… It prevents those without need from getting them.”
> 
>  
> 
> Owen’s comment is absolutely false!  It allows large organizing who 
> request resources to get what they need or something smaller.  It allows 
> medium size organizations who request resources to get what they need or 
> s

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Bill Buhler]

Thanks Owen for your thoughts, it sounds to me like we are getting a lot closer 
to a compromise, would this be a sufficient circuit breaker:

Small end users and ISPs are allowed initial and follow up transfers up to a 
/20 for ISPs or /22 for end users from the market. These transfers can be 
conducted in no more than three operations over a 24 month period. None of the 
transferred addresses can be transferred to another entity for twenty-four 
months following the date of the last transfer. If the company ceases 
operations within that twenty-four month window the addresses automatically 
become property of ARIN and are placed in the free pool. After that period of 
time regular transfer rights exist.

All subsequent allocations / transfers require regular needs testing.

Eligible entities for this policy consist of ISPs and End users who have a 
unique physical address in the ARIN region at the suite level. Meaning if two 
companies share the same suite they are not eligible to both have ARIN 
allocations.

My reasoning of allowing follow up transfers is within the first two years, but 
not allowing transfers out for twenty-four months from the last transfer is it 
encourages companies to go for a small initial allocation rather than buying 
their max possible size initially knowing that they next time they will need to 
go through needs testing.

Any thoughts?

Bill Buhler

From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On Behalf 
Of Owen DeLong
Sent: Monday, September 28, 2015 11:11 AM
To: Adam Thompson
Cc: arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

I’m not going to support anything that provides a blanket exemption from needs 
basis.

I will support a change which allows an initial allocation/assignment/transfer 
of a minimal block of addresses (up to a /22 for an end-user or up to a /20 for 
an ISP seems reasonable to me) so long as it also includes anti-flip 
protections and some language preventing spinning up related party entities 
strictly for address acquisition.

I believe this would address most of the concerns expressed (other than those 
seeking to eliminate needs basis altogether).

Owen

On Sep 26, 2015, at 19:48 , Adam Thompson 
<athom...@athompso.net<mailto:athom...@athompso.net>> wrote:

At this point, I support anything that looks like a compromise so we can get 
*any* change in policy at all... So this looks like a decent compromise to me. 
Yes, it'll have to be revisited in a couple of years' time; yes, the specifics 
probably aren't perfect. The community can change those. The policy can even be 
written such that ARIN staff can change them independently (although this 
doesn't seem to be a popular model).
Insisting on perfection is just hamstringing the entire service region... both 
the speculators *and* legitimate users.
-Adam

On September 26, 2015 8:47:46 PM CDT, Brian Jones 
<bjo...@vt.edu<mailto:bjo...@vt.edu>> wrote:
I find Bill's proposal an interesting middle ground approach. I do not believe 
completely eliminating needs-based justification for addresses is the correct 
thing to do.

--
Brian

On Fri, Sep 25, 2015 at 4:05 PM, Bill Buhler 
<b...@tknow.com<mailto:b...@tknow.com>> wrote:
Having watched this for the last couple of years let me make a couple of 
observations / one proposal:

There seems to be a lot of fear on both sides of this debate, on the needs test 
side there seems to be a complete fear of monopolization of the IP address 
space by those with deep pockets.

On the other side there seem to be a couple of thoughts:

1.   It’s a market, markets work best when freed from constraints that 
increase the complexity of non-harmful transactions, and that allowing 
companies to more freely exchange IP resources is not harmful.
2.Not liking to justify future and current operations to a third party 
/ fear of rejection by this process.

I may not have encapsulated both arguments well, and these have been hashed 
over again and again for the last few years. So what is different today? ARIN 
has allocated every last resource from the free pool, and has a long waiting 
list.

So what if we strike a compromise? What if some restrictions were put on 
allocation size and frequency without a needs test and left only the truly 
large or frequent transactions to do it. Something like this:

Every legal entity can obtain up to a /22 from the transfer market every year, 
in up to two transactions. They may not transfer these resources out of their 
network within twelve months. Each legal entity has to occupy a unique address 
(suite level) from any other entity in the ARIN database.

All transfers larger than a /22 need to have needs based justification done 
based on the current model.


If you wanted to speculate, you would need to spin-up dozens of entities all 
with unique m

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Owen DeLong]

I could live with this. Do you need help putting it into a proposal template?

Owen

> On Sep 28, 2015, at 12:59 , Bill Buhler <b...@tknow.com> wrote:
> 
> OK, how about this:
>  
> Small end users and ISPs are allowed to obtain IPv4 address blocks without a 
> needs test as long as the following criteria are met:
>  
> a.   The total size of their ARIN allocations at any time of the process 
> does not exceed a /20 if a ISP or /22 for an end user.
> b.  They cannot purchase IP address from the transfer market more than 
> three total times to reach this size, including the initial operation.
> c.   None of the addresses purchased can be transferred to any other 
> entity for twenty-four months following the date of the last transfer.
> d.  If the company ceases operations within the twenty-four month window 
> the addresses are automatically transferred to the ARIN free pool. After that 
> period of time regular transfer rights exist.
> e.  All subsequent allocations / transfers require regular needs testing 
> after the initial twenty-four month allocation window.
> f.Eligible entities for this policy consist of ISPs and End users who 
> have a unique physical address in the ARIN region at the suite level. Meaning 
> if two companies share the same suite they are not eligible to both have ARIN 
> allocations.
>  
>  
> ---
>  
> I believe that meets all of your concerns. I would prefer companies get 
> everything they think they will need in one operation, but I don’t want to 
> have fear drive them into buying the max amount just in case.
>  
> Best regards,
>  
> Bill Buhler
>  
> From: Owen DeLong [mailto:o...@delong.com] 
> Sent: Monday, September 28, 2015 1:09 PM
> To: Bill Buhler
> Cc: Adam Thompson; arin-ppml@arin.net
> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
> evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
>  
>  
> On Sep 28, 2015, at 11:50 , Bill Buhler <b...@tknow.com 
> <mailto:b...@tknow.com>> wrote:
>  
> Thanks Owen for your thoughts, it sounds to me like we are getting a lot 
> closer to a compromise, would this be a sufficient circuit breaker:
>  
> Small end users and ISPs are allowed initial and follow up transfers up to a 
> /20 for ISPs or /22 for end users from the market. These transfers can be 
> conducted in no more than three operations over a 24 month period. None of 
> the transferred addresses can be transferred to another entity for 
> twenty-four months following the date of the last transfer. If the company 
> ceases operations within that twenty-four month window the addresses 
> automatically become property of ARIN and are placed in the free pool. After 
> that period of time regular transfer rights exist.
>  
> Property is a loaded term in this context.
>  
> I would be OK with the proposal, but we would need to change “automatically 
> become property of...” to “are automatically returned to the ARIN free pool”.
>  
> Also, you’re still allowing “follow up” transfers without needs testing. So 
> there’s ambiguity as to whether you mean follow-ups up to a total holding of 
> (/20,/22) or if you mean there’s a new (/20,/22) followup cycle each 24 
> months.
>  
> The former would be acceptable to me. The latter would not.
>  
> 
> 
> All subsequent allocations / transfers require regular needs testing.
>  
> Eligible entities for this policy consist of ISPs and End users who have a 
> unique physical address in the ARIN region at the suite level. Meaning if two 
> companies share the same suite they are not eligible to both have ARIN 
> allocations.
>  
>  
> My reasoning of allowing follow up transfers is within the first two years, 
> but not allowing transfers out for twenty-four months from the last transfer 
> is it encourages companies to go for a small initial allocation rather than 
> buying their max possible size initially knowing that they next time they 
> will need to go through needs testing.
>  
> I don’t see any reason to worry about this in the transfer market. We allow 
> for a 24 month need, so there’s no overall advantage IMHO to facilitating a 
> smaller initial transfer and allowing subsequent transfers without need, but 
> if people feel this is useful, I can live with it. Personally, I think it 
> just encourages fragmentation of the routing table without providing a 
> tangible benefit.
>  
> Owen
> 
> 
>  
> Any thoughts?
>  
> Bill Buhler
>  
> From: arin-ppml-boun...@arin.net <mailto:arin-ppml-boun...@arin.net> 
> [mailto:arin-ppml-boun...@arin.net <mailto:arin-ppml-boun...@arin.net>] On 
> Behalf Of Ow

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Mark Mahle]

Bill, 

Great compromise proposal. 

Can you clarify your point b) -- why limit the number of inbound transfers to 
reach n size in a ? 

Thanks, 
Mark 


From: "Bill Buhler" <b...@tknow.com> 
To: "owen" <o...@delong.com> 
Cc: arin-ppml@arin.net 
Sent: Monday, September 28, 2015 12:59:30 PM 
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks 



OK, how about this: 



Small end users and ISPs are allowed to obtain IPv4 address blocks without a 
needs test as long as the following criteria are met: 



a. The total size of their ARIN allocations at any time of the process does not 
exceed a /20 if a ISP or /22 for an end user. 

b. They cannot purchase IP address from the transfer market more than three 
total times to reach this size, including the initial operation. 

c. None of the addresses purchased can be transferred to any other entity for 
twenty-four months following the date of the last transfer. 

d. If the company ceases operations within the twenty-four month window the 
addresses are automatically transferred to the ARIN free pool. After that 
period of time regular transfer rights exist. 

e. All subsequent allocations / transfers require regular needs testing after 
the initial twenty-four month allocation window. 

f. Eligible entities for this policy consist of ISPs and End users who have a 
unique physical address in the ARIN region at the suite level. Meaning if two 
companies share the same suite they are not eligible to both have ARIN 
allocations. 





--- 



I believe that meets all of your concerns. I would prefer companies get 
everything they think they will need in one operation, but I don’t want to have 
fear drive them into buying the max amount just in case. 



Best regards, 



Bill Buhler 




From: Owen DeLong [mailto:o...@delong.com] 
Sent: Monday, September 28, 2015 1:09 PM 
To: Bill Buhler 
Cc: Adam Thompson; arin-ppml@arin.net 
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks 










On Sep 28, 2015, at 11:50 , Bill Buhler < b...@tknow.com > wrote: 





Thanks Owen for your thoughts, it sounds to me like we are getting a lot closer 
to a compromise, would this be a sufficient circuit breaker: 





Small end users and ISPs are allowed initial and follow up transfers up to a 
/20 for ISPs or /22 for end users from the market. These transfers can be 
conducted in no more than three operations over a 24 month period. None of the 
transferred addresses can be transferred to another entity for twenty-four 
months following the date of the last transfer. If the company ceases 
operations within that twenty-four month window the addresses automatically 
become property of ARIN and are placed in the free pool. After that period of 
time regular transfer rights exist. 








Property is a loaded term in this context. 





I would be OK with the proposal, but we would need to change “automatically 
become property of...” to “are automatically returned to the ARIN free pool”. 





Also, you’re still allowing “follow up” transfers without needs testing. So 
there’s ambiguity as to whether you mean follow-ups up to a total holding of 
(/20,/22) or if you mean there’s a new (/20,/22) followup cycle each 24 months. 





The former would be acceptable to me. The latter would not. 









All subsequent allocations / transfers require regular needs testing. 





Eligible entities for this policy consist of ISPs and End users who have a 
unique physical address in the ARIN region at the suite level. Meaning if two 
companies share the same suite they are not eligible to both have ARIN 
allocations. 




BQ_BEGIN






My reasoning of allowing follow up transfers is within the first two years, but 
not allowing transfers out for twenty-four months from the last transfer is it 
encourages companies to go for a small initial allocation rather than buying 
their max possible size initially knowing that they next time they will need to 
go through needs testing. 

BQ_END






I don’t see any reason to worry about this in the transfer market. We allow for 
a 24 month need, so there’s no overall advantage IMHO to facilitating a smaller 
initial transfer and allowing subsequent transfers without need, but if people 
feel this is useful, I can live with it. Personally, I think it just encourages 
fragmentation of the routing table without providing a tangible benefit. 





Owen 









Any thoughts? 





Bill Buhler 





From: arin-ppml-boun...@arin.net [ mailto:arin-ppml-boun...@arin.net ] On 
Behalf Of Owen DeLong 
Sent: Monday, September 28, 2015 11:11 AM 
To: Adam Thompson 
Cc: arin-ppml@arin.net 
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Brian Jones]

On Sep 28, 2015 1:11 PM, "Owen DeLong" <o...@delong.com> wrote:
>
> I’m not going to support anything that provides a blanket exemption from
needs basis.
>
> I will support a change which allows an initial
allocation/assignment/transfer of a minimal block of addresses (up to a /22
for an end-user or up to a /20 for an ISP seems reasonable to me) so long
as it also includes anti-flip protections and some language preventing
spinning up related party entities strictly for address acquisition.
>
> I believe this would address most of the concerns expressed (other than
those seeking to eliminate needs basis altogether).
>
> Owen

Thanks for these thoughts Owen. +1 on your points made here.

>
>> On Sep 26, 2015, at 19:48 , Adam Thompson <athom...@athompso.net> wrote:
>>
>> At this point, I support anything that looks like a compromise so we can
get *any* change in policy at all... So this looks like a decent compromise
to me. Yes, it'll have to be revisited in a couple of years' time; yes, the
specifics probably aren't perfect. The community can change those. The
policy can even be written such that ARIN staff can change them
independently (although this doesn't seem to be a popular model).
>> Insisting on perfection is just hamstringing the entire service
region... both the speculators *and* legitimate users.
>> -Adam
>>
>>
>> On September 26, 2015 8:47:46 PM CDT, Brian Jones <bjo...@vt.edu> wrote:
>>>
>>> I find Bill's proposal an interesting middle ground approach. I do not
believe completely eliminating needs-based justification for addresses is
the correct thing to do.
>>>
>>> --
>>> Brian
>>>
>>> On Fri, Sep 25, 2015 at 4:05 PM, Bill Buhler <b...@tknow.com> wrote:
>>>>
>>>> Having watched this for the last couple of years let me make a couple
of observations / one proposal:
>>>>
>>>>
>>>>
>>>> There seems to be a lot of fear on both sides of this debate, on the
needs test side there seems to be a complete fear of monopolization of the
IP address space by those with deep pockets.
>>>>
>>>>
>>>>
>>>> On the other side there seem to be a couple of thoughts:
>>>>
>>>>
>>>>
>>>> 1.   It’s a market, markets work best when freed from constraints
that increase the complexity of non-harmful transactions, and that allowing
companies to more freely exchange IP resources is not harmful.
>>>>
>>>> 2.Not liking to justify future and current operations to a
third party / fear of rejection by this process.
>>>>
>>>>
>>>>
>>>> I may not have encapsulated both arguments well, and these have been
hashed over again and again for the last few years. So what is different
today? ARIN has allocated every last resource from the free pool, and has a
long waiting list.
>>>>
>>>>
>>>>
>>>> So what if we strike a compromise? What if some restrictions were put
on allocation size and frequency without a needs test and left only the
truly large or frequent transactions to do it. Something like this:
>>>>
>>>>
>>>>
>>>> Every legal entity can obtain up to a /22 from the transfer market
every year, in up to two transactions. They may not transfer these
resources out of their network within twelve months. Each legal entity has
to occupy a unique address (suite level) from any other entity in the ARIN
database.
>>>>
>>>>
>>>>
>>>> All transfers larger than a /22 need to have needs based justification
done based on the current model.
>>>>
>>>>
>>>>
>>>>
>>>>
>>>> If you wanted to speculate, you would need to spin-up dozens of
entities all with unique mailstops, and you would have to camp on the
addresses for a year. Meanwhile the small end users and ISPs could obtain
up to a /22 of a resource that with a lot of careful use of NAT would
support a fairly large public network.
>>>>
>>>>
>>>>
>>>> Best regards,
>>>>
>>>>
>>>>
>>>> Bill Buhler
>>>>
>>>>
>>>>
>>>> From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net]
On Behalf Of Steven Ryerse
>>>> Sent: Friday, September 25, 2015 11:48 AM
>>>> To: Owen DeLong
>>>>
>>>>
>>>> Cc: arin-ppml@arin.net
>>>> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating
needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4
netbl

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Bill Buhler]

I would love some help.

From: Owen DeLong [mailto:o...@delong.com]
Sent: Monday, September 28, 2015 3:20 PM
To: Bill Buhler
Cc: Adam Thompson; arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

I could live with this. Do you need help putting it into a proposal template?

Owen

On Sep 28, 2015, at 12:59 , Bill Buhler <b...@tknow.com<mailto:b...@tknow.com>> 
wrote:

OK, how about this:

Small end users and ISPs are allowed to obtain IPv4 address blocks without a 
needs test as long as the following criteria are met:

a.   The total size of their ARIN allocations at any time of the process 
does not exceed a /20 if a ISP or /22 for an end user.
b.  They cannot purchase IP address from the transfer market more than 
three total times to reach this size, including the initial operation.
c.   None of the addresses purchased can be transferred to any other entity 
for twenty-four months following the date of the last transfer.
d.  If the company ceases operations within the twenty-four month window 
the addresses are automatically transferred to the ARIN free pool. After that 
period of time regular transfer rights exist.
e.  All subsequent allocations / transfers require regular needs testing 
after the initial twenty-four month allocation window.
f.Eligible entities for this policy consist of ISPs and End users who 
have a unique physical address in the ARIN region at the suite level. Meaning 
if two companies share the same suite they are not eligible to both have ARIN 
allocations.


---

I believe that meets all of your concerns. I would prefer companies get 
everything they think they will need in one operation, but I don’t want to have 
fear drive them into buying the max amount just in case.

Best regards,

Bill Buhler

From: Owen DeLong [mailto:o...@delong.com]
Sent: Monday, September 28, 2015 1:09 PM
To: Bill Buhler
Cc: Adam Thompson; arin-ppml@arin.net<mailto:arin-ppml@arin.net>
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks


On Sep 28, 2015, at 11:50 , Bill Buhler <b...@tknow.com<mailto:b...@tknow.com>> 
wrote:

Thanks Owen for your thoughts, it sounds to me like we are getting a lot closer 
to a compromise, would this be a sufficient circuit breaker:

Small end users and ISPs are allowed initial and follow up transfers up to a 
/20 for ISPs or /22 for end users from the market. These transfers can be 
conducted in no more than three operations over a 24 month period. None of the 
transferred addresses can be transferred to another entity for twenty-four 
months following the date of the last transfer. If the company ceases 
operations within that twenty-four month window the addresses automatically 
become property of ARIN and are placed in the free pool. After that period of 
time regular transfer rights exist.

Property is a loaded term in this context.

I would be OK with the proposal, but we would need to change “automatically 
become property of...” to “are automatically returned to the ARIN free pool”.

Also, you’re still allowing “follow up” transfers without needs testing. So 
there’s ambiguity as to whether you mean follow-ups up to a total holding of 
(/20,/22) or if you mean there’s a new (/20,/22) followup cycle each 24 months.

The former would be acceptable to me. The latter would not.




All subsequent allocations / transfers require regular needs testing.

Eligible entities for this policy consist of ISPs and End users who have a 
unique physical address in the ARIN region at the suite level. Meaning if two 
companies share the same suite they are not eligible to both have ARIN 
allocations.


My reasoning of allowing follow up transfers is within the first two years, but 
not allowing transfers out for twenty-four months from the last transfer is it 
encourages companies to go for a small initial allocation rather than buying 
their max possible size initially knowing that they next time they will need to 
go through needs testing.

I don’t see any reason to worry about this in the transfer market. We allow for 
a 24 month need, so there’s no overall advantage IMHO to facilitating a smaller 
initial transfer and allowing subsequent transfers without need, but if people 
feel this is useful, I can live with it. Personally, I think it just encourages 
fragmentation of the routing table without providing a tangible benefit.

Owen




Any thoughts?

Bill Buhler

From: arin-ppml-boun...@arin.net<mailto:arin-ppml-boun...@arin.net> 
[mailto:arin-ppml-boun...@arin.net] On Behalf Of Owen DeLong
Sent: Monday, September 28, 2015 11:11 AM
To: Adam Thompson
Cc: arin-ppml@arin.net<mailto:arin-ppml@arin.net>
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for S

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Stephen Sprunk]

On 25-Sep-15 14:33, Steven Ryerse wrote:
> Stephen Sprunk on Friday, September 25, 2015 3:26:
>> On 25-Sep-15 12:48, Steven Ryerse wrote: >>> It is time to fix this inequity 
>> and removing needs tests would be
>>> a big help to small organizations who really need resources! >> >>
If they actually need the resources, then a needs-based policy >> does
not present an obstacle. Where's the problem? >> >> However, not having
such a policy will mean that folks who _don't_ >> need resources can
also get them, which makes the (IPv4) scarcity >> problem even worse
than it already is. That benefits speculators >> at the expense of those
who actually need resources. >> >> You appear to be arguing against your
stated interests. > > It appears to me that you are still trying to
somehow save IPv4 from > exhaustion. That horse is out of the barn and gone.

My comments above merely point out that your justification does not
support your proposed action: if organizations actually need resources,
then a needs-based policy is not an obstacle, so removing such will not
help them and may, in fact, hurt them.

It is certainly possible that current needs-based policy sets the bar
too high, e.g. the minimum block size is too large.  If so, then the
proper action would be improving that policy, e.g. by reducing the
minimum block size, rather than throwing it away entirely.

S

-- 
Stephen Sprunk "God does not play dice."  --Albert Einstein
CCIE #3723 "God is an inveterate gambler, and He throws the
K5SSSdice at every possible opportunity." --Stephen Hawking


smime.p7s
Description: S/MIME Cryptographic Signature
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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Andrew Dul]

On 9/26/2015 12:11 PM, Elvis Daniel Velea wrote:
> Owen,
>
> On 25/09/15 20:24, Owen DeLong wrote:
>> Please provide the metrics on which you base this assertion. How was
>> RIPE-NCC accuracy measured prior to the policy change and to what
>> extent was it improved as a result of this policy change. What
>> mechanism was used to determine that the measured increase in
>> accuracy was the result of the particular policy abandoning
>> needs-based evaluation?
>>
> just have a look at the number of transfers pre-2013-03 and the number
> of transfers after the policy proposal was implemented.
>
> Basically, transfers via the RIPE NCC (recorded in the registry) have
> become the standard for everyone in the RIPE region, financial
> artifices have not been used anymore (as far as I know) once the
> need-based barrier has been removed.
>

Just because there are more transfers, one cannot know for sure that the
data is more accurate.  The number of transfers may be increasing for
other reasons.  It is possible that the data is more accurate, but just
saying "see there are more transfers" does not mean the database is more
accurate.

Andrew


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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Elvis Daniel Velea]

Owen,

On 25/09/15 20:24, Owen DeLong wrote:
Please provide the metrics on which you base this assertion. How was 
RIPE-NCC accuracy measured prior to the policy change and to what 
extent was it improved as a result of this policy change. What 
mechanism was used to determine that the measured increase in accuracy 
was the result of the particular policy abandoning needs-based evaluation?


just have a look at the number of transfers pre-2013-03 and the number 
of transfers after the policy proposal was implemented.


Basically, transfers via the RIPE NCC (recorded in the registry) have 
become the standard for everyone in the RIPE region, financial artifices 
have not been used anymore (as far as I know) once the need-based 
barrier has been removed.


cheers,
elvis
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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Brian Jones]

I find Bill's proposal an interesting middle ground approach. I do not
believe completely eliminating needs-based justification for addresses is
the correct thing to do.

--
Brian

On Fri, Sep 25, 2015 at 4:05 PM, Bill Buhler <b...@tknow.com> wrote:

> Having watched this for the last couple of years let me make a couple of
> observations / one proposal:
>
>
>
> There seems to be a lot of fear on both sides of this debate, on the needs
> test side there seems to be a complete fear of monopolization of the IP
> address space by those with deep pockets.
>
>
>
> On the other side there seem to be a couple of thoughts:
>
>
>
> 1.   It’s a market, markets work best when freed from constraints
> that increase the complexity of non-harmful transactions, and that allowing
> companies to more freely exchange IP resources is not harmful.
>
> 2.Not liking to justify future and current operations to a third
> party / fear of rejection by this process.
>
>
>
> I may not have encapsulated both arguments well, and these have been
> hashed over again and again for the last few years. So what is different
> today? ARIN has allocated every last resource from the free pool, and has a
> long waiting list.
>
>
>
> So what if we strike a compromise? What if some restrictions were put on
> allocation size and frequency without a needs test and left only the truly
> large or frequent transactions to do it. Something like this:
>
>
>
> Every legal entity can obtain up to a /22 from the transfer market every
> year, in up to two transactions. They may not transfer these resources out
> of their network within twelve months. Each legal entity has to occupy a
> unique address (suite level) from any other entity in the ARIN database.
>
>
>
> All transfers larger than a /22 need to have needs based justification
> done based on the current model.
>
>
>
>
>
> If you wanted to speculate, you would need to spin-up dozens of entities
> all with unique mailstops, and you would have to camp on the addresses for
> a year. Meanwhile the small end users and ISPs could obtain up to a /22 of
> a resource that with a lot of careful use of NAT would support a fairly
> large public network.
>
>
>
> Best regards,
>
>
>
> Bill Buhler
>
>
>
> *From:* arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] *On
> Behalf Of *Steven Ryerse
> *Sent:* Friday, September 25, 2015 11:48 AM
> *To:* Owen DeLong
>
> *Cc:* arin-ppml@arin.net
> *Subject:* Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating
> needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4
> netblocks
>
>
>
> Owens comment from below:
>
> “2. To the extent that there is supply, anyone who needs addresses can get
> them already. Needs-based evaluation does not prevent those with need from
> getting addresses… It prevents those without need from getting them.”
>
>
>
> Owen’s comment is absolutely false!  It allows large organizing who
> request resources to get what they need or something smaller.  It allows
> medium size organizations who request resources to get what they need or
> something smaller.  It allows small organizations who request resources to
> get what they need or nothing, and there is no other source to get
> resources if ARIN rejects a request, but the open market which Owen and
> others seem to wish did not exist!
>
>
>
> It is time to fix this inequity and removing needs tests would be a big
> help to small organizations who really need resources!
>
>
>
> *Steven Ryerse*
>
> *President*
>
> *100 Ashford Center North, Suite 110, Atlanta, GA  30338*
>
> *770.656.1460 <770.656.1460> - Cell*
>
> *770.399.9099 <770.399.9099>- Office*
>
>
>
> [image: Description: Description: Eclipse Networks Logo_small.png]℠ Eclipse
> Networks, Inc.
>
>         Conquering Complex Networks℠
>
>
>
> *From:* arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net
> <arin-ppml-boun...@arin.net>] *On Behalf Of *Owen DeLong
> *Sent:* Friday, September 25, 2015 1:24 PM
> *To:* el...@velea.eu
> *Cc:* arin-ppml@arin.net
> *Subject:* Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating
> needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4
> netblocks
>
>
>
>
>
> On Sep 25, 2015, at 04:42 , Elvis Daniel Velea <el...@velea.eu> wrote:
>
>
>
> Hi Richard,
>
> On 25/09/15 06:46, Richard J. Letts wrote:
>
> b)
> There is no definitive outcome from the policy change, which makes me feel
> that it's not worth changing -- the problem statement argument is weak at
> best.
>
>

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Matthew Petach]

I am OPPOSED to the proposal as written;
I think it's a bridge too far.  I would instead
support a compromise as has been discussed
of a total of one /22 per year per org-ID transferrable
needs-free; I would recommend the hold period
be two years from transfer date (ie, you may not
transfer that block of addresses again for 24
months so long as you remain a solvent
business entity; if you become insolvent,
ARIN can arm wrestle with the court over
control of the number resource).  Any
transfer larger than a /22 would still be
subject to need analysis.

Matt


On Thu, Sep 24, 2015 at 6:20 PM, Dani Roisman <drois...@softlayer.com> wrote:
> | Date: Wed, 23 Sep 2015 16:53:59 -0400
> | From: ARIN <i...@arin.net>
> | To: arin-ppml@arin.net
> | Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based
> |       evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
> | Message-ID: <56031167.1010...@arin.net>
> | Content-Type: text/plain; charset=utf-8; format=flowed
> |
> | Draft Policy ARIN-2015-9
> | Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4
> | transfers of IPv4 netblocks
> |
> | On 17 September 2015 the ARIN Advisory Council (AC) accepted
> | "ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3,
> | and 8.4 transfers of IPv4 netblocks" as a Draft Policy.
> |
> | Draft Policy ARIN-2015-9 is below and can be found at:
> | https://www.arin.net/policy/proposals/2015_9.html
>
> Greetings,
>
> There has been some stimulating dialog about the merits of 2015-9.  I'd like 
> to ask that in addition to any overall support or lack thereof, you also 
> review the policy language and comment specifically on the changes proposed:
> a) For those of you generally in support of this effort, are there any 
> refinements to the changes made which you think will improve this should 
> these policy changes be implemented?
> b) For those of you generally opposed to this effort, are there any 
> adjustments to the policy changes which, if implemented, would gain your 
> support?
>
> --
> Dani Roisman
> ___
> PPML
> You are receiving this message because you are subscribed to
> the ARIN Public Policy Mailing List (ARIN-PPML@arin.net).
> Unsubscribe or manage your mailing list subscription at:
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> Please contact i...@arin.net if you experience any issues.
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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Adam Thompson]

At this point, I support anything that looks like a compromise so we can get 
*any* change in policy at all... So this looks like a decent compromise to me.  
Yes, it'll have to be revisited in a couple of years' time; yes, the specifics 
probably aren't perfect.  The community can change those.  The policy can even 
be written such that ARIN staff can change them independently (although this 
doesn't seem to be a popular model).
Insisting on perfection is just hamstringing the entire service region... both 
the speculators *and* legitimate users.
-Adam


On September 26, 2015 8:47:46 PM CDT, Brian Jones <bjo...@vt.edu> wrote:
>I find Bill's proposal an interesting middle ground approach. I do not
>believe completely eliminating needs-based justification for addresses
>is
>the correct thing to do.
>
>--
>Brian
>
>On Fri, Sep 25, 2015 at 4:05 PM, Bill Buhler <b...@tknow.com> wrote:
>
>> Having watched this for the last couple of years let me make a couple
>of
>> observations / one proposal:
>>
>>
>>
>> There seems to be a lot of fear on both sides of this debate, on the
>needs
>> test side there seems to be a complete fear of monopolization of the
>IP
>> address space by those with deep pockets.
>>
>>
>>
>> On the other side there seem to be a couple of thoughts:
>>
>>
>>
>> 1.   It’s a market, markets work best when freed from constraints
>> that increase the complexity of non-harmful transactions, and that
>allowing
>> companies to more freely exchange IP resources is not harmful.
>>
>> 2.Not liking to justify future and current operations to a
>third
>> party / fear of rejection by this process.
>>
>>
>>
>> I may not have encapsulated both arguments well, and these have been
>> hashed over again and again for the last few years. So what is
>different
>> today? ARIN has allocated every last resource from the free pool, and
>has a
>> long waiting list.
>>
>>
>>
>> So what if we strike a compromise? What if some restrictions were put
>on
>> allocation size and frequency without a needs test and left only the
>truly
>> large or frequent transactions to do it. Something like this:
>>
>>
>>
>> Every legal entity can obtain up to a /22 from the transfer market
>every
>> year, in up to two transactions. They may not transfer these
>resources out
>> of their network within twelve months. Each legal entity has to
>occupy a
>> unique address (suite level) from any other entity in the ARIN
>database.
>>
>>
>>
>> All transfers larger than a /22 need to have needs based
>justification
>> done based on the current model.
>>
>>
>>
>>
>>
>> If you wanted to speculate, you would need to spin-up dozens of
>entities
>> all with unique mailstops, and you would have to camp on the
>addresses for
>> a year. Meanwhile the small end users and ISPs could obtain up to a
>/22 of
>> a resource that with a lot of careful use of NAT would support a
>fairly
>> large public network.
>>
>>
>>
>> Best regards,
>>
>>
>>
>> Bill Buhler
>>
>>
>>
>> *From:* arin-ppml-boun...@arin.net
>[mailto:arin-ppml-boun...@arin.net] *On
>> Behalf Of *Steven Ryerse
>> *Sent:* Friday, September 25, 2015 11:48 AM
>> *To:* Owen DeLong
>>
>> *Cc:* arin-ppml@arin.net
>> *Subject:* Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating
>> needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of
>IPv4
>> netblocks
>>
>>
>>
>> Owens comment from below:
>>
>> “2. To the extent that there is supply, anyone who needs addresses
>can get
>> them already. Needs-based evaluation does not prevent those with need
>from
>> getting addresses… It prevents those without need from getting them.”
>>
>>
>>
>> Owen’s comment is absolutely false!  It allows large organizing
>who
>> request resources to get what they need or something smaller.  It
>allows
>> medium size organizations who request resources to get what they need
>or
>> something smaller.  It allows small organizations who request
>resources to
>> get what they need or nothing, and there is no other source to get
>> resources if ARIN rejects a request, but the open market which Owen
>and
>> others seem to wish did not exist!
>>
>>
>>
>> It is time to fix this inequity and removing needs tests would be a
>big
>> help to small organizations who really need resources!
>>
>>
>

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Elvis Daniel Velea]

Hi Owen,

On 25/09/15 21:56, Owen DeLong wrote:

On Sep 25, 2015, at 04:23 , Elvis Daniel Velea  wrote:

Hi Owen,

On 25/09/15 09:23, Owen DeLong wrote:

It’s not ARIN’s mission to prevent profits nor did I say it was.

My point is that Elvis support for removing policy is strongly influenced by 
the potential windfall he stands to reap while not actually providing
any internet services in the process if the policy is changed as he wishes.

Please stop implying what influences my beliefs. I doubt you can read my mind.

I already said it several times that regardless of the outcome, there are 
plenty of organizations that have already received 'pre-approvals' and helping 
at least those will fill up my plate.. What do you mean we do not provide an 
internet service? We offer various services, not just the brokerage part.

As yo pointed out, many folks make a profit on various INETERNET SERVICES. 
Elvis, OTOH is not in the internet services business. He’s strictly
an address broker.

What do you mean by 'not in the internet services business' ? I think you are 
starting to be rude and would like to ask you to back off a bit.
We offer various services to our customers: IP management, LIR management, 
audits, Sponsoring LIR services (RIPE Region), IPv6 migration support, etc…

Do you offer any services involving moving bits between your clients and other 
organizations?
so you are saying that only companies that move bits between 
customers/other organisations are in the internet service business?


what about the RIRs? or the I* organizations ? I doubt they move bits 
for customers.. are they also excluded from your list or they do offer 
internet services? if the latter, what is then the difference?




Or are you strictly in the address marketing/management business?

 From everything you have said to me, I’ve been led to believe the latter. If 
you actually sell access or transit services, hosting, or anything like that, 
then I stand corrected.
we are discussing a policy change on the ARIN PPML list, not on nanog... 
and I am not even sure why you keep talking about this.. It really does 
not matter what the company I work for does, we are discussing here as 
citizens interested in the policies.



It would be sort of like Realtors arguing against transfer taxes on real 
estate. An argument based solely in greed rather than any actual concern for 
the common good.

Again, you are just guessing why I am commenting on this policy proposal. As an 
ex-RIR employee, I've told you (and others) several times that I still want to 
do the right thing for the community. I have already made several policy 
proposals in the RIPE Region (one recently accepted by the community) and I am 
active in APNIC and now ARIN…

Fair enough, but I’d call it an educated guess based on conversations we’ve had.
I talk here in my name and not in the name of my company. Same as you 
and most of the people on this list.



Owen, last time we discussed you said that you understand the need of brokers 
and while a few years back you did not agree with us existing, now you are no 
longer against... I see personal attacks in the two e-mails you sent and I 
don't understand where these come from.

Not exactly.

I said I understand the needs of brokers, not that I saw a need for brokers. 
Understanding the needs of brokers does not imply a desire to accommodate them.
I did say that I am not opposed to brokers existing and I am not. However, I’m 
not in favor of supporting them to the detriment of the community, either.

In fact, I have worked with brokers to get IP addresses for organizations. I 
see no incompatibility between needs basis and brokers working above board.

Your repeated expressions of willingness to conduct transfers outside the 
system if you can’t do whatever you want within the system are where I take 
exception. These have been your own words even in this very thread.
I did not say that we will support transfers outside the system.. 
actually, this is our problem. Because we want to comply with the policy 
and because we do not close our eyes to potential customers violating 
the policies, we lose those potential customers.


I’m sorry you see those as personal attacks. What I am attacking is the idea of 
contorting policy to suit the profit motives of an ancillary industry to the 
detriment of those actually building and operating infrastructure.
I think you are looking at this from the wrong direction. I do want to 
have more customers and the removal of the needs based criteria will 
help. But you misunderstand the reasons behind it. I have repeated them 
several times already...


If a potential buyer has the money and wants to buy the resource (in 
order to use them, or keep them for a few years - maybe they want to 
make sure that they will never run out) they will buy them.. through 
financial artifices if they can not do it through the brokers and with 
ARIN's blessing.


It was never my intent 

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Elvis Daniel Velea]

One more thing regarding the moving bits businesses..

On 25/09/15 21:56, Owen DeLong wrote:
Do you offer any services involving moving bits between your clients 
and other organizations? Or are you strictly in the address 
marketing/management business? From everything you have said to me, 
I’ve been led to believe the latter. If you actually sell access or 
transit services, hosting, or anything like that, then I stand corrected.


the fact that service providers are willing to route blocks which are 
not reflected in the registry indicates (at some level) support for more 
transfer-friendly policies, even if they are not advocating for changes 
on this list...


my 2 cents,
elvis
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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Elvis Daniel Velea]

Hi Owen,

On 25/09/15 09:23, Owen DeLong wrote:

It’s not ARIN’s mission to prevent profits nor did I say it was.

My point is that Elvis support for removing policy is strongly influenced by 
the potential windfall he stands to reap while not actually providing
any internet services in the process if the policy is changed as he wishes.
Please stop implying what influences my beliefs. I doubt you can read my 
mind.


I already said it several times that regardless of the outcome, there 
are plenty of organizations that have already received 'pre-approvals' 
and helping at least those will fill up my plate.. What do you mean we 
do not provide an internet service? We offer various services, not just 
the brokerage part.

As yo pointed out, many folks make a profit on various INETERNET SERVICES. 
Elvis, OTOH is not in the internet services business. He’s strictly
an address broker.
What do you mean by 'not in the internet services business' ? I think 
you are starting to be rude and would like to ask you to back off a bit.
We offer various services to our customers: IP management, LIR 
management, audits, Sponsoring LIR services (RIPE Region), IPv6 
migration support, etc...

It would be sort of like Realtors arguing against transfer taxes on real 
estate. An argument based solely in greed rather than any actual concern for 
the common good.
Again, you are just guessing why I am commenting on this policy 
proposal. As an ex-RIR employee, I've told you (and others) several 
times that I still want to do the right thing for the community. I have 
already made several policy proposals in the RIPE Region (one recently 
accepted by the community) and I am active in APNIC and now ARIN...


Owen, last time we discussed you said that you understand the need of 
brokers and while a few years back you did not agree with us existing, 
now you are no longer against... I see personal attacks in the two 
e-mails you sent and I don't understand where these come from.


Owen, please stop guessing what my business does and why I participate 
in the discussions. I doubt this is what an ARIN AC member should do..


regards,
Elvis

PS: I could have registered to the mailing list with my work e-mail 
address if all I wanted to do is to profit from my position on this (and 
other) policy proposals discussions. These messages are sent on my 
behalf and may or may not be the point of view of the company I work for


Owen


On Sep 24, 2015, at 13:53 , Steven Ryerse <srye...@eclipse-networks.com> wrote:

Many folks make a profit on various Internet services in this Region. ARIN was 
created to further the Internet and not stifle it.  Nowhere do I see that it is 
part of ARIN's mission to somehow prevent profits via policies. Appears to me 
to be all about the haves keeping the have nots from obtaining resources.  :-(

Steven Ryerse
President
100 Ashford Center North, Suite 110, Atlanta, GA  30338
770.656.1460 - Cell
770.399.9099- Office

℠ Eclipse Networks, Inc.
 Conquering Complex Networks℠

-Original Message-
From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On Behalf 
Of Owen DeLong
Sent: Thursday, September 24, 2015 4:37 PM
To: el...@velea.eu
Cc: arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

Of course your position wouldn’t have anything to do with the profits you stand 
to make from an unrestricted transfer market.

Owen


On Sep 24, 2015, at 13:12 , Elvis Daniel Velea <el...@velea.eu> wrote:

Hi Owen,

On 24/09/15 22:09, Owen DeLong wrote:

Short answer: NO

Longer answer:

Finance alone does not reflect all community values. Eliminating
needs-based evaluation for transfers will foster an environment open
to speculation and other artifice used to maximize the monetization of address 
resources without providing the benefit to the community of maximizing 
utilization.

The environment open to speculation already exists, a needs-based criteria will 
not stop the ones that want to speculate. Keeping needs-based criteria in 
policy will only drive (keep some of the) transfers underground (ie: futures 
contracts, all kind of financial artifices). I actually believe the needs-based 
criteria removal will benefit the community by eliminating a barrier in the 
correct registration of the transfers (resources) in the registry (and whois).

The allocation era has passed, ARIN should just be a shepherd and record the 
transfers (and do the allocation exercise twice per year, when the IANA 
allocates the few crumbs remaining). From my experience and observations, if 
someone needs the IP addresses and has the money to pay for them I am sure that 
they will not be stopped by ARIN's needs-base criteria...

In fact, I believe that eliminating needs-basis will likely cause
actual utilization to be reduced in the long run in favor of financial 
manipulation.

I dare

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Steven Ryerse]

There was a proposal similar to that in the last year and it had more folks 
from this community by far  agreeing with it than any proposal on this subject 
I have ever seen since I joined this community. I would be very much in favor 
of your proposal!

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: Bill Buhler [mailto:b...@tknow.com]
Sent: Friday, September 25, 2015 4:06 PM
To: Steven Ryerse <srye...@eclipse-networks.com>; Owen DeLong <o...@delong.com>
Cc: arin-ppml@arin.net
Subject: RE: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

Having watched this for the last couple of years let me make a couple of 
observations / one proposal:

There seems to be a lot of fear on both sides of this debate, on the needs test 
side there seems to be a complete fear of monopolization of the IP address 
space by those with deep pockets.

On the other side there seem to be a couple of thoughts:


1.   It’s a market, markets work best when freed from constraints that 
increase the complexity of non-harmful transactions, and that allowing 
companies to more freely exchange IP resources is not harmful.

2.Not liking to justify future and current operations to a third party 
/ fear of rejection by this process.

I may not have encapsulated both arguments well, and these have been hashed 
over again and again for the last few years. So what is different today? ARIN 
has allocated every last resource from the free pool, and has a long waiting 
list.

So what if we strike a compromise? What if some restrictions were put on 
allocation size and frequency without a needs test and left only the truly 
large or frequent transactions to do it. Something like this:

Every legal entity can obtain up to a /22 from the transfer market every year, 
in up to two transactions. They may not transfer these resources out of their 
network within twelve months. Each legal entity has to occupy a unique address 
(suite level) from any other entity in the ARIN database.

All transfers larger than a /22 need to have needs based justification done 
based on the current model.


If you wanted to speculate, you would need to spin-up dozens of entities all 
with unique mailstops, and you would have to camp on the addresses for a year. 
Meanwhile the small end users and ISPs could obtain up to a /22 of a resource 
that with a lot of careful use of NAT would support a fairly large public 
network.

Best regards,

Bill Buhler

From: arin-ppml-boun...@arin.net<mailto:arin-ppml-boun...@arin.net> 
[mailto:arin-ppml-boun...@arin.net] On Behalf Of Steven Ryerse
Sent: Friday, September 25, 2015 11:48 AM
To: Owen DeLong
Cc: arin-ppml@arin.net<mailto:arin-ppml@arin.net>
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

Owens comment from below:
“2. To the extent that there is supply, anyone who needs addresses can get them 
already. Needs-based evaluation does not prevent those with need from getting 
addresses… It prevents those without need from getting them.”

Owen’s comment is absolutely false!  It allows large organizing who request 
resources to get what they need or something smaller.  It allows medium size 
organizations who request resources to get what they need or something smaller. 
 It allows small organizations who request resources to get what they need or 
nothing, and there is no other source to get resources if ARIN rejects a 
request, but the open market which Owen and others seem to wish did not exist!

It is time to fix this inequity and removing needs tests would be a big help to 
small organizations who really need resources!

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: arin-ppml-boun...@arin.net<mailto:arin-ppml-boun...@arin.net> 
[mailto:arin-ppml-boun...@arin.net] On Behalf Of Owen DeLong
Sent: Friday, September 25, 2015 1:24 PM
To: el...@velea.eu<mailto:el...@velea.eu>
Cc: arin-ppml@arin.net<mailto:arin-ppml@arin.net>
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks


On Sep 25, 2015, at 04:42 , Elvis Daniel Velea 
<el...@velea.eu<mailto:el...@velea.eu>> wrote:

Hi Richard,

On 25/09/15 06:46, Richard J. Letts wrote:
b)
There is no definitive outcome from the policy change, which makes me feel that 
it's not worth changing -- the problem statement argument is weak at best.
the outcome is 

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Owen DeLong]

> On Sep 25, 2015, at 10:48 , Steven Ryerse  
> wrote:
> 
> Owens comment from below:
> “2. To the extent that there is supply, anyone who needs addresses can get 
> them already. Needs-based evaluation does not prevent those with need from 
> getting addresses… It prevents those without need from getting them.”
>  
> Owen’s comment is absolutely false!  It allows large organizing who 
> request resources to get what they need or something smaller.  It allows 
> medium size organizations who request resources to get what they need or 
> something smaller.  It allows small organizations who request resources to 
> get what they need or nothing, and there is no other source to get resources 
> if ARIN rejects a request, but the open market which Owen and others seem to 
> wish did not exist!

This is patently false.

Many small organizations have gotten resources from ARIN.

I have no problem with the open market so long as it conforms to the same 
needs-basis evaluations that were used for free pool assignments/allocations.

Sure, organizations with larger needs have the option of getting less resources 
than they need, but I don’t see how that differs from what I said.

Organizations with small needs can get what they need, assuming there is 
supply. I did not distinguish between supply from the market and supply from 
the free pool as I believe the rules should apply the same regardless of the 
source of resources.

You say my statement is false and then go on to confirm that it is actually 
true.

> It is time to fix this inequity and removing needs tests would be a big help 
> to small organizations who really need resources! 

What inequity?

You haven’t yet shown one.

Owen

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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Steven Ryerse]

I would probably agree with your comment that neither of the above really helps 
anyone and probably creates a host of other issues. I would probably not 
advocate them either but they would be more fair that the policies in place now.

Of course the easy fix is to allow Organizations of any size to easily get the 
Minimum size block which I believe is now a /24 and that would go a long way 
towards fixing the problem.  I put forth just that policy change proposal a 
while back with a limit of one block per year for small organizations and that 
Policy Proposal was summarily dumped by folks with Owen’s views.

My preference is to allow organizations to more easily get resources in this 
post Run-Out world, rather than to somehow try to miserly block allocations in 
the hope of saving them for some unknown future use.

I appreciate your attempt to be constructive.

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: Mike Winters [mailto:mwint...@edwardrose.com]
Sent: Friday, September 25, 2015 3:03 PM
To: Steven Ryerse <srye...@eclipse-networks.com>
Cc: arin-ppml@arin.net
Subject: RE: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

That’s an interesting take on the “inequity”…

However, there is a fundamental flaw with your “inequity” situation.  If there 
is not enough addresses for a small organization to get them, then nobody would 
get them.
They will eventually rise to the top just like everyone else, ergo no inequity.

Assuming for a moment your argument is correct and not seriously flawed, then 
arguing that letting people who don’t need addresses get addresses is silly 
since it would only exacerbate the problem.
It seems the best way to “fix this inequity” that you describe would be to 
either:

a)  not let larger organizations accept smaller allocations; or

b)  make everyone take smaller allocations; or

c)   let ARIN allocate smaller blocks (really bad idea); or

d)  some crazy combination of the above

Neither of the above really helps anyone and probably creates a host of other 
issues.
To be clear, I am not advocating any of the above.

Mike


From: arin-ppml-boun...@arin.net<mailto:arin-ppml-boun...@arin.net> 
[mailto:arin-ppml-boun...@arin.net] On Behalf Of Steven Ryerse
Sent: Friday, September 25, 2015 1:48 PM
To: Owen DeLong
Cc: arin-ppml@arin.net<mailto:arin-ppml@arin.net>
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

Owens comment from below:
“2. To the extent that there is supply, anyone who needs addresses can get them 
already. Needs-based evaluation does not prevent those with need from getting 
addresses… It prevents those without need from getting them.”

Owen’s comment is absolutely false!  It allows large organizing who request 
resources to get what they need or something smaller.  It allows medium size 
organizations who request resources to get what they need or something smaller. 
 It allows small organizations who request resources to get what they need or 
nothing, and there is no other source to get resources if ARIN rejects a 
request, but the open market which Owen and others seem to wish did not exist!

It is time to fix this inequity and removing needs tests would be a big help to 
small organizations who really need resources!

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: arin-ppml-boun...@arin.net<mailto:arin-ppml-boun...@arin.net> 
[mailto:arin-ppml-boun...@arin.net] On Behalf Of Owen DeLong
Sent: Friday, September 25, 2015 1:24 PM
To: el...@velea.eu<mailto:el...@velea.eu>
Cc: arin-ppml@arin.net<mailto:arin-ppml@arin.net>
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks


On Sep 25, 2015, at 04:42 , Elvis Daniel Velea 
<el...@velea.eu<mailto:el...@velea.eu>> wrote:

Hi Richard,

On 25/09/15 06:46, Richard J. Letts wrote:
b)
There is no definitive outcome from the policy change, which makes me feel that 
it's not worth changing -- the problem statement argument is weak at best.
the outcome is that everyone that will need IP addresses will be able to get 
them. Isn't that quite definitive and clear?

Sure, except it isn’t actually an outcome of the proposal on many levels:

1. The proposal does nothing to guarantee a supply of addresses or even 
increase the supply.
2. To the extent that there is supply, anyone who ne

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Steven Ryerse]

It appears to me that you are still trying to somehow save IPv4 from 
exhaustion. That horse is out of the barn and gone.

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: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On Behalf 
Of Stephen Sprunk
Sent: Friday, September 25, 2015 3:26 PM
To: arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

On 25-Sep-15 12:48, Steven Ryerse wrote:
> Owens comment from below:
>
> “2. To the extent that there is supply, anyone who needs addresses
> can get them already. Needs-based evaluation does not prevent those
> with need from getting addresses… It prevents those without need from
> getting them.”
>
> Owen’s comment is absolutely false!  It allows large organizing
> who request resources to get what they need or something smaller.  It
> allows medium size organizations who request resources to get what
> they need or something smaller.  It allows small organizations who
> request resources to get what they need or nothing, and there is no
> other source to get resources if ARIN rejects a request, but the open
> market which Owen and others seem to wish did not exist!
>
> It is time to fix this inequity and removing needs tests would be a
> big help to small organizations who really need resources!

If they actually need the resources, then a needs-based policy does not present 
an obstacle.  Where's the problem?

However, not having such a policy will mean that folks who _don't_ need 
resources can also get them, which makes the (IPv4) scarcity problem even worse 
than it already is.  That benefits speculators at the expense of those who 
actually need resources.

You appear to be arguing against your stated interests.

S

--
Stephen Sprunk "God does not play dice."  --Albert Einstein
CCIE #3723 "God is an inveterate gambler, and He throws the
K5SSSdice at every possible opportunity." --Stephen Hawking
___
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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Steven Ryerse]

Obviously you are entitled to your opinion and I respect it, but I don’t share 
it.

Market price is driven by supply and demand and there is actually quite a 
supply of IPv4 resources out there in the huge amount of Legacy blocks that 
were issued before ARIN existed. If this community would fully embrace the 
transfers of these blocks in a way that encouraged, instead of discouraged, 
bringing those into the ARIN sphere - I think there would be so many blocks 
become available, the price would go way way down because of oversupply.

I know John will tell us that ARIN already has a mechanism for that built into 
current policy and that some Legacy blocks have become available thru that 
policy, but the fact that a large number of transactions continue to completely 
go around ARIN is indication that those Legacy holders do not want to abide by 
current ARIN policy.

So this community can refuse to make the changes to policy that would make 
these resources available above board on the open market, or it can continue to 
refuse to change and watch prices continue to rise until only big Orgs can 
afford them. At some point IPv6 might be the solution but until then IPv4 
resources continues to be required. I think it is about time for this community 
to truly embrace the Legacy holders and I hope others come to that conclusion 
as well.  Maybe we need IPv4 Amnesty. My two cents.

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: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On Behalf 
Of Stephen Sprunk
Sent: Friday, September 25, 2015 3:33 PM
To: arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

On 25-Sep-15 14:05, Steven Ryerse wrote:
> It’s pretty obvious that if needs testing goes away, Legacy blocks will
> become much more available to anyone who needs them, ...

If so, only because it allows speculators to drive up the market price, which 
is not in the interests of those who actually need resources.

> When any small Organization requesting a very small amount of
> resources is completely denied resources because of arbitrary
> “policy”,

ARIN policy is not arbitrary, and it's set by the community; if you see a 
problem with how needs testing is done, feel free to suggest changes.

If your complaint is actually that the minimum block size is not small enough, 
that is an entirely different problem from needs testing.

S

--
Stephen Sprunk "God does not play dice."  --Albert Einstein
CCIE #3723 "God is an inveterate gambler, and He throws the
K5SSSdice at every possible opportunity." --Stephen Hawking
___
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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Bill Buhler]

Having watched this for the last couple of years let me make a couple of 
observations / one proposal:

There seems to be a lot of fear on both sides of this debate, on the needs test 
side there seems to be a complete fear of monopolization of the IP address 
space by those with deep pockets.

On the other side there seem to be a couple of thoughts:


1.   It’s a market, markets work best when freed from constraints that 
increase the complexity of non-harmful transactions, and that allowing 
companies to more freely exchange IP resources is not harmful.

2.Not liking to justify future and current operations to a third party 
/ fear of rejection by this process.

I may not have encapsulated both arguments well, and these have been hashed 
over again and again for the last few years. So what is different today? ARIN 
has allocated every last resource from the free pool, and has a long waiting 
list.

So what if we strike a compromise? What if some restrictions were put on 
allocation size and frequency without a needs test and left only the truly 
large or frequent transactions to do it. Something like this:

Every legal entity can obtain up to a /22 from the transfer market every year, 
in up to two transactions. They may not transfer these resources out of their 
network within twelve months. Each legal entity has to occupy a unique address 
(suite level) from any other entity in the ARIN database.

All transfers larger than a /22 need to have needs based justification done 
based on the current model.


If you wanted to speculate, you would need to spin-up dozens of entities all 
with unique mailstops, and you would have to camp on the addresses for a year. 
Meanwhile the small end users and ISPs could obtain up to a /22 of a resource 
that with a lot of careful use of NAT would support a fairly large public 
network.

Best regards,

Bill Buhler

From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On Behalf 
Of Steven Ryerse
Sent: Friday, September 25, 2015 11:48 AM
To: Owen DeLong
Cc: arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

Owens comment from below:
“2. To the extent that there is supply, anyone who needs addresses can get them 
already. Needs-based evaluation does not prevent those with need from getting 
addresses… It prevents those without need from getting them.”

Owen’s comment is absolutely false!  It allows large organizing who request 
resources to get what they need or something smaller.  It allows medium size 
organizations who request resources to get what they need or something smaller. 
 It allows small organizations who request resources to get what they need or 
nothing, and there is no other source to get resources if ARIN rejects a 
request, but the open market which Owen and others seem to wish did not exist!

It is time to fix this inequity and removing needs tests would be a big help to 
small organizations who really need resources!

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: arin-ppml-boun...@arin.net<mailto:arin-ppml-boun...@arin.net> 
[mailto:arin-ppml-boun...@arin.net] On Behalf Of Owen DeLong
Sent: Friday, September 25, 2015 1:24 PM
To: el...@velea.eu<mailto:el...@velea.eu>
Cc: arin-ppml@arin.net<mailto:arin-ppml@arin.net>
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks


On Sep 25, 2015, at 04:42 , Elvis Daniel Velea 
<el...@velea.eu<mailto:el...@velea.eu>> wrote:

Hi Richard,

On 25/09/15 06:46, Richard J. Letts wrote:
b)
There is no definitive outcome from the policy change, which makes me feel that 
it's not worth changing -- the problem statement argument is weak at best.
the outcome is that everyone that will need IP addresses will be able to get 
them. Isn't that quite definitive and clear?

Sure, except it isn’t actually an outcome of the proposal on many levels:

1. The proposal does nothing to guarantee a supply of addresses or even 
increase the supply.
2. To the extent that there is supply, anyone who needs addresses can get them 
already. Needs-based evaluation does not prevent those with need from getting 
addresses… It prevents those without need from getting them.
3. The definitive outcome from the policy change, if there is such, is that 
those without need will now be more easily able to acquire addresses, 
potentially preventing those with need from acquiring them.


It is potentially enabling organizations with more money than need gain more 
resources, potentially at the expense of non-profit and educational 
organizations who might not be able to raise cash for additi

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Steven Ryerse]

From Owen’s Comments below: “What inequity?   You haven’t yet shown one.”

With run-out here, it is time to turn that around.  You need to prove that 
Needs Testing is still needed in the post Run-Out period.  Everything has 
changed and it is a different Internet world we are now living in.  Since 
removal of Needs Testing has NOT been tried in this RIR, you are just guessing 
what the effect on available resources will be.

Elvis made a pretty good argument in this thread that Needs Testing is no 
longer needed.  He describes what is happening in real life with resources in 
other RIR’s which counter your argument – and it is not a guess.  It’s pretty 
obvious that if needs testing goes away, Legacy blocks will become much more 
available to anyone who needs them, and as Elvis indicated the Database will 
become much more accurate.

When any small Organization requesting a very small amount of resources is 
completely denied resources because of arbitrary “policy”, ARIN has done the 
opposite of the Mission it was founded to perform!  As I said the time has come 
to fix this inequity and embrace the new Internet world we are now in.

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:o...@delong.com]
Sent: Friday, September 25, 2015 2:48 PM
To: Steven Ryerse <srye...@eclipse-networks.com>
Cc: arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks


On Sep 25, 2015, at 10:48 , Steven Ryerse 
<srye...@eclipse-networks.com<mailto:srye...@eclipse-networks.com>> wrote:

Owens comment from below:
“2. To the extent that there is supply, anyone who needs addresses can get them 
already. Needs-based evaluation does not prevent those with need from getting 
addresses… It prevents those without need from getting them.”

Owen’s comment is absolutely false!  It allows large organizing who request 
resources to get what they need or something smaller.  It allows medium size 
organizations who request resources to get what they need or something smaller. 
 It allows small organizations who request resources to get what they need or 
nothing, and there is no other source to get resources if ARIN rejects a 
request, but the open market which Owen and others seem to wish did not exist!

This is patently false.

Many small organizations have gotten resources from ARIN.

I have no problem with the open market so long as it conforms to the same 
needs-basis evaluations that were used for free pool assignments/allocations.

Sure, organizations with larger needs have the option of getting less resources 
than they need, but I don’t see how that differs from what I said.

Organizations with small needs can get what they need, assuming there is 
supply. I did not distinguish between supply from the market and supply from 
the free pool as I believe the rules should apply the same regardless of the 
source of resources.

You say my statement is false and then go on to confirm that it is actually 
true.

It is time to fix this inequity and removing needs tests would be a big help to 
small organizations who really need resources!

What inequity?

You haven’t yet shown one.

Owen

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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Steven Ryerse]

So explain to me how anyone can corner the market on IPv4 blocks when they can 
only get one /24 per year without going thru your needs testing.  They have to 
pay ARIN for them every year so in 3 years they can get up to 3 /24’s as long 
as they are willing to pay for them every year they have them.  If they stop 
paying they lose the resources.

This is a miniscule amount of resources, and I respectfully submit it would not 
appreciably change the availability of resources for anyone. It hasn’t in other 
regions as Elvis pointed out.  It would however make a big difference to small 
Organizations and level the playing field.

We are not far apart conceptually but we are far apart in what actually happens.

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:o...@delong.com]
Sent: Friday, September 25, 2015 3:46 PM
To: Steven Ryerse <srye...@eclipse-networks.com>
Cc: Mike Winters <mwint...@edwardrose.com>; arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

Your proposal was to allow anyone to get a /24 per year whether they needed 
anything or not.

I am not opposed to a policy which would allow organizations with lesser need 
to obtain a minimum size block (/24 or /48) if the potential for abuse can be 
adequately addressed.

By abuse, I mean, for example, the creation of entities with minimalist 
infrastructure strictly for the sake of qualifying for addresses.

I’m all for the local bakery to be able to get a /24 to support their 3 cash 
registers, a router, and a few menu board displays.

However, I’m not for VPNs-R-US being able to create 1024 entities each of which 
owns an SRX-100 and qualifies for a /24 on that basis.

I don’t think resource policy should substantially change in a post-runout 
world and nothing said so far gives me any reason to believe there is benefit 
to the community from doing so.

This isn't about miserly blocking of allocations for future theoretical use. 
This is about trying to make sure that organizations with need have the best 
chance of getting resources they need that we can provide. Allowing 
organizations without need to hoard addresses is contrary to that goal.

Interestingly, we seem to have the same goal but radically different opinions 
on how best to achieve it.

Owen

On Sep 25, 2015, at 12:32 , Steven Ryerse 
<srye...@eclipse-networks.com<mailto:srye...@eclipse-networks.com>> wrote:

I would probably agree with your comment that neither of the above really helps 
anyone and probably creates a host of other issues. I would probably not 
advocate them either but they would be more fair that the policies in place now.

Of course the easy fix is to allow Organizations of any size to easily get the 
Minimum size block which I believe is now a /24 and that would go a long way 
towards fixing the problem.  I put forth just that policy change proposal a 
while back with a limit of one block per year for small organizations and that 
Policy Proposal was summarily dumped by folks with Owen’s views.

My preference is to allow organizations to more easily get resources in this 
post Run-Out world, rather than to somehow try to miserly block allocations in 
the hope of saving them for some unknown future use.

I appreciate your attempt to be constructive.

Steven Ryerse
President
100 Ashford Center North, Suite 110, Atlanta, GA  30338
770.656.1460 - Cell
770.399.9099- Office

℠ Eclipse Networks, Inc.
Conquering Complex Networks℠

From: Mike Winters [mailto:mwint...@edwardrose.com]
Sent: Friday, September 25, 2015 3:03 PM
To: Steven Ryerse 
<srye...@eclipse-networks.com<mailto:srye...@eclipse-networks.com>>
Cc: arin-ppml@arin.net<mailto:arin-ppml@arin.net>
Subject: RE: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

That’s an interesting take on the “inequity”…

However, there is a fundamental flaw with your “inequity” situation.  If there 
is not enough addresses for a small organization to get them, then nobody would 
get them.
They will eventually rise to the top just like everyone else, ergo no inequity.

Assuming for a moment your argument is correct and not seriously flawed, then 
arguing that letting people who don’t need addresses get addresses is silly 
since it would only exacerbate the problem.
It seems the best way to “fix this inequity” that you describe would be to 
either:
a)  not let larger organizations accept smaller allocations; or
b)  make everyone take smaller allocations; or
c)   let ARIN allocate smaller blocks (really bad idea); or
d)  some crazy combination of the above

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Steven Ryerse]

Owens comment from below:
“2. To the extent that there is supply, anyone who needs addresses can get them 
already. Needs-based evaluation does not prevent those with need from getting 
addresses… It prevents those without need from getting them.”

Owen’s comment is absolutely false!  It allows large organizing who request 
resources to get what they need or something smaller.  It allows medium size 
organizations who request resources to get what they need or something smaller. 
 It allows small organizations who request resources to get what they need or 
nothing, and there is no other source to get resources if ARIN rejects a 
request, but the open market which Owen and others seem to wish did not exist!

It is time to fix this inequity and removing needs tests would be a big help to 
small organizations who really need resources!

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: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On Behalf 
Of Owen DeLong
Sent: Friday, September 25, 2015 1:24 PM
To: el...@velea.eu
Cc: arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks


On Sep 25, 2015, at 04:42 , Elvis Daniel Velea 
<el...@velea.eu<mailto:el...@velea.eu>> wrote:

Hi Richard,

On 25/09/15 06:46, Richard J. Letts wrote:

b)
There is no definitive outcome from the policy change, which makes me feel that 
it's not worth changing -- the problem statement argument is weak at best.
the outcome is that everyone that will need IP addresses will be able to get 
them. Isn't that quite definitive and clear?

Sure, except it isn’t actually an outcome of the proposal on many levels:

1. The proposal does nothing to guarantee a supply of addresses or even 
increase the supply.
2. To the extent that there is supply, anyone who needs addresses can get them 
already. Needs-based evaluation does not prevent those with need from getting 
addresses… It prevents those without need from getting them.
3. The definitive outcome from the policy change, if there is such, is that 
those without need will now be more easily able to acquire addresses, 
potentially preventing those with need from acquiring them.



It is potentially enabling organizations with more money than need gain more 
resources, potentially at the expense of non-profit and educational 
organizations who might not be able to raise cash for additional IPv4 space [or 
equipment to support a transition to IPv6].
So, you think that in today's market the non-profit/educational organizations 
will have the chance at getting some of the IP space from the market? And if 
the needs-based barrier is removed, they will no longer have that chance?
Everyone knows that the IP address is now an asset and is worth a buck. Who do 
you think will say: I'll give it for free to this educational organization 
(because they have proven the need to ARIN) instead of giving it for money to 
this commercial entity (that may or may not have a demonstrated need need for 
it).


Contrary to your statement, there have been addresses returned to ARIN and 
there have been organizations who chose to transfer addresses to those they 
found worthy rather than maximize the monetization of those addresses.

OTOH, having a policy like this in place certainly makes it easier to 
manipulate the market to maximize the price.


I think we need to wake up. Keeping needs-based criteria in the policy will 
only cause SOME transfers to be driven underground and block some others.

I think claiming that those of us who believe needs-based criteria is still 
useful are asleep is unwarranted.


Changing policy just to (potentially) improve the accuracy of a database seems 
not worth the (potential) risk.
The change of the accuracy of the registry is already proven in the RIPE 
region. I would say it's not just potential, it is real and visible.

Please provide the metrics on which you base this assertion. How was RIPE-NCC 
accuracy measured prior to the policy change and to what extent was it improved 
as a result of this policy change. What mechanism was used to determine that 
the measured increase in accuracy was the result of the particular policy 
abandoning needs-based evaluation?

Owen



Richard
regards,
Elvis



From: arin-ppml-boun...@arin.net<mailto:arin-ppml-boun...@arin.net> 
<arin-ppml-boun...@arin.net<mailto:arin-ppml-boun...@arin.net>> on behalf of 
Dani Roisman <drois...@softlayer.com<mailto:drois...@softlayer.com>>
Sent: Thursday, September 24, 2015 6:20 PM
To: arin-ppml@arin.net<mailto:arin-ppml@arin.net>
Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Mike Burns]

The RIPE issue related directly to the price of IP addresses being doled out 
needs-free to each LIR.
The price then was the fees paid to RIPE plus any fees incurred in creating the 
new LIR business entity.
The net price was still far lower than the price for a /22 on the transfer 
market.
It was the price difference that drove the policy work-arounds in RIPE.
This is not an issue we face because our incentives are not misaligned.

Because we know RIPE offers needs-free transfers, it was not the needs 
requirement that drove this practice.
It was the profit incentive derived from policy conditions.

Likewise here in North America policy conditions work to provide incentive for 
off-the-books transfers.
As RIPE changed their policy to meet these real world conditions, ARIN should 
do the same and get rid of needs testing  because it provides a disincentive 
for properly recording the transfer.


Regards,
Mike

- Original Message - 
  From: Andrew Dul 
  To: arin-ppml@arin.net 
  Sent: Friday, September 25, 2015 6:17 PM
  Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks


  One might want to be reminded about what happened in the RIPE region when 
they allowed organizations to obtain /22 blocks by just opening a new LIR.  

  There are lots of threads in the RIPE mailing-list that you can go read 
through if you desire.  Here is a link to the outcome, a policy that restricts 
block flipping.

  https://www.ripe.net/participate/policies/proposals/2015-01

  Yes, a /24 is not a /22, but if you decide that an organization can just come 
and get a free block, people will find ways to abuse the system.  This doesn't 
apply in the ARIN region now, because our free pool is empty, but still we can 
see what happens when incentives are misaligned in resource allocation.

  Andrew

  On 9/25/2015 1:07 PM, Steven Ryerse wrote:

So explain to me how anyone can corner the market on IPv4 blocks when they 
can only get one /24 per year without going thru your needs testing.  They have 
to pay ARIN for them every year so in 3 years they can get up to 3 /24’s as 
long as they are willing to pay for them every year they have them.  If they 
stop paying they lose the resources.



This is a miniscule amount of resources, and I respectfully submit it would 
not appreciably change the availability of resources for anyone. It hasn’t in 
other regions as Elvis pointed out.  It would however make a big difference to 
small Organizations and level the playing field. 



We are not far apart conceptually but we are far apart in what actually 
happens.  



Steven Ryerse

President

100 Ashford Center North, Suite 110, Atlanta, GA  30338

770.656.1460 - Cell

770.399.9099- Office



℠ Eclipse Networks, Inc.

Conquering Complex Networks℠



From: Owen DeLong [mailto:o...@delong.com] 
Sent: Friday, September 25, 2015 3:46 PM
To: Steven Ryerse <srye...@eclipse-networks.com>
Cc: Mike Winters <mwint...@edwardrose.com>; arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks



Your proposal was to allow anyone to get a /24 per year whether they needed 
anything or not.



I am not opposed to a policy which would allow organizations with lesser 
need to obtain a minimum size block (/24 or /48) if the potential for abuse can 
be adequately addressed.



By abuse, I mean, for example, the creation of entities with minimalist 
infrastructure strictly for the sake of qualifying for addresses.



I’m all for the local bakery to be able to get a /24 to support their 3 
cash registers, a router, and a few menu board displays.



However, I’m not for VPNs-R-US being able to create 1024 entities each of 
which owns an SRX-100 and qualifies for a /24 on that basis.



I don’t think resource policy should substantially change in a post-runout 
world and nothing said so far gives me any reason to believe there is benefit 
to the community from doing so.



This isn't about miserly blocking of allocations for future theoretical 
use. This is about trying to make sure that organizations with need have the 
best chance of getting resources they need that we can provide. Allowing 
organizations without need to hoard addresses is contrary to that goal.



Interestingly, we seem to have the same goal but radically different 
opinions on how best to achieve it.



Owen



  On Sep 25, 2015, at 12:32 , Steven Ryerse <srye...@eclipse-networks.com> 
wrote:



  I would probably agree with your comment that neither of the above really 
helps anyone and probably creates a host of other issues. I would probably not 
advocate them either but they would be more fair that the policies in place 
now. 



  Of course the ea

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Owen DeLong]

> On Sep 25, 2015, at 13:07 , Steven Ryerse <srye...@eclipse-networks.com> 
> wrote:
> 
> So explain to me how anyone can corner the market on IPv4 blocks when they 
> can only get one /24 per year without going thru your needs testing.  They 
> have to pay ARIN for them every year so in 3 years they can get up to 3 /24’s 
> as long as they are willing to pay for them every year they have them.  If 
> they stop paying they lose the resources.

I never said your proposal allowed anyone to corner the market.

It had no protection for related parties, so it would allow wide-scale abuse by 
entity creation.

Additionally, I am opposed in principle to handing out addresses without need. 
I’m willing to substantially relax the definition of need and I can see need 
for a single /24 being “I exist” just as I consider that valid need for a /48.

However, once you want an additional /24 or an additional /48, you need to show 
how you’ve outgrown your existing address space.

Note, a second physical location is, IMHO, sufficient for that.

I’d support policy that codified things in this way… In fact, I helped write 
IPv6 policy that comes very close to this notion which is the current IPv6 
policy.

I wouldn’t be opposed to authorizing IPv4 transfers on a similar basis.

> This is a miniscule amount of resources, and I respectfully submit it would 
> not appreciably change the availability of resources for anyone. It hasn’t in 
> other regions as Elvis pointed out.  It would however make a big difference 
> to small Organizations and level the playing field.

Your policy was never adopted in ANY region, so that claim remains unproven.

> We are not far apart conceptually but we are far apart in what actually 
> happens. 

I don’t think we are as far apart as you claim. I’ve never encountered a small 
organization for whom I couldn’t find a legitimate way to justify an ARIN 
allocation or assignment (whichever was appropriate to the organization).

I’ve handled a lot of requests for a lot of very small entities over the years. 
I’ve always found it more difficult to get a large amount of space for a large 
organization than to get a small amount of space for a small one.

That’s why I have trouble believing your claims that need justification 
prevents people from getting addresses.

Owen

>  
> Steven Ryerse
> President
> 100 Ashford Center North, Suite 110, Atlanta, GA  30338
> 770.656.1460 - Cell
> 770.399.9099- Office
>  
> ℠ Eclipse Networks, Inc.
> Conquering Complex Networks℠
>  
> From: Owen DeLong [mailto:o...@delong.com] 
> Sent: Friday, September 25, 2015 3:46 PM
> To: Steven Ryerse <srye...@eclipse-networks.com>
> Cc: Mike Winters <mwint...@edwardrose.com>; arin-ppml@arin.net
> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
> evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
>  
> Your proposal was to allow anyone to get a /24 per year whether they needed 
> anything or not.
>  
> I am not opposed to a policy which would allow organizations with lesser need 
> to obtain a minimum size block (/24 or /48) if the potential for abuse can be 
> adequately addressed.
>  
> By abuse, I mean, for example, the creation of entities with minimalist 
> infrastructure strictly for the sake of qualifying for addresses.
>  
> I’m all for the local bakery to be able to get a /24 to support their 3 cash 
> registers, a router, and a few menu board displays.
>  
> However, I’m not for VPNs-R-US being able to create 1024 entities each of 
> which owns an SRX-100 and qualifies for a /24 on that basis.
>  
> I don’t think resource policy should substantially change in a post-runout 
> world and nothing said so far gives me any reason to believe there is benefit 
> to the community from doing so.
>  
> This isn't about miserly blocking of allocations for future theoretical use. 
> This is about trying to make sure that organizations with need have the best 
> chance of getting resources they need that we can provide. Allowing 
> organizations without need to hoard addresses is contrary to that goal.
>  
> Interestingly, we seem to have the same goal but radically different opinions 
> on how best to achieve it.
>  
> Owen
>  
> On Sep 25, 2015, at 12:32 , Steven Ryerse <srye...@eclipse-networks.com 
> <mailto:srye...@eclipse-networks.com>> wrote:
>  
> I would probably agree with your comment that neither of the above really 
> helps anyone and probably creates a host of other issues. I would probably 
> not advocate them either but they would be more fair that the policies in 
> place now. 
>  
> Of course the easy fix is to allow Organizations of any size to easily get 
> the Minimum size block which I believe is now a

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Owen DeLong]

While it may have that desirable effect, it certainly also comes with several 
undesirable effects as well.

Owen

> On Sep 24, 2015, at 14:02 , Matthew Kaufman <matt...@matthew.at> wrote:
> 
> If you're right, doesn't that simply drive v6 adoption, which is the desired 
> goal?
> 
> 
> 
> Matthew Kaufman
> 
> On 9/24/2015 12:09 PM, Owen DeLong wrote:
>> Short answer: NO
>> 
>> Longer answer:
>> 
>> Finance alone does not reflect all community values. Eliminating needs-based 
>> evaluation for transfers
>> will foster an environment open to speculation and other artifice used to 
>> maximize the monetization of
>> address resources without providing the benefit to the community of 
>> maximizing utilization.
>> 
>> In fact, I believe that eliminating needs-basis will likely cause actual 
>> utilization to be reduced in the
>> long run in favor of financial manipulation.
>> 
>> Owen
>> 
>>> On Sep 24, 2015, at 11:55 , Leif Sawyer <lsaw...@gci.com> wrote:
>>> 
>>> Now that we've reached the magic ZERO in the free pool, what does the 
>>> community
>>> think about this new draft policy?
>>> 
>>> Should ARIN begin the process of streamlining the IPv4 policy so that it is
>>> geared more toward the transfer market, and remove "need" as a criteria in
>>> certain sections of the NRPM to increase the database accuracy?
>>> 
>>> 
>>> -Original Message-
>>> From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On 
>>> Behalf Of ARIN
>>> Sent: Wednesday, September 23, 2015 12:54 PM
>>> To: arin-ppml@arin.net
>>> Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
>>> evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
>>> 
>>> Draft Policy ARIN-2015-9
>>> Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers 
>>> of IPv4 netblocks
>>> 
>>> On 17 September 2015 the ARIN Advisory Council (AC) accepted
>>> "ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3, and 
>>> 8.4 transfers of IPv4 netblocks" as a Draft Policy.
>>> 
>>> Draft Policy ARIN-2015-9 is below and can be found at:
>>> https://www.arin.net/policy/proposals/2015_9.html
>>> 
>>> You are encouraged to discuss the merits and your concerns of Draft Policy 
>>> 2015-9 on the Public Policy Mailing List.
>>> 
>>> The AC will evaluate the discussion in order to assess the conformance of 
>>> this draft policy with ARIN's Principles of Internet Number Resource Policy 
>>> as stated in the PDP. Specifically, these principles are:
>>> 
>>>* Enabling Fair and Impartial Number Resource Administration
>>>* Technically Sound
>>>* Supported by the Community
>>> 
>>> The ARIN Policy Development Process (PDP) can be found at:
>>> https://www.arin.net/policy/pdp.html
>>> 
>>> Draft Policies and Proposals under discussion can be found at:
>>> https://www.arin.net/policy/proposals/index.html
>>> 
>>> Regards,
>>> 
>>> Communications and Member Services
>>> American Registry for Internet Numbers (ARIN)
>>> 
>>> 
>>> ## * ##
>>> 
>>> Draft Policy ARIN-2015-9
>>> Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers 
>>> of IPv4 netblocks
>>> 
>>> Date: 23 September 2015
>>> 
>>> Problem statement:
>>> 
>>> The current policies in NRPM sections 8.2, 8.3, and 8.4 regarding transfer 
>>> of IPv4 netblocks from one organization to another are currently a 
>>> hindrance in ensuring database accuracy. In practice, ARIN staff are 
>>> utilizing those polices to refuse to complete database updates which would 
>>> reflect an accurate transfer of control / utilization of netblocks in cases 
>>> where ARIN doesn't agree that the recipient organization has need, or more 
>>> often where the recipient organization bypasses the ARIN registry entirely 
>>> in order to secure the needed IPv4 netblocks in a more timely fashion 
>>> directly from the current holder.
>>> Additionally, the 8.1 introduction section includes a perceived "threat"
>>> of reclaim which serves as a hindrance to long-term resource holders 
>>> approaching ARIN with database updates when transferring resources. The 
>>> result is that the data vi

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Owen DeLong]

It’s not ARIN’s mission to prevent profits nor did I say it was.

My point is that Elvis support for removing policy is strongly influenced by 
the potential windfall he stands to reap while not actually providing
any internet services in the process if the policy is changed as he wishes.

As yo pointed out, many folks make a profit on various INETERNET SERVICES. 
Elvis, OTOH is not in the internet services business. He’s strictly
an address broker.

It would be sort of like Realtors arguing against transfer taxes on real 
estate. An argument based solely in greed rather than any actual concern for 
the common good.

Owen

> On Sep 24, 2015, at 13:53 , Steven Ryerse <srye...@eclipse-networks.com> 
> wrote:
> 
> Many folks make a profit on various Internet services in this Region. ARIN 
> was created to further the Internet and not stifle it.  Nowhere do I see that 
> it is part of ARIN's mission to somehow prevent profits via policies. Appears 
> to me to be all about the haves keeping the have nots from obtaining 
> resources.  :-( 
> 
> Steven Ryerse
> President
> 100 Ashford Center North, Suite 110, Atlanta, GA  30338
> 770.656.1460 - Cell
> 770.399.9099- Office
> 
> ℠ Eclipse Networks, Inc.
> Conquering Complex Networks℠
> 
> -Original Message-
> From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On 
> Behalf Of Owen DeLong
> Sent: Thursday, September 24, 2015 4:37 PM
> To: el...@velea.eu
> Cc: arin-ppml@arin.net
> Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
> evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
> 
> Of course your position wouldn’t have anything to do with the profits you 
> stand to make from an unrestricted transfer market.
> 
> Owen
> 
>> On Sep 24, 2015, at 13:12 , Elvis Daniel Velea <el...@velea.eu> wrote:
>> 
>> Hi Owen,
>> 
>> On 24/09/15 22:09, Owen DeLong wrote:
>>> Short answer: NO
>>> 
>>> Longer answer:
>>> 
>>> Finance alone does not reflect all community values. Eliminating 
>>> needs-based evaluation for transfers will foster an environment open 
>>> to speculation and other artifice used to maximize the monetization of 
>>> address resources without providing the benefit to the community of 
>>> maximizing utilization.
>> The environment open to speculation already exists, a needs-based criteria 
>> will not stop the ones that want to speculate. Keeping needs-based criteria 
>> in policy will only drive (keep some of the) transfers underground (ie: 
>> futures contracts, all kind of financial artifices). I actually believe the 
>> needs-based criteria removal will benefit the community by eliminating a 
>> barrier in the correct registration of the transfers (resources) in the 
>> registry (and whois).
>> 
>> The allocation era has passed, ARIN should just be a shepherd and record the 
>> transfers (and do the allocation exercise twice per year, when the IANA 
>> allocates the few crumbs remaining). From my experience and observations, if 
>> someone needs the IP addresses and has the money to pay for them I am sure 
>> that they will not be stopped by ARIN's needs-base criteria...
>>> In fact, I believe that eliminating needs-basis will likely cause 
>>> actual utilization to be reduced in the long run in favor of financial 
>>> manipulation.
>> I dare to disagree. From where I am standing, the removal of needs-basis 
>> criteria from the RIPE Region has increased utilization of the resources 
>> transferred through the IPv4 marketplace.
>> Additionally, the removal of the needs-basis criteria has increased the 
>> number of transfers, showing that the marketplace works and is useful to 
>> hundreds (or even thousands) of companies from the region.
>> 
>> I am not saying that the ARIN community should copy what the RIPE community 
>> has done. I am just saying that if something is working and it's usability 
>> is proven, it is rather strange to see some saying the opposite as an 
>> argument against the removal of the needs-based criteria.
>>> 
>>> Owen
>> cheers,
>> elvis
>>> 
>>>> On Sep 24, 2015, at 11:55 , Leif Sawyer <lsaw...@gci.com> wrote:
>>>> 
>>>> Now that we've reached the magic ZERO in the free pool, what does 
>>>> the community think about this new draft policy?
>>>> 
>>>> Should ARIN begin the process of streamlining the IPv4 policy so 
>>>> that it is geared more toward the transfer market, and remove "need" 
>>>> as a crite

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Elvis Daniel Velea]

Hi Richard,

On 25/09/15 06:46, Richard J. Letts wrote:

b)
There is no definitive outcome from the policy change, which makes me feel that 
it's not worth changing -- the problem statement argument is weak at best.
the outcome is that everyone that will need IP addresses will be able to 
get them. Isn't that quite definitive and clear?


It is potentially enabling organizations with more money than need gain more 
resources, potentially at the expense of non-profit and educational 
organizations who might not be able to raise cash for additional IPv4 space [or 
equipment to support a transition to IPv6].
So, you think that in today's market the non-profit/educational 
organizations will have the chance at getting some of the IP space from 
the market? And if the needs-based barrier is removed, they will no 
longer have that chance?
Everyone knows that the IP address is now an asset and is worth a buck. 
Who do you think will say: I'll give it for free to this educational 
organization (because they have proven the need to ARIN) instead of 
giving it for money to this commercial entity (that may or may not have 
a demonstrated need need for it).


I think we need to wake up. Keeping needs-based criteria in the policy 
will only cause SOME transfers to be driven underground and block some 
others.

Changing policy just to (potentially) improve the accuracy of a database seems 
not worth the (potential) risk.
The change of the accuracy of the registry is already proven in the RIPE 
region. I would say it's not just potential, it is real and visible.


Richard

regards,
Elvis



From: arin-ppml-boun...@arin.net <arin-ppml-boun...@arin.net> on behalf of Dani 
Roisman <drois...@softlayer.com>
Sent: Thursday, September 24, 2015 6:20 PM
To: arin-ppml@arin.net
Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

| Date: Wed, 23 Sep 2015 16:53:59 -0400
| From: ARIN <i...@arin.net>
| To: arin-ppml@arin.net
| Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based
|   evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
| Message-ID: <56031167.1010...@arin.net>
| Content-Type: text/plain; charset=utf-8; format=flowed
|
| Draft Policy ARIN-2015-9
| Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4
| transfers of IPv4 netblocks
|
| On 17 September 2015 the ARIN Advisory Council (AC) accepted
| "ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3,
| and 8.4 transfers of IPv4 netblocks" as a Draft Policy.
|
| Draft Policy ARIN-2015-9 is below and can be found at:
| https://www.arin.net/policy/proposals/2015_9.html

Greetings,

There has been some stimulating dialog about the merits of 2015-9.  I'd like to 
ask that in addition to any overall support or lack thereof, you also review 
the policy language and comment specifically on the changes proposed:
a) For those of you generally in support of this effort, are there any 
refinements to the changes made which you think will improve this should these 
policy changes be implemented?
b) For those of you generally opposed to this effort, are there any adjustments 
to the policy changes which, if implemented, would gain your support?

--
Dani Roisman
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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Owen DeLong]

Richard did a pretty good job of expressing my thoughts as well.

Owen

> On Sep 24, 2015, at 20:46 , Richard J. Letts <rjle...@uw.edu> wrote:
> 
> b) 
> There is no definitive outcome from the policy change, which makes me feel 
> that it's not worth changing -- the problem statement argument is weak at 
> best.
> 
> It is potentially enabling organizations with more money than need gain more 
> resources, potentially at the expense of non-profit and educational 
> organizations who might not be able to raise cash for additional IPv4 space 
> [or equipment to support a transition to IPv6]. Changing policy just to 
> (potentially) improve the accuracy of a database seems not worth the 
> (potential) risk.
> 
> Richard
> 
> 
> 
> From: arin-ppml-boun...@arin.net <arin-ppml-boun...@arin.net> on behalf of 
> Dani Roisman <drois...@softlayer.com>
> Sent: Thursday, September 24, 2015 6:20 PM
> To: arin-ppml@arin.net
> Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
> evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
> 
> | Date: Wed, 23 Sep 2015 16:53:59 -0400
> | From: ARIN <i...@arin.net>
> | To: arin-ppml@arin.net
> | Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based
> |   evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
> | Message-ID: <56031167.1010...@arin.net>
> | Content-Type: text/plain; charset=utf-8; format=flowed
> |
> | Draft Policy ARIN-2015-9
> | Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4
> | transfers of IPv4 netblocks
> |
> | On 17 September 2015 the ARIN Advisory Council (AC) accepted
> | "ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3,
> | and 8.4 transfers of IPv4 netblocks" as a Draft Policy.
> |
> | Draft Policy ARIN-2015-9 is below and can be found at:
> | https://www.arin.net/policy/proposals/2015_9.html
> 
> Greetings,
> 
> There has been some stimulating dialog about the merits of 2015-9.  I'd like 
> to ask that in addition to any overall support or lack thereof, you also 
> review the policy language and comment specifically on the changes proposed:
> a) For those of you generally in support of this effort, are there any 
> refinements to the changes made which you think will improve this should 
> these policy changes be implemented?
> b) For those of you generally opposed to this effort, are there any 
> adjustments to the policy changes which, if implemented, would gain your 
> support?
> 
> --
> Dani Roisman
> ___
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> ___
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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Leif Sawyer]

Now that we've reached the magic ZERO in the free pool, what does the community
think about this new draft policy?

Should ARIN begin the process of streamlining the IPv4 policy so that it is
geared more toward the transfer market, and remove "need" as a criteria in
certain sections of the NRPM to increase the database accuracy?


-Original Message-
From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On Behalf 
Of ARIN
Sent: Wednesday, September 23, 2015 12:54 PM
To: arin-ppml@arin.net
Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

Draft Policy ARIN-2015-9
Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of 
IPv4 netblocks

On 17 September 2015 the ARIN Advisory Council (AC) accepted
"ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 
transfers of IPv4 netblocks" as a Draft Policy.

Draft Policy ARIN-2015-9 is below and can be found at:
https://www.arin.net/policy/proposals/2015_9.html

You are encouraged to discuss the merits and your concerns of Draft Policy 
2015-9 on the Public Policy Mailing List.

The AC will evaluate the discussion in order to assess the conformance of this 
draft policy with ARIN's Principles of Internet Number Resource Policy as 
stated in the PDP. Specifically, these principles are:

* Enabling Fair and Impartial Number Resource Administration
* Technically Sound
* Supported by the Community

The ARIN Policy Development Process (PDP) can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)


## * ##

Draft Policy ARIN-2015-9
Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of 
IPv4 netblocks

Date: 23 September 2015

Problem statement:

The current policies in NRPM sections 8.2, 8.3, and 8.4 regarding transfer of 
IPv4 netblocks from one organization to another are currently a hindrance in 
ensuring database accuracy. In practice, ARIN staff are utilizing those polices 
to refuse to complete database updates which would reflect an accurate transfer 
of control / utilization of netblocks in cases where ARIN doesn't agree that 
the recipient organization has need, or more often where the recipient 
organization bypasses the ARIN registry entirely in order to secure the needed 
IPv4 netblocks in a more timely fashion directly from the current holder. 
Additionally, the 8.1 introduction section includes a perceived "threat" 
of reclaim which serves as a hindrance to long-term resource holders 
approaching ARIN with database updates when transferring resources. The result 
is that the data visible in ARIN registry continues to become more inaccurate 
over time.

Policy statement:

This proposal is for the following language changes in the respective NRPM 
sections in order to eliminate all needs-based evaluation for the respective 
transfer type, and allow 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 3rd paragraph which begins with "Number resources are issued, 
based on justified need, to organizations. . ." since it mostly reiterates 
other sections of ARIN policy. All transfers are subjected to those policies, 
as called out in 8.2, 8.3, 8.4. Additionally, removing this paragraph removes 
the perceived "threat" of reclaim which serves as a hindrance to long-term 
resource holders approaching ARIN with database updates, since in practice ARIN 
has not been forcibly reclaiming IP resources assigned to "failed businesses."

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 or inspection of current or 
future utilization rate."

- Remove entirely the last paragraph which reads "In the event that number 
resources of the combined organizations are no longer justified under ARIN 
policy at the time ARIN becomes aware of the transaction, through a transfer 
request or otherwise, ARIN will work with the resource holder(s) to return or 
transfer resources as needed to restore compliance via the processes outlined 
in current 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

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Steven Ryerse]

I couldn't agree more!

Steven Ryerse
President
100 Ashford Center North, Suite 110, Atlanta, GA  30338
770.656.1460 - Cell
770.399.9099- Office

℠ Eclipse Networks, Inc.
     Conquering Complex Networks℠

-Original Message-
From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On Behalf 
Of Mike Burns
Sent: Thursday, September 24, 2015 3:35 PM
To: Leif Sawyer <lsaw...@gci.com>; arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks


- Original Message -
From: "Leif Sawyer" <lsaw...@gci.com>

> Should ARIN begin the process of streamlining the IPv4 policy so that 
> it is geared more toward the transfer market, and remove "need" as a 
> criteria in certain sections of the NRPM to increase the database 
> accuracy?
>
>
Hi Leif,

Yes. The community distributed the addresses appropriately, IMO.
Now it's time to step back and let the market work to conserve addresses and 
bring them into their highest and best use.
And reap the rewards in increased Whois acccuracy, more efficient transfers, 
and less cost to the ARIN community.

Regards,
Mike Burns

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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Elvis Daniel Velea]

+1

Keeping needs basis in the NRPM will only drive the transfers 
underground. Some are already using all kind of financial tricks 
(futures contracts, lease contracts, etc) and are waiting for the needs 
basis criteria to be removed from NRPM in order to register the 
transfers in the ARIN Registry.


The Registry/Whois will win most from the removal of needs basis from 
the NRPM and process streamlining.


regards,
elvis

On 24/09/15 22:36, Steven Ryerse wrote:

I couldn't agree more!

Steven Ryerse
President
100 Ashford Center North, Suite 110, Atlanta, GA  30338
770.656.1460 - Cell
770.399.9099- Office

℠ Eclipse Networks, Inc.
  Conquering Complex Networks℠

-Original Message-
From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On Behalf 
Of Mike Burns
Sent: Thursday, September 24, 2015 3:35 PM
To: Leif Sawyer <lsaw...@gci.com>; arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks


- Original Message -
From: "Leif Sawyer" <lsaw...@gci.com>


Should ARIN begin the process of streamlining the IPv4 policy so that
it is geared more toward the transfer market, and remove "need" as a
criteria in certain sections of the NRPM to increase the database
accuracy?



Hi Leif,

Yes. The community distributed the addresses appropriately, IMO.
Now it's time to step back and let the market work to conserve addresses and 
bring them into their highest and best use.
And reap the rewards in increased Whois acccuracy, more efficient transfers, 
and less cost to the ARIN community.

Regards,
Mike Burns

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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[John Curran]

On Sep 24, 2015, at 3:51 PM, Elvis Daniel Velea  wrote:
> 
> +1
> 
> Keeping needs basis in the NRPM will only drive the transfers underground. 
> Some are already using all kind of financial tricks (futures contracts, lease 
> contracts, etc) and are waiting for the needs basis criteria to be removed 
> from NRPM in order to register the transfers in the ARIN Registry.
> 
> The Registry/Whois will win most from the removal of needs basis from the 
> NRPM and process streamlining.

Elvis - 

   To be clear, there is nothing “improper” about a future or option contract 
if two
   private parties decide to engage in such (and I can imagine cases where such
   an arrangement might make sense regardless of state of IPv4 transfer policy.)

   This does not detract from the your point that the usefulness of the 
registry is 
   maximum when the party actually using the address block is the registrant
   (and hence transfer policies which even indirectly encourage other outcomes
   reduce its functionality, e.g. for operations, etc.)

   There are even cases where loaning/leasing of address blocks may make sense;
   I believe your point is that we don’t want to see these sorts of 
arrangements appear
   (in circumstances beyond their normal useful roles) as alternatives to 
transfers
   simply as a result of transfer policy hurdles - is that correct?

Thanks,
/John

John Curran
President and CEO
ARIN
 
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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Owen DeLong]

Short answer: NO

Longer answer:

Finance alone does not reflect all community values. Eliminating needs-based 
evaluation for transfers
will foster an environment open to speculation and other artifice used to 
maximize the monetization of
address resources without providing the benefit to the community of maximizing 
utilization.

In fact, I believe that eliminating needs-basis will likely cause actual 
utilization to be reduced in the
long run in favor of financial manipulation.

Owen

> On Sep 24, 2015, at 11:55 , Leif Sawyer <lsaw...@gci.com> wrote:
> 
> Now that we've reached the magic ZERO in the free pool, what does the 
> community
> think about this new draft policy?
> 
> Should ARIN begin the process of streamlining the IPv4 policy so that it is
> geared more toward the transfer market, and remove "need" as a criteria in
> certain sections of the NRPM to increase the database accuracy?
> 
> 
> -Original Message-
> From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On 
> Behalf Of ARIN
> Sent: Wednesday, September 23, 2015 12:54 PM
> To: arin-ppml@arin.net
> Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
> evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
> 
> Draft Policy ARIN-2015-9
> Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of 
> IPv4 netblocks
> 
> On 17 September 2015 the ARIN Advisory Council (AC) accepted
> "ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3, and 
> 8.4 transfers of IPv4 netblocks" as a Draft Policy.
> 
> Draft Policy ARIN-2015-9 is below and can be found at:
> https://www.arin.net/policy/proposals/2015_9.html
> 
> You are encouraged to discuss the merits and your concerns of Draft Policy 
> 2015-9 on the Public Policy Mailing List.
> 
> The AC will evaluate the discussion in order to assess the conformance of 
> this draft policy with ARIN's Principles of Internet Number Resource Policy 
> as stated in the PDP. Specifically, these principles are:
> 
>* Enabling Fair and Impartial Number Resource Administration
>* Technically Sound
>* Supported by the Community
> 
> The ARIN Policy Development Process (PDP) can be found at:
> https://www.arin.net/policy/pdp.html
> 
> Draft Policies and Proposals under discussion can be found at:
> https://www.arin.net/policy/proposals/index.html
> 
> Regards,
> 
> Communications and Member Services
> American Registry for Internet Numbers (ARIN)
> 
> 
> ## * ##
> 
> Draft Policy ARIN-2015-9
> Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of 
> IPv4 netblocks
> 
> Date: 23 September 2015
> 
> Problem statement:
> 
> The current policies in NRPM sections 8.2, 8.3, and 8.4 regarding transfer of 
> IPv4 netblocks from one organization to another are currently a hindrance in 
> ensuring database accuracy. In practice, ARIN staff are utilizing those 
> polices to refuse to complete database updates which would reflect an 
> accurate transfer of control / utilization of netblocks in cases where ARIN 
> doesn't agree that the recipient organization has need, or more often where 
> the recipient organization bypasses the ARIN registry entirely in order to 
> secure the needed IPv4 netblocks in a more timely fashion directly from the 
> current holder. 
> Additionally, the 8.1 introduction section includes a perceived "threat" 
> of reclaim which serves as a hindrance to long-term resource holders 
> approaching ARIN with database updates when transferring resources. The 
> result is that the data visible in ARIN registry continues to become more 
> inaccurate over time.
> 
> Policy statement:
> 
> This proposal is for the following language changes in the respective NRPM 
> sections in order to eliminate all needs-based evaluation for the respective 
> transfer type, and allow 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 3rd paragraph which begins with "Number resources are issued, 
> based on justified need, to organizations. . ." since it mostly reiterates 
> other sections of ARIN policy. All transfers are subjected to those policies, 
> as called out in 8.2, 8.3, 8.4. Additionally, removing this paragraph removes 
> the perceived "threat" of reclaim which serves as a hindrance to long-term 
> resource holders approaching ARIN with database updates, since in practice 
> ARIN has not been forcibly reclaiming IP resources assigned to "failed 
> businesses."
> 
> Section 8.2 Mergers and Acqu

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Elvis Daniel Velea]

Hi John,

On 24/09/15 23:16, John Curran wrote:

On Sep 24, 2015, at 3:51 PM, Elvis Daniel Velea  wrote:

+1

Keeping needs basis in the NRPM will only drive the transfers underground. Some 
are already using all kind of financial tricks (futures contracts, lease 
contracts, etc) and are waiting for the needs basis criteria to be removed from 
NRPM in order to register the transfers in the ARIN Registry.

The Registry/Whois will win most from the removal of needs basis from the NRPM 
and process streamlining.

Elvis -

To be clear, there is nothing “improper” about a future or option contract 
if two
private parties decide to engage in such (and I can imagine cases where such
an arrangement might make sense regardless of state of IPv4 transfer 
policy.)

correct.


This does not detract from the your point that the usefulness of the 
registry is
maximum when the party actually using the address block is the registrant
(and hence transfer policies which even indirectly encourage other outcomes
reduce its functionality, e.g. for operations, etc.)
And I believe that some financial 'tricks' are used instead of just 
registration in the registry/whois.


There are even cases where loaning/leasing of address blocks may make sense;

that's true..

I believe your point is that we don’t want to see these sorts of 
arrangements appear
(in circumstances beyond their normal useful roles) as alternatives to 
transfers
simply as a result of transfer policy hurdles - is that correct?
You got my point. I would rather see needs-based criteria removed in 
place of having all kind of documents hidden in archives as alternative 
for the transfer.


Thanks,
/John

John Curran
President and CEO
ARIN
  

regards,
elvis
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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Steven Ryerse]

Many folks make a profit on various Internet services in this Region. ARIN was 
created to further the Internet and not stifle it.  Nowhere do I see that it is 
part of ARIN's mission to somehow prevent profits via policies. Appears to me 
to be all about the haves keeping the have nots from obtaining resources.  :-( 

Steven Ryerse
President
100 Ashford Center North, Suite 110, Atlanta, GA  30338
770.656.1460 - Cell
770.399.9099- Office

℠ Eclipse Networks, Inc.
     Conquering Complex Networks℠

-Original Message-
From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On Behalf 
Of Owen DeLong
Sent: Thursday, September 24, 2015 4:37 PM
To: el...@velea.eu
Cc: arin-ppml@arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

Of course your position wouldn’t have anything to do with the profits you stand 
to make from an unrestricted transfer market.

Owen

> On Sep 24, 2015, at 13:12 , Elvis Daniel Velea <el...@velea.eu> wrote:
> 
> Hi Owen,
> 
> On 24/09/15 22:09, Owen DeLong wrote:
>> Short answer: NO
>> 
>> Longer answer:
>> 
>> Finance alone does not reflect all community values. Eliminating 
>> needs-based evaluation for transfers will foster an environment open 
>> to speculation and other artifice used to maximize the monetization of 
>> address resources without providing the benefit to the community of 
>> maximizing utilization.
> The environment open to speculation already exists, a needs-based criteria 
> will not stop the ones that want to speculate. Keeping needs-based criteria 
> in policy will only drive (keep some of the) transfers underground (ie: 
> futures contracts, all kind of financial artifices). I actually believe the 
> needs-based criteria removal will benefit the community by eliminating a 
> barrier in the correct registration of the transfers (resources) in the 
> registry (and whois).
> 
> The allocation era has passed, ARIN should just be a shepherd and record the 
> transfers (and do the allocation exercise twice per year, when the IANA 
> allocates the few crumbs remaining). From my experience and observations, if 
> someone needs the IP addresses and has the money to pay for them I am sure 
> that they will not be stopped by ARIN's needs-base criteria...
>> In fact, I believe that eliminating needs-basis will likely cause 
>> actual utilization to be reduced in the long run in favor of financial 
>> manipulation.
> I dare to disagree. From where I am standing, the removal of needs-basis 
> criteria from the RIPE Region has increased utilization of the resources 
> transferred through the IPv4 marketplace.
> Additionally, the removal of the needs-basis criteria has increased the 
> number of transfers, showing that the marketplace works and is useful to 
> hundreds (or even thousands) of companies from the region.
> 
> I am not saying that the ARIN community should copy what the RIPE community 
> has done. I am just saying that if something is working and it's usability is 
> proven, it is rather strange to see some saying the opposite as an argument 
> against the removal of the needs-based criteria.
>> 
>> Owen
> cheers,
> elvis
>> 
>>> On Sep 24, 2015, at 11:55 , Leif Sawyer <lsaw...@gci.com> wrote:
>>> 
>>> Now that we've reached the magic ZERO in the free pool, what does 
>>> the community think about this new draft policy?
>>> 
>>> Should ARIN begin the process of streamlining the IPv4 policy so 
>>> that it is geared more toward the transfer market, and remove "need" 
>>> as a criteria in certain sections of the NRPM to increase the database 
>>> accuracy?
>>> 
>>> 
>>> -----Original Message-
>>> From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] 
>>> On Behalf Of ARIN
>>> Sent: Wednesday, September 23, 2015 12:54 PM
>>> To: arin-ppml@arin.net
>>> Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating 
>>> needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of 
>>> IPv4 netblocks
>>> 
>>> Draft Policy ARIN-2015-9
>>> Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 
>>> transfers of IPv4 netblocks
>>> 
>>> On 17 September 2015 the ARIN Advisory Council (AC) accepted
>>> "ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3, and 
>>> 8.4 transfers of IPv4 netblocks" as a Draft Policy.
>>> 
>>> Draft Policy ARIN-2015-9 is below and can be found at:
>>> https://www.arin.net/p

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Matthew Kaufman]

And your position has nothing to do with what you stand to gain as IPv6 
becomes more popular and yet IPv4 isn't so constrained as to hamper 
traffic growth.


Why don't we instead completely refrain from allegations of wrongdoing 
with regard to one's opinions about the policies?


Matthew Kaufman

On 9/24/2015 1:37 PM, Owen DeLong wrote:

Of course your position wouldn’t have anything to do with the profits you stand 
to make from an unrestricted transfer market.

Owen


On Sep 24, 2015, at 13:12 , Elvis Daniel Velea <el...@velea.eu> wrote:

Hi Owen,

On 24/09/15 22:09, Owen DeLong wrote:

Short answer: NO

Longer answer:

Finance alone does not reflect all community values. Eliminating needs-based 
evaluation for transfers
will foster an environment open to speculation and other artifice used to 
maximize the monetization of
address resources without providing the benefit to the community of maximizing 
utilization.

The environment open to speculation already exists, a needs-based criteria will 
not stop the ones that want to speculate. Keeping needs-based criteria in 
policy will only drive (keep some of the) transfers underground (ie: futures 
contracts, all kind of financial artifices). I actually believe the needs-based 
criteria removal will benefit the community by eliminating a barrier in the 
correct registration of the transfers (resources) in the registry (and whois).

The allocation era has passed, ARIN should just be a shepherd and record the 
transfers (and do the allocation exercise twice per year, when the IANA 
allocates the few crumbs remaining). From my experience and observations, if 
someone needs the IP addresses and has the money to pay for them I am sure that 
they will not be stopped by ARIN's needs-base criteria...

In fact, I believe that eliminating needs-basis will likely cause actual 
utilization to be reduced in the
long run in favor of financial manipulation.

I dare to disagree. From where I am standing, the removal of needs-basis 
criteria from the RIPE Region has increased utilization of the resources 
transferred through the IPv4 marketplace.
Additionally, the removal of the needs-basis criteria has increased the number 
of transfers, showing that the marketplace works and is useful to hundreds (or 
even thousands) of companies from the region.

I am not saying that the ARIN community should copy what the RIPE community has 
done. I am just saying that if something is working and it's usability is 
proven, it is rather strange to see some saying the opposite as an argument 
against the removal of the needs-based criteria.

Owen

cheers,
elvis

On Sep 24, 2015, at 11:55 , Leif Sawyer <lsaw...@gci.com> wrote:

Now that we've reached the magic ZERO in the free pool, what does the community
think about this new draft policy?

Should ARIN begin the process of streamlining the IPv4 policy so that it is
geared more toward the transfer market, and remove "need" as a criteria in
certain sections of the NRPM to increase the database accuracy?


-Original Message-
From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On Behalf 
Of ARIN
Sent: Wednesday, September 23, 2015 12:54 PM
To: arin-ppml@arin.net
Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

Draft Policy ARIN-2015-9
Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of 
IPv4 netblocks

On 17 September 2015 the ARIN Advisory Council (AC) accepted
"ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 
transfers of IPv4 netblocks" as a Draft Policy.

Draft Policy ARIN-2015-9 is below and can be found at:
https://www.arin.net/policy/proposals/2015_9.html

You are encouraged to discuss the merits and your concerns of Draft Policy 
2015-9 on the Public Policy Mailing List.

The AC will evaluate the discussion in order to assess the conformance of this 
draft policy with ARIN's Principles of Internet Number Resource Policy as 
stated in the PDP. Specifically, these principles are:

* Enabling Fair and Impartial Number Resource Administration
* Technically Sound
* Supported by the Community

The ARIN Policy Development Process (PDP) can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)


## * ##

Draft Policy ARIN-2015-9
Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of 
IPv4 netblocks

Date: 23 September 2015

Problem statement:

The current policies in NRPM sections 8.2, 8.3, and 8.4 regarding transfer of 
IPv4 netblocks from one organization to another are currently a hindrance in 
ensuring database accuracy. In practice, ARIN staff are utilizing those polices 
to refuse to complete data

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Matthew Kaufman]

If you're right, doesn't that simply drive v6 adoption, which is the 
desired goal?




Matthew Kaufman

On 9/24/2015 12:09 PM, Owen DeLong wrote:

Short answer: NO

Longer answer:

Finance alone does not reflect all community values. Eliminating needs-based 
evaluation for transfers
will foster an environment open to speculation and other artifice used to 
maximize the monetization of
address resources without providing the benefit to the community of maximizing 
utilization.

In fact, I believe that eliminating needs-basis will likely cause actual 
utilization to be reduced in the
long run in favor of financial manipulation.

Owen


On Sep 24, 2015, at 11:55 , Leif Sawyer <lsaw...@gci.com> wrote:

Now that we've reached the magic ZERO in the free pool, what does the community
think about this new draft policy?

Should ARIN begin the process of streamlining the IPv4 policy so that it is
geared more toward the transfer market, and remove "need" as a criteria in
certain sections of the NRPM to increase the database accuracy?


-Original Message-
From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On Behalf 
Of ARIN
Sent: Wednesday, September 23, 2015 12:54 PM
To: arin-ppml@arin.net
Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

Draft Policy ARIN-2015-9
Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of 
IPv4 netblocks

On 17 September 2015 the ARIN Advisory Council (AC) accepted
"ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 
transfers of IPv4 netblocks" as a Draft Policy.

Draft Policy ARIN-2015-9 is below and can be found at:
https://www.arin.net/policy/proposals/2015_9.html

You are encouraged to discuss the merits and your concerns of Draft Policy 
2015-9 on the Public Policy Mailing List.

The AC will evaluate the discussion in order to assess the conformance of this 
draft policy with ARIN's Principles of Internet Number Resource Policy as 
stated in the PDP. Specifically, these principles are:

* Enabling Fair and Impartial Number Resource Administration
* Technically Sound
* Supported by the Community

The ARIN Policy Development Process (PDP) can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)


## * ##

Draft Policy ARIN-2015-9
Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of 
IPv4 netblocks

Date: 23 September 2015

Problem statement:

The current policies in NRPM sections 8.2, 8.3, and 8.4 regarding transfer of 
IPv4 netblocks from one organization to another are currently a hindrance in 
ensuring database accuracy. In practice, ARIN staff are utilizing those polices 
to refuse to complete database updates which would reflect an accurate transfer 
of control / utilization of netblocks in cases where ARIN doesn't agree that 
the recipient organization has need, or more often where the recipient 
organization bypasses the ARIN registry entirely in order to secure the needed 
IPv4 netblocks in a more timely fashion directly from the current holder.
Additionally, the 8.1 introduction section includes a perceived "threat"
of reclaim which serves as a hindrance to long-term resource holders 
approaching ARIN with database updates when transferring resources. The result 
is that the data visible in ARIN registry continues to become more inaccurate 
over time.

Policy statement:

This proposal is for the following language changes in the respective NRPM 
sections in order to eliminate all needs-based evaluation for the respective 
transfer type, and allow 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 3rd paragraph which begins with "Number resources are issued, based on justified need, to 
organizations. . ." since it mostly reiterates other sections of ARIN policy. All transfers are 
subjected to those policies, as called out in 8.2, 8.3, 8.4. Additionally, removing this paragraph removes 
the perceived "threat" of reclaim which serves as a hindrance to long-term resource holders 
approaching ARIN with database updates, since in practice ARIN has not been forcibly reclaiming IP resources 
assigned to "failed businesses."

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 or inspection of current or future 
utilization rate."

- Remove entire

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Elvis Daniel Velea]

Owen,

if someone needs an IPv4 transfer and wants to use our brokerage firm, 
believe me we will be happy to assist them and help them get what they 
need (regardless of whether the needs-based criteria is still in the 
policy or not). Off course, we will do everything to respect the 
policies of (all of) the RIRs while helping our customers get what they 
want.


An unrestricted transfer market may increase the number of transfers we 
broker - that's true, but in the end 'the money' (you call it profits) 
will be the same. The number of available (read: unused and ready to be 
transferred) IP addresses will not change, we (the brokers) will broker 
them regardless of who the buyer is. What will change is the correct 
registration (in place of the contracts hidden in a drawer in a lawyer's 
office).


There is almost a /12 unmet (read: justified) on the ARIN waiting list.. 
in 2.5 months. We won't probably be able to keep up with the number of 
companies receiving approvals from ARIN, so.. no I have worries about 
our 'profits'. What I worry about is that, maybe, those that have the 
funds will buy the resources and not keep a proper registration because 
either the policy is too restrictive to them, their employee has not 
succeeded in convincing the ARIN staff or their future usage plans were 
maybe not clear enough.


Again, from my experience (we've brokered more than a /11 in the 2 years 
since our company exists) if someone has the money for it and wants it, 
they will get it .


regards,
elvis

On 24/09/15 23:37, Owen DeLong wrote:

Of course your position wouldn’t have anything to do with the profits you stand 
to make from an unrestricted transfer market.

Owen


On Sep 24, 2015, at 13:12 , Elvis Daniel Velea <el...@velea.eu> wrote:

Hi Owen,

On 24/09/15 22:09, Owen DeLong wrote:

Short answer: NO

Longer answer:

Finance alone does not reflect all community values. Eliminating needs-based 
evaluation for transfers
will foster an environment open to speculation and other artifice used to 
maximize the monetization of
address resources without providing the benefit to the community of maximizing 
utilization.

The environment open to speculation already exists, a needs-based criteria will 
not stop the ones that want to speculate. Keeping needs-based criteria in 
policy will only drive (keep some of the) transfers underground (ie: futures 
contracts, all kind of financial artifices). I actually believe the needs-based 
criteria removal will benefit the community by eliminating a barrier in the 
correct registration of the transfers (resources) in the registry (and whois).

The allocation era has passed, ARIN should just be a shepherd and record the 
transfers (and do the allocation exercise twice per year, when the IANA 
allocates the few crumbs remaining). From my experience and observations, if 
someone needs the IP addresses and has the money to pay for them I am sure that 
they will not be stopped by ARIN's needs-base criteria...

In fact, I believe that eliminating needs-basis will likely cause actual 
utilization to be reduced in the
long run in favor of financial manipulation.

I dare to disagree. From where I am standing, the removal of needs-basis 
criteria from the RIPE Region has increased utilization of the resources 
transferred through the IPv4 marketplace.
Additionally, the removal of the needs-basis criteria has increased the number 
of transfers, showing that the marketplace works and is useful to hundreds (or 
even thousands) of companies from the region.

I am not saying that the ARIN community should copy what the RIPE community has 
done. I am just saying that if something is working and it's usability is 
proven, it is rather strange to see some saying the opposite as an argument 
against the removal of the needs-based criteria.

Owen

cheers,
elvis

On Sep 24, 2015, at 11:55 , Leif Sawyer <lsaw...@gci.com> wrote:

Now that we've reached the magic ZERO in the free pool, what does the community
think about this new draft policy?

Should ARIN begin the process of streamlining the IPv4 policy so that it is
geared more toward the transfer market, and remove "need" as a criteria in
certain sections of the NRPM to increase the database accuracy?


-Original Message-
From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On Behalf 
Of ARIN
Sent: Wednesday, September 23, 2015 12:54 PM
To: arin-ppml@arin.net
Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

Draft Policy ARIN-2015-9
Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of 
IPv4 netblocks

On 17 September 2015 the ARIN Advisory Council (AC) accepted
"ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 
transfers of IPv4 netblocks" as a Draft Policy.

Draft Policy ARIN-2015-9 is below and can be found at:
https://www.arin.net/p

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Brett Frankenberger]

On Thu, Sep 24, 2015 at 10:51:29PM +0300, Elvis Daniel Velea wrote:
> +1
> 
> Keeping needs basis in the NRPM will only drive the transfers underground.
> Some are already using all kind of financial tricks (futures contracts,
> lease contracts, etc) and are waiting for the needs basis criteria to be
> removed from NRPM in order to register the transfers in the ARIN Registry.

Requiring that the transfer be handled completely underground adds risk
and cost to a transaction that would be less risky and less expensive
if it could be handled completely above board and recorded in ARIN's
records.

That additional cost and risk will cause some people who can't justify
their need (as defined in ARIN policies) to forgo an underground
transfer.  And that will have the effect of reducing the volume of
non-needs-based transfers.

So it's not true that the *only* effect of the needs basis is to drive
transfers underground.  It does that with some transfers; it also
prevents some transfers.

Some people might rationally believe that that's a benefit, and enough
of a benefit to offset the costs of having IP addresses in defacto use
by parties other than those listed in the ARIN database.  (I'm not
agreeing with that position; just commenting on it's existence.)

What's more interesting is that the speculative transfers are possibly
the ones least impacted by forcing them underground.  If I want to
acquire IP addresses today to use on my operational network tomorrow
(but in a manner that won't meet ARIN's criteria for justified need),
there's risk to me doing an underground transaction, because it
increases the difficultly associated with getting the IP address space
that I acquire routed on the public Internet, and with resolving issues
should someone else announce the space.

On the other hand, if I want to acquire IP addresses today, for the
purpose of reselling them for a higher price at some point in the
future, there's much less reason for me to be concerned about an
underground transfer.  I contract for the right to direct the current
owner to transfer them as I see fit (and to direct the current owner to
not route them on the public Internet -- to make sure he doesn't
reputationally damage them), and then I wait until the price goes up to
the point where I want to sell.  At that point, I find a buyer who can
satisfy ARIN's needs-based jutification, and I direct that the
addresses be transferred to him.  He has no trouble routing them on the
public Internet because it's an ARIN-recognized transfer.  I got to
engage in my intended speculation (and the IP addresses remained idle,
because the original (and ARIN-recognized) holder of the space couldn't
use them or transfer them, because he was contractually prohibited from
doing so).

Obviously, the inability to register the initial transaction with ARIN
creates some risk.  For example, the original holder could "sell" his
addresses multiple times, and the buyers only resources would be to sue
him when the duplicity was discovered; by then, he might have made
himself judgement proof.  Certainly the multiple-sale case is also
possible with an underground transfer to a recipient who uses the
addresses on the public Internet immediately, but it's harder to sell
addresses a second time when the first buyer is currently routing them
on the public Internet.  

Still, the point stands that the burden imposed by needs-based policies
is at least arguably higher on buyers that want to use the addresses
now is higher than the burden imposed on speculators.

> The Registry/Whois will win most from the removal of needs basis from the
> NRPM and process streamlining.

 -- Brett
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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Owen DeLong]

Of course your position wouldn’t have anything to do with the profits you stand 
to make from an unrestricted transfer market.

Owen

> On Sep 24, 2015, at 13:12 , Elvis Daniel Velea <el...@velea.eu> wrote:
> 
> Hi Owen,
> 
> On 24/09/15 22:09, Owen DeLong wrote:
>> Short answer: NO
>> 
>> Longer answer:
>> 
>> Finance alone does not reflect all community values. Eliminating needs-based 
>> evaluation for transfers
>> will foster an environment open to speculation and other artifice used to 
>> maximize the monetization of
>> address resources without providing the benefit to the community of 
>> maximizing utilization.
> The environment open to speculation already exists, a needs-based criteria 
> will not stop the ones that want to speculate. Keeping needs-based criteria 
> in policy will only drive (keep some of the) transfers underground (ie: 
> futures contracts, all kind of financial artifices). I actually believe the 
> needs-based criteria removal will benefit the community by eliminating a 
> barrier in the correct registration of the transfers (resources) in the 
> registry (and whois).
> 
> The allocation era has passed, ARIN should just be a shepherd and record the 
> transfers (and do the allocation exercise twice per year, when the IANA 
> allocates the few crumbs remaining). From my experience and observations, if 
> someone needs the IP addresses and has the money to pay for them I am sure 
> that they will not be stopped by ARIN's needs-base criteria...
>> In fact, I believe that eliminating needs-basis will likely cause actual 
>> utilization to be reduced in the
>> long run in favor of financial manipulation.
> I dare to disagree. From where I am standing, the removal of needs-basis 
> criteria from the RIPE Region has increased utilization of the resources 
> transferred through the IPv4 marketplace.
> Additionally, the removal of the needs-basis criteria has increased the 
> number of transfers, showing that the marketplace works and is useful to 
> hundreds (or even thousands) of companies from the region.
> 
> I am not saying that the ARIN community should copy what the RIPE community 
> has done. I am just saying that if something is working and it's usability is 
> proven, it is rather strange to see some saying the opposite as an argument 
> against the removal of the needs-based criteria.
>> 
>> Owen
> cheers,
> elvis
>> 
>>> On Sep 24, 2015, at 11:55 , Leif Sawyer <lsaw...@gci.com> wrote:
>>> 
>>> Now that we've reached the magic ZERO in the free pool, what does the 
>>> community
>>> think about this new draft policy?
>>> 
>>> Should ARIN begin the process of streamlining the IPv4 policy so that it is
>>> geared more toward the transfer market, and remove "need" as a criteria in
>>> certain sections of the NRPM to increase the database accuracy?
>>> 
>>> 
>>> -Original Message-
>>> From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On 
>>> Behalf Of ARIN
>>> Sent: Wednesday, September 23, 2015 12:54 PM
>>> To: arin-ppml@arin.net
>>> Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
>>> evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
>>> 
>>> Draft Policy ARIN-2015-9
>>> Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers 
>>> of IPv4 netblocks
>>> 
>>> On 17 September 2015 the ARIN Advisory Council (AC) accepted
>>> "ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3, and 
>>> 8.4 transfers of IPv4 netblocks" as a Draft Policy.
>>> 
>>> Draft Policy ARIN-2015-9 is below and can be found at:
>>> https://www.arin.net/policy/proposals/2015_9.html
>>> 
>>> You are encouraged to discuss the merits and your concerns of Draft Policy 
>>> 2015-9 on the Public Policy Mailing List.
>>> 
>>> The AC will evaluate the discussion in order to assess the conformance of 
>>> this draft policy with ARIN's Principles of Internet Number Resource Policy 
>>> as stated in the PDP. Specifically, these principles are:
>>> 
>>>* Enabling Fair and Impartial Number Resource Administration
>>>* Technically Sound
>>>* Supported by the Community
>>> 
>>> The ARIN Policy Development Process (PDP) can be found at:
>>> https://www.arin.net/policy/pdp.html
>>> 
>>> Draft Policies and Proposals under discussion can be found at:
>>> https://www.arin.net/policy/propos

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Mike Burns]

- Original Message - 
From: "Leif Sawyer" 


Should ARIN begin the process of streamlining the IPv4 policy so that it 
is

geared more toward the transfer market, and remove "need" as a criteria in
certain sections of the NRPM to increase the database accuracy?



Hi Leif,

Yes. The community distributed the addresses appropriately, IMO.
Now it's time to step back and let the market work to conserve addresses and 
bring them into their highest and best use.
And reap the rewards in increased Whois acccuracy, more efficient transfers, 
and less cost to the ARIN community.


Regards,
Mike Burns

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Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Elvis Daniel Velea]

Hi Owen,

On 24/09/15 22:09, Owen DeLong wrote:

Short answer: NO

Longer answer:

Finance alone does not reflect all community values. Eliminating needs-based 
evaluation for transfers
will foster an environment open to speculation and other artifice used to 
maximize the monetization of
address resources without providing the benefit to the community of maximizing 
utilization.
The environment open to speculation already exists, a needs-based 
criteria will not stop the ones that want to speculate. Keeping 
needs-based criteria in policy will only drive (keep some of the) 
transfers underground (ie: futures contracts, all kind of financial 
artifices). I actually believe the needs-based criteria removal will 
benefit the community by eliminating a barrier in the correct 
registration of the transfers (resources) in the registry (and whois).


The allocation era has passed, ARIN should just be a shepherd and record 
the transfers (and do the allocation exercise twice per year, when the 
IANA allocates the few crumbs remaining). From my experience and 
observations, if someone needs the IP addresses and has the money to pay 
for them I am sure that they will not be stopped by ARIN's needs-base 
criteria...

In fact, I believe that eliminating needs-basis will likely cause actual 
utilization to be reduced in the
long run in favor of financial manipulation.
I dare to disagree. From where I am standing, the removal of needs-basis 
criteria from the RIPE Region has increased utilization of the resources 
transferred through the IPv4 marketplace.
Additionally, the removal of the needs-basis criteria has increased the 
number of transfers, showing that the marketplace works and is useful to 
hundreds (or even thousands) of companies from the region.


I am not saying that the ARIN community should copy what the RIPE 
community has done. I am just saying that if something is working and 
it's usability is proven, it is rather strange to see some saying the 
opposite as an argument against the removal of the needs-based criteria.


Owen

cheers,
elvis



On Sep 24, 2015, at 11:55 , Leif Sawyer <lsaw...@gci.com> wrote:

Now that we've reached the magic ZERO in the free pool, what does the community
think about this new draft policy?

Should ARIN begin the process of streamlining the IPv4 policy so that it is
geared more toward the transfer market, and remove "need" as a criteria in
certain sections of the NRPM to increase the database accuracy?


-Original Message-
From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On Behalf 
Of ARIN
Sent: Wednesday, September 23, 2015 12:54 PM
To: arin-ppml@arin.net
Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

Draft Policy ARIN-2015-9
Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of 
IPv4 netblocks

On 17 September 2015 the ARIN Advisory Council (AC) accepted
"ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 
transfers of IPv4 netblocks" as a Draft Policy.

Draft Policy ARIN-2015-9 is below and can be found at:
https://www.arin.net/policy/proposals/2015_9.html

You are encouraged to discuss the merits and your concerns of Draft Policy 
2015-9 on the Public Policy Mailing List.

The AC will evaluate the discussion in order to assess the conformance of this 
draft policy with ARIN's Principles of Internet Number Resource Policy as 
stated in the PDP. Specifically, these principles are:

* Enabling Fair and Impartial Number Resource Administration
* Technically Sound
* Supported by the Community

The ARIN Policy Development Process (PDP) can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)


## * ##

Draft Policy ARIN-2015-9
Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of 
IPv4 netblocks

Date: 23 September 2015

Problem statement:

The current policies in NRPM sections 8.2, 8.3, and 8.4 regarding transfer of 
IPv4 netblocks from one organization to another are currently a hindrance in 
ensuring database accuracy. In practice, ARIN staff are utilizing those polices 
to refuse to complete database updates which would reflect an accurate transfer 
of control / utilization of netblocks in cases where ARIN doesn't agree that 
the recipient organization has need, or more often where the recipient 
organization bypasses the ARIN registry entirely in order to secure the needed 
IPv4 netblocks in a more timely fashion directly from the current holder.
Additionally, the 8.1 introduction section includes a perceived "threat"
of reclaim which serves as a hindrance to long-term resource holders 
approaching ARIN with database

Re: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[Richard J. Letts]

b) 
There is no definitive outcome from the policy change, which makes me feel that 
it's not worth changing -- the problem statement argument is weak at best.

It is potentially enabling organizations with more money than need gain more 
resources, potentially at the expense of non-profit and educational 
organizations who might not be able to raise cash for additional IPv4 space [or 
equipment to support a transition to IPv6]. Changing policy just to 
(potentially) improve the accuracy of a database seems not worth the 
(potential) risk.

Richard



From: arin-ppml-boun...@arin.net <arin-ppml-boun...@arin.net> on behalf of Dani 
Roisman <drois...@softlayer.com>
Sent: Thursday, September 24, 2015 6:20 PM
To: arin-ppml@arin.net
Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based 
evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

| Date: Wed, 23 Sep 2015 16:53:59 -0400
| From: ARIN <i...@arin.net>
| To: arin-ppml@arin.net
| Subject: [arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based
|   evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks
| Message-ID: <56031167.1010...@arin.net>
| Content-Type: text/plain; charset=utf-8; format=flowed
|
| Draft Policy ARIN-2015-9
| Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4
| transfers of IPv4 netblocks
|
| On 17 September 2015 the ARIN Advisory Council (AC) accepted
| "ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3,
| and 8.4 transfers of IPv4 netblocks" as a Draft Policy.
|
| Draft Policy ARIN-2015-9 is below and can be found at:
| https://www.arin.net/policy/proposals/2015_9.html

Greetings,

There has been some stimulating dialog about the merits of 2015-9.  I'd like to 
ask that in addition to any overall support or lack thereof, you also review 
the policy language and comment specifically on the changes proposed:
a) For those of you generally in support of this effort, are there any 
refinements to the changes made which you think will improve this should these 
policy changes be implemented?
b) For those of you generally opposed to this effort, are there any adjustments 
to the policy changes which, if implemented, would gain your support?

--
Dani Roisman
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[arin-ppml] Draft Policy ARIN-2015-9: Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 transfers of IPv4 netblocks

[ARIN]

Draft Policy ARIN-2015-9
Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 
transfers of IPv4 netblocks


On 17 September 2015 the ARIN Advisory Council (AC) accepted 
"ARIN-prop-223 Eliminating needs-based evaluation for Section 8.2, 8.3, 
and 8.4 transfers of IPv4 netblocks" as a Draft Policy.


Draft Policy ARIN-2015-9 is below and can be found at:
https://www.arin.net/policy/proposals/2015_9.html

You are encouraged to discuss the merits and your concerns of Draft
Policy 2015-9 on the Public Policy Mailing List.

The AC will evaluate the discussion in order to assess the conformance
of this draft policy with ARIN's Principles of Internet Number Resource
Policy as stated in the PDP. Specifically, these principles are:

   * Enabling Fair and Impartial Number Resource Administration
   * Technically Sound
   * Supported by the Community

The ARIN Policy Development Process (PDP) can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Communications and Member Services
American Registry for Internet Numbers (ARIN)


## * ##

Draft Policy ARIN-2015-9
Eliminating needs-based evaluation for Section 8.2, 8.3, and 8.4 
transfers of IPv4 netblocks


Date: 23 September 2015

Problem statement:

The current policies in NRPM sections 8.2, 8.3, and 8.4 regarding 
transfer of IPv4 netblocks from one organization to another are 
currently a hindrance in ensuring database accuracy. In practice, ARIN 
staff are utilizing those polices to refuse to complete database updates 
which would reflect an accurate transfer of control / utilization of 
netblocks in cases where ARIN doesn't agree that the recipient 
organization has need, or more often where the recipient organization 
bypasses the ARIN registry entirely in order to secure the needed IPv4 
netblocks in a more timely fashion directly from the current holder. 
Additionally, the 8.1 introduction section includes a perceived "threat" 
of reclaim which serves as a hindrance to long-term resource holders 
approaching ARIN with database updates when transferring resources. The 
result is that the data visible in ARIN registry continues to become 
more inaccurate over time.


Policy statement:

This proposal is for the following language changes in the respective 
NRPM sections in order to eliminate all needs-based evaluation for the 
respective transfer type, and allow 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 3rd paragraph which begins with "Number resources are 
issued, based on justified need, to organizations. . ." since it mostly 
reiterates other sections of ARIN policy. All transfers are subjected to 
those policies, as called out in 8.2, 8.3, 8.4. Additionally, removing 
this paragraph removes the perceived "threat" of reclaim which serves as 
a hindrance to long-term resource holders approaching ARIN with database 
updates, since in practice ARIN has not been forcibly reclaiming IP 
resources assigned to "failed businesses."


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 or 
inspection of current or future utilization rate."


- Remove entirely the last paragraph which reads "In the event that 
number resources of the combined organizations are no longer justified 
under ARIN policy at the time ARIN becomes aware of the transaction, 
through a transfer request or otherwise, ARIN will work with the 
resource holder(s) to return or transfer resources as needed to restore 
compliance via the processes outlined in current 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 or 
inspection of current or future utilization rate."


Section 8.4 Inter-RIR Transfers to Specified Recipients:

- Change the introductory language from:

"Inter-regional transfers may take place only via RIRs who agree to the 
transfer and share reciprocal, compatible, needs-based policies."


to:

"Inter-regional transfers may take place only via RIRs who agree to the 
transfer and share reciprocal, compatible, policies."