Re: [arin-ppml] Thoughts on 2015-7

[Scott Leibrand]

Thanks for the constructive suggestions.  Let me see (inline below) if I
understand exactly what you're saying.

On Wed, Feb 10, 2016 at 9:31 PM, Jason Schiller 
wrote:

> I oppose as written.
>
> I opposed ARIN-2015-3 and I oppose this draft policy on the same grounds.
> I support simplifying some transfers and keeping the more complicated old
> rules for others in general...
>
> However, the policy as written requires no real, tangible, and verifiable
> claim.  Without such a check justified need for transfers simply becomes a
> 2 year future looking projection, and with sufficient arm waving an easy
> end run around justified need.
>
> I could certainly get on board if there were some other tangible and
> verifiable claim to show there was a real commitment to use half the
> address space within two years.
>
> I choose Scott's email to reply to because I like his approach in general.
>
> 1. Make an agreement to acquire addresses in the quantity you believe you
> need.
> 2. If that agreement brings your total address holdings to less than 2x
> your current or 24-month projected usage, get easy approval for the
> transfer from ARIN under the Simplified requirements for demonstrated
> need for IPv4 transfers defined in this draft policy.
> 3. Skip the LOA and ongoing legal stuff.
> 4. Use the addresses.
>
> I would suggest a slight modification and a slight clarification.
>
> 1. Make an agreement to acquire addresses in the quantity you believe you
> need.
> 2. If that agreement brings your total address holdings to less than 2x
> your current holdings
> And your current holdings are > 80% utilized in aggregate and no less
> that 50% per resource,
> then you qualify for a simplified transfer.
>

So if I understand correctly, you're suggesting that we reinstate the >80%
overall and 50% per-resource utilization requirements for simplified
transfers, but once an organization has met that threshold, they can
qualify for a simplified transfer that will get them up to 2x their current
holdings?  (You removed "or 24-month projected usage".)

The proposed text as written ("IPv4 transfer recipients must demonstrate
(and an officer of the requesting organization must attest) that they will
use at least 50% of their aggregate IPv4 addresses (including the requested
resources) on an operational network within 24 months.") is more liberal
than that on two counts: 1) it does not include any requirement for
utilization level of current resources, and 2) it allows the transfer of
resources up to 2x the 24-month projection (as attested by an officer).  I
understand your objection to 2), but can you clarify why you think 1) is
problematic?

I would like to get more feedback from others here on PPML as to how
comfortable we are trusting officer attestations of forward-looking
projections, plus the need to shell out real hard cash for any space
obtained, as a limit on any fraudulent or anticompetitive behavior.

*If* a lot of people are uncomfortable with trusting officer-attested
forward-looking projections, then another middle ground would be to simply
limit simplified transfers to 2x current holdings.  I think that would be
sufficient for most organizations, and any for whom RSA section 4 is a
better option can of course elect to use that, as you mentioned in your #3
below.  It would also address your desire for a "tangible and verifiable
claim to show there was a real commitment to use half the address space
within two years", because they would actually be required to demonstrate
use of half the resulting address space holdings before they qualify for
the simplified transfer at all.

Thoughts?

-Scott


> 3. You can still qualify for a two year supply under the current
> unsimplified policy
> You can get twice your last year's run rate
> if your current holding are > 80% utilization in aggregate and no
> less that 50% per resource,
> 4. Sign an RSA
> 5. Use the addresses
>
> Note: sources of a transfer still:
> - must be the current (dispute free) registered holder of the IPv4 address
> space
> - must not have received a transfer, allocation or assignment from ARIN in
> the last year
>   (not including M)
> - minimum /24
>
>
> Neither Scott's nor my approach here deal with organizations that have no
> resources.
>
> I (and MJ) tried a more complicated version of this as ARIN-2014-20.
>
> Scott, do you want to consider my (friendly) amendment and draft some
> text?
> Do you want to consider what to do for organizations with no resources?
>
>
> ___Jason
>
>
> On Mon, Oct 5, 2015 at 4:30 PM, Scott Leibrand 
> wrote:
>
>> I believe we should make it easy to:
>>
>> 1. Make an agreement to acquire addresses in the quantity you believe you
>> need.
>> 2. If that agreement brings your total address holdings to less than 2x
>> your current or 24-month projected usage, get easy approval for the
>> transfer from ARIN under the Simplified requirements for demonstrated

Re: [arin-ppml] Thoughts on 2015-7

[Brian Jones]

On Fri, Aug 21, 2015 at 10:55 AM, Scott Leibrand 
wrote:

>
> On Aug 20, 2015, at 7:17 PM, Brian Jones  wrote:
>
> Mathew,
> I think we are in agreement on some level. I don't want valuable resources
> to sit idle either. At the same time arbitrarily handing out large blocks
> of resources without any real show of need allows for possible misuse of
> the resources by those who would hang on to them to get a better price or
> for whatever reason they want.
>
>
> The IPv4 free pool is now empty, and there are no more large blocks to
> hand out. Is this still a concern when all blocks must be acquired via
> transfer? If so, can you explain why that's more of a concern under the
> proposed policy than under current policy?
>

The "large blocks" reference I used is probably not the appropriate
wording, but routed blocks matter and should be documented appropriately in
order to help keep the Internet routing tables as accurate as possible. I
still believe some show of need should be present.

Either way the resources sit idle. I am for a reasonable amount of
> justification for the amount of resources that can be consumed in a
> reasonable time period. Defining reasonable in the last two sentences and
> coming to agreement may be the crux of the matter.
>
> If the organization was mistaken about how many or how fast they would use
> the resources, then the process should be able to easily accommodate
> transfer, selling, or returning them as long as they follow procedures to
> ensure that documentation records of the resources can be appropriately
> updated for the good of the Internet.
>
> In the end there is really not a good way to prevent unused addresses
> sitting idle. It is up to the recipients of justified resources to be good
> stewards and use them appropriately and hopefully transfer, sell, or return
> them if they no longer need them.
>
>
> Totally agreed.
>
> -Scott
>
>
> On Aug 20, 2015 9:15 PM, "Matthew Kaufman"  wrote:
>
>> On 8/20/2015 1:04 PM, Brian Jones wrote:
>>
>>
>> ​I agree with this simplified requirement but would even be willing to
>> accept a 50% within 12 months and 75% in 24 months requirement. Two years
>> is a long time to tie up valuable resources that are not being used. IMHO​
>>
>>
>> I do not understand this reasoning. There is no more free pool. If Org A
>> is not using "valuable resources" and they are transferred to Org B who was
>> mistaken about how fast they will use them, then Org B is also not using
>> "valuable resources". But if instead Org A can't transfer them, then Org B
>> doesn't get them and Org A still has "valuable resources" which are "tied
>> up". They're "tied up" not being used either way... and ARIN can't do
>> anything about it.
>>
>> If you really want to make sure that these resources don't sit unused,
>> make it so that after Org A transfers to Org B then if Org B doesn't use
>> all of them, Org B can sell what they're not using.
>>
>> Matthew Kaufman
>>
>> ___
>> PPML
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>> 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] Thoughts on 2015-7

[Owen DeLong]

Steven,

You don’t have to go outside of policy to use a broker.

If you actually need the addresses, you can get a pre-approval through ARIN, 
take your pre-approval to one or more brokers and arrange to obtain the 
addresses you need and come back to ARIN and complete the transfer.

We have new rules to address the fact that times have changed somewhat.

That’s what 8.3 and 8.4 of the NRPM are.

Owen

> On Oct 5, 2015, at 1:29 PM, Steven Ryerse <srye...@eclipse-networks.com> 
> wrote:
> 
> I don’t understand why everyone wants to keep blocking all outside of ARIN 
> transactions.  A year from now there might be a thousand or more legitimate 
> organizations that meet one or more of the current policies to qualify for an 
> IPv4 allocation.  Let’s say that is your Org or your Customer’s Org - and 
> ARIN dutifully places you on their waiting list.  Time passes and no 
> significant supply comes available for your request.  
>  
> So then what do you do? ARIN can’t fulfill your request timely. You have a 
> legitimate need. If IPv6 won’t work, Is living without the resources you need 
> really acceptable?  If not do you break down and call a Broker to help find 
> you the resources that you need?
>  
> Why does this community continually paint organizations into the corner of 
> not being able to get IPv4 resources without going outside of ARINs policies? 
>  John asked this community to visit the issue of runout several months ago, 
> and there was some discussion but I’ve seen no real will to make any 
> significant adjustments to try and deal with the new world we all must live 
> in now.
>  
> We can keep rearranging deck chairs on the Titanic, or we can face reality 
> that times have completely changed and the old rules won’t work in a new ARIN 
> world.  My 2 cents. 
>  
> 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: 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 Martin Hannigan
> Sent: Monday, October 5, 2015 4:08 PM
> To: Scott Leibrand <scottleibr...@gmail.com <mailto:scottleibr...@gmail.com>>
> Cc: p...@arin.net <mailto:p...@arin.net>
> Subject: Re: [arin-ppml] Thoughts on 2015-7
>  
>  
>  
> On Mon, Oct 5, 2015 at 3:29 PM, Scott Leibrand <scottleibr...@gmail.com 
> <mailto:scottleibr...@gmail.com>> wrote:
> Reducing the burden on ARIN staff is not part of the problem statement for 
> this proposal (though it might be a side effect, depending on how they 
> implement it).  The main goal here is to reduce the administrative burden on 
> organizations who need to acquire IPv4 space via transfer.  That burden may 
> actually be higher for smaller entities who don't have experience with and 
> processes in place for jumping through ARIN's hoops.
>  
> I don't think this policy would have much impact on the ability of large 
> well-funded entities to purchase as much address space as they like.  
> Currently, those organizations simply write a contract that gives them full 
> rights to the address space they're buying, and allows them to transfer the 
> space with ARIN whenever they are ready to put it into use on their network 
> (or can otherwise pass ARIN's needs justification tests).
>  
>  
>  
> 
> Let me give you a real world example.
> 
> 1. Buy rights to use addresses in any quantity you believe you need
> 2. Use those addresses as you need them, assuming the agreement you made with 
> the party works properly
> 3. Get an LOA from the documented owner
> 4. Bypass ARIN entirely
> 5. Use the addresses.
> 
> How do you think we should solve that problem?
> 
> 
> Best,
> 
> -M<
> 
> 
>  
> ___
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Re: [arin-ppml] Thoughts on 2015-7

[Azinger, Marla]

Does ARIN staff feel this is needed to support how they asses transfers?

Right now I don't support this proposal.   Based on experience I don't see a 
problem.

Additionally this could have a side effect of letting larger money endowed 
entities to purchase more address space faster and deplete the chances smaller 
entities had on the market.  This would shorten the life span of the v4 market.

Regards
Marla Azinger

-Original Message-
From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On Behalf 
Of Rob Seastrom
Sent: Thursday, August 20, 2015 12:46 PM
To: p...@arin.net
Subject: [arin-ppml] Thoughts on 2015-7


Dear Colleagues,

It's been almost two months since ARIN 2015-7 was submitted.  Anyone have 
thoughts on "Simplified requirements for demonstrated need for IPv4 transfers"?

The AC would love your input.

Draft policy text follows:

Draft Policy ARIN-2015-7
Simplified requirements for demonstrated need for IPv4 transfers

Date: 23 June 2015

Problem statement:

ARIN transfer policy currently inherits all its demonstrated need requirements 
for IPv4 transfers from NRPM sections 4. Because that section was written 
primarily to deal with free pool allocations, it is much more complicated than 
is really necessary for transfers. In practice, ARIN staff applies much more 
lenient needs assessment to section 8 IPv4 transfer requests than to free pool 
requests, as 24-month needs are much more difficult to assess to the same level 
of detail.

This proposal seeks to dramatically simplify the needs assessment process for 
8.3 transfers, while still allowing organizations with corner-case requirements 
to apply under existing policy if necessary.

Policy statement:

8.1.x Simplified requirements for demonstrated need for IPv4 transfers

IPv4 transfer recipients must demonstrate (and an officer of the requesting 
organization must attest) that they will use at least 50% of their aggregate 
IPv4 addresses (including the requested resources) on an operational network 
within 24 months.

Organizations that do not meet the simplified criteria above may instead 
demonstrate the need for number resources using the criteria in section
4 of the NRPM.

Comments:

a. Timetable for implementation: Immediate

b. Anything else




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Re: [arin-ppml] Thoughts on 2015-7

[Azinger, Marla]

I’ve seen it from all sizes.  I don’t see an issue.  If a large quantity of 
people stand up and say they struggle.  I’ll be surprised.  And the assumption 
its easier for larger entities than smaller is very off base.  I’ve managed a 
variety of entity sizes and there are different variables at all levels that 
really create a level playing field.

And not everyone has the same contracts.  I’ve seen a variety and in those 
varieties there can also be contingencies.

That said, if the majority of people stand up and say it’s too difficult.  Then 
so be it.

Regards
Marla Azinger


From: Scott Leibrand [mailto:scottleibr...@gmail.com]
Sent: Monday, October 05, 2015 12:29 PM
To: Azinger, Marla <marla.azin...@ftr.com>
Cc: Rob Seastrom <rs-li...@seastrom.com>; p...@arin.net
Subject: Re: [arin-ppml] Thoughts on 2015-7

Reducing the burden on ARIN staff is not part of the problem statement for this 
proposal (though it might be a side effect, depending on how they implement 
it).  The main goal here is to reduce the administrative burden on 
organizations who need to acquire IPv4 space via transfer.  That burden may 
actually be higher for smaller entities who don't have experience with and 
processes in place for jumping through ARIN's hoops.

I don't think this policy would have much impact on the ability of large 
well-funded entities to purchase as much address space as they like.  
Currently, those organizations simply write a contract that gives them full 
rights to the address space they're buying, and allows them to transfer the 
space with ARIN whenever they are ready to put it into use on their network (or 
can otherwise pass ARIN's needs justification tests).

-Scott


On Mon, Oct 5, 2015 at 11:45 AM, Azinger, Marla 
<marla.azin...@ftr.com<mailto:marla.azin...@ftr.com>> wrote:
Does ARIN staff feel this is needed to support how they asses transfers?

Right now I don't support this proposal.   Based on experience I don't see a 
problem.

Additionally this could have a side effect of letting larger money endowed 
entities to purchase more address space faster and deplete the chances smaller 
entities had on the market.  This would shorten the life span of the v4 market.

Regards
Marla Azinger

-Original Message-
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 Rob Seastrom
Sent: Thursday, August 20, 2015 12:46 PM
To: p...@arin.net<mailto:p...@arin.net>
Subject: [arin-ppml] Thoughts on 2015-7

Dear Colleagues,

It's been almost two months since ARIN 2015-7 was submitted.  Anyone have 
thoughts on "Simplified requirements for demonstrated need for IPv4 transfers"?

The AC would love your input.

Draft policy text follows:

Draft Policy ARIN-2015-7
Simplified requirements for demonstrated need for IPv4 transfers

Date: 23 June 2015

Problem statement:

ARIN transfer policy currently inherits all its demonstrated need requirements 
for IPv4 transfers from NRPM sections 4. Because that section was written 
primarily to deal with free pool allocations, it is much more complicated than 
is really necessary for transfers. In practice, ARIN staff applies much more 
lenient needs assessment to section 8 IPv4 transfer requests than to free pool 
requests, as 24-month needs are much more difficult to assess to the same level 
of detail.

This proposal seeks to dramatically simplify the needs assessment process for 
8.3 transfers, while still allowing organizations with corner-case requirements 
to apply under existing policy if necessary.

Policy statement:

8.1.x Simplified requirements for demonstrated need for IPv4 transfers

IPv4 transfer recipients must demonstrate (and an officer of the requesting 
organization must attest) that they will use at least 50% of their aggregate 
IPv4 addresses (including the requested resources) on an operational network 
within 24 months.

Organizations that do not meet the simplified criteria above may instead 
demonstrate the need for number resources using the criteria in section
4 of the NRPM.

Comments:

a. Timetable for implementation: Immediate

b. Anything else




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Re: [arin-ppml] Thoughts on 2015-7

[Steven Ryerse]

I don’t understand why everyone wants to keep blocking all outside of ARIN 
transactions.  A year from now there might be a thousand or more legitimate 
organizations that meet one or more of the current policies to qualify for an 
IPv4 allocation.  Let’s say that is your Org or your Customer’s Org - and ARIN 
dutifully places you on their waiting list.  Time passes and no significant 
supply comes available for your request.

So then what do you do? ARIN can’t fulfill your request timely. You have a 
legitimate need. If IPv6 won’t work, Is living without the resources you need 
really acceptable?  If not do you break down and call a Broker to help find you 
the resources that you need?

Why does this community continually paint organizations into the corner of not 
being able to get IPv4 resources without going outside of ARINs policies?  John 
asked this community to visit the issue of runout several months ago, and there 
was some discussion but I’ve seen no real will to make any significant 
adjustments to try and deal with the new world we all must live in now.

We can keep rearranging deck chairs on the Titanic, or we can face reality that 
times have completely changed and the old rules won’t work in a new ARIN world. 
 My 2 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 Martin Hannigan
Sent: Monday, October 5, 2015 4:08 PM
To: Scott Leibrand <scottleibr...@gmail.com>
Cc: p...@arin.net
Subject: Re: [arin-ppml] Thoughts on 2015-7



On Mon, Oct 5, 2015 at 3:29 PM, Scott Leibrand 
<scottleibr...@gmail.com<mailto:scottleibr...@gmail.com>> wrote:
Reducing the burden on ARIN staff is not part of the problem statement for this 
proposal (though it might be a side effect, depending on how they implement 
it).  The main goal here is to reduce the administrative burden on 
organizations who need to acquire IPv4 space via transfer.  That burden may 
actually be higher for smaller entities who don't have experience with and 
processes in place for jumping through ARIN's hoops.

I don't think this policy would have much impact on the ability of large 
well-funded entities to purchase as much address space as they like.  
Currently, those organizations simply write a contract that gives them full 
rights to the address space they're buying, and allows them to transfer the 
space with ARIN whenever they are ready to put it into use on their network (or 
can otherwise pass ARIN's needs justification tests).



Let me give you a real world example.
1. Buy rights to use addresses in any quantity you believe you need
2. Use those addresses as you need them, assuming the agreement you made with 
the party works properly
3. Get an LOA from the documented owner
4. Bypass ARIN entirely
5. Use the addresses.
How do you think we should solve that problem?

Best,
-M<



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Re: [arin-ppml] Thoughts on 2015-7

[Scott Leibrand]

Reducing the burden on ARIN staff is not part of the problem statement for
this proposal (though it might be a side effect, depending on how they
implement it).  The main goal here is to reduce the administrative burden
on organizations who need to acquire IPv4 space via transfer.  That burden
may actually be higher for smaller entities who don't have experience with
and processes in place for jumping through ARIN's hoops.

I don't think this policy would have much impact on the ability of large
well-funded entities to purchase as much address space as they like.
Currently, those organizations simply write a contract that gives them full
rights to the address space they're buying, and allows them to transfer the
space with ARIN whenever they are ready to put it into use on their network
(or can otherwise pass ARIN's needs justification tests).

-Scott


On Mon, Oct 5, 2015 at 11:45 AM, Azinger, Marla 
wrote:

> Does ARIN staff feel this is needed to support how they asses transfers?
>
> Right now I don't support this proposal.   Based on experience I don't see
> a problem.
>
> Additionally this could have a side effect of letting larger money endowed
> entities to purchase more address space faster and deplete the chances
> smaller entities had on the market.  This would shorten the life span of
> the v4 market.
>
> Regards
> Marla Azinger
>
> -Original Message-
> From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On
> Behalf Of Rob Seastrom
> Sent: Thursday, August 20, 2015 12:46 PM
> To: p...@arin.net
> Subject: [arin-ppml] Thoughts on 2015-7
>
>
> Dear Colleagues,
>
> It's been almost two months since ARIN 2015-7 was submitted.  Anyone have
> thoughts on "Simplified requirements for demonstrated need for IPv4
> transfers"?
>
> The AC would love your input.
>
> Draft policy text follows:
>
> Draft Policy ARIN-2015-7
> Simplified requirements for demonstrated need for IPv4 transfers
>
> Date: 23 June 2015
>
> Problem statement:
>
> ARIN transfer policy currently inherits all its demonstrated need
> requirements for IPv4 transfers from NRPM sections 4. Because that section
> was written primarily to deal with free pool allocations, it is much more
> complicated than is really necessary for transfers. In practice, ARIN staff
> applies much more lenient needs assessment to section 8 IPv4 transfer
> requests than to free pool requests, as 24-month needs are much more
> difficult to assess to the same level of detail.
>
> This proposal seeks to dramatically simplify the needs assessment process
> for 8.3 transfers, while still allowing organizations with corner-case
> requirements to apply under existing policy if necessary.
>
> Policy statement:
>
> 8.1.x Simplified requirements for demonstrated need for IPv4 transfers
>
> IPv4 transfer recipients must demonstrate (and an officer of the
> requesting organization must attest) that they will use at least 50% of
> their aggregate IPv4 addresses (including the requested resources) on an
> operational network within 24 months.
>
> Organizations that do not meet the simplified criteria above may instead
> demonstrate the need for number resources using the criteria in section
> 4 of the NRPM.
>
> Comments:
>
> a. Timetable for implementation: Immediate
>
> b. Anything else
>
>
>
>
> ___
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> Unsubscribe or manage your mailing list subscription at:
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> Please contact i...@arin.net if you experience any issues.
>
> 
>
> This communication is confidential. Frontier only sends and receives email
> on the basis of the terms set out at
> http://www.frontier.com/email_disclaimer.
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Re: [arin-ppml] Thoughts on 2015-7

[Scott Leibrand]

I think the threshold is "unnecessarily difficult" rather than "too
difficult".

If we didn't have NRPM section 4 already, and had to set up rules for needs
assessment for transfers, I think we would end up with something a lot
closer to this draft policy than to the current section 4.  If so, that
would indicate that all the extra requirements in section 4 are probably no
longer serving a useful function, and just making transfer recipients' life
unnecessarily difficult.

-Scott

On Mon, Oct 5, 2015 at 12:50 PM, Azinger, Marla <marla.azin...@ftr.com>
wrote:

> I’ve seen it from all sizes.  I don’t see an issue.  If a large quantity
> of people stand up and say they struggle.  I’ll be surprised.  And the
> assumption its easier for larger entities than smaller is very off base.
> I’ve managed a variety of entity sizes and there are different variables at
> all levels that really create a level playing field.
>
>
>
> And not everyone has the same contracts.  I’ve seen a variety and in those
> varieties there can also be contingencies.
>
>
>
> That said, if the majority of people stand up and say it’s too difficult.
> Then so be it.
>
>
>
> Regards
>
> Marla Azinger
>
>
>
>
>
> *From:* Scott Leibrand [mailto:scottleibr...@gmail.com]
> *Sent:* Monday, October 05, 2015 12:29 PM
> *To:* Azinger, Marla <marla.azin...@ftr.com>
> *Cc:* Rob Seastrom <rs-li...@seastrom.com>; p...@arin.net
> *Subject:* Re: [arin-ppml] Thoughts on 2015-7
>
>
>
> Reducing the burden on ARIN staff is not part of the problem statement for
> this proposal (though it might be a side effect, depending on how they
> implement it).  The main goal here is to reduce the administrative burden
> on organizations who need to acquire IPv4 space via transfer.  That burden
> may actually be higher for smaller entities who don't have experience with
> and processes in place for jumping through ARIN's hoops.
>
>
>
> I don't think this policy would have much impact on the ability of large
> well-funded entities to purchase as much address space as they like.
> Currently, those organizations simply write a contract that gives them full
> rights to the address space they're buying, and allows them to transfer the
> space with ARIN whenever they are ready to put it into use on their network
> (or can otherwise pass ARIN's needs justification tests).
>
>
>
> -Scott
>
>
>
>
>
> On Mon, Oct 5, 2015 at 11:45 AM, Azinger, Marla <marla.azin...@ftr.com>
> wrote:
>
> Does ARIN staff feel this is needed to support how they asses transfers?
>
> Right now I don't support this proposal.   Based on experience I don't see
> a problem.
>
> Additionally this could have a side effect of letting larger money endowed
> entities to purchase more address space faster and deplete the chances
> smaller entities had on the market.  This would shorten the life span of
> the v4 market.
>
> Regards
> Marla Azinger
>
> -Original Message-
> From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On
> Behalf Of Rob Seastrom
> Sent: Thursday, August 20, 2015 12:46 PM
> To: p...@arin.net
> Subject: [arin-ppml] Thoughts on 2015-7
>
> Dear Colleagues,
>
> It's been almost two months since ARIN 2015-7 was submitted.  Anyone have
> thoughts on "Simplified requirements for demonstrated need for IPv4
> transfers"?
>
> The AC would love your input.
>
> Draft policy text follows:
>
> Draft Policy ARIN-2015-7
> Simplified requirements for demonstrated need for IPv4 transfers
>
> Date: 23 June 2015
>
> Problem statement:
>
> ARIN transfer policy currently inherits all its demonstrated need
> requirements for IPv4 transfers from NRPM sections 4. Because that section
> was written primarily to deal with free pool allocations, it is much more
> complicated than is really necessary for transfers. In practice, ARIN staff
> applies much more lenient needs assessment to section 8 IPv4 transfer
> requests than to free pool requests, as 24-month needs are much more
> difficult to assess to the same level of detail.
>
> This proposal seeks to dramatically simplify the needs assessment process
> for 8.3 transfers, while still allowing organizations with corner-case
> requirements to apply under existing policy if necessary.
>
> Policy statement:
>
> 8.1.x Simplified requirements for demonstrated need for IPv4 transfers
>
> IPv4 transfer recipients must demonstrate (and an officer of the
> requesting organization must attest) that they will use at least 50% of
> their aggregate IPv4 addresses (including the requested resources) on an
> operational network within 24 months.
>
> Org

Re: [arin-ppml] Thoughts on 2015-7

[Scott Leibrand]

I believe we should make it easy to:

1. Make an agreement to acquire addresses in the quantity you believe you
need.
2. If that agreement brings your total address holdings to less than 2x
your current or 24-month projected usage, get easy approval for the
transfer from ARIN under the Simplified requirements for demonstrated need
for IPv4 transfers defined in this draft policy.
3. Skip the LOA and ongoing legal stuff.
4. Use the addresses.

-Scott

On Mon, Oct 5, 2015 at 1:07 PM, Martin Hannigan  wrote:

>
>
> On Mon, Oct 5, 2015 at 3:29 PM, Scott Leibrand 
> wrote:
>
>> Reducing the burden on ARIN staff is not part of the problem statement
>> for this proposal (though it might be a side effect, depending on how they
>> implement it).  The main goal here is to reduce the administrative burden
>> on organizations who need to acquire IPv4 space via transfer.  That burden
>> may actually be higher for smaller entities who don't have experience with
>> and processes in place for jumping through ARIN's hoops.
>>
>> I don't think this policy would have much impact on the ability of large
>> well-funded entities to purchase as much address space as they like.
>> Currently, those organizations simply write a contract that gives them full
>> rights to the address space they're buying, and allows them to transfer the
>> space with ARIN whenever they are ready to put it into use on their network
>> (or can otherwise pass ARIN's needs justification tests).
>>
>>
>>
>
> Let me give you a real world example.
>
> 1. Buy rights to use addresses in any quantity you believe you need
> 2. Use those addresses as you need them, assuming the agreement you made
> with the party works properly
> 3. Get an LOA from the documented owner
> 4. Bypass ARIN entirely
> 5. Use the addresses.
>
> How do you think we should solve that problem?
>
>
> Best,
>
> -M<
>
>
>
>
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Re: [arin-ppml] Thoughts on 2015-7

[Martin Hannigan]

On Mon, Oct 5, 2015 at 3:29 PM, Scott Leibrand 
wrote:

> Reducing the burden on ARIN staff is not part of the problem statement for
> this proposal (though it might be a side effect, depending on how they
> implement it).  The main goal here is to reduce the administrative burden
> on organizations who need to acquire IPv4 space via transfer.  That burden
> may actually be higher for smaller entities who don't have experience with
> and processes in place for jumping through ARIN's hoops.
>
> I don't think this policy would have much impact on the ability of large
> well-funded entities to purchase as much address space as they like.
> Currently, those organizations simply write a contract that gives them full
> rights to the address space they're buying, and allows them to transfer the
> space with ARIN whenever they are ready to put it into use on their network
> (or can otherwise pass ARIN's needs justification tests).
>
>
>

Let me give you a real world example.

1. Buy rights to use addresses in any quantity you believe you need
2. Use those addresses as you need them, assuming the agreement you made
with the party works properly
3. Get an LOA from the documented owner
4. Bypass ARIN entirely
5. Use the addresses.

How do you think we should solve that problem?


Best,

-M<
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Re: [arin-ppml] Thoughts on 2015-7

[John Curran]

On Oct 5, 2015, at 4:07 PM, Martin Hannigan  wrote:
> 
> Let me give you a real world example.
> 
> 1. Buy rights to use addresses in any quantity you believe you need
> 2. Use those addresses as you need them, assuming the agreement you made with 
> the party works properly
> 3. Get an LOA from the documented owner
> 4. Bypass ARIN entirely
> 5. Use the addresses.
> 
> How do you think we should solve that problem?


It is not my job to determine whether the example above is a major problem (or 
not) - 
that’s for the community to assess, but I do want to highlight some aspects 
that result 
from situations (such as the one described above) of which everyone on the list 
might 
not be aware - 

1) While the network operations confusion that can result is fairly well 
understood to
those on this list, what may not be apparently is that there are others who 
rely upon 
the registry (e.g. researchers, anti-spam folks, law enforcement, etc.) and 
for whom
address blocks being used as described above results in real impacts to 
their ability
to rely upon the registry, and thus accomplish their job.

2) Because the “documented owner” doesn’t ever update the registry, a number of
creative schemes are possible whereby the documented owner gets paid from
multiple parties for the same rights and then effectively disappears with 
their 
proceeds leaving the individual buyers to fight it out.  There are ways to 
reduce
this risk (e.g. escrow arrangements, guarantees with adequate backing, etc.)
but the need for these (and probability of circumvention) goes up 
dramatically 
absent an updated registry.  Likewise for the case where the “documented 
owner” doesn’t actually have a documentation trail that would support their 
ability to sell the rights to even one party, but that is not uncovered 
since the
documentation never gets reviewed by the registry.

I have not seen a clear expression of these cases on the list, and felt it 
important
to describe them for those who may not have first hand involvement. It is true 
that 
under 2015-7, parties would be able to obtain more address space then presently 
allowed and to so do based upon an officer representation, so the risks that 
such 
a change would bring about should be carefully weighted by the community against
the situations outlined above which exist under the status quo.

Thanks,
/John

John Curran
President and CEO
ARIN




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Re: [arin-ppml] Thoughts on 2015-7

[Martin Hannigan]

> On Oct 5, 2015, at 16:40, John Curran  wrote:
> 
>> On Oct 5, 2015, at 4:07 PM, Martin Hannigan  wrote:
>> 
>> Let me give you a real world example.
>> 
>> 1. Buy rights to use addresses in any quantity you believe you need
>> 2. Use those addresses as you need them, assuming the agreement you made 
>> with the party works properly
>> 3. Get an LOA from the documented owner
>> 4. Bypass ARIN entirely
>> 5. Use the addresses.
>> 
>> How do you think we should solve that problem?
> 
> 
> It is not my job to determine whether the example above is a major problem 
> (or not) - 
> that’s for the community to assess, but I do want to highlight some aspects 
> that result 
> from situations (such as the one described above) of which everyone on the 
> list might 
> not be aware - 
> 
> 1) While the network operations confusion that can result is fairly well 
> understood to
>those on this list, what may not be apparently is that there are others 
> who rely upon 
>the registry (e.g. researchers, anti-spam folks, law enforcement, etc.) 
> and for whom
>address blocks being used as described above results in real impacts to 
> their ability
>to rely upon the registry, and thus accomplish their job.
> 
> 2) Because the “documented owner” doesn’t ever update the registry, a number 
> of
>creative schemes are possible whereby the documented owner gets paid from
>multiple parties for the same rights and then effectively disappears with 
> their 
>proceeds leaving the individual buyers to fight it out.  There are ways to 
> reduce
>this risk (e.g. escrow arrangements, guarantees with adequate backing, 
> etc.)
>but the need for these (and probability of circumvention) goes up 
> dramatically 
>absent an updated registry.  Likewise for the case where the “documented 
>owner” doesn’t actually have a documentation trail that would support 
> their 
>ability to sell the rights to even one party, but that is not uncovered 
> since the
>documentation never gets reviewed by the registry.
> 
> I have not seen a clear expression of these cases on the list, and felt it 
> important
> to describe them for those who may not have first hand involvement. It is 
> true that 
> under 2015-7, parties would be able to obtain more address space then 
> presently 
> allowed and to so do based upon an officer representation, so the risks that 
> such 
> a change would bring about should be carefully weighted by the community 
> against
> the situations outlined above which exist under the status quo.
> 
> 

Sounds like focused and friendly registry accuracy policy might work better? 

Best, 

Marty



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Re: [arin-ppml] Thoughts on 2015-7

[Matthew Kaufman]

On 10/5/2015 1:07 PM, Martin Hannigan wrote:



Let me give you a real world example.

1. Buy rights to use addresses in any quantity you believe you need
2. Use those addresses as you need them, assuming the agreement you 
made with the party works properly

3. Get an LOA from the documented owner
4. Bypass ARIN entirely
5. Use the addresses.

How do you think we should solve that problem?


How about another real-world example (several of these in play that I 
know of)


1. Enter into a contract to acquire addresses in any quantity you 
believe you need (or more)
2. Not use the addresses right now, but know that you have as many as 
you want locked up from that seller, who can't sell to anyone else now

3. Transfer the addresses if/when ARIN policy permits
4. Use the addresses.

There is absolutely nothing in the current needs-based policy that 
ensures that entities that failed to plan for IPv4 runout and do not 
have sufficient cash to bid against entities engaged in this sort of 
practice will be able to get IPv4 addresses on the transfer market. And 
there is nothing about removing needs basis from the transfer policy 
that will change that. The game is already over, why insist on policies 
that no longer make any sense in the current environment?


Matthew Kaufman
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Re: [arin-ppml] Thoughts on 2015-7

[Martin Hannigan]

> On Oct 5, 2015, at 17:27, Matthew Kaufman  wrote:
> 
>> On 10/5/2015 1:07 PM, Martin Hannigan wrote:
>> 
>> 
>> Let me give you a real world example.
>> 
>> 1. Buy rights to use addresses in any quantity you believe you need
>> 2. Use those addresses as you need them, assuming the agreement you made 
>> with the party works properly
>> 3. Get an LOA from the documented owner
>> 4. Bypass ARIN entirely
>> 5. Use the addresses.
>> 
>> How do you think we should solve that problem?
> 
> How about another real-world example (several of these in play that I know of)
> 
> 1. Enter into a contract to acquire addresses in any quantity you believe you 
> need (or more)
> 2. Not use the addresses right now, but know that you have as many as you 
> want locked up from that seller, who can't sell to anyone else now
> 3. Transfer the addresses if/when ARIN policy permits
> 4. Use the addresses.
> 
> There is absolutely nothing in the current needs-based policy that ensures 
> that entities that failed to plan for IPv4 runout and do not have sufficient 
> cash to bid against entities engaged in this sort of practice will be able to 
> get IPv4 addresses on the transfer market. And there is nothing about 
> removing needs basis from the transfer policy that will change that. The game 
> is already over, why insist on policies that no longer make any sense in the 
> current environment?
> 


Bingo. The only sufferer is the directory and that is ARINs responsibility. 

Best, 

Marty







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Re: [arin-ppml] Thoughts on 2015-7

[Gary T. Giesen]

I am opposed to the proposal, for the reasons Owen and Rob describe.

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Re: [arin-ppml] Thoughts on 2015-7

[Scott Leibrand]

 On Aug 20, 2015, at 7:17 PM, Brian Jones bjo...@vt.edu wrote:
 
 Mathew, 
 I think we are in agreement on some level. I don't want valuable resources to 
 sit idle either. At the same time arbitrarily handing out large blocks of 
 resources without any real show of need allows for possible misuse of the 
 resources by those who would hang on to them to get a better price or for 
 whatever reason they want.
 

The IPv4 free pool is now empty, and there are no more large blocks to hand 
out. Is this still a concern when all blocks must be acquired via transfer? If 
so, can you explain why that's more of a concern under the proposed policy than 
under current policy?

 Either way the resources sit idle. I am for a reasonable amount of 
 justification for the amount of resources that can be consumed in a 
 reasonable time period. Defining reasonable in the last two sentences and 
 coming to agreement may be the crux of the matter.
 
 If the organization was mistaken about how many or how fast they would use 
 the resources, then the process should be able to easily accommodate 
 transfer, selling, or returning them as long as they follow procedures to 
 ensure that documentation records of the resources can be appropriately 
 updated for the good of the Internet.
 
 In the end there is really not a good way to prevent unused addresses sitting 
 idle. It is up to the recipients of justified resources to be good stewards 
 and use them appropriately and hopefully transfer, sell, or return them if 
 they no longer need them.
 

Totally agreed. 

-Scott


 On Aug 20, 2015 9:15 PM, Matthew Kaufman matt...@matthew.at wrote:
 On 8/20/2015 1:04 PM, Brian Jones wrote:
 
 ​I agree with this simplified requirement but would even be willing to 
 accept a 50% within 12 months and 75% in 24 months requirement. Two years 
 is a long time to tie up valuable resources that are not being used. IMHO​
 
 I do not understand this reasoning. There is no more free pool. If Org A is 
 not using valuable resources and they are transferred to Org B who was 
 mistaken about how fast they will use them, then Org B is also not using 
 valuable resources. But if instead Org A can't transfer them, then Org B 
 doesn't get them and Org A still has valuable resources which are tied 
 up. They're tied up not being used either way... and ARIN can't do 
 anything about it.
 
 If you really want to make sure that these resources don't sit unused, make 
 it so that after Org A transfers to Org B then if Org B doesn't use all of 
 them, Org B can sell what they're not using.
 
 Matthew Kaufman
 
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Re: [arin-ppml] Thoughts on 2015-7

[Scott Leibrand]

 On Aug 20, 2015, at 1:30 PM, William Herrin b...@herrin.us wrote:
 
 On Thu, Aug 20, 2015 at 3:46 PM, Rob Seastrom rs-li...@seastrom.com wrote:
 8.1.x Simplified requirements for demonstrated need for IPv4 transfers
 
 IPv4 transfer recipients must demonstrate (and an officer of the
 requesting organization must attest) that they will use at least 50% of
 their aggregate IPv4 addresses (including the requested resources) on an
 operational network within 24 months.
 
 Howdy,
 
 Still against it because it still applies to out-region transfers
 where ARIN no longer has access to it and CAN NOT revoke it for fraud
 when the attestation turns out to be untrue.

Actually, it does not apply to the recipients of out-of-region transfers. NRPM 
8.4 states that The conditions on a recipient outside of the ARIN region will 
be defined by the policies of the receiving RIR. 

This proposed language would only apply to 8.3 and 8.4 transfer recipients in 
the ARIN region. 

-Scott
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Re: [arin-ppml] Thoughts on 2015-7

[Mike Burns]

I support the proposal.

Regards,
Mike Burns


Sent from my Sprint phone

div Original message /divdivFrom: Scott Leibrand 
scottleibr...@gmail.com /divdivDate:08/21/2015  11:14 AM  (GMT-05:00) 
/divdivTo: William Herrin b...@herrin.us /divdivCc: 
arin-ppml@arin.net p...@arin.net /divdivSubject: Re: [arin-ppml] 
Thoughts on 2015-7 /divdiv
/div
 On Aug 20, 2015, at 1:30 PM, William Herrin b...@herrin.us wrote:
 
 On Thu, Aug 20, 2015 at 3:46 PM, Rob Seastrom rs-li...@seastrom.com wrote:
 8.1.x Simplified requirements for demonstrated need for IPv4 transfers
 
 IPv4 transfer recipients must demonstrate (and an officer of the
 requesting organization must attest) that they will use at least 50% of
 their aggregate IPv4 addresses (including the requested resources) on an
 operational network within 24 months.
 
 Howdy,
 
 Still against it because it still applies to out-region transfers
 where ARIN no longer has access to it and CAN NOT revoke it for fraud
 when the attestation turns out to be untrue.

Actually, it does not apply to the recipients of out-of-region transfers. NRPM 
8.4 states that The conditions on a recipient outside of the ARIN region will 
be defined by the policies of the receiving RIR. 

This proposed language would only apply to 8.3 and 8.4 transfer recipients in 
the ARIN region. 

-Scott
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Re: [arin-ppml] Thoughts on 2015-7

[Michael Peddemors]

It looks like it is obvious, we need a new proposal that will 
accommodate both sides of this devide, enabling accurate record keeping, 
without language that encourages a positioning 'policy' that stake 
holders are uncomfortable with.


On 15-08-20 04:35 PM, Matthew Kaufman wrote:

On 8/20/2015 4:09 PM, Owen DeLong wrote:

This is one of those areas where people of good conscience can disagree.

I absolutely feel it is ARINs job as a steward of resources held in
trust for the community
to exercise due diligence in the issuance of those resources and to
revoke them when
fraud is detected.


That'd be a whole lot more than ARIN has ever done. You want them
spending their time trying to revoke and reclaim IPv4 space from
spammers (for instance) instead of working on getting IPv6 everywhere?

And of course the part they have been great at - diligence in the
issuance of IPv4 resources - is within a hair's breadth of done forever.



It may not be ARIN’s job to catch 100% of the liars out there, but it
is certainly important
that we do not hamstring ARIN in their ability to protect the
community from the liars
and the fraudsters to the extent possible.

I am opposed to the proposal.



Can you explain exactly how ARIN can keep liars and fraudsters from
paying someone money, using their address block anywhere in the world
for any purpose whatsoever, etc.?

All they can do is update, or not update, the registration database per
policy. This policy proposal makes their job easier and makes the
database more likely to reflect the ongoing state of the IPv4 transfer
market.

Matthew Kaufman


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Re: [arin-ppml] Thoughts on 2015-7

[Matthew Kaufman]

On 8/20/2015 1:04 PM, Brian Jones wrote:


​I agree with this simplified requirement but would even be willing to 
accept a 50% within 12 months and 75% in 24 months requirement. Two 
years is a long time to tie up valuable resources that are not being 
used. IMHO​




I do not understand this reasoning. There is no more free pool. If Org A 
is not using valuable resources and they are transferred to Org B who 
was mistaken about how fast they will use them, then Org B is also not 
using valuable resources. But if instead Org A can't transfer them, 
then Org B doesn't get them and Org A still has valuable resources 
which are tied up. They're tied up not being used either way... and 
ARIN can't do anything about it.


If you really want to make sure that these resources don't sit unused, 
make it so that after Org A transfers to Org B then if Org B doesn't use 
all of them, Org B can sell what they're not using.


Matthew Kaufman
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Re: [arin-ppml] Thoughts on 2015-7

[khatfield]

I agree with David here. I do believe there should be a requirement that any 
new allocations must keep the allocation x amount of time before it can 
transferred. Possibly 12 months+ which would thereby kill most ideas to sell 
for profit.

-Kevin



 On Aug 20, 2015, at 4:05 PM, David Huberman david.huber...@microsoft.com 
 wrote:
 
 Hi Bill,
  
  Still against it because it still applies to out-region transfers where 
  ARIN no
  longer has access to it and CAN NOT revoke it for fraud when the attestation
  turns out to be untrue.
  
 So I get what you're saying.  And you're right.  You and I petition ARIN, 
 attest
 that we forecast to use a /X, we're lying, and we transfer it out of the 
 region and
 ARIN is done with it - ARIN has no control over the block transferred out.
  
 The disagreement I have with this view is that I don't want us making policy 
 that
 punishes the 99.9% of people who are telling the truth and just want to run 
 their
 network, so that we can somehow catch the 0.01% of the scammers.  I prefer
 making policy which works well for bona fide network operators.  People will 
 always
 lie, and I do not believe it’s ARIN’s job to catch that.
  
 Thanks!
 David
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Re: [arin-ppml] Thoughts on 2015-7

[Matthew Kaufman]

On 8/20/2015 2:05 PM, David Huberman wrote:


Hi Bill,

 Still against it because it still applies to out-region transfers 
where ARIN no


 longer has access to it and CAN NOT revoke it for fraud when the 
attestation


 turns out to be untrue.

So I get what you're saying.  And you're right.  You and I petition 
ARIN, attest
that we forecast to use a /X, we're lying, and we transfer it out of 
the region and


ARIN is done with it - ARIN has no control over the block transferred out.



That is true today. ARIN does not have any control over how IP blocks 
are used (or transferred) today.


Which is why I'm supportive of this policy... it makes the right thing 
(recording a transfer properly in the ARIN database) happen.



The disagreement I have with this view is that I don't want us making 
policy that


punishes the 99.9% of people who are telling the truth and just want 
to run their


network, so that we can somehow catch the 0.01% of the scammers.  I 
prefer


making policy which works well for bona fide network operators.  
People will always


lie, and I do not believe it’s ARIN’s job to catch that.



Also agree... writing policy to try to block the wrongdoers always makes 
it harder for the legitimate users... which is the group ARIN should be 
supporting.


Matthew Kaufman

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Re: [arin-ppml] Thoughts on 2015-7

[Matthew Kaufman]

On 8/20/2015 4:09 PM, Owen DeLong wrote:

This is one of those areas where people of good conscience can disagree.

I absolutely feel it is ARINs job as a steward of resources held in 
trust for the community
to exercise due diligence in the issuance of those resources and to 
revoke them when

fraud is detected.


That'd be a whole lot more than ARIN has ever done. You want them 
spending their time trying to revoke and reclaim IPv4 space from 
spammers (for instance) instead of working on getting IPv6 everywhere?


And of course the part they have been great at - diligence in the 
issuance of IPv4 resources - is within a hair's breadth of done forever.




It may not be ARIN’s job to catch 100% of the liars out there, but it 
is certainly important
that we do not hamstring ARIN in their ability to protect the 
community from the liars

and the fraudsters to the extent possible.

I am opposed to the proposal.



Can you explain exactly how ARIN can keep liars and fraudsters from 
paying someone money, using their address block anywhere in the world 
for any purpose whatsoever, etc.?


All they can do is update, or not update, the registration database per 
policy. This policy proposal makes their job easier and makes the 
database more likely to reflect the ongoing state of the IPv4 transfer 
market.


Matthew Kaufman
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