Don't know if a /12 cap would work if a big guy like tmobile or Microsoft 
applied for a larger allocation. It is fine for most organizations though. 

Sent from my iPhone

On Jun 12, 2013, at 10:21 AM, "Mike Burns" <m...@iptrading.com> wrote:

> Hi Steve, Bill, Brandon,
> 
> Thanks for your input.
> Yes, I should have been clearer in that the original proposal called for a 
> /12 per year per organization cap.
> 
> At least at this point in time, the number of transfers is relatively low, 
> the block sizes also, and  I think the staff at the RIRs would certainly 
> detect attempts to evade the needs test through transfers to linked shell 
> corporations.  When the block sizes and values get big (/12, $10million), the 
> number of players willing to risk borderline fraud gets small, in my opinion. 
> With ARIN staff freed from processing justifications, perhaps they will have 
> more time to devote to detecting this kind of activity.
> 
> As for the cap size being based not on annual transfers, but instead on 
> aggregate block size of the receiving entity, I think it worthy of 
> consideration. It seems like the effect will be to allow most transfer 
> transactions to proceed without needs tests.  Do we think that this form of 
> cap will have the same effect on the protection against hoarding and price 
> manipulation?
> 
> Regards,
> Mike
> 
> 
> 
> 
> 
> 
> -----Original Message----- From: Steven Ryerse
> Sent: Wednesday, June 12, 2013 7:23 AM
> To: Brandon Ross ; William Herrin
> Cc: Mike Burns ; ARIN PPML
> Subject: RE: [arin-ppml] A Redefinition of IPv4 Need post ARIN run-out 
> (was:Re:Against 2013-4)
> 
> Brandon and Bill, I think you are on the right track.  I've said recently 
> that allocations of IPv4 should be limited to some combination of 
> organization size and/or current IP allocations.  Of course translating that 
> into a policy that works is tricky but doable I think.  Why not take the 
> needs test completely off the "Minimum Allocation Size" which I think is 
> currently a /22.  Add a standard waiting period between allocations of say 6 
> months.  Provide some way an organization with a hardship can apply sooner 
> than 6 months if they have a truly demonstrable need.  Then match the 
> allocation request size with the organizations current allocation's - and/or 
> their current network size or financial size.
> 
> On the low end some more /22 allocations really aren't going to cause 
> exhaustion that much faster and on the large size all the way to a /8, only 
> organizations who are big enough would get a big allocation similar to the 
> way T-Mobile got 3/4 of a /8 a while back.  If a big guy like an AT&T or 
> Verizon  were to apply for a /8, even though ARIN only has one full /8 left, 
> I'm guessing they could justify it under almost any needs criteria or they 
> wouldn't be requesting it.  I'm sure this community has the knowhow to come 
> up with policies that accomplish this.
> 
> Under this scenario the needs part of the allocation request is removed and 
> what remains is a rightsizing policy in its place to reduce hoarding as best 
> as we can.  My gut tells me that changing to this kind of allocation process 
> would not cause ARIN to run out of addresses much sooner than current 
> policies.
> 
> -----Original Message-----
> From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] On 
> Behalf Of Brandon Ross
> Sent: Wednesday, June 12, 2013 12:07 AM
> To: William Herrin
> Cc: Mike Burns; ARIN PPML
> Subject: Re: [arin-ppml] A Redefinition of IPv4 Need post ARIN run-out 
> (was:Re:Against 2013-4)
> 
> On Tue, 11 Jun 2013, William Herrin wrote:
> 
>> On Tue, Jun 11, 2013 at 9:22 PM, Mike Burns <m...@nationwideinc.com> wrote:
>>> What about a needs-free transfer cap?
>> 
>> It'd have to be per-timeframe (per year). A per-transfer cap would be
>> meaningless.
> 
> I support the idea, in general, of needs-free transfer cap, however, I'd 
> suggest that cap be based on the total amount of address space that an entity 
> controls rather than a per period or per transfer based cap.
> 
> In other words, if you are big enough to justify, in total, a /12 of address 
> space, then you are big enough to handle the burden of justification.  If you 
> have less space than that, in aggregate, then the needs requirement can be 
> waived.
> 
> If shell corporations are a concern, then the cap can be made small enough 
> such that any attempt to corner the market would be easy to detect because of 
> the sheer number of shells necessary to do so.  Perhaps it's possible to hide 
> the ownership of a dozen, but certainly not 100 or 1000.
> 
> It is worthwhile, however, to point out that if I wanted to hoard IPv4 
> address space, there's nothing stopping me from doing that using shell 
> corporations now, so I don't see how removing the cap for small allocations 
> really makes much of a difference.
> 
> -- 
> Brandon Ross                                      Yahoo & AIM:  BrandonNRoss
> +1-404-635-6667                                                ICQ:  2269442
> Schedule a meeting:  https://doodle.com/bross            Skype:  brandonross
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