In February 2012, I authored an ARIN policy proposal to eliminate any needs-based justification on paid transfers. It was not adopted obviously. Interestingly, the RIPE NCC adopted policy to remove needs-based justification on paid transfers in February 2014. With the benefit of two plus years facilitating transfers in ARIN, APNIC and RIPE regions since my original policy proposal, I would still prefer ARIN remove all needs analysis on paid transfers rather than compromising on a /16 maximum transfer without demonstrated need but only ONCE per year. It seems to me such a compromise is intended solely to appease rather than doing what is right for ARIN region businesses that shortly, may have no recourse but to enter the transfer market to obtain IPv4 resources that ARIN can no longer supply regardless of whether or not need is demonstrated. While it has only been a few months since RIPE region buyers have not been directed to demonstrate need in order to obtain transfer approval, I can tell the ARIN community one thing with certainty: the requested block sizes we receive may or may not be larger than truly "needed", but once market pricing is applied based on the most recent transfers completed, a /18 block request may quickly be modified by the prospective buyer to a /19 if the cost/benefit cannot be realized for their business within acceptable timelines. It is not about demonstrating justified need to the RIR, it is about balancing expense with the need to maintain business continuity and accommodating growth forecasts. The market has an interesting correction mechanism without RIR resources being applied to interrogate need regardless of block size requested/desired. If the ARIN community is concerned about speculation and hoarding with no needs assessment, I would invite you to review the RIPE transfer market statistics paying particular attention to block size (with or without need): http://www.ripe.net/lir-services/resource-management/ipv4-transfers/table-of-transfers.
So for those ARIN region companies that will have impending requirements for IPv4 resources based on previous allocations (consumption) and future growth, now is the time for you to weigh in with a position on the PPML. If you believe paying for transferred IPv4 resources with an officer attestation is sufficient justification in order to obtain blocks that inevitably, ARIN can no longer distribute, your comments would be most meaningful . Jeff Mehlenbacher IPv4 Market Group _______________________________________________ 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: http://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.