Milton, On Sun, Jun 22, 2014 at 6:21 AM, Milton L Mueller <muel...@syr.edu> wrote: > David > I don't think an intransigent attitude toward retaining needs testing is > justified by anything you have cited here or elsewhere.
None of the folks who support needs-testing are being intransigent. Most have signaled a willingness to compromise. RIPE has basically eliminated needs assessment, see this article for an assessment of the results: > http://www.internetgovernance.org/2014/06/20/baby-steps-and-big-differences-in-address-transfer-market/ > > In economics there is the concept of transaction costs. Needs testing is a > transaction cost in both free pool allocations and market transfers. If the > transactions costs are too high, it is a barrier to transactions happening at > all. Basically, it means that you don't spend $5,000 worth of staff time and > transacting parties' time to effectuate a transfer that may be worth $4,000 > or even $6,000. > > I think the case that's being made here is that for small transfers, the cost > of a full-fledged needs assessment is simply not worth the trouble, as it is > disproportionately large relative to the value of the overall transaction. > For the smaller transactions, which cannot really pose threats of hoarding > and speculation, the value the community gains from imposing traditional > needs assessment criteria is pretty minimal compared to the natural form of > rationing you are going to get from the market price for the number block. As David said: "I don't support fixing the perceived problem and do not agree it is even a real problem." "Problem Statement: ARIN staff, faced with a surge in near-exhaust allocations and subsequent transfer requests and a requirement for team review of these, is spending scarce staff time on needs testing of small transfers..." Do you have evidence from Registration Services that it is a "real problem"? The data you provide on the link above doesn't show this at all. -- Cheers, McTim "A name indicates what we seek. An address indicates where it is. A route indicates how we get there." Jon Postel p.s. the Metropole lobby does a smashing High Tea > > >> -----Original Message----- >> From: arin-ppml-boun...@arin.net [mailto:arin-ppml-boun...@arin.net] >> On Behalf Of David Farmer >> Sent: Tuesday, June 17, 2014 7:21 PM >> To: ARIN PPML >> Subject: Re: [arin-ppml] Draft Policy ARIN-2014-14: Removing Needs Test >> from Small IPv4 Transfers >> >> First, While this policy has a clearly formed problem statement, I don't >> support fixing the perceived problem and do not agree it is even a real >> problem. >> >> Then, the proposed solution to this none problem is "removing needs >> testing" for small IPv4 transfers. I can not support the concept of removing >> needs testing, that is a line I'm not willing to cross. >> >> However, some of the ideas for this policy come from comments I've made. >> But, for some reason those ideas are spun around to eliminate need, >> instead of redefining need, which I think can gain community consensus. >> >> I support a fundamental reexamination and redefinition of what justified >> need means in a post (or nearly post) free pool world. But, fundamentally >> there has to be need involved, the definition for that need may look >> radically >> different than what we have used for the last 20 years or so. >> >> I support redefining justified need for the transfer of a /24 and up to a >> /20 as >> justified by an officer attestation that the resources are needed for use on >> a >> operational network within 6 months and a willingness to expend financial >> resources necessary to acquire the IPv4 resources on the transfer market. >> However, this is only one small part of the reexamination and redefinition of >> justified need that is necessary, but is seems like a reasonable bit size >> chunk >> to start with. >> >> Some may argue that is the same thing that this policy does, and I must >> disagree; This policy wants to eliminate needs justification, granted only >> for >> small transfers. But it eliminates need none the less. >> >> Where as what I'm suggesting fundamental redefines and simplifies what >> justified need means in a post (or nearly post) free pool world for small >> transfers, but does not eliminate need. Granted, I'm talking about a fairly >> low bar being set. But there is a bar and it's not as low as some may think. >> The fact that IPv4 resources have to be acquired on the transfer market is >> accounted for as part of the demonstration of need, this is a real constraint >> for most organizations. Furthermore, the officer attestation requirement >> provides organizational commitment that resources are going to be used and >> not just stockpiled. >> >> I think the real problem this solves is failure of slow start when there is >> no >> free pool to prime the pump. >> >> So, unfortunately while this policy is at least partially based on my >> suggestion, I can not support the problem statement given, nor can I support >> the policy as written. Therefore, I suggest abandoning this problem >> statement and policy, and starting over with a problem statement focused on >> a different issue and not focusing on the elimination of need at a solution. >> >> On 5/16/14, 15:20 , ARIN wrote: >> > On 15 May 2014 the ARIN Advisory Council (AC) accepted "ARIN-prop-204 >> > Removing Needs Test from Small IPv4 Transfers" as a Draft Policy. >> > >> > Draft Policy ARIN-2014-14 is below and can be found at: >> > https://www.arin.net/policy/proposals/2014_14.html >> > >> > You are encouraged to discuss the merits and your concerns of Draft >> > Policy 2014-14 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-2014-14 >> > Removing Needs Test from Small IPv4 Transfers >> > >> > Date: 16 May 2014 >> > >> > Problem Statement: >> > >> > ARIN staff, faced with a surge in near-exhaust allocations and >> > subsequent transfer requests and a requirement for team review of >> > these, is spending scarce staff time on needs testing of small >> > transfers. This proposal seeks to decrease overall ARIN processing >> > time through elimination of that needs test. >> > >> > Policy statement: >> > >> > Change the language in NRPM 8.3 after Conditions on the 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 "For transfers larger than a /16 equivalent or >> > for recipients who have completed a needs-free transfer in the prior >> > year, 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." >> > >> > Change the language in the third bullet point in NRPM 8.4 after >> > Conditions on the recipient of the transfer: from "Recipients within >> > the ARIN region must demonstrate the need for up to a 24-month supply >> > of >> > IPv4 address space." to "For transfers larger than a /16 equivalent or >> > for recipients who have completed a needs-free transfer in the prior >> > year, recipients in the ARIN region must demonstrate the need for up >> > to a 24-month supply of IP address resources under current ARIN >> > policies and sign an RSA." >> > >> > Comments: >> > >> > Needs testing has been maintained for transfers largely because the >> > community wishes to ensure protection against hoarding and speculation >> > in the IPv4 market. This proposal seeks a middle ground between the >> > elimination of needs tests for transfers altogether, and the >> > continuance of needs tests for every transfer. This should help ARIN >> > staff to reduce transfer processing time, since most transfers have been >> smaller than /16. >> > >> > Timetable for implementation: Immediate >> >> -- >> ================================================ >> David Farmer Email: far...@umn.edu >> Office of Information Technology >> University of Minnesota >> 2218 University Ave SE Phone: 1-612-626-0815 >> Minneapolis, MN 55414-3029 Cell: 1-612-812-9952 >> ================================================ >> _______________________________________________ >> 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. > _______________________________________________ > 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. _______________________________________________ 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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