Dear Kevin,
The needs test has several flaws when operating in the new market environment.
It worked okay, not great, for the free-pool environment.
But now there are forces which were absent from the free pool environment which
are working on network operators.
These forces will tend towards policy avoidance, and there are several methods
of avoidance which reduce Whois accuracy.
In addition, the needs test creates an additional barrier for small entrants
such as yourself and absolutely prevents a first allocation via transfer.
Your attitude seems to be that those problems are acceptable so as to reduce
the likelihood of larger problems inherent to a commodity market.
Could you please provide a scenario in which the passage of one of the
proposals seeking to address the new reality will lead to these larger problems?
In particular, 2014-14 seeks to address this situation through the limited
removal of needs testing for a /16 or less, once per year per recipient.
Should that proposal pass, what in your mind would be the downside risk?
Perhaps if we can identify that risk, we can address it.
For example, there is the fear that nefarious actors would spin up separate
organizations and use them to get around the limits of 2014-14.
Perhaps there is a way to allow ARIN staff the power to identify and protect
against this through some definition of related organizations?
For another example, there are many who feel a /16 is not small, and would
provide a great enough opportunity for hoarding by enough separate
organizations that it could affect the overall transfer marketplace. Would you
consider a smaller block size more appropriate to minimize this risk? Owen has
suggested a /20, temporarily.
As ARIN gets to the dregs of the free pool, staff will be busy team-reviewing
every allocation, and there is a long tail of unaggregatable /24s, more than a
thousand. Since every applicant will get only a /24 and be told to come back in
three months, we can easily foresee ARIN staff being very busy. My reading of
policy also finds that in our current Phase IV, team review has to happen to
transfers, too. Maybe John Curran can confirm or deny this? I could be mistaken.
But if that is indeed the case and ARIN staff is very busy, response times will
decay. ARIN already posted a warning to that effect on their website. Should
this slowdown materialize, is this the kind of support of network operators you
think is ARIN’s proper role? Would you consider a change to policy which
required organizations attest to their need for a small block rather than
involve ARIN staff in review? If so, is there a maximum block size for which
you would accept attestation in lieu of staff review? What about how much team
review of /24s costs the community, as we consider funding, is that a worthy
investment?
I read you as concerned about the impact of the profit motive on the IPv4
allocation process, but surely you understand that the genie is out of the
bottle in that regard, and ARIN will register a block to a needy porn site that
pays more than a needy community workshop? So the needs test does not prevent
those with more money from outbidding those with less. Those with more money
will get the space. What the needs test does is prevent hoarding by those who
seek to buy without need, as we define need. I think that it is incumbent on
you to go beyond lamenting the profit motive and the commodity market as
problematic, and actually provide a scenario which could be damaging to network
operators should a limited removal of needs-testing be implemented.
Finally, as should be expected of every organization, you wish to leverage the
system that exists to your benefit.
Here is my advice: go to ARIN under immediate need and tell them you plan to
stop the NATTING, then get your /24.
ARIN does not require you to NAT. In the stewardship community’s expressed
wisdom, conserving addresses in this way reduces your justifiable need for IPv4.
Perversely, you are being punished for your conservation, although I am sure
your NAT is functioning perfectly for you.
Regards,
Mike Burns
From: Kevin Kargel
Sent: Tuesday, September 23, 2014 11:44 AM
To: [email protected]
Subject: [arin-ppml] reverse COE statement
I should point out that the strength of my convictions on the discussion of
needs assessment impacts me negatively on a personal level. I am in a position
where I would love to get a /24 for my own use, personally and business.
Unfortunately I would not pass the needs requirement. I could present about 40
IP addresses that are currently NATed, with some small future growth
projection. That would not – in my understanding – pass muster for an
allocation under the current rules. I will in the near future be changing
locations and providers for that network and a portable IP block would be most
handy.
I honestly do not believe that eliminating needs tests would be good for
society.
If needs tests were eliminated all that would be left in my way would be the
money hurdle, which presents a relatively low bar to vault.
Don’t get me wrong, if needs tests are eliminated over my objections I will be
at the front of the line with my application. I see nothing wrong with
legitimately leveraging the system that exists.
I know it would be trivial as a network operator to game the system for a /24,
I just don’t want to do it that way.
--------------------------------------------------------------------------------
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