I can see the logic of supporting "3". I am going inclined to agree with David. We have to promote accuracy in whois as a policy priority.
I support No. 3 Rudi Daniel (information technologist) 784 430 9235 On Mar 5, 2014 10:02 PM, <[email protected]> wrote: > Send ARIN-PPML mailing list submissions to > [email protected] > > To subscribe or unsubscribe via the World Wide Web, visit > http://lists.arin.net/mailman/listinfo/arin-ppml > or, via email, send a message with subject or body 'help' to > [email protected] > > You can reach the person managing the list at > [email protected] > > When replying, please edit your Subject line so it is more specific > than "Re: Contents of ARIN-PPML digest..." > > > Today's Topics: > > 1. Re: ARIN Draft Policy 2014-2 Improved 8.4 Anti-Flip Language > (David Huberman) > 2. Re: ARIN Draft Policy 2014-2 Improved 8.4 Anti-Flip Language > (Spam Auditor) > 3. Re: ARIN Draft Policy 2014-2 Improved 8.4 Anti-Flip Language > (Bill Darte) > > > ---------------------------------------------------------------------- > > Message: 1 > Date: Wed, 5 Mar 2014 21:17:58 +0000 > From: David Huberman <[email protected]> > To: Bill Darte <[email protected]>, "[email protected]" > <[email protected]>, Owen DeLong <[email protected]> > Subject: Re: [arin-ppml] ARIN Draft Policy 2014-2 Improved 8.4 > Anti-Flip Language > Message-ID: > < > 87b03e32ad2743559958047e94c94...@dm2pr03mb398.namprd03.prod.outlook.com> > > Content-Type: text/plain; charset="us-ascii" > > As the author of this proposal, and having encountered the real-world > consequences of existing 8.4 anti-flip language, I support #3 as the > cleanest, simplest approach that best promotes Whois accuracy. > > > > ARIN is a registry, not a regulator. Let's write policy that promotes > accuracy in Whois, please. > > > > David R Huberman > Microsoft Corporation > Senior IT/OPS Program Manager (GFS) > ________________________________ > From: Bill Darte <[email protected]> > Sent: Wednesday, March 5, 2014 7:00 AM > To: [email protected]; David Huberman; Owen DeLong > Subject: ARIN Draft Policy 2014-2 Improved 8.4 Anti-Flip Language > > On Feb. 21 I sent the message (far below) to PPML asking the community to > support one of 3 alternatives or propose new language which makes one or > the other better, or a completely new wording which they believe > accomplishes the goal of producing policy language that is needed, > technically sound and improves existing policy in the 8.4 Inter-RIR > transfer realm. > > > Summary of feedback so far: > 2 persons supporting #2 with the removal of "and its subsidiaries". There > was some support for the extended language of "and its subsidiaries having > been operational for a minimum of xx months" in order to mitigate the > rinse-repeat abuse that might accrue through new shell subsidiaries. > > > There was some support for the alternative language expressed in #3 at the > PPC in Atlanta and at the ARIN AC meeting on Feb 20. This language simply > restricts the transfer of the block having been received...which would > allow other existing blocks or components to be transferred. One view > against #3 was expressed as "An org that currently has a /8 can obtain the > resources it needs and sell off the /8 out of region a few chunks at a time > by backfilling with new space from the ARIN region.". A rejoinder to this > was expressed pointing out that other existing language in 8.4 > states...."Source entities within the ARIN region will not be eligible to > receive any further IPv4 address allocations or assignments from ARIN for a > period of 12 months after a transfer approval, or until the exhaustion of > ARIN's IPv4 space, whichever occurs first." > <<< end summary >>>> > > > > > It is important that I receive a significant measure of support FOR or > AGAINST continuing to work on this Draft and before the ARIN AC meeting on > Mar 20, I would like to have better language to propose if we are to make > this Draft a Recommended Draft prior to the April PPM in Chicago. > > > I would be grateful for your feedback as early as possible. > > > bd > > > <<<<<<<<< earlier email sent to PPML on Feb 21 >>>>>>>>>>>>>>> > At the Advisory Council's meeting of Feb 20, discussion about Draft Policy > 2014-2 concluded that there is a real issue with transfer restrictions of > address blocks between RIR jurisdictions for organizations having received > a different block of addresses from ARIN within the last 12 months (per > existing policy). > > > The current Draft Policy language is as follows with only the last > sentence being added from what is current ARIN policy: > "Source entities within the ARIN region must not have received a transfer, > allocation, or assignment of IPv4 number resources from ARIN for the 12 > months prior to the approval of a transfer request. This restriction does > not include M&A transfers. Restrictions related to recent receipt of blocks > shall not apply to inter-RIR transfers within the same organization and its > subsidiaries." > > > The last sentence of this language was added to mitigate the problems > related by the author in the problem statement and from experience. The > author supported this change, however, some concern has been expressed on > the PPML and within the AC about the possibility of 'rinse and repeat' > abuse associated with the ease of establishing new subsidiaries and using > those transfers to get around the restrictions of the existing transfer > policy. > > > Three alternatives were primarily discussed and I wish to elicit feedback > from the community relative to each. > > > 1. Use the existing last sentence as is and ask ARIN staff to be > particularly watchful for seeming abuse and to bring such back to the > community through regular Policy Experience Reports. There was discussion > about this option suggesting that by the time abuse was recognized and > reported, and given limited existing free pool stocks and the extended > policy development cycle....this option may be moot. > > > 2. Remove the clause 'and its subsidiaries' or modify it in such a way as > to mitigate the risk of a laundering of addresses through fraudulent > transfers, but this may still potentially limit the utility to > organizations who may have complex organizational structures in use > internationally. > > > 3. Take an alternative tack and simply restrict transfers on a per-block > rather than a per-organization basis. e.g. 'No block acquired within the > past 24 months would be eligible for transfer.' (The time frame is of > course an arbitrary number at this point.) > > > If you believe this Draft Policy is improved most significantly by one of > the above alternatives, or through another alternative you can pose....I, > and the community would benefit from your input. Thanks, > > > Bill Darte > Policy Shepherd for 2014-2 and > Advisory Council member > -------------- next part -------------- > An HTML attachment was scrubbed... > URL: < > http://lists.arin.net/pipermail/arin-ppml/attachments/20140305/629d8e4f/attachment-0001.html > > > > ------------------------------ > > Message: 2 > Date: Wed, 05 Mar 2014 17:54:34 -0800 > From: Spam Auditor <[email protected]> > To: [email protected] > Subject: Re: [arin-ppml] ARIN Draft Policy 2014-2 Improved 8.4 > Anti-Flip Language > Message-ID: <[email protected]> > Content-Type: text/plain; charset=ISO-8859-1; format=flowed > > On 14-03-05 01:17 PM, David Huberman wrote: > > As the author of this proposal, and having encountered the real-world > > consequences of existing 8.4 anti-flip language, I support #3 as the > > cleanest, simplest approach that best promotes Whois accuracy. > > > > ARIN is a registry, not a regulator. Let's write policy that promotes > > accuracy in Whois, please. > > > > *David R Huberman* > > Microsoft Corporation > > Senior IT/OPS Program Manager (GFS) > > Here, Here... > > However, even though it isn't a regulator, there should be enforcement > considerations, especially when IP Space is granted and used for > purposes contrary to the application.. > > > > > ------------------------------ > > Message: 3 > Date: Wed, 5 Mar 2014 19:58:50 -0600 > From: Bill Darte <[email protected]> > To: Spam Auditor <[email protected]> > Cc: "[email protected]" <[email protected]> > Subject: Re: [arin-ppml] ARIN Draft Policy 2014-2 Improved 8.4 > Anti-Flip Language > Message-ID: > <CAMApp35hhh= > [email protected]> > Content-Type: text/plain; charset="iso-8859-1" > > Spam Auditor.... > Are you FOR or AGAINST the proposal in general....and does your 'Hear, > Here' include David's support for option #3? > Thanks, > bd > > > On Wed, Mar 5, 2014 at 7:54 PM, Spam Auditor <[email protected] > >wrote: > > > On 14-03-05 01:17 PM, David Huberman wrote: > > > >> As the author of this proposal, and having encountered the real-world > >> consequences of existing 8.4 anti-flip language, I support #3 as the > >> cleanest, simplest approach that best promotes Whois accuracy. > >> > >> ARIN is a registry, not a regulator. Let's write policy that promotes > >> accuracy in Whois, please. > >> > >> *David R Huberman* > >> Microsoft Corporation > >> Senior IT/OPS Program Manager (GFS) > >> > > > > Here, Here... > > > > However, even though it isn't a regulator, there should be enforcement > > considerations, especially when IP Space is granted and used for purposes > > contrary to the application.. > > > > > > _______________________________________________ > > PPML > > You are receiving this message because you are subscribed to > > the ARIN Public Policy Mailing List ([email protected]). > > Unsubscribe or manage your mailing list subscription at: > > http://lists.arin.net/mailman/listinfo/arin-ppml > > Please contact [email protected] if you experience any issues. > > > -------------- next part -------------- > An HTML attachment was scrubbed... > URL: < > http://lists.arin.net/pipermail/arin-ppml/attachments/20140305/378b9d59/attachment.html > > > > ------------------------------ > > _______________________________________________ > ARIN-PPML mailing list > [email protected] > http://lists.arin.net/mailman/listinfo/arin-ppml > > End of ARIN-PPML Digest, Vol 105, Issue 11 > ****************************************** >
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