Hi David,
On Tue, 17 Jun 2014, David Farmer wrote:
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.
You mean the problem of delays in resource request processing time as
suggested by Leslie and seemingly confirmed by others? Please share the
information that you have that contradicts this.
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.
Why not? Because it is a line? Why?
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.
Happens all the time. People have the right to spin. That some other
proposal might gain consensus is not a valid argument against the current
proposal. Cum hoc ergo propter hoc, probably
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.
First sentence, thank you for that good idea. Second sentence, Why? What
gives you the right to say? To just declare and make it be so. State the
reason.
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.
About .03%. Accurate numbers coming. A useless gesture. Symbolism.
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.
Argument through tautology. No one is disputing that this policy seeks to
eliminate needs basis for small transfers. Please show your work. State
the reason for your disagreement. Don't go in circles. Please.
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.
Possibly a good idea, but not a _REASON_ for not doing this.
Granted, I'm talking about a fairly
low bar being set.
No danger of tripping. A piece of tape on the floor.
But there is a bar and it's not as low as some may think.
This will require evidence, I think. I'll have some coming as soon as I
stop being interrupted.
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.
Not even a policy proposal, just the suggestion of one and it is an
argument against 2014-14? No.
I think the real problem this solves is failure of slow start when there is
no free pool to prime the pump.
Starting to see a pattern? Something that happened before is not evidence
of causation. post hoc ergo propter hoc.
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.
Everybody gets to change their mind. However unless you provide logical
_REASONS_, your stance may be acknowledged and then not taken into
account, by fair minded people who wish to have a logic based discussion.
Clearly you _FEEL_ strongly. As Lee Howard would say, that does not make
you more persuasive. Reasons will do that.
John Springer
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: [email protected]
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
================================================
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