Sandra and all, Some comments below. On 25/07/2013, at 7:19 AM, <sandrabrown@ipv4marketgroup.com> wrote:
Dear Tore,
Thank you for inviting me to speak.
I feel this statement is somewhat disingenuous. The "odd RIR out" here is really ARIN, who is the only one to have a inter-RIR transfer policy that has a needs-based requirement that is also applied to the other region involved in the transfer.
I agree 100% that ARIN is the "Odd RIR Out". Only ARIN pushes for needs assessments and other silliness on transfers, and I agree 100% that companies will not be silly about spending good money on IPv4 addresses that may become worthless.
To clarify, the entire APNIC transfer system is "needs-based". The requirement applies to the recipient of any transfer, whether it is intra- and inter-regional; and not just in the case of transfers received from ARIN. I will also add that once the policy decision was made, the implementation of needs-based transfers has been almost entirely without complaint or controversy at APNIC. The requirements for receiving a transfer are exactly the same as they were for receiving an allocation, and these are well understood within the APNIC community. The only difference is that the recipient receives a "pre-approval" rather than an actual allocation. By the way, recipients can opt to have their pre-approval listed on the APNIC website, and you can see this listing here: http://www.apnic.net/services/become-a-member/manage-your-membership/pre-app... Currently we are completing on average around 10 transfers per month, 20% being inter-regional. All the best Paul Wilson Director General.
That said, there has been an inter-RIR proposal (2012-02) on the table for a while now, but the community does not seem to want or care much about it. I think that this is important to keep that in mind when deciding on how much weight to give this argument against 2013-03.
Yes, 2012-02 was on the table, but has now been withdrawn, pending the outcome of 2013-03. If, and hopefully when, 2013-03 is implemented, then my intention is to put in place a new inter-RIR proposal for the RIPE community, at a time the community feels is appropriate, which allows for transfer of **legacy** IP's currently in the ARIN registry. As you probably know, legacy IP's were issued to resource holders prior to the creation of ARIN in 1997, and thus legacy holders can request RIPE to register their IP's, if the RIPE community agrees, rather than ARIN, as the registry. Then the inter-RIR transfer of legacy IP's from ARIN to RIPE can proceed regardless of needs justification, as the legacy IP's would be in the RIPE registry rather than the ARIN registry. We would have to discuss the mechanics as it might better be regarded as an inter-RIR transfer from a legacy ARIN registry element to a RIPE LIR. This is much like the ERX transfers of the past, but to a purchasing LIR.
I'm not at all principally opposed to inter-RIR transfers, so if the author of 2012-02 would add a "need compatibility clause" to the proposed inter-RIR policy, I would have nothing against that. In other words, if it would be possible to make the need evaluation a voluntary thing that you only had to do if transferring addresses from the ARIN region - fine. Then those 5 LIRs, and those 5 only, could subject themselves to whatever demands the ARIN community might have, while the rest of us would be free of the IPv4 bureaucracy. Win-win.
No, the author of 2012-02 is strongly opposed to needs justification so I would not be interested in adding needs compatibility to inter-RIR transfers. I would much rather focus on legacy IP's for inter-RIR transfers, intra-RIR transfers within RIPE, and will support any discussion within the community to bring modern economics to ARIN.
Best Regards, and Thanks for the Invitation, Sandra Brown