[ppml] Policy Proposal 2008-2: IPv4 Transfer Policy Proposal

[Scott Leibrand]

Cliff Bedore wrote:
>> Cliff,
>>
>> Thanks for your feedback on the IPv4 transfer policy proposal.
>>
>> I'd be interested in your feedback on the Safe Harbor language in the 
>> policy proposal, as it directly relates to what you said about 
>> transferors no longer needing their space.
> 
> I guess I'd have to say this strikes me as contrary to what I understand
> to be current policy of "efficient utilization" requirements.  It may be that
> in some cases, selling a small section of an allocation wouldn't violate 
> "efficient utilization" but I think in many cases it would and ARIN would be
> simultaneously requiring the efficiency and letting people not be efficient if
> they are selling numbers for a profit.

I actually look at it a bit differently.  IMO we are attempting to 
encourage efficient utilization in several ways.  The primary current 
way, which will continue under the proposed transfer policy, is to 
require efficient use of current space, and plans to efficiently use new 
space, before anyone can get additional space.  Today, we don't have any 
good method of going back to legacy holders, and those whose networks 
are no longer growing, and verify efficient use.  Recent proposals 
confirmed that ARIN has the right to do so, but I haven't seen much 
space reclaimed as a result of that.  Additionally, and perhaps more 
importantly, space can be in use for purposes of audit, but may not be 
absolutely needed.  Without some incentive, most organizations in that 
situation won't want to take on the task of renumbering things to free 
up space.

So as I see it, encouraging people to free up space by allowing them to 
transfer it is a very effective way to encourage efficient utilization. 
  If you have ideas for equally effective ways to encourage such 
behavior, I'd love to hear them, but I don't think I've seen any so far.

> ---
> From 6.4.1 6.4.1. Address space not to be considered property
> 
> It is contrary to the goals of this document and is not in the interests of
> the Internet community as a whole for address space to be considered freehold
> property.
> ---
> 
> Whatever the proposed policy says, when someone can get paid for transferring
> something from themselves to another, it strikes me that that something is 
> effectively property.

This is definitely a valid concern.  ARIN counsel has been involved in 
helping us ensure that the proposed policy preserves the 
addresses-are-not-property legal regime as much as possible.  I suspect 
there will be an opportunity at Denver to discuss this issue at length, 
and unless ARIN wants to have counsel discuss the issue here on PPML, I 
think that's the best venue for discussing it.


>> On the issue of PIv6 space for IPv4 holders, the policy proposal to 
>> allow that did indeed get consensus at ABQ.  Unfortunately, due to 
>> issues with wordsmithing on the floor of the meeting, final approval has 
>> been delayed until we can bring the revised wording back at the Denver 
>> meeting and make sure no one feels it represents a significant change 
>> from the intent of the original proposal and what got consensus at ABQ.
> 
> Depending upon the outcome of that policy, I may submit a proposal to change
> that.

I look forward to seeing it.

-Scott

>> Cliff Bedore wrote:
>>> Leo Bicknell wrote:
>>>> In a message written on Thu, Feb 28, 2008 at 10:11:33AM -0500, Cliff Bedore wrote:
>>>>   
>>>>> I think the idea of this proposal is necessary but I don't think ARIN should
>>>>> be in the business of assisting transfer sales of IP addresses unless they
>>>>> have no assets to fill a legitmate request.  It may be implied somewhere that
>>>>> ARIN will not allow a sale if they have assets available but I didn't see it.
>>>>> Therefore I'm not convinced that "exhaustion of the IANA IPv4 free pool" is
>>>>> the correct time.  I think transfer sales should start the first time ARIN
>>>>> can't meet a legitmate request and even after that, should only be allowed
>>>>> when ARIN doesn't have the particular size requested available.  
>>>>>     
>>>> In one of our sessions someone proposed "the first time ARIN could
>>>> not fill a request"; and we were in fact informed that had already
>>>> occurred.  While a bit of a technicality, I suspect the issue was
>>>> ARIN did not have enough free space for a large request, and had
>>>> to go back to IANA for more space which prevented them from filling
>>>> the request right away.
>>>>
>>>> The problem with using the date ARIN can't make a sale is that it
>>>> is different for different people, and in fact may not be what you
>>>> request.  ARIN could keep a table of "we can make /18, /19, and
>>>> /20's" on the web site, but making a /20 may use up the last /18
>>>> and take it away.  Or, someone may ask for a /20, work with ARIN
>>>> staff who only sees justification for a /21, but there are none of
>>>> those left.  If someone was basing their decision on the availability
>>>> of /20's that won't work so well.
>>>>   
>>> I realize that ARIN resources and user resources for sale will happen in 
>>> an overlapping manner.  I realize it is a complex problem due to 
>>> considerations such as splitting a large block to handle a small block 
>>> vs transfer/sale of a user block of the right size.  Probably more 
>>> complex than I can imagine right now but ARIN is also chartered(? 
>>> whatever term is correct) to get users to convert to IPv6 and spending 
>>> lots of time and money to extend IPv4 seems to be contrary to that 
>>> goal.  I'm not sure anyone coming in for addresses that late in the game 
>>> shouldn't suffer a few delays in getting addresses.  It's not like they 
>>> haven't had ample warning about a shortage.
>>>> Lastly, if we wait for ARIN to be unavailable and then spin up the
>>>> system described in 2008-2 there will likely be a small gap during
>>>> which no one can get space.  While I believe ARIN staff can manage
>>>> the transition quite nicely, there is a level of public education,
>>>> putting information on the web, having staff process a new type of
>>>> request, etc.  I think many on the AC wanted to err on th side of
>>>> a small amount of overlap rather than a small gap in service.
>>>>   
>>> I don't think ARIN has to wait to set up the procedures.  I just think 
>>> they should wait to start using them. :-)  One problem with listing end 
>>> user blocks for sale is that technically, the end user can no longer 
>>> justify their current allocation and it would seem that ARIN would be 
>>> justified in reclaiming them is a fair number of cases rather than 
>>> approving a transfer sale.
>>>> Do any of those reasons alter your opinion, or do you still believe
>>>> IANA Free Pool exhaustion is the wrong time?
>>>>   
>>> I understand your argument but I think the answer has to decided based 
>>> on whether ARIN is more interested in promoting the switch to v6 or 
>>> band-aiding v4 for as long as possible.
>>>
>>> ARIN does seem to have something of a split personality toward 
>>> perpetuating v4 and promoting v6.  This proposal seems to me to be 
>>> bending over backwards toward perpetuating v4.  The proposals to 
>>> allow/get legacy users to use v6 and sign RSAs however seems to have 
>>> some dis-incentives to them.  If ARIN really wanted legacy users to sign 
>>> an RSA and convert to v6, they would allow them to qualify for a v6 
>>> allocation equivalent to the v4 size they received during the legacy 
>>> period without regard to whether they meet the current requirements.  As 
>>> an example, I have a /24 PI which was granted long before ARIN ever came 
>>> along.  I currently don't meet the 25/50% rule to justify that /24 but I 
>>> did meet the requirements at the time it was issued.  I would think that 
>>> ARIN could offer the minimum v6 allocation to any /24 (or maybe any) 
>>> legacy holder who is willing to sign the RSA and join the fold.  I don't 
>>> think it would be a big number since I expect many of the legacy 
>>> addresses have been abandoned and many who are active would qualify 
>>> under current rules but it would demonstrate ARIN's seriousness about 
>>> getting v6 started.  This should probably be a separate discussion but 
>>> it fits in with (at least my perception of) the ARIN split personality 
>>> aspect of the 2008-2
>>>
>>> Also note that in reality, I'll probably be retired and in a home before 
>>> my /24 will cease to be useful.  I'd like to get the v6 space to use for 
>>> learning/testing and maybe forcing my upstream ISP to start routing v6.  
>>> If enough people did that, it would help speed the transition.
>>>
>>> Cliff
>>>>   
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