[arin-ppml] Some observations on the differences in the various transfer policy proposals

[David Farmer]

Geoff,

You make a persuasive argument for the separation of the Registry and the 
Allocation functions in the RIR and that the Regulatory functions are tied to 
the Allocation functions and not to the Registry functions.

When I look at the construction of RIPE and APNIC Policy, I easily see this 
separation. However, when I look at the construction of ARIN Policy, I don't 
as easily see this separation.  It may actually be there, but just hidden and 
maybe this is a defect in ARIN Policy, or maybe it is a strength in the way 
ARIN policy was structured.  At the very least I believe this would need to be 
clarified in ARIN policy to create the outcome you are suggesting.

Second, you analogize the Registry Function with the function of a title 
office, and I tend to agree with this, especially in the transfer of whole 
Allocated block of addresses.   But unless a whole block that was already 
Allocated is being transferred, then we are talking about a Subdivision 
process, and for land there is defiantly a regulatory regime involved in doing 
that.  The title office may or may not be directly involved in the regulation of 
the subdivision process, honestly I am not sure how that works everywhere.  
But even if the title office is not directly involved in the regulation of the 
subdivision process, it is not free to register the subdivision of the land 
without the necessary regulatory approvals. 

So while I think agree with you about the separation of the Allocation and 
Registry functions.  I don't think IPv4 Address Exhaustion implies the end of 
the Regulatory processes and responsibilities of the RIRs for IPv4, it may  
change the focus, more to the Sub-Allocation process.  This Sub-Allocation 
process is already at least basically regulated in the current regulatory 
regime, all the RIRs place policy on what the LIRs (ISPs) do with the 
allocations granted to them.  If anything IPv4 Address Exhaustion reinforces 
the need for proper regulation of the important process of Sub-Allocation.  

So, at best I think the argument for separation the Registry and Allocation 
Functions provides a argument for the unrestricted transfer of whole IPv4 
address blocks as currently Allocated but does not provide a valid argument 
for deregulation of the Sub-Allocation or the dividing of IPv4 blocks into 
smaller ones.  

Just as with land and the fact that there are many valid reasons it is in the 
public interest to regulate Subdivision of land parcels, there are equally 
many reasons it is in the Internet Community's interest to regulate the Sub-
Allocation of IP address blocks.  And just as a title office can't register the 
subdivision of land without regulatory approval, an Internet Registry can't 
register the Sub-Allocation of IP address blocks without regulatory approval 
either.  In either case it, the title office or Internet Registry, would be acting 
outside of its separate role from the regulatory function and against the 
public interest.

Thanks

David Farmer

On 20 Oct 2008 Geoff Huston wrote:

> Hi,
> 
> At the ARIN meeting last week the question arose as to why the various  
> policy proposals related to address transfers in the different RIRs  
> were so different. I made some comments in response to this question  
> from my perspective and then I had some followup questions mailed to  
> me, so I thought maybe there is some value in writing up from my  
> perspective. After all there is still some difference between the  
> proposal(s) before ARIN and Proposal-50 before APNIC, and  the  
> question as to why this difference exists is an interesting one.
> 
> If you are interested its at: http://www.potaroo.net/ispcol/2008-11/transfers.html
> 
> thanks,
> 
>     Geoff Huston
> 
>     DIsclaimer: I'm speaking for myself, again!
 


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