[arin-ppml] Policy Proposal 2008-6: Emergency TransferPolicyfor IPv4 Addresses - Last Call

[Geoff Huston]

On 03/01/2009, at 7:07 AM, John Schnizlein wrote:
>> - IPv6 is deployed fairly rapidly, and with limited pain.
>
> What would prompt this sort of radical change from the deplorably slow
> deployment over the last several years?
>

Divine intervention? :-)

>>
>
>> And lastly, I've suggested an alternative method where by IPv4 space
>> can be redistributed.  One which I think puts ARIN in a much better
>> position with respect to the long term stability of ARIN and IPv6
>> allocations.  To suggest I'm opposing a market when I put forth a
>> proposal that creates one is rather silly.
>
> It seems to me that operating a market for IPv4 addresses is a risky
> business.
>

yes - if you are intending to insert the RIR into the role of  
qualifier, facilitator, and price setter. That path poses risks that I  
would see as being untenable for an RIR.


> Geoff Huston has made a (persuasive to me) argument that RIRs should
> not attempt to act as regulators, which is what the requirement that
> the recipient justify its need for IPv4 address space implies.

Yes, I believe that the RIPE policy, which places RIPE in the role of  
a "market qualifier" places the RIPE NCC into a position that is  
unreasonable and, I suspect, untenable. I have the same problem with a  
recent policy proposal proposed in the APNIC region which contains  
similar words relating to the RIR performing some form of  
qualification of market participants. Such a role is one that exposes  
the RIR to extremely high levels of risk in terms of the potential  
liability in its assessment procedures and also places it into a role  
of market regulator where the RIR is singularly ill equipped to  
perform and it has no recognized mandate or authority to perform, and  
calls into question the RIR's current de facto monopoly position with  
respect to address distribution and price setting. The scale of risk  
here, as I see it, is appropriately phrased as a risk to the continued  
existence of the RIR structure itself.

The 2008-06 policy, with the same proposed role of ARIN acting in a  
manner of a market regulator, in my opinion poses a similar level of  
risk to ARIN in its role as a de facto monopoly operation. A diligent  
process of review of this proposal may well benefit from some level of  
serious consideration of anti-trust issues within the region in which  
ARIN operates.

> But if getting into the regulation business is risky, just imagine the
> risk of operating an address market as the target of regulators!
> Every price and transaction would be subject to scrutiny of its
> fairness by parties involved in the transaction and others.  During
> the time that governments appear to be pursuing greater regulation of
> already established markets, a new lucrative market in IPv4 addresses
> would likely draw attention.  What would risk the existence of RIRs
> less, and help preserve the stability of the Internet would be
> reliable registration of address authorization-to-use.


A fine question - and I suspect personally that a more minimalist  
approach here in terms of a RIR's registry maintenance function is  
called for as a reasonable response.

   regards,

     Geoff