[arin-ppml] Draft proposal that needs some wordsmithing

[Mike Burns]

Hi Chris,
>
>> The underlying proposition behind this policy proposal is that the
>> registry of IPv4 addresses operated by ARIN is of general utility and
>> value only while it accurately describes the current state of address
>> distribution. If a class of address movement transactions are excluded
>> from being entered in the registry, then the registry will have
>> decreasing value to the broader community, and the integrity of the
>> network itself is thereby compromised.  This proposal's central aim is
>> to ensure the continuing utility and value of the ARIN address
>> registry by allowing the registry to record transactions where IPv4
>> addresses are transfered between ARIN account holders.
>
> Here is where you lose me. The first two sentences are fundamentally
> true and the third sentence is a valuable and noble goal. The piece of
> the puzzle that I am still missing is this: Why would organizations
> choose to "move addresses" in an excluded manner? A few facts that I
> find important:
>
> 1) IPv4 addresses have value for Internet routing only if they are unique.

Yes, good stewardship should have reliable registry service as a primary 
goal.

> 2) The best way to ensure uniqueness on this scale is to maintain a
> public record or database of some form.

Yes, a publilcy queryable database to determine routing authority and to 
maintain uniqueness of registry.


> 3) ARIN (and the other RIRs, in cooperation with the IANA) maintains
> entries in such a database (plus a couple other services provided) for
> a nominal fee.

Yes.

> 4) Because spots in this database are limited, for at least the last
> decade (it can be argued that this was true from the very beginning,
> with increasing oversight over time), receiving a spot in this
> database has required a justification of need. You've had to
> demonstrate that you were actually going to use the spot that you
> wanted to occupy to add value to the global network.

Yes, it made obvious sense to apply a needs requirement to the allocation of 
addresses from the free pool.


> 5) Completely new spots in the database (unused IPv4 addresses) are
> about to run out.

Yes.

>
> Based on those facts, I end up with two questions:
>
> 1) How/why does fact number five change any of the preceding facts?
> (i.e. Why should the realization of scarcity change our stewardship
> behavior, behavior that was based on an understanding of scarcity?)

Because prior to exhaust there was no other mechanism to ensure addresses 
were allocated and used efficiently.
After exhaust a free market is the appropriate mechanism to ensure addresses 
are allocated and used efficiently.
Prior to exhaust, without such a mechanism, I could have walked up and asked 
for a /2.
Obviously to anybody, I hope, that would have been unworkable.
The system that was devised and implemented was a needs analysis which 
simply made allocations according to demonstrated need.
The ensured that at least at the start, addresses would not be frivolously 
wasted.
After exhaust and in the presence of a free market, the price of the 
addresses will fill the role that needs analysis filled before.
They will cause addresses to move to efficient usage.
We know the needs requirement was not a perfect way to ensure efficiencies.
We know that from the number or allocated and not advertised space, if 
nothing else.
A market will not be perfect either, but unlike the prior needs analysis, we 
seem to be judging the free market by the exceptions.


> 2) Why would any organization with need for unique IPv4 addresses
> choose to not have those addresses recorded in the database which
> guarantees their value in order to escape stating their need? (i.e.
> What class of organization with legitimate need would be hurt by
> having to demonstrate that need before receiving addresses?)
>

An aggregator buying unroutable bits to aggregate to a routable size?.
Somebody who has a different view on the IPv6 transition timeframe and has a 
longer planning horizon for IPv4?
A reseller of vanity addresses, like 100.100.100.100?
A wholesaler of addresses who caters to those who need instant availability 
(needs analysis takes time)?
A speculator, who could have a positive role in free markets?
An organization that does not want to undergo an ARIN analysis for fear it 
will lead to a review and recovery procedure?
An organization from another region?
A buyer of a /24 who thinks an ARIN needs analysis isn't worth the expense?
Microsoft? They didn't seem to want or need a needs analysis until ARIN 
began negotiating with them after the original asset agreement with Nortel 
had been negotiated.

I don't pretend to be able to able to identify all the types of transactions 
for which an ARIN needs analysis seems an unnecessary intrusion into a 
transaction between two private entities.

The point is that many prior transfers have taken place, particularly with 
legacy space, that have not been reflected in whois. One of the problems 
relates to the requirement for a needs analysis.
If a holder of legacy space acquired through an asset sale approached ARIN 
to reflect that transfer, ARIN would not update whois without a needs 
analysis.
In addition, the requirement for ARIN to do a needs analysis and the 
potential for review and recovery on either the buyer or seller increases 
the FUD factor in the market.
For a market to function efficiently, Fear, Uncertainty, and Doubt need to 
be assuaged, and this proposal does that.

I copied liberally, almost entirely, from the APNIC policy to allow 
needs-free transfers. The rationale which was most effective in that 
regions's deliberations may have been the concern that by imposing the needs 
requirement, transactions would be more likely to occur outside the system, 
leading to a decay in whois reliability.

By structuring my proposal in this way, I am trying to get people to 
consider whether the original and laudable needs requirement should be 
maintained when keeping it could lead to whois degradation.
My argument is that  proper stewardship recognizes the existence of a market 
which will fulfill the original stewarship role of ensuring efficient use, 
and we can direct our stewardship best to policies which help to ensure 
whois veracity.

Regards,
Mike