[arin-ppml] IPv4 Transfer Policy Change to Keep Whois Accurate

[John Curran]

On May 13, 2011, at 8:21 AM, Chris Engel wrote:
> 
> Actually, I would argue that "manufactured" need would be functionally identical to "genuine" need from the point of anyone forced to make approval decisions based upon that, unless the organization attempting to game the system was incredibly un-artful in their attempt.  How would someone charged with deciding to approve the "IP-Enabled virtual pet rock program" that was simply instituted to grab and hold IP addresses for a time until they were actually needed for a legitimate project or could be sold (at a profit) to someone who had a legitimate need for those addresses..... from a company that legitimately wanted to enter the "IP-Enabled virtual pet rock" business and were simply bad at business planning?  On paper, they'd be identical....the only thing that would be different was the motivation of the organization acquiring the resources....and how could anyone discern that without being a mind-reader?

Both receive approval for a small initial allocation (unless the one 
which was serious could show a history of subassignments from their 
existing IP-enabled "digital paperweight" program...)

As soon as either reached 80% utilization, we'd be happy to approve
a significantly larger allocation (and so on)

Does this clarify how these two organizations would be handled, and
how gaming the system works in the small but has diminishing returns?

> Note that speculators always risk being left holding the bag when the bottom falls out of the market they are playing with. Risk is inherent in what they do...unfortunately it doesn't seem to curtail their activities very much in most scarcity markets.

Agreed, although far fewer participate in situations where the risk
is self-created due to operating contrary to the system.  It's one
thing to point out to investors that you misread the market, it is 
another to explain that you were doing something that was technically
contrary to market rules and that resulted in the loss.

> Functionally the only things I see a needs based requirement accomplishing in a transfer market is artificially inflating the cost of transfers,

It definitely increases the net transaction cost.

> increasing the cost for ARIN to administer transfers

To be clear: it results in transfers having overhead similar to 
the assignment approvals which we are presently doing.

> and creating a new job position among certain companies of "needs justification designer".

That position or at least job task (IP address management) already 
exists in ISPs today (or at least those ISPs which are growing and
need additional allocations on a routine basis)

> I don't think it's going to accomplish what many proponents might hope it would very effectively.

For clarity: there is a big difference between "effective" and "very 
effective"; do you mean that you don't think it will curtail routing 
growth and prevent speculation at all, or simply that it will provide
less than ideal protection from such?

> In a market where acquiring IP addresses is relatively trivial (i.e. unassigned space from ARIN), I can certainly see why there has to be some artificial barrier built into the system to prevent people from acquiring IP space for trivial reasons....with a scarcity market, the cost of acquisition through transfers itself should act as a barrier to that. Anyway, that's how I see it...for whatever it's worth.

Good comments; hopefully this discussion will help folks in consideration 
of the large set of policy proposals before us.

Thanks!
/John

John Curran
President and CEO
ARIN