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

[Mike Burns]

> On 5/11/11 22:09 CDT, Mike Burns wrote:
> ...
>> I'm sure there are many more that I cannot think of. I agree with you
>> that most buyers will have need, and I agree with you that most buyers
>> will see the value of maintaining a valid ARIN whois record pointing to
>> their authority.
>
> Unfortunately, most rules are meant to enforce something on those who are 
> not necessarily acting reasonably.  Above you save "most buyers will see 
> value" what about those that don't.  Or, what about those, that see a 
> value in ensuring that their competitors can't get addresses and that the 
> whole system doesn't shift to IPv6.  I don't want to see something like 
> that happen and I'm not entirely sure it can't.
>
>> But the policy in APNIC was changed to remove needs requirements for
>> transfers for the same reasons I am requesting its removal here.
>
> There are other policy differences between APNIC and ARIN then just needs 
> or non-needs based transfers that are relevant to the changes due to IPv4 
> run-out. There is also a fundamental difference in the way APNIC and ARIN 
> plan to operate the pool of addresses they have left, APNIC is reserving 
> their whole /8 and allowing each organization a single /22. The ARIN 
> community has reserved /10 of IPv4 for IPv6 purposes, but is allowing need 
> to driver the run-out of the rest of the pool, limiting to 3 month need 
> for fairness with new entrants and to reduce the competitive disparity 
> created by IPv4 run-out.  Additionally ARIN added officer attestations, to 
> ensure organizational accountability for requests, I believe this will 
> strongly suppress the tendency for ARIN to have a run-out curve like APNIC 
> had during the first 4 months of 2011.

Yes, there are other policy differences and the runout curve would be 
different, although they both lead to zero in the free pool, whatever the 
curve shape.


>
> So there are a number of differences in how ARIN and APNIC are approaching 
> the fundamental changes that are occurring, and it would be a mistake to 
> evaluate only one of these issues out of context with the others.  I'm not 
> trying to say APNIC did or is doing something wrong or ARIN did or is 
> doing it right, but there is more to the picture than just needs or 
> non-needs based transfers.  If ARIN is going to change to a non-needs 
> based transfer regime lime APNIC we may also need to change many more 
> parts of policy as a consequence.

What other parts of the policy do you think require change should my 
proposal be accepted?
I don't see them, but if they are there we should address them directly.

>
> The point here is that ARIN's policies are consistent, if you have need 
> you can have addresses, be that from the free pool or from transfers. Much 
> of the ARIN community didn't like to idea of addresses sitting at ARIN, if 
> there was need for them.
>

But it's inconsistent in that if you have need, you can have addresses for 
free from the pool.
You can't have addresses for free from the transfer market.
What is the point of the consistency between transfer and free pool 
allocation requirements ?



> APNIC is also consistent, in that once they get down to the last /8, it 
> doesn't matter if you need addresses you only get a /22 once from the last 
> /8 pool, and you can transfer without need.
>
> I believe it would be unwise for ARIN community to change only one part of 
> its policies to emulate APNIC.

I am not changing policy to emulate APNIC, I use APNIC to shield from the 
emotionally laden charges about shirking stewardship which don't add to the 
debate.


>
>> My policy proposal also has the benefit of incentivizing legacy
>> resources to come under RSA, and it serves to even the playing field
>> between the disparate rights of legacy versus non-legacy holders.
>>
>> And my underlying point is the obvious one, that the very act of paying
>> for address space is a very good indication of need, or at least
>> perceived need on the part of the buyer.
>
> I think it is a good indication of perceived value in all cases, it is a 
> indication of need in some cases, but not in all cases.  If you want to 
> corner the market on IPv4 there maybe sufficient value to someone to do 
> so, but that is not a valid need.  And, this is the case where your 
> analysis breaks down.

If you reread what I have said, you will not find that I ever made the claim 
that every transaction in a non-needs based system will involve a buyer with 
need as ARIN defines it.
I put this objection of yours in the category of fear of the free market.
Perhaps it would be valuable to quote some successful examples of market 
cornering in a free market, and for each I will provide 5 examples of 
failures?
I have expressed that to corner this market would involve serious coin over 
long periods of time as new suppliers bubble up to the surface as they 
renumber or whatnot.
Since the market cornerer will have no information about the potential 
limits to these new suppliers, and since there is IPv6, the cornerer will be 
taking an extraordinary risk of losing.
Do we have any evidence of this in the APNIC region, where transfers can 
happen without need?
Wouldn't a market cornerer already be  working through entities like 
tradeipv4.com to start sucking up all the supply?


>
> That said I'm not certain that current criteria for evaluating need will 
> even be valid once there is no longer a free pool.  The basic idea that 
> you get a years worth of need based on your past years consumption of 
> addresses assumes the existence of a free pool.  Once we get more than a 
> year into a market-like transfer system, what you used last year has more 
> to do with how much money you were willing to spend that what your actual 
> need was.  And if the price was high the previous year and if you simply 
> evaluate your need by how much addressing you used last year when the 
> price was high that isn't necessarily a true representation of your actual 
> need.
>

Yes, the price will reflect the market's beliefs about things like CGN, 
IPv6, growth rates, address conservation techniques, and lots of other 
things we can't envision.
And needs criteria based on available free pool addresses will appear 
increasingly anachronistic.


> So I am equally skeptical of maintaining the current needs based system as 
> is, as I am of completely abandoning the concept of a needs basis. Right 
> now I'm thinking allowing transfers up to some size limit over some period 
> of time without justifying need more than putting up the cash to do it, on 
> the premise that within some safety limits it might be a good idea to let 
> the market work things out.  However, if you want to transfer more than 
> those limits you can, but you must justify your need beyond those limits. 
> Either based on your previous years usage or based on the fact that you 
> have put previously transferred addresses into documented use.
>
> Just throwing some numbers out, I'm thinking up to the equilivant of a /12 
> (or a little more than 1 million IPv4 addresses) of transfers received 
> within 12 months per organization without documenting need. There needs to 
> be a mechanism that prevents gaming by creating multiple organizations by 
> the same real organization, maybe this is another place for officer 
> attestations.
>
> For most organizations a /12 is more or less unlimited, but that is 
> probably not enough to corner the market of IPv4 addresses and anyone who 
> really needs more than a /12 can probably justify it without much more 
> hassle then now.  If they really need more than a /12 they are probably 
> quite adept at working with ARIN already.  I think this would give the 
> invisible hand enough room to do its magic, without allowing someone to 
> corner the IPv4 market and destroy the Internet as we know it.  Depending 
> how the actually market progresses, someone could maybe still corner the 
> IPv4 address market, but if they can do that with a /12 then it will 
> really be the time for everyone to move to IPv6.
>
These sound like reasonable matters for further discussion, let's call them 
protections against cornering?



> What I mean by "destroy the Internet as we know it", is anyone big enough, 
> or that anyone thinks is big enough, to stall the transition of the 
> Internet to IPv6, getting enough IPv4 addresses to attempt to do so. I'm 
> not sure anyone is big enough, but I'm just not sure no one is.
>
> In my view this doesn't abandon needs basis, it significantly changes it 
> based on new the realities we are facing.  We are using the market to 
> determine need up to a cretin extent, and beyond that requiring documented 
> need.
>

Let me consider what you say, there seems to be a great concern over 
speculators and market-cornering which I think to be largely unfounded in an 
area as fraught with risk due to the potential for IPv6 to devalue IPv4 
addresses to zero worth, the difficulties in dealing with many thousands of 
suppliers, the decentralization of control in the hands of network 
operators, and fears of the ITU, among just some issues.

Regards,
Mike