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

[Owen DeLong]

On May 20, 2011, at 12:56 PM, Mike Burns wrote:

> Hello to the list,
> 
> Per what Tom wrote at the bottom, I am all for considering the consequences of my proposal, intended or otherwise.
> 
> So I believe the consequences we have considered, and please add to this list if you want, are:
> 
> 1. Market distortions will happen due to the selfish actions of speculators, including market cornering attempts.
> 2. Disaggregation will increase.
> 3. It is too radical a change, and change should appropriately come incrementally, like extending the length of the needs window.
> 4. It will make it easier for bad players like spammers to get addresses.
> 5. It will run the risk of actually making Whois less accurate.
> 6. Addresses will be used less efficiently if we only rely on price to drive their productive use.
> 
> I figure we have addressed these issues enough, and that we are rehashing discussions to no additional benefit.
> 

Agreed, actually.

> And I have had the opportunity to address the intentions of the policy proposal, which are:
> 
> 1. Provides an incentive for more transactions to be registered by ARIN

No, this is not accurate. It provides no incentive. It does reduce disincentive to register transactions
that the community might not look upon favorably. It does not create incentives.

> 2. Provides an incentive for legacy space to be brought under RSA

I don't see this in any way shape or form. Can you please explain how, exactly, removal of needs
basis influences this in any way?

> 3. Provides for explicit protections against review audits for RSA holders after one year, bringing RSA rights more in accord with LRSA rights.

Uh, yeah, I don't see that as a good thing. Quite the opposite. However, I do agree that it is an intended
consequence of the proposal.

> 4. Reduces transaction costs for transferers

I believe it will actually increase them.

> 5. Reduces ARIN costs for needs analyses

Agreed, but, not necessarily something I see as a beneficial aspect.

> 6. Aligns ARIN policy with most possible interpretations of the legal rights of legacy holders

No, aligns ARIN policy with one possible interpretation of the legal rights of legacy holders.
IMHO, not even the most probable one.

> 7. Imposes a yearly limit on needs-free transactions intended to prevent cornering.

Yes, but, this limit is effectively a no-op because anyone can create multiple entities needed
to accomplish enough /12 transfers to meet their desires.

> 
> And likewise we have fairly addressed these issues.
> 

To some extent.

> Without considering (any more) the merits of those prior discussions, I would like to invite the consideration of any other potential benefits or consequences which we have not discussed.
> I am cognizant that this is proposal is a significant departure, and that the discussion of similar policy in APNIC consumed several years.

As it did here prior to being rejected here and accepted there.

> I think we have covered pretty much all the bases in our relatively short but active discussion period, but I agree with Tom that we really should stretch our minds to consider all the potential pitfalls.
> So did we miss anything, or is there anything left to be said on the topics arrayed above? Any large loopholes or gotchas? Risks or threats we haven't considered?

One I think worth exploring is that given the recent staff interpretation of the term RSA in policy,
the requirement for RSA in the proposal may be insufficiently specific to express community
intent.

> Maybe the increased/decreased exposure of ARIN to lawsuits?

I think this would not significantly impact the legal exposure. We are as likely to get sued
by someone unable to obtain resources in the market on the basis that we failed to properly
regulate need in the market as we are to get sued by someone opposed to our attempts
to regulate need, IMHO.

> 
> (I will admit to enjoying reading my own words. But as they are growing tiresome to me, they must be coma-inducing to you by now.)
> 

It's been a good debate, IMHO and I agree we have both well established our positions.

Owen