[arin-ppml] Fw: Accusationof fundamentalconflictofinterest/IPaddress policypitched directly to ICANN

Owen DeLong owen at delong.com
Wed May 4 15:16:01 EDT 2011

On May 4, 2011, at 11:16 AM, Mike Burns wrote:

> Hi Owen,
> I think private registries are a good idea.

And I disagree, but, this is not a surprise to you.

> I think Benson's proposals would have led to them, but were voted down by the ARIN community.


> One of the reasons given was the lack of oversight which would result from the implementation of Benson's proposals.


> To my mind, such oversight can only come from a higher level.

What higher level is there than the community which is being governed?

> The proposed private registry after all, would be on the same level and performing the same function as the RIRs.
Yes... You once again conflate the RIR and the RIR community.

> ICANN is the higher level, in my mind, based on their clear approval responsiblity for new RIRs, and their predating the RIRs.
> ICANN has a policymaking apparatus which is being appealed to by the writer of the letter which started this thread.
Your mind is clearly confused on multiple levels...

ICANN does not predate RIRs. Both RIPE and APNIC, as does ARIN.

ICAN was formed in October of 1998.

APNIC was formed in 1992.
RIPE NCC was formed in 1992
ARIN was formed in 1993

Their approval responsibility for new RIRs is delegated to them by the RIRs and serves as a
self-imposed check-and-balance on the RIR system. ICANN cannot approve a new RIR without
the consent of the RIRs (as expressed through the NRO which is comprised of the RIRs and
members elected by the RIR communities). Neither can ICANN withhold such approval
except in a case where they feel that some aspect of the documented policy and procedures
has not been met.

ICANN has no apparatus for making number policy other than the ASO AC/NRO NC which
is made up of members elected by the RIR communities. The ASO AC/NRO NC process for
making policy is the global policy process which I have explained to you before and for which
the first step is to pass substantially identical policy in all 5 RIR policy processes as a proposed
global policy.

> Here is a document I found which proposes that ICANN adopts a set of requirements for those who wish to provide private registry services:
> http://www.icann.org/en/correspondence/statement-ip-address-registrar-accreditation-policy-31mar11-en.pdf

Given that this is shown as "correspondence" and not attributed to a source but also does not
contain any information about it having been adopted, to the best of my knowledge, this is
just a suggestion from some random source which has not necessarily received any
community support for implementation.

> I just skimmed it, but if the community decided that Benson's proposals suffered only from a lack of oversight, and required action at a global level, then perhaps they will add their voice to the support which I offered.
Perhaps, but, you would still need a global policy proposal to voice support for.

> If the action happens at this level as a result of an informed decisionmaking process at ICANN, then I am happy because it will expedite the appearance of competing registries.
I'm not sure I can parse what you are saying here in the context of the current way
decisions are made by either ICANN (with the limitations that exist on their
decision making ability) or the RIR level.

> And why do I want competing registries? Is it because ARIN charges too much, or their website is hard to navigate?
> Is it because I wish to take my business elsewhere as a statement against ARIN staff? Is it their response time?
> Is it because I am a buyer who requires more than officer attestation for determining the right to sell addresses?
> Is it because I am a buyer who does not wish to sign an LRSA or RSA?
> Is it because I choose a 5 year planning horizon?
> Do I want to transfer out of region?
> No, none of those reasons, although are all, in my mind, potentially valid reasons for somebody to change registries.
> It is because I think a competing registrar would naturally reduce barriers to transfers.
It is, perhaps, exactly this reduction of barriers that leads me to believe that competing registries
would be a bad idea. I believe that the barriers that exist in the transfer process today were
considered by the community and have the support of the vast majority of community members.
I believe they were placed there for good reason and represent appropriate safeguards in the
proper stewardship of number resources.

> And that is my underlying goal. In fact, ARIN could probably pull the rug out from under a private registry by beating them to the punch and removing restrictions for all transfers.
Q.E.D... "If ARIN merely abandons its stewardship role, we wouldn't need other registries to
do that instead." In my opinion, stewardship is a good thing that should not be abandoned.

> (I think needs analysis should be done on free-pool allocations, though. I hope that goes without saying.)
I fail to see a reason that needs analysis should not be done on transfer recipients. Nothing
you have said so far makes the case for that. If you could get the community to come to
consensus that needs basis should be abandoned, a simple ARIN policy proposal could
cause ARIN to do so. I believe that the community consensus is against such an abandonment
of stewardship and so development of competing registries to override that community
judgment strikes me as inappropriate at best.

> As for the talk about the perils or benefits of free markets, I will leave that aside in the belief that the readers have internalized our different perspectives.

Likely true.


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