[arin-ppml] Draft proposal that needs some wordsmithing

Owen DeLong owen at delong.com
Fri May 6 12:22:49 EDT 2011

>> 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.

If a market was the best mechanism, we could have adopted policy to auction
IPv4 addresses off to the highest bidders before exhaustion. Exhaustion would
likely have come much earlier in such a case, but, it was possible, so, your
assertion that no other mechanism existed is false. No other mechanism was
chosen, but, it did exist.

> After exhaust a free market is the appropriate mechanism to ensure addresses are allocated and used efficiently.

This is an assertion or your opinion stated as fact. I believe that a market moderated by
need is more appropriate than an unmoderated market. That is the mechanism that
has been chosen by the community in this region and which came to consensus
some time ago.

It's possible the community may want to change that at some point, but, the presumption
until some new consensus is reached is that the appropriate mechanism is the one
around which the community achieved consensus.

> Prior to exhaust, without such a mechanism, I could have walked up and asked for a /2.

What prevents you from doing so post exhaustion in an unmoderated market if you think
that purchasing all (or as much as you can) of the available address space will have
a sufficient negative impact on your competitors as to be worth the investment?

> Obviously to anybody, I hope, that would have been unworkable.

Indeed... Hence my difficulty in seeing how it would be somehow more workable in a
post exhaustion environment.

> 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.

It also ensured that address registrations did not become an artificially valuable
commodity. Exhaustion will force this artificial valuation on such registrations, but,
removing the justified need restriction from this forced market will not help
the situation as it would still have the same effect of allowing waste. Admittedly,
the degree of frivolity may be more a matter of perspective at that point, but,
waste through capture for competitive advantage is still waste as far as I am

> After exhaust and in the presence of a free market, the price of the addresses will fill the role that needs analysis filled before.

I remain unconvinced of this. Indeed, I believe that the role price will pay is
to substantially change that mechanism and not for the better.

> They will cause addresses to move to efficient usage.

Depends on how you define efficiency and assumes only good actors in the market.

> 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.

No, we do not. Allocated and not advertised DOES NOT mean underutilized.
There are many legitimate reasons IP resources may be unadvertised while still
fully utilized (or more accurately, utilized but not visible in any routing table to which
you particularly have access).

> A market will not be perfect either, but unlike the prior needs analysis, we seem to be judging the free market by the exceptions.
Since the misdeeds (which you claim will be "exceptions") in the market have the
potential to overwhelm the market, where no such risk existed in the needs
analysis, I think that is  a legitimate approach.

>> 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?.

I see no reason this couldn't be done by an organization with need just as effectively
as by some random aggregator intending to resell the result.

> Somebody who has a different view on the IPv6 transition timeframe and has a longer planning horizon for IPv4?

Then they come to the market multiple times.

> A reseller of vanity addresses, like

I see no reason to promote or create these. They offer no meaningful benefit to the
community at large.

> A wholesaler of addresses who caters to those who need instant availability (needs analysis takes time)?

My last needs analysis took less than 24 hours. The average of my last 5 needs analysis is less than 36 hours.
That's real-time, not resource analyst or my hours.

I think that 1-3 days to get addresses is well within reason.

Frankly, the non-needs-analysis portion of my applications usually takes more time than the needs-analysis

> A speculator, who could have a positive role in free markets?

ROFL -- The concept of speculator in the same sentence with "positive role" amuses me.

> An organization that does not want to undergo an ARIN analysis for fear it will lead to a review and recovery procedure?

An organization which has reason to fear this is an organization which probably shouldn't
be getting additional resources from the community.

> An organization from another region?

You say this as if it is somehow a benefit.

> A buyer of a /24 who thinks an ARIN needs analysis isn't worth the expense?

Again, not seeing the benefit to the community in providing this person the opportunity to take
that /24 out of the hands of some more deserving organization with documented need.

> 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.

This, also, strikes me as an indication that removing needs basis would have a negative impact
on the overall outcome.

> 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.
What you call unnecessary, I call vital to the overall interests of the community.

> The point is that many prior transfers have taken place, particularly with legacy space, that have not been reflected in whois.

Hopefully as these can be identified, the space can be revoked and reallocated
to organizations that comply with policy. The original legacy holder has some
protections. A third party as a result of an unauthorized transfer should not have
any protections in this regard.

> One of the problems relates to the requirement for a needs analysis.

No, the problem is the belief that community resources can be transferred outside
of community policy.

> 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.

As it should be.

> 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.

Only for those attempting to circumvent policies constructed by the consensus of the community.

> For a market to function efficiently, Fear, Uncertainty, and Doubt need to be assuaged, and this proposal does that.
I have tremendous fear and uncertainty about the effects of this proposal. I doubt that it will function as
advertised. Indeed, I believe this proposal increases each of those things from my perspective.

> 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.
That is the argument Geoff used which appears to have had sway in that region.

Geoff has repeatedly made that argument in the ARIN and RIPE regions (and I'm not sure
that he has not made it in LACNIC or AfriNIC as well). So far, it has not been found to be
convincing outside of APNIC.

> 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.

This question has been asked and answered as part of the debate around 2008-2, its successor
2008-15 (IIRC) and the boards reconstruction of that into 2009-1. You are welcome to ask the
question again, but, I'm not inclined to believe the answer has changed.

> 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.

My argument is that the market alone is not a good steward and a regulated market is necessary
to ensure the vital interests of the community.


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