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

Mike Burns mike at nationwideinc.com
Wed May 11 22:41:10 EDT 2011

Hi Owen
>> I have personally seen many asset sale agreements which included legacy 
>> IP addresses which were completed without notifying ARIN, as there is 
>> still no >>requirement for legacy holders to do that. I have seen asset 
>> sale agreements which include ARIN accounts and passwords among the 
>> listed assets. The >>addresses change control, but whois still shows the 
>> original registrant.

>There is no reason that ARIN, upon conducting a section 12 review and 
>finding that the original holder was
>no longer using the resources and/or was defunct could not reclaim those 
>resources, so, the recipient in that
>case is taking a rather large risk.

Wrong, may I quote NRPM 12.8?
This policy does not create any additional authority for ARIN to revoke 
legacy address space.

> I do not believe ARIN will view the asset sale agreement as legitimizing
>the transfer and the community developed policies support reclamation of 
>resources from defunct legacy

I never said they were defunct, they may have simply been acquired.

>> When it comes time to route the addresses, if the network operator 
>> questions the situation, I have seen them accept the asset sales 
>> agreements as acceptable >>proof of routing authority. And the addresses 
>> allocated to entity A are now in control of entity B, with bogus whois 
>> data. This is the kind of eventuality which I >>believe motivated the 
>> APNIC community to place the stewardship role of uniqueness above the 
>> stewardship role of needs-based transfers. Obviously I am >>asserting 
>> these things without documentary proof.

>Again, can you cite an independently verifiable example? If not, then, I 
>still believe this is a straw man argument.

>How many such agreements have you seen? (I tend to think that it represents 
>a relatively small fraction of
>the address space and will likely get resolved through the current contact 
>validation process for the most

Owen, if it were just Mike Burns saying this, would APNIC have changed their 
Yes, the agreements I have seen represent a small fraction of the address 
No, I can not cite an independently verifiable example, I hoped by now you 
would have thought higher of my intelligence.

>> While I don't think that's the entire argument or even a particularly 
>> accurate framing of that portion of the
>> argument, I would say that the history of free markets does give one 
>> plenty to fear. Especially when you
>> consider that history in situations of truly finite (even for a short 
>> time) resources. (Tulips anyone?)
> > You seem to consider that needs-based allocations were some kind of 
> > social agreement preventing malfeasance of the wealthy and protecting 
> > the little guy.

Indeed, i do.

>> In reality, it was the least  rulemaking possible in an era of free-pool 
>> allocations.

>No, we could easily have handed addresses out for the asking without any 
>regulation whatsoever.
>We, as a community chose not to. We made that choice for good reasons. I 
>believe those reasons
>remain and may even be enhanced by runout.

C'mon Owen! Who could possibly believe what you are saying here? Of course 
there were good reasons for not handing them out without any regulation 
whatsoever. I have expressed over and over that nobody has ever supported 
that notion, to my knowledge. Needs assessment was a noble and valid means 
of stewarding addresses into productive use.

>> There really was no other way to distribute scarce resources with no 
>> price unless the allocations were limited by need.

>Not at all true. They could have been simply handed out to whoever asked 
>first. I agree such an
>approach would have been ridiculous. The difference between us is that I 
>believe even when you
>include dollars in the process, such an approach remains ridiculous because 
>it transfers the
>address regulation from community based stewardship to a system where the 
>only factor
>determining resource allocation is the accumulation of capital.

Owen, like it or not, dollars are going to be involved in the process of 
address transfers.
That is not at issue here.
Thanks for agreeing that your proposed alternate mechanism for allocation 
from the free pool is ridiculous, it should be a short step from there 
towards acknowledging that the needs requirement was the lightest touch of a 
proper steward allocating from the free pool.

>> And nobody really debates that, even an outlier like me.

>Interesting... I will actually debate that. I agree the alternatives were 
>absurd. However, to claim that
>they did not exist would be as logical as my claiming that an unregulated 
>market is not an option.
>It's an equally detrimental option, but, it's an option.

Would you at least admit that there was no other option if we wished to be 
proper stewards, both ensuring productive use and making the minimum of 
rules to allow for that?

>> That cause goes away with the free pool, and the imperative against more 
>> rules than necessary dictates we lift those needs-based transfer rules.

>Indeed, we do disagree. I believe that the cause for needs-basis was the 
>idea that the community
>preferred not to grant resources to entities that did not need them to the 
>exclusion of entities that

No, I think we agree. At least I agree with your last statement, if we limit 
it to the free pool, which was the context.

>I see no way in which bringing money into the picture changes that reality 
>or that community ideal.

Owen, you are conflating issues. Money is coming into the picture regardless 
of needs requirements.

>> We have to understand the cause of needs requirements. It wasn't some 
>> egalitarian ethos, it was an obvious and fair mechanism for placing some 
>> limit on >>address allocations from a free pool of limited size.

>And it still is. The source pool for IPv4 address transfers is not 
>unlimited in size, either.

No, it is not unlimited, but now we have price to ensure productive use, 
something we did not have when allocating from the free pool, so we chose 
the least intrusive mechanism to ensure that at the time, which was needs 
requirements. Now we have no free pool and the mechanisms of supply and 
demand to ensure productive use.
I agree that needs requirements be continued on free pool allocations.

> We didn't impose max limits per allocant, we didn't impose progressive 
> fees that made larger blocks proportionally more expensive, we didn't 
> create rules to >favor corporate diversity, we didn't limit distributions 
> per country, we didn't require an income statement of recipients so that 
> we could judge whom to allocate to.

>No, we chose not to allow greedy entities to absorb more space than they 
>to the exclusion of others. Your claim is that adding money to the 
>situation somehow
>removes the need to do so. My argument and belief is that it does not.

Again, Owen, this is not about money. Money is going to be part of all 
This is about maintaing a needs requirement.

>> We chose the most limited mechanism to ensure that the addresses were not 
>> wasted. If we understand that, and we understand that stewards make only 
>> the >>minimum rules necessary for order, it is easier to drop the 
>> emotional attachment to needs requirements in the face of free pool 
>> exhaust. You will note that despite >>my free-market inclinations, I have 
>> never argued to drop needs requirements for new allocations of IPv4 or 
>> for IPv6.

>My attachment to needs basis is not based in emotion. It is based in logic. 
>You have
>done nothing to show that money acts as a regulator to prevent those with 
>capital from absorbing addresses they do not need to the detriment of the 
>of the community. In fact, you have even gone so far as to provide examples 
>situations where you believe such an occurrence would actually be a good 

Yes, I gave several examples of where transactions which might be profitably 
engaged in but which would not meet ARIN's needs policies.
These are the kinds of transactions which will likely occur outside ARIN's 
purview and would cost Whois accuracy.

>> I have searched long and hard for a historical analog to this situation. 
>> The best I could find was a policy of the US after the Revolutionary War, 
>> which allocated >>property to veterans of that war for free. You had to 
>> qualify by being a veteran, the total property available for allocation 
>> was limited in size, and the property >>had value.

>Not an accurate analogue. There was also other land available through a 
>of other land grants, purchases, and even in some cases, just being the 
>first to
>arrive somewhere and stake a claim.

>Indeed, since there was no "justified need" basis for land allocation at 
>any point
>prior, the fact that things continued without it on a relatively even keel 
>is kind
>of irrelevant.

The justification was that you had to be a veteran who fought in the 
Revolutionary War.
There ARE other addresses available, I have heard that you are aware of 

> In the historical case, there were no limits on resale of the allocated 
> land, there were aggregators, there were speculators, and things 
> progressed normally during ?>the allocation time period, and the time 
> period after the land was fully allocated.

>But there was nothing like needs-basis in the initial allocation and there 
>many other sources of land as well. This simply isn't the case with IPv4.

There was something like needs-basis. You needed to demonstrate that you 
were a veteran.
Land was not handed out to just anybody. (Remember, this land had value.)
Sure you could move somewhere else and purchase land, like you can choose to 
deploy IPv6 or CGN.

>> Some people intended to live and farm the land, others intended to sell 
>> their allocations. And American law allowed a free market in which these 
>> men could decide.
>> Rather than judge the benefits of free markets by exceptions like manias 
>> and successful market cornering, both rare and shortlived events, why 
>> don't we judge >>free markets like our American ancestors did, even if 
>> we're Canadian, eh!

>Completely unregulated free markets have never functioned. All markets
>degrade to the point of requiring the government (or some industry
>organization) to step in and mitigate the issues they create. This is
>not the exception, it is the reality we have seen time and again.

>Preserving needs basis is merely a rational and good form of regulating
>the IPv4 transfer market to the benefit of the community.

What is the great benefit that outweighs the danger to Whois of unbooked 
transfers and the benefits of incentivizing legacy resources to come under 
Who says my proposal would result in completely unregulated markets? Every 
transferee would sign an RSA and be subject to ARIN policy.
And with my policy or without my policy, addresses are bound to flow to the 
highest bidder.
If the policy proposal doesn't fly, it will be to the highest bidder who can 
show need.
Do you think that we should take more steps to protect the little guy in 
this event?
Maybe a price cap? An address czar?


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