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

Ted Mittelstaedt tedm at ipinc.net
Fri May 13 00:11:34 EDT 2011

On 5/12/2011 5:22 PM, David Farmer wrote:
> 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.

APNIC has higher population and less market penetration.  It is in a
very high rate of growth scenario.  Arin has lower population and higher
penetration.  This alone puts it in a much lower rate of growth scenario.


> 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.
> 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.
> 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.
>> 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.
> 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.
> 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.
> 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.

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