[arin-ppml] IPv4 Transfer Policy Change to Keep Whois Accurate
mike at nationwideinc.com
Fri May 13 10:45:50 EDT 2011
Hi John, thanks for the feedback, responses inline.
>> 1. Policy Proposal Name: IPv4 Transfer Policy Change to Keep Whois
> I note with interest the explanation that the Policy Proposal Name is
> intended to be taken with tongue firmly in cheek. I'm glad that's cleared
> up as I was fixin to expostulate,
I will correct that when I send it to policy at arin.net for official
>> 10. ARIN will not use utilization as a measure of policy compliance
>> for addresses transferred under 8.3.
> because I was confused as to why a policy whose major (only?) proposed
> effect is to remove utilization devotes most of its wording to WHOIS
> accuracy. Who wouldn't want that? But I understand now that it is
> intended only as a witticism. I will therefore attempt to speak only to
> the non-WHOIS part of the proposal.
No, there are two major effects to my proposal, one related to removing
needs-requirements from transfers, the other allowing existing RSA holders
to sell unused IPv4 addresses without fear of a review/return request if
they have had them for more than a year.
I copied the proposal largely from the APNIC proposal which passed there,
and I believe that the Whois accuracy argument is the most persuasive, the
name is a witticism, not the rationale.
I fully believe that if Microsoft chose not to sign an LRSA with ARIN, or if
ARIN had never become aware of the deal, MS could have legally consummated
the deal with Nortel, and that somebody would have routed the addresses for
The net effect would have been Whois data for those blocks showing
allocations to the original and long defunct entities, instead of pointing
accurately to Microsoft.
>> 8. Rationale:
>> The underlying proposition behind this policy proposal is that the
>> registry of IPv4 addresses operated by ARIN is of general utility and
>> value only while it accurately describes the current state of address
>> distribution. If a class of address movement transactions are excluded
>> from being entered in the registry, then the registry will have
>> decreasing value to the broader community, and the integrity of the
>> network itself is thereby compromised. This proposal's central aim is
>> to ensure the continuing utility and value of the ARIN address
>> registry by allowing the registry to record transactions where IPv4
>> addresses are transfered between ARIN account holders.
> But where is utilization in this underlying proposition?
As far as I can tell, the word utilization in the paragraph above refers to
the utilization of the whois registry, not address space.
I have argued that when things are valuable, especially if they are valuable
for a short time, they will be sold if not needed.
To me, this will naturally increase utilization, I point to the billion or
so unrouted but allocated addresses as some evidence that there is more
efficiency to be wrung from these allocations.
Yes, I understand that some allocated but unrouted addresses are used
internally, my perception is that this is a subset of unadvertised but
allocated space, much of which is simply wasted.
My argument about needs requirement is that it is an artificial contrivance
designed to constrain free pool allocations whose purpose has been subsumed
by the mechanism of price in the transfer market.
And that maintaining that market artificiality will result in some
transactions being performed privately, and because the addresses will still
work for their intended purpose whether or not ARIN is notified, and because
there is no legal venue to challenge the transaction if it involves legacy
space, those transactions will not be reflected properly in Whois.
> Having observed the preparatory discussions that led to this proposal and
> subsequent comments to it, I recall massive dialogue on the MS/NN
> transaction. To integrate that subject with this proposal, I must go to
> comments to the proposal for guidance. In the authors response of 11 May
> 2011 17:12:57 to Tom Vest regarding "current legal realities" it is
> stated: "4. Finally, the requirement at issue here, a needs analysis had
> to be completed by ARIN, which magically showed that MS qualified for
> exactly the amount already bid for and negotiated the sale of."
> And this paragraph
> "If they had needed fewer addresses, they could have bid for less than the
> full pool. If they needed more addresses, they should have received an
> additional ARIN allocation. Paraphrasing Goldilocks, the random allocation
> of addresses to long-ago Nortel acquisitions was "just right."
> which I interpret as expressing disbelief. I could be wrong here.
No, you are right, I was expressing disbelief. I believe that all the other
issues with the transfer as negotiated prior to ARIN's knowledge of the deal
were ably finessed so as to fit the deal into the existing policies, via
some ex-post-facto 8.2 transfers, stretching "RSA" to include "LRSA",
syntactically applying "single aggregate" to need and not to receipt of
addresses, and considering the "issue to ARIN" language to be a mere
To my mind, the most difficult effort in shoehorning the transaction into
existing policy was the needs requirement. I believe that requirement
contorted ARIN into knots, and at least put ARIN into the potentially
corruptible position of deciding the fate of a $7.5 million dollar
I believe that had my proposed policy been in effect, the deal would have
been simply booked into Whois, the market would have put addresses right
where they were needed (according to ARIN), unused addresses would have come
off the shelf, and those addresses would be put under the same RSA that
every other RSA holder is under, and questions about ARIN trust and
potential corruptability would be absent.
> 2) It looks to me like we have a fundamental logic flaw here. This
> proposal will fix a problem that does not exist! From my perspective, a
> needs assessment was properly conducted in the Microsoft/Nortel bankruptcy
> affair and ARIN policy was followed. John Curran says so, author says no.
> Which brings us to the realm of belief and he said, he said. Who do I
> believe, John or author? Well, John has been exposed to the facts of the
> matter and cannot talk about it, except obliquely. The rest of us have
> only our interpretations of public documents. John has a fiduciary
> responsibility here, so real penalties might apply if he prevaricates.
> Author can pretty much say what he likes, the worst we could do is get
> quite cross. John has several decades of credibility in public policy and
> networking. So might the author, but I can't say. But here's the deal, IT
> DOESN'T MATTER. We will never know and can't know.
We may never know, but have you considered an NDA with a time limit?
So may we please
> dispense with the APNIC did it thing? It's a fallacy anyway:
> John Springer
I will make a deal. If aspersions of poor stewardship can be done away with,
I will do away with the APNIC references.
It doesn't advance the argument and doesn't advance our relationship with
the APNIC steward community.
It is easy to declare one person a poor steward, it is less believable when
another steward community is being included in the smear.
I have already requested that posters stop equating my proposal to remove
needs tests from transfers to phrases like "jettisoning stewardship".
We are arguing over proper stewardship, as stewards, and I have tried to
refrain from accusing those who oppose my policy of being poor stewards of
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