[arin-ppml] ARIN-prop-165 Eliminate Needs-Based Justificationon 8.3 Specified Transfers

Astrodog astrodog at gmail.com
Fri Feb 17 14:41:39 EST 2012

On Fri, Feb 17, 2012 at 1:12 PM, Ryan Riske
<rriske at visionfinancialmarkets.com> wrote:
> I also vote against prop 165 as written and in spirit.  Needs-based
> justification keeps the field level for all players, and is important to
> prevent speculation, hoarding, and other anti-competitive and anti-community
> behaviors.

Something is being missed here that I think is significant. The
current system does not keep the field level for all players. It
rewards players which are better at interpreting and writing their
justification to exactly what ARIN requires, or who have proposed uses
more in line with what is expected. While this is easier to do with
actual need, that is not actually required. A large number of
organizations can meet the letter of the rules for an allocation, but
have no real use for the address space currently. This results in
those organizations requesting more space than they will actually use,
simply to avoid fighting with it again later. If those organizations
knew that there was an easy way to obtain and release address space as
required, they would be inclined to sell address space they are not
currently using, knowing that new space could be acquired at a later
date. This would serve to keep their allocation in line with their

I think a big part of stewardship of the IPv4 space, as it nears
exhaustion, is ensuring that organizations that have more space than
they need can easily transfer that space to another organization that
will use it, and has a financial incentive to do so. Otherwise, the
only way to claim this space is for ARIN to audit these organizations,
and do something along the lines of revoking the allocation. The needs
test creates a regulatory hurdle for organizations, making them much
less likely to attempt to transfer.

Keep in mind that in as far as speculation goes, the value of IPv4
addresses will, over the long term, trend to 0. There would be a very
real risk in cornering the market that one would instead speed the
migration to IPv6, and greatly reduce the value of the address space.

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