[arin-ppml] Fwd: ARIN-prop-165 Eliminate Needs-Based Justification

Matthew Petach mpetach at netflight.com
Sun Feb 26 15:56:19 EST 2012

After mulling over this thread for a few days, I think what I'm coming to
realize is that my primary concern for maintaining the "needs based"
rule is that it enforces a dichotomy in the market.

Newer players must abide strictly by the needs-based assessment of
the ARIN staff to get addresses.  Their world is strictly defined through
the eyes of the ARIN staff evaluation, and their vision and growth is
strictly curtailed by that evaluation.

Older players, especially legacy players, are not required to follow any
type of needs-based assessment to hold onto their resources; they
may squander it at will, or dream big, and roll out an audacious
undertaking that might never pass the ARIN staff "needs" scrutiny.

In doing so, we've created an "Old Boys Club", where those who already
have space essentially *are* the speculators; those with legacy /8s, for
example, may have no plans for actually making use of the vast majority
of their space, and thus have no "needs" based justification for it; but we
allow them to sit on it indefinitely, as the scarcity of the resource increases
for everyone else.

I think my support for abolition of the needs-based allocation stems from
a desire to see equal treatment in the market for everyone; upon further
reflection, I can see that a similar level of equality can be achieved by
subjecting *everyone* to the same requirements, no matter when the
address space was registered.  Annual audits, and if the need is no
longer shown to be present, the resource registration is revoked, applied
equally to everyone with v4 address resources.

I suspect that my alternate option for establishing equality in the market
will be met with a great outcry from those hoarders already holding blocks
of address space that they know darn well don't meet a "needs-based"
criterion.  And those holders will fight tooth and nail to hold onto
those allocations;
because in spite of all the rhetoric about how v4 address allocations aren't
property, and will someday have no value...right now, deep down, they
sure as hell believe that what they have has real value, and with increasing
scarcity in the market, that what they have has *increasing* value in the
market.  And, if you're holding onto a scarce resource in a time of
increasing scarcity with no demonstrated need for the resource...well, in
most books, that would make you a speculator.  The fact that your chunk
of the resource was gifted to you years ago doesn't negate the fact that
you're holding onto an unused portion of a scarce resource, thus driving
up the market price for that resource.

So.  Let's call a spade a spade.  We already have speculation in the IPv4
address allocation market.  We have a set of investors who have large chunks
of address space that they have obtained without demonstrated need, and
are holding onto them in spite of not having a demonstrated need at a time
when scarcity is driving the value of those resources up.  We can't turn a
blind eye to them, and claim we have to preserve "needs-based" allocations
to keep spectators out, *because they're already here.*  If we're not willing
to make things equitable by enforcing needs-based requirements on them,
then the only other way to make this situation equitable is to remove the
needs-based requirements on the rest of the participants.  And thus, I
continue to support removal of the need-based requirement, in the
interests of restoring equality among the market participants.


(now to start digging through the NRPM and see if it's time to propose
an AC action to replace "legacy" with "speculator" throughout it, in the
interests of clarity and honesty.)

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