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

Tom Vest tvest at eyeconomics.com
Tue Feb 28 12:17:12 EST 2012

On Feb 28, 2012, at 5:23 AM, Matthew Petach wrote:

> On Mon, Feb 27, 2012 at 1:46 PM, Tom Vest <tvest at eyeconomics.com> wrote:
>> Thanks for the responses Matt -- follow-ups inline...
>> On Feb 27, 2012, at 12:40 PM, Matthew Petach wrote:
>>> On Sun, Feb 26, 2012 at 7:02 PM, Tom Vest <tvest at eyeconomics.com> wrote:
>>>> Hi Matt,
>>>> You seem to be arguing the following:
>>>> 1. "IPv4 Speculation" is bad (or maybe good for the lucky speculators, but bad/unfair for everyone else).
>>> I was trying not to assign it a category of "good' or "bad"--simply stating
>>> it does exist today; and thus, one of the arguments *against* a free and
>>> unfettered market is not relevant.  The cry of "but if we allow anyone to
>>> buy and sell IP blocks, we'll be overrun with speculators" rings hollow
>>> when the market is already supporting dozens of speculators who operate
>>> outside the needs-based criteria.
>> But, notwithstanding rhetorical force of habit, is anyone actually crying about "allowing anyone to buy and sell IP blocks" i.e., as opposed to "allowing non-operators (or those who can't demonstrate the equivalent of an operator's "need") to buy IP blocks?" You're still trying to conflate the prerogatives of an(y) aspiring IPv4 seller with those of a(ny) potential IPv4 buyer -- but you really can't claim that the two are the same, or that the differences don't matter without explaining why. Membership in the class of "anyone that can sell IPv4" is bounded by the material fact that in order to sell IPv4 one must actually have some to sell -- and throughout all time to the present moment, 100% of the members of that class have already satisfied, at minimum, whatever definition of "operator" was officially recognized  at the time when they received their address resources (and in most cases, additional/more demanding eligibility requirements that came thereafter). By contrast, the class of "anyone that can buy IPv4" has no equivalent limiting factor.
> I suppose what I'm stumbling over is that today, we
> have large blocks of v4 address space that today
> are held be registrants who are not routing them
> as part of the global IPv4 routing table.  You seem
> to feel that they somehow qualified as "operators"
> in a way that has significance, in spite of them not
> routing their address space in a reachable fashion,
> whereas "speculators" would somehow be categorized
> as "non-operators".
> Can I ask, what characteristic would you use to
> distinguish an "operator" from a "non-operator"
> that we can externally observe?  

You are right to call attention to the fact "we" (here meaning anyone who correctly recognizes their common interest in the productive allocation of this, or any other critical+finite/scarce shared resource) have a very real ongoing *need to know* that address resources are being made available *as appropriate* to the private sector players (aka "operators") that have the privilege($$$)/responsibility of moving those resource into productive use in the broader economy. However, just as in certain other critical service industries that are involved in the distribution of other valuable but finite shared resources, it is often impossible for third parties to accurately gauge the exact "compliance status" of individual private sector operators. Did operator (x) actually satisfy any/all applicable prerequisites that were/are deemed necessary in order to qualify to deliver that service? Do they still possess the mean to deliver that critical service now, (n) days/weeks/months/years after the most recent assessment of their capabilities? Are they actually delivering the service in a prudent/sustainable manner, in accordance with any/all applicable industry or externally defined performance requirements, or are they hoarding, or squandering and/or misallocating that service? The reason that such things tend to be impossible for third parties to observe is not because the service itself is ephemeral -- though it is in both cases -- but rather because in both industries the operators themselves insist on strictly controlling and limiting the release of information about their internal operations. In both domains, operators argue (quite reasonably) that such controls are essential to ongoing commercial viability (not just their own, but everybody's), both because every industry member is necessarily/unavoidably vulnerable in certain ways to systemic or transitive events triggered by remote third parties, and also because, in both domains, most providers operate in a crowded and competitive marketplace in which any release of internal operational information could be commercially exploited to their disadvantage by other industry members. 

So you see, ours is not the only critical service industry that embodies this particular conflict between the public's need for assurances of ongoing/long-term service availability on one hand, and the private sector's need for commercial confidentiality on the other. That coincidence may help to explain why, over time, both industries also witnessed the emergence of the exact same kinds of endogenous mechanisms for mitigating that fundamental conflict in information requirements. In both cases, those mechanisms include things like: 

(a) Identification and administration of certain industry-specific technical eligibility criteria that all aspiring new service providers must satisfy in order to be officially recognized as "operators" in that industry. Our own criteria relate "need" for addresses to beneficial access (including but not limited to outright ownership) of network-related hardware plus fractional use rights to various telecom capital assets to connect the hardware together. The other industry typically describes their criteria in reverse terms, i.e., as the "adequacy" of an aspiring service provider's portfolio of directly owned and beneficially "accessible" capital reserves/assets, etc., relative to a a given volume of the service they provider (which in their case is called "credit" or "liquidity"). 

(b) Maintenance of a similar set of uniform, neutrally administered pre-qualification requirements for any/all subsequent service expansions that invoke the same conflicting public/private information requirements. In our industry, vetting of service expansion proposals are handled by the same institution(s) that administer new industry member establishment, i.e., the RIRs. In the other (i.e., banking/credit creation) industry, established operators are required to publicly disclose limited but truthful* summary information in an ongoing basis, while oversight of major new one-off credit extensions are currently evaluated by a separate set of institutions (i.e., the CRAs).

(c) Establishment of a standing deliberative body of industry experts empowered to assure that, as technology, industry circumstances, and overall economic conditions change, the sort of rules and administrative practices that are employed to assess new service/industry expansion proposals ala (a,b) also adapt as necessary, so that the overall service/industry/operating environment continues to satisfy both public and private requirements, and (insh'Allah) the industry continues to avoid succumbing to one of its intrinsic systemic vulnerabilities (e.g., gross oversupply/oversubscription leading to "hyperinflation," gross undersupply/maldistribution leading to a "deflationary spiral," broad-based e2e degradation partially offset with with costly ad hoc technical patches leading to system-wide "stagflation," etc.), and then collapsing. 

Granted, history is positively full of examples showing that such industry-centric conflict-mitigation mechanisms are far from infallible -- and institutions that ultimately fail to maintain a satisfactory balance of interests and outcomes tend to pay the ultimate price and disappear forevermore. Note for example that, at various points during the 17th-19th century, many (most?) of what are now the world's richest countries had banking/monetary policy sectors that were coordinated by industry-led institutions not unlike our own RIRs. By the early 20th century, however, that number had fallen to 0.00, and that's where it remains today, and will likely remain forevermore (at least on this planet). 

As you probably know, the vacuum created by the disappearance of those old banking industry self-governance mechanisms did not remain empty for long -- nor were the resulting breaches filled with institutions that were more flexible and accommodating of changing conditions or individual industry members' private demands. They really couldn't be, because like it or not the conflicts of interest over allocation and information sharing practices that those old systems temporarily succeeded but eventually failed to balance, are both real and unavoidable; they are an intrinsic feature of all liquidity (or exchange-facilitating) industries -- like ours, like the monetary/banking sector -- that are critically dependent on some distributed technology that performs as expected only under relatively narrow conditions, and that tend fail absolutely in one ugly way or another whenever aggregate usage patterns substantially exceeds those bounds.

Needless to say, history provides even more examples suggesting that government-administered industry "regulatory" regimes are no less vulnerable (and quite possibly even more vulnerable) to the same sort of errors, missteps, and plain dumb luck that ultimately led to the disappearance of their private, industry consortia-led predecessors. Even so, after a century and counting of uniformly public/gov-centric monetary and banking regulation worldwide, it looks like the odds that the banking industry might ever get another chance at self-governance is appx. 0.00%. 

So... you and everyone else that participates in this particular industry coordination mechanism are not only right, but positively obligated to demand "reasonable" assurance that number resources are allocated prudently -- not just IPv4, not just now, in consideration of the critical role that IPv4 will play during the next few years -- but always, for all protocol number resources. 

That said, I personally think that the demands for detailed assurances about the cumulative historical distribution of IPv4 that you have articulated in the course of this discussion fall well outside of the bounds of what's "reasonable," and also that the proposed changes embodied in your current proposal would have an overwhelmingly negative net effect on the subsequent distribution of IPv4 going forward.

>> Here you seem to be implying either one or both of the following;
>> (a) anything that anyone accomplished/acquired in the past, under conditions that are "easier" than they are now, is by definition unfair; either the "old boys" should be stripped of all accumulated "unfair" benefits, or I should be compensated to make up for the difference. In general any/all past or present legal contracts that provide(d) someone else with forward-looking terms to something that I want that are more more favorable than terms that are currently available to me are automatically rendered null and void simply by that fact.
>> (b) the fairness of anything that anyone previously accomplished/acquired and which is also subject to some kind of ongoing administrative oversight is automatically negated if the current administrative mechanisms are not universally recognized as being 100% infallible at all moments in time. If at any point in time there is any nonzero possibility that the administrative process has failed to identify and punish anyone that is noncompliant with the policy, then it may be reasonably assumed that everyone is noncompliant; either everyone else should be stripped of their accumulated "unfair" gains, or else I should be compensated to make up for the difference.
>> Either way, this is a one-time deal that is available only to me and my contemporaries; anyone that comes along later, and who might have similar objections, can suck it.
>> I think that many of us may succumb to thinking along the lines of (a) from time to time, even though at other times we recognize those feelings for what they are, i.e., "sour grapes." At all times/places, someone somewhere has inherited some "unfair" present-day advantage that they didn't "earn" in the way that I'd have to earn it myself. Except in cases where the consequences of that inheritance are so profound/intolerable that they justify bloody revolution (if such a thing is possible), we tend to shrug and move on...
>> (b) is just a variant of a straw man argument that applies equally (i.e., with equal non-validity) to all organizations/processes in human history. "Someone somewhere is breaking the law -- I believe, anyway... no, I don't have any actual evidence -- but my suspicions about the fallibility and non-impartiality of law enforcement are sufficient in themselves to declare that the law is unfair and illegitimate."
>> If I'm missing or misunderstanding something, and you actually have some other method for deriving and calculating the "unfair" portion of an institution's IPv4 holdings, I'd be interested in hearing it.
> You read far too much into what I said.

You can chalk that up to misplaced overcompensation; you read far too little into what you actually said, and seemingly remain oblivious of all of the things that you propose to put at risk without even bothering to mention.



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