[arin-ppml] ARIN-prop-176 Increase Needs-Based Justification to 60 months on 8.3 Specified Transfers

Scott Leibrand scottleibrand at gmail.com
Tue Jul 3 17:57:29 EDT 2012

Another factor I haven't seen discussed is the imminent implementation of
the inter-RIR transfer policy.  Once that is implemented, I would assume
that the scarcity-induced demand from the APNIC region will swamp any
remaining time-horizon-certainty demand here in the ARIN region, and we
should see a large increase in the number of transfers, most of them to
organizations in Asia.  I'm not sure whether that is an argument for or
against raising the ARIN-region needs basis from 24 months, though.


On Tue, Jul 3, 2012 at 2:44 PM, Milton L Mueller <mueller at syr.edu> wrote:

> Sorry, Owen,
> I wasn't aware that you were calling for a statistical comparison of the 1
> year vs. 2 year, I only saw Jimmy Hess's message, which seemed to be
> calling for "substantial statistical evidence" favoring 5 years before
> making a change. It was unclear to me how one could ever get statistical
> evidence about a 5 year period.
> How long was 1-year in effect? How long has 2-year been in effect? Based
> on my rough understanding of the periods, it would seem that increasing the
> time horizon has already greatly increased the pace and number of
> transfers. However, there are confounding variables, namely the growing
> scarcity of IPv4 as time passes and the depletion of the free pool.
> Regarding the experiment with no needs assessment at all, I guess if you
> view an experiment with the absence of needs assessment as equivalent to
> releasing hordes of murderers and rapists into the community unfettered you
> would indeed be opposed to such an experiment. My point was simply that the
> difference between a 5 year horizon and no needs assessment at all might be
> small enough that we needn't bother with a specified time period, if we
> were actually willing to conduct an "experiment."
> --MM
> > -----Original Message-----
> > From: Owen DeLong [mailto:owen at delong.com]
> > Sent: Sunday, July 01, 2012 11:22 PM
> > To: Milton L Mueller
> > Cc: jeffmehlenbacher at ipv4marketgroup.com; Scott Leibrand; arin-
> > ppml at arin.net
> > Subject: Re: [arin-ppml] ARIN-prop-176 Increase Needs-Based
> > Justification to 60 months on 8.3 Specified Transfers
> >
> >
> > On Jul 1, 2012, at 4:17 PM, Milton L Mueller wrote:
> >
> > >
> > >> -----Original Message-----
> > >> I understand your desire to sit tight and assess statistical evidence
> > >> before suggesting a longer justification period is required. My
> > >> concern with such a strategy is the decided lack of comprehensive
> > >> transfer market data.  We have only the ARIN Specified Transfer
> > >> Listing Service
> > >
> > > [Milton L Mueller] As a social scientist, it seems obvious to me that
> > asking for statistical support for a longer time frame, without allowing
> > an actual, real-world experiment with the longer time frame, is asking
> > for the impossible.
> > >
> > > The only way to gather "statistical evidence" on the impact of
> > changing the time frame for needs justifications is to allow a different
> > needs assessment time and see how the change affects the quantity and
> > type of transfers authorized. No empirical conclusions can be drawn
> > about the relative merit of a 24-month and 60-month period by looking
> > ONLY at the statistics generated by a 24-month period.
> >
> > And we have now allowed a different policy (24 months instead of 12) and
> > I want to see a statistical analysis of that change before making yet
> > another modification. I'm not sure how you think your argument applies
> > more accurately to 24->60 than it does when I propose it for analyzing
> > the change from 12->24 before applying another change from 24->60.  Can
> > you please clarify what I am missing here?
> >
> > > That is why I view the request for statistical evidence as a tactic
> > designed to delay or defeat Jeff's proposal.
> >
> > A very interesting conclusion. Inherently, it would delay Jeff's
> > proposal since we are seeking to wait and see what happens with the last
> > change before applying Jeff's proposed additional change, but, I fail to
> > see how your above statement makes that an unreasonable approach or why
> > delaying Jeff's proposal is somehow an inherently bad thing to do as
> > your statement above seems intended to imply.
> >
> > > If one really wants to do an experiment, it would probably make more
> > sense to conduct a limited experiment with no needs assessment at all,
> > and see what happens. If one discovered a significant increase in the
> > number of approved transactions, and/or a massive increase in what
> > appeared to be speculative acquisitions, and if either result could not
> > be explained by other variables, it would support the conclusion that
> > the current time horizon constricts the number of transactions in a
> > specific way.
> >
> > Other than the magnitude of the consequences, how would this differ from
> > an experiment in cost-cutting prisons where we simply released every
> > prisoner that signed a written promise to obey the law and reversed the
> > policy only after we found many of the criminals breaking the law again?
> > I don't advocate this kind of destructive testing.
> >
> > > In the absence of such an experiment, the only empirical data that
> > might support or refute the change would be a survey of all prospective
> > buyers in which a statistically significant sample of them stated
> > unambiguously that they would participate in the transfer market if the
> > needs period were extended to 60 months; or that their planning horizon
> > for acquiring IP addresses was closer to 5 years than to 2 years. Such a
> > survey would be very difficult to conduct, and you would still be
> > dealing with stated preference rather than revealed preference. But it
> > would be potentially informative.
> >
> > I'm not sure that preference is in question here. I'm sure that those
> > seeking to acquire resources through the transfer market would prefer
> > maximum leniency in the process. I'm willing to accept that as a given.
> >
> > The question at hand is whether allowing that would be damaging to other
> > areas of internet policy and to what extent. Looking at the impact of
> > the switch from 12 to 24 months for some period of time before making
> > yet another modification seems prudent.
> >
> > > The bottom line is that those calling for statistical evidence have
> > one of two choices: either they must agree to conduct an experiment, or
> > they can abandon the claim that they oppose the proposal for lack of
> > statistical evidence and admit that they just don't want it to happen,
> > regardless of evidence.
> >
> > Given sufficient evidence that it would not harm the community to do so,
> > I would not oppose the proposal. Until such evidence becomes available,
> > yes, I oppose the proposal. Whether or not such evidence is or can be
> > made available does not change my desire not to harm the community. As a
> > general rule, it is not unreasonable for the community to expect those
> > desiring a change to bear the burden of proving that the change is more
> > beneficial than harmful to said community. It is my opinion that those
> > supporting this policy have not yet met that burden.
> >
> > Owen
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