[arin-ppml] Draft Policy ARIN-2014-11: Improved Registry Accuracy Proposal

[Morizot Timothy S]

And the discussions on 2014-9 today clarified the central thing that bothered me about this proposal.

> Section 2, Adds to "Definitions"
> 
> Legacy Internet Resource
> 
> Any Internet Resource obtained prior to or otherwise outside the
> current system of hierarchical distribution (by allocation or
> assignment) through the Regional Internet Registries.
> 
> Legacy Internet Resource Holder
> 
> The holder of a Legacy Internet Resource. Either by receiving these
> resources directly or by receiving (part of) Legacy Internet Resources
> from a Legacy Internet Resource Holder.

I do not agree with the above definitions. A set of numbers is just a set of numbers. Rather, if we're going to add formal definitions I would suggest something more like the following.

Legacy Internet Resource Holder

An organization that received a resource allocation prior to or
otherwise outside the current system of hierarchical distribution
(by allocation or assignment) through the Regional Internet Registries.

Legacy Internet Resource

A resource held by a Legacy Internet Resource Holder that was allocated
To the holder prior to or otherwise outside the current system
of hierarchical distribution (by allocation or assignment) through
the Regional Internet Registries.

I see no reason to assign special status to a number allocation independent of its association with the organization that obtained the legacy allocation. And I'm not at all convinced that this proposal is actually intended or designed to promote improved registry accuracy.

I will also note that if registry degradation reduces the value of IPv4 Internet numbers, I'm also not entirely convinced that's a bad thing. One of a number of my hats at work is the "IPv6 Transition Technical Lead" hat. (The title sounds more impressive than it actually is. I also have other impressive-sounding labels I rarely use associated with other hats I wear. I normally describe myself as "no-one of consequence" mostly to see who catches the joke.) So I'm neck deep, at least, in the IPv6 transition effort. (And we've done pretty well, I think. Most of our Internet-facing stuff is IPv6 enabled. Our "Trusted Internet Connection Access Points" or TICAPs are mostly dual-stacked for services in both directions. And we've IPv6 enabled our 13 largest sites with more to follow after filing season. We're at the point where we're actively discussing when we believe we can start removing IPv4 from portions of our enterprise network.) With that role in mind, I've supported proposals to raise the free pool allocation needs justification to two years to match  the transfer utilization policy. I would probably support reducing the needs-based requirements overall. (I don't think policy should let someone come in and request all of ARIN's free IPv4 and IPv6 pools just because, but I do think the IPv4 needs based rules could and should be greatly relaxed.) But I am not at all in favor of granting special status to legacy IPv4 resources once they leave the hands of the actual legacy holder. 

Basically, I don't believe that "legacy" resources should be treated any differently on the transfer market than non-legacy resources. Equal footing for all. And if people choose to cease using the registry and thus degrade the value and utility of those IPv4 resources, I'm not sure I have a problem with that scenario. I certainly don't think it's a crisis. In fact, I think anything that pushes the Internet toward IPv6 and away from the IPv4 swamp will end up being a plus in the long term.

So I don't support this proposal as written. I would consider a proposal that expanded the time frame for free pool allocations to match that of the transfer market or that eliminated all needs based criteria for all IPv4 transfers. But I don't support trying to carve out one subset of IPv4 resources for special treatment on the transfer market.

And while I fully support ARIN's position of providing free basic registry support to legacy resource holders with no contractual relationship with ARIN and thus contributing not even a nominal sum to support those services, I do not support making that basic support transferable simply because someone "acquires" a resource from someone who had originally obtained the allocation prior to ARIN's formation. Or because someone obtains a resource from someone who had obtained a resource ... ad nauseum. TANSTAAFL. I appreciation the registry and reverse DNS support ARIN provided us for years before we signed an LRSA agreement. I think they provide a valuable Internet service through that support. But I see no reason to make it a transferable burden on ARIN. Nor do I see any value provided to the Internet community by doing so.

Thanks,

Scott