[arin-ppml] Draft Policy ARIN-2016-5: Post-IPv4-Free-Pool-Depletion Transfer Policy

Mike Burns mike at iptrading.com
Fri Jun 24 10:17:19 EDT 2016

Hi Scott,


I see the harm in the inclusion of non-operational text which seems to put into the NRPM something like a specific community expression against financial speculation which I think is not necessary. This inclusion could end up being a Trojan horse for future policy which could hinge on the assumption that the ARIN community had made this overt expression.


As I said I support the intent of simplifying the transfer policy but I don’t think 8.5.2 is necessary in light of NRPM 1.2 Conservation:  Conservation of these common number spaces requires that Internet number resources be efficiently distributed to those organizations who have a technical need for them in support of operational networks.



On the assumption that we don’t want wasted or non-op verbiage in the NRPM, why is this section required?










From: Scott Leibrand [mailto:scottleibrand at gmail.com] 
Sent: Friday, June 24, 2016 10:09 AM
To: Mike Burns <mike at iptrading.com>; Michael Peddemors <michael at linuxmagic.com>; John Curran <jcurran at arin.net>
Cc: arin-ppml at arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2016-5: Post-IPv4-Free-Pool-Depletion Transfer Policy




I think you're misunderstanding the intent here. This very simple "operational use" clause, that doesn't interfere with *any* legitimate transfers, is all that should be needed to prevent financial speculation, and allow us to dramatically simplify the needs test, or even remove it entirely in some cases (like the /24 for new entrants). Unless you see some actual harm that the clause would do, please just consider it "insurance" against an unlikely event that some people are concerned about, so we can move on to actually simplifying the rest of the policy. 



On Fri, Jun 24, 2016 at 8:59 AM -0500, "Mike Burns" <mike at iptrading.com <mailto:mike at iptrading.com> > wrote:

   I do believe such a provision would have significant teeth with respect to inhibiting
   IP address blocks as a viable large scale investment opportunity.   While those 
   of questionable repute may want work around such provisions, it would be rather
   difficult to establish a formal vehicle (i.e. fund) for investment in IP resource blocks 
   based on a requirement for the necessary representations and the associated risk 
   of loss of the entire investment in cases of fraud.   Other than that circumstance, 
   I agree that it would be fairly straightforward for most operating companies to make
   reasonable representations based on anticipated needs without significant concern.
Now the boogeyman has morphed into a hypothetical formal investment fund for IPv4 addresses. Despite zero evidence of anybody buying addresses and then reselling them for profit, we are asked to include this non-operational chaff in the NRPM. Despite an atomized supply, despite anti-flip provisions, despite IPv6 in the offing.  I wonder again what is keeping this fictional investment fund from opening a RIPE LIR and buying all they want? 
For what it's worth, there are active buyers today seeking to acquire millions of addresses which they desperately need for their operational networks and planned growth. Guess what, despite having the largest warchests around, they can't find sellers capable of meeting their needs. Why do you think a fund would have any more luck? Where is your evidence that 8.5.2 would have significant teeth regarding its inhibiting effect on viable large scale investments in ipv4? Is this just your opinion?
John, people can have different views on whether IP blocks should be treated as other commodities, and thus hedged, invested in, or speculated on. There is no need to cast aspersions on those who have this view, and your language about "questionable repute" goes beyond policy advice and veers into policy partisanship.
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