[address-policy-wg] 2007-08 Review Period extended until 9 July 2008 (Enabling Methods for Reallocation of IPv4 Resources)

I do not support this proposal for the following reasons:

* It breaks the policy of providing addresses to those who need them in a 
fair and non-discriminatory fashion because it allows LIRs to choose who 
gets spare addresses for arbitrary and secret reasons rather than through 
the open and transparent process of the RIR.

* It is discriminatory to those LIRs in developing countries (within this 
RIR region) who have fewer IPv4 addresses than other countries for 
historic reasons and will now have to pay considerably more for addresses 
by buying them from other LIRs.  This will only exacerbate an already 
difficult global position where some countries are pushing for a change in 
the global management of the Internet driven by a perception of exclusion. 


* It is only a partial solution to the problem.  Many LIRs believe that 
much more can be achieved by a determined and well implemented policy on 
reclaim/reuse.  However this policy only addresses the potential transfer 
solution to the problem, not the potential reclaim/reuse solution. 
Furthermore, it is likely that this policy, if implemented before a proper 
reclaim/reuse policy will render such a policy unachievable and 
unworkable.

* It will create a landrush of false or exaggerated allocation requests 
from people who wish to profit by arbitrage, leading to far faster 
exhaustion of IPv4 addresses.  In other words there will now be a 
significant difference in the price that IP addresses can be 'bought' from 
RIPE NCC compared to that at which they can be sold on the open market. 
This difference in price, the arbitrage opportunity, will lead to an 
influx of speculators who will work out how to play the system and so lead 
to many more addresses being allocated than otherwise.

* It takes RIPE NCC into the business of a regulator of a secondary 
market, which is something it has no expertise in and brings considerable 
risk.  RIPE NCC has to develop into this role because the nature of the 
proposal requires policing to check transfers have happened within the 
rules.  However, with the potential for transfers to have commercial and 
financial implications there is far greater possibility of costly and 
complex challenges to RIPE NCCs decisions.  This in turns brings with it 
the risks of scrutiny from competition authorities.

* It will lead to rapid degradation of the IPv4 LIR database and loss of 
control for RIPE NCC in the registration of IPv4 addresses.  If LIR A 
sells a block of IPv4 addresses to LIR B then the legal ownership is 
adequately covered by the contract that exists between the two and so 
there is no incentive to register the transfer with RIPE NCC other than 
when peering with people that make strict use the LIR database.  Rival 
databases, based around IPv4 trading exchanges, will spring up.

Jay Daley
Nominet UK