[address-policy-wg] 2012-01 New Policy Proposal (Inter-RIR IPv4 Address Transfers)

Hi,

On Thursday, April 5, 2012, wrote:

> Thank you for your comments on proposal 2012-01, which I have submitted.
> I will undertake to speak to several of the points you have raised.
>
> My opinion on the question of the use of the word "sold" is that I would
> also be ok with the word "transfer".  I believe this policy can cover two
> situations:  1) where related companies, for example ABC-NA transfers a
> block from ARIN to ABC-EMEA to RIPE-NCC, and no money is exchanged; and 2)
> where unrelated organizations transfer a block.  Only in the second case is
> money likely to be exchanged in order to encourage the sending organization
> to initiate the transfer.  Thus only the second case is truly a sale.   And
> let's be very clear that I do mean for money to be exchanged:  in most
> cases there is work to be done to free up blocks of IPv4 addresses for
> re-allocation, and the incentive for entities to do so is financial
> benefit.
>


In the past, the incentive has been to act as good net citizens by
following policy that mandates return of unused resources.




> Otherwise, large portions of their blocks will continue to sit dormant and
> unused.  The entire purpose of the IPv4 address market is to free up
> dormant, unused IPv4 addresses to fill needs.
>

A cynic might say that the entire purpose is to make money.



> A number of people have questioned the 15 month window before allowing a
> buyer to re-sell.  I have had suggestions ranging from 12 months to 36
> months.  I think the point is that there is some feeling that an entity
> could acquire IPv4 addresses with the intent to flip them for profit.  I am
> not sure this would be possible since at some point, the transition to IPv6
> will make IPv4 addresses a declining value asset.  I, for one, believe in a
> free market for IPv4 addresses, where no holding period is required.  In a
> free market for IP's, the price of IP's would move up and down like the
> price of a commodity.  However, there are artificial trading rules at play
> with IPv4, so some window seems to be needed.  Hence, I chose 15 months as
> a compromise for those who feel that 15 months allows a company to satisfy
> its IPv6 conversion needs and possibly be done with IPv4 and be ready to
> sell them.
>
> To Mr. Blessing's question about an LIR changing its policy, I believe the
> answer is that there would be a legal binding agreement between the buyer
> and the seller that would cover this situation.  The RIPE-NCC policy does
> not need to cover the legalities between the two parties.
>

> I am not sure what the question of a reverse policy refers to?
>


I'm pretty sure it means reverse DNS.


> Do you mean to reverse the transaction?  If so, you could add a clause
> that states that the two parties can reverse the transfer at any time in
> the future or something to that effect.  I did have a hypothetical
> discussion with Sanjaya of APNIC for a situation that may require this.  I
> was asking about a potential lease situation where an APNIC member may wish
> to lease a block from another RIR.  He wondered if the APNIC registry could
> initially be updated to reflect the lease, and then once the APNIC member
> had completed the upgrade to IPv6, the IPv4 addresses could be returned to
> the originator.  We then wondered how to reverse the transfer to return the
> IP's to the owner.  This clause above that Mr. Blessing is possibly
> questioning about would take care of lease returns.
>
> I believe these transfers would always be between entities, ie. LIR's.
>
> Mr. Hilliard is concerned about Afrinic losing IP's.  Frankly, I have not
> looked at oversupply or demand in the Afrinic region.  Right now Afrinic
> does not have an Inter-RIR transfer policy
>

I would say that here in the AfriNIC region, we do have such a policy, or
at least a statement of the sense of the community on the issue.  It just
doesn't allow what you want.  You can find it in our Soft-Landing policy.




>  and by including a statement that RIPE-NCC will only transfer with RIR's
> that have a policy, you allow Afrinic to take care of itself.
>
> Mr. Lenz is concerned about the use of the word "business" purposes.  That
> is, perhaps, a semantic point.  I believe that the word business should not
> be taken too narrowly.  Business may be defined as an activity a person or
> organization is engaged in, and I would just take it at that.
>


Sascha is correct I think, in that buying and selling Internet resources is
a business.  Internet numbering resources should be used to provide
connectivity and other network services, not for speculation in a numbers
market.



>
> Mr. Leefman suggested we realign the proposal to a /21 as the minimum
> size, and I think that is an excellent suggestion.  Other RIR's such as
> ARIN and APNIC work with a minimum size of a /24 and I was trying to
> keep RIPE in line with them, but frankly that is such as small
> block, why bother?
>
> Mr. Leefman also suggested changing the requirements for proving need to
> align with the intra-RIR policy.  In checking with Mr. Madaio, he informs
> me that there have been no intra-RIR transfers to date. That suggests to me
> that RIPE's intra-RIR policy needs some rework,
>

Does it not instead suggest that there is not yet a need for intra-RIRS
transfers, since there are addresses left in the RIR allocation pool?



> f I may be blunt.  My experience with transfer markets in other RIR
> service areas has shown three things: 1)  that entities need to be assured
> that their transfers will be approved, when they put money on the line,
> 2)  that when they pay, they don't want, or believe that they should have
> to, go through the same needs justification process as when they apply for
> free allocations,
>

Then perhaps you can help educate your customers that the RIR policy making
communities seem to be overwhelmingly in favor of retaining needs based
justification.



>  3) while the period of a free allocation may be fixed (ie 3 months), when
> a business has a need and a business plan for which it acquires IP's it is
> a much longer time horizon, and it is not RIPE-NCC's role to limit its
> members business planning horizon to 3 months.
>

That is correct.  The RIPE NCC as the secretariat of the RIPE policy making
community has as it's role the administration of numbering resources
according to community policy.  In other words, it is the role of RIPE (the
community) to determine things like time horizons in the prescence of
dwindling common resources.


  (If RIPE approves me for a three month supply now, I have no guarantee I
> will get another 3 month supply in 3 months....I cannot plan or operate
> this way!).
>


Neither can others if they stick with a v4 only strategy.  Everyone is in
the same boat.

Regards,

McTim








>
> For example, and you may not care about what other RIR's do, but ARIN has
> a 24 month supply for a transfer, and as you may know, we are working
> to convince ARIN to modify its policy on needs justification for transfers.
>
> So, I would not support a change in the inter-RIR policy to  your
> intra-RIR policy.  I would instead suggest that you consider modification
> of your intra-RIR policy to match what your constituents need.
>
> Lastly, I like Mr. Van Mook's comments, other than that he opposes the
> policy.  It is excellent and simple to outline the transfer in and transfer
> out options, and as noted above, I concur with him that the RIPE intra-RIR
> policy needs clean-up.  I guess I thought that was a bigger mountain than I
> could climb, but if it is possible to have a conversation about doing it at
> the same time, I am all ears.
>
> Again, thank you for your support, your comments, and your thoughtful
> feedback.
>
> Respectfully,
> Sandra Brown
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-- 
Cheers,

McTim
"A name indicates what we seek. An address indicates where it is. A route
indicates how we get there."  Jon Postel
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