[address-policy-wg] 2013-03 New Draft Document and Impact Analysis Published (No Need - Post-Depletion Reality Adjustment and Clean up)

* Filiz Yilmaz

> So that we at least put a barrier in front of those who would just
> ask for an allocation to immediately turn it into an asset. But those
> who really are in need are primarily highlighted by the policy.
> 
> Current policy has the following text: "Members can receive an
> initial IPv4 allocation when they have demonstrated a need for IPv4
> address space."
> 
> Tore's proposal is removing this totally and I do not agree with it.

Hi Filiz, and thanks for pointing out the specific text! I'll just reply
with my reasons for removing this text and why I think it is the right
thing to do, given 2013-03's ambition. I understand that ultimately, we
might just have to agree to disagree on this. :-/

First, on a higher philosophical level, the only reason for the above
sentence's existence, is the "Conservation" goal in section 3.0 ("..To
maximise the lifetime of the public IPv4 address space, addresses must
be distributed according to need..."). 2013-03 removes the
"Conservation" goal, which means it also removes the only rationale for
requiring the demonstration of need for initial IPv4 allocations. Hence,
it makes sense to remove this part of the policy text as well.

Second, on a more pragmatic level, when we hit IPv4 depletion last year,
the requirement to demonstrate need in order to receive initial
allocations changed. It is no longer "specify how many addresses do you
need?", but a boolean "do you need more than 0 addresses? yes/no".
Demonstrating the need for 1 IPv4 address is, in my opinion, merely a
formality - anyone could do that with almost no effort.

So I do not believe that the current requirement to demonstrate need in
order to receive an initial allocation could be considered a "barrier",
as you put it. If an organisation is determined enough to join the NCC
and pay its membership fees, it will be able to receive its initial (and
last) IPv4 /22 as well, regardless of what its ulterior intentions for
its use are, including "assetification". Also, we do need to make a
cost/benefit analysis here and look at the proposal as a whole - i.e.,
does it make sense to maintain the entire IPv4 assignment bureaucracy,
in order to keep this completely inefficient barrier around?

Third, referring more to ensuring the policy text forms a complete
whole: Let's say I agreed to add this particular sentence back into the
proposed policy, in order to alleviate your concerns and make you
support the proposal. (Pragmatically, I wouldn't mind - I don't
particularly care if the NCC asks the new LIRs "do you need at least 1
IPv4 address?" before handing out the initial /22 allocation as I see
this as a mere formality.) This would cause a headache for the NCC, as
we're telling them to demand a "need demonstration" from new LIRs,
without telling them what that actually means. So the exchange could
very well be "NCC: do you need it? LIR: yes, I plan on selling it." -
which is pretty much exactly what you'd wanted a barrier against, right?
So in order to prevent that, we'd need to add back more and more "need"
text, and sooner or later we'd be end up back where we started. So I
don't really want to go down that road, especially when the potential
upside from doing so is a totally inefficient deterrence in the first place.

> The latter, "evaluation of justification for need" is totally an
> operational matter that is performed by the RIPE NCC. Neither the
> current policy nor Tore's proposal has any significant text on this
> but this is one of his arguments for his proposal.
> 
> In my opinion, real solution to this procedural problem of evaluation
> is on procedural level, not on the policy level. RIPE NCC may be
> asked to change their evaluation tools/systems/mechanisms. This does
> not require to remove the entire "need" notion from the policy text.

I actually tried something like this during the discussion of 2012-05.
At this point, the service requested from the NCC was something that was
not mentioned in the policy at all, and for which there had been no
previous established practice. My point of view was pretty much the same
as yours above: "Do we need to put this in policy? Can't we just ask the
NCC first?" However, the answer given by the NCC was that they preferred
this to be a clear request coming out of the PDP.

Evaluation of need, on the other hand, is deeply entrenched in our
current policy document, and we have years of previously established
practice. In light of this, and also my experiences in this approach
failing for 2012-05, I highly doubt that me withdrawing 2013-03 and
instead simply asking the NCC to stop evaluating need and expecting the
LIRs to do so is likely to get anywhere. (I'm sure Andrea will correct
me if I'm wrong!)

Best regards,
Tore Anderson