[address-policy-wg] 2013-03 New Policy Proposal (No Need - Post-Depletion Reality Adjustment and Cleanup)

On Mar 25, 2013, at 2:09 PM, Milton L Mueller <mueller at syr.edu> wrote:

> ... Do you seriously think there is a major likelihood of lots of people making winning bids for number blocks just for the heck of it? Given the incredible flexibility and even subjectivity of the concept of "operational need" we are adding massive bureaucratic costs and delays but the gain achieved is completely unclear to me. 
> 
> I note that the secondary market for radio spectrum resources in the U.S. and elsewhere does not require acquirers to prove to anyone that they "need" it, yet there is no big problem with the way it has worked. 


Just to complete your analogy...

If RIPE were to operate with policies similar to the US radio spectrum market,
it is possible that the absence of needs-assessment would not automatically lead
to rampant speculation.  Of course, this is also because to perform a transfer in
the US spectrum market, you're likely going to hire lawyers, complete a 40 page form 
(FCC Form 603) and "certify that the proposed transaction meets specific criteria 
indicating the absence of potential pubic interest concerns relating to eligibility, 
use restrictions, foreign ownership, designated entity policies, and competition."
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-05-2226A1.pdf>

Postulating what might or might not happen with a transfer market in the RIPE region
(in the absence of needs-assessment) based on history with the US radio spectrum market 
is disingenuous without also noting the fact that the US radio spectrum market has 
its own "bureaucratic costs and delays" of a completely different nature which may
easily impact the resulting dynamics.

FYI,
/John

John Curran
President and CEO
ARIN