[address-policy-wg] 2014-02 New Policy Proposal (Allow IPv4 PI transfer)

Dear address-policy-wg,

With such a policy in place, IP address broker needs to offers potential IP
space buyers only a marginally lower price than the cost of being a LIR for the
expected duration of use of the IPv4 PI space in question (and requesting this
IP space from the last /8 or realizing an inter-LIR PA transfer) in order to
create a perverse incentive for IPv4 address buyers to line the pockets of IP
address brokers instead of stepping up and becoming members of the RIPE NCC.

This policy appears to fail the most basic economic incentive test, and will in
practice create a secondary and desirable 'asset class' from which IP transfer
brokers benefit considerably more than the community as a whole.

To deconstruct the arguments which purportedly support this proposal:

a) "Currently the policy for PA and PI space isn’t the same and people don’t
understand the difference between the various types of IP Space."

Ignoring that this is a superfluous argument which goes in the face of nearly
two decades of policy, this appears to argue that letting PI space be sold would
somehow eliminate this distinction.

This, of course, is disingenuous. If this is indeed the goal, a policy should be
introduced to allow PI space to be converted into PA space and assigned to a LIR
- this will enable its "transferability" and eliminate many of the concerns
raised above by ensuring that all holders of "transferred" IPv4 space are first
rate LIRs who contribute financially toward the operation of the RIPE NCC and
fall under all obligations imposed on such.

b) "There is already some trade in PI space, however it is not documented or
registered, which doesn’t help to keep the registry updated."

This is also disingenuous, as every IPv4 PI space holder has a contract with the
sponsoring LIR (and indirectly, with the RIPE NCC). This LIR can, and should,
regularly verify and update these details in cooperation with the registrant.

c) "A lot of current PI space holders are more than happy to have their
assignments re-assigned to other parties, but due to the current policy it is
not possible. The same goes for the documentation provided to the RIPE NCC
during mergers or acquisitions of infrastructure with PI space. Due to the
current policy, some changes in company names are marked as mergers or
acquisitions when they are actually a transfer of IP space with added
documentation to make it look like an merger or acquisition of infrastructure."

If a legitimate transfer has occurred as part of legitimate organizational
restructuring, there is no disincentive to document it. The disincentive only
exists if the registrant fears the transfer's legitimacy may be questioned,
which is exactly the intention for non-transferable, end-user assigned PI space.
Such transferred allocations could, and should, per current policy, be simply
reclaimed.

d) "We want to have an open and honest communication to the RIPE NCC from the
community and we need to make sure that the registry is up to date, without
having to fluff up the procedures, bend the rules and truth in communication to
the RIPE NCC to be able to transfer the IP space."

Alternatively, elements which "bend the rules and truth" could be identified,
and, within reason, have their resources reclaimed. Certainly, such enforcement
can never be perfect - but speed traps also do not catch 100% of speeding cars.

With a few documented instances, this would create tremendous uncertainty and
disincentive to engage in such practices from the buy side, as it will mean that
any resources acquired in this manner may very suddenly get written off.

e) "The goal of this policy change is to get PI space on-par with PA space in
respect to the ability to transfer it."

See (a). It seems very disingenuous to make PI and PA "equal for purposes of
transferability" but maintain the distinction in all other aspects.

To summarize, I strongly object to this policy in its current form.

I concur that the mobility of IPv4 PI space toward those who value it most is
desirable - on the condition that this mobility occurs as part of a wider reform
to eliminate the distinction between PA and PI status of IPv4 resources.

This should result in equitable burden for all resource holders toward the RIPE
NCC instead of lining the pockets of IP address brokers by helping address space
speculators which presently hoard IPv4 PI assignments against policy realize
profits at the expense of the community.

--
Respectfully yours,

David Monosov