Hi Jason and thanks for your interesting reply. As you know, my original proposal was not based on a cap that is based on the size of the entity, but instead on the number of addresses allowed to be transferred without a needs test per annum.There was a suggestion that this cap instead be placed on the aggregate number of addresses held by an organization. The reason given was that these organizations would likely have more experience with justifications, and that the needs test would be less of a burden for them.
I agree that this aggregate cap does burden the larger organizations, but consider that these larger organizations by definition have fed at the trough of the free pool extensively compared to their less endowed competitors. One could argue that they are reaping the advantage of being there early and thus should shoulder the burden of needs testing additional transfers that late entrants who have to pay for their addresses should be exempted from. As for me, I think either version of the cap will serve to prevent hoarding and market cornering, but will reply inline to some of your other comments: >Consider a small rural residential ISP, with a /22. >- This ISP is using a single /24 for loopback, point-to-point, management network, and corporate network. >- This IPS has 615 customers each with a single IPv4 address. >- This ISP has seen fairly linear growth of 600 customers every two years. >In 6 months they will exhaust their currently held space. >They already qualify for another /22. >Once they get this additional /22 that gives them addresses to cover 4 years. >(/22 is about 3.4 years of customer + 6 months current available) >A /12 represents 6,990 years worth of address space >A /16 represents 218 years of address space >A /20 represents 13.5 years of address space >Should small organizations be able to by a virtually unlimited amount of address if they can afford it? First of all, it would be an odd rural residential ISP who could fork over $10 million for a /12. And a /12 is not the same as “virtually unlimited”, surely you know that. The limit is just .0002 of available IPv4 space. >Should a large organization (who can demonstrate need) only be permitted to buy two years worth of address space? As I said, I am agnostic about whether the cap is on aggregate holdings or annual transfers. But I would point out that it is the large companies who pose the greatest risk of hoarding addresses, simply because they usually have the required funds to risk in this endeavor. >Organizations have also realized they only have to do native IPv4 for shortly >longer than their competitors then they can force all new customers into some sort of provider based large scale NAT (CGN 444 + IPv6 / GCN 644). >So now people are bracing for a slow and painful transition to IPv6. >Never mind anti-competitive behavior of cornoring the market on IPv4 addresses, think about reasonable players the feel the need to stockpile enough addresses to continue doing native IPv4 longer than their competition in order to not loose their customer base to competitors who can offer a better native IPv4 product when you can't. >Which means getting years worth of IPv4 space... >Which means we are not going to run out... >Which means we can continue to save by deferring the cost of deploying IPv6... >Which menas buying more space... >(if we are not ready to deploy IPv6 buy two more years worth) >(or if the industry hasn't embraced IPv6 in a real way buy enough to last >until it has) I agree with what you are saying, although “forcing” customers into CGN is not something I am aware of, rather this is being provided as an option to users, with the ability to opt out, at least with the British deployments and Verizon residential DSL. My Sprint 4G has been using CGN on squat space for years without my ability to opt out, though. But if you take this view, that an IPv4 market will provide a disincentive toward IPv6 deployment, maybe what you should be after is policy designed to make the market less viable, less vibrant, through increasingly onerous restrictions on transfers and allocations. Also, if ISPs can realize a 10:1 or even 100:1 address savings ratio through the use of CGN, wouldn’t they be more likely simply to introduce CGN and then hoard the addresses they have saved, rather than go to the transfer market to buy more? Note that this is only an option for those who already have large holdings of IPv4 space. >If you are looking to make needs justification easier then maybe something >like: >- any org can transfer a single /22 no need required >- any org can transfer up to four times the amount of address rounded to nearest CIDR utilized in the last year > * (jan 1, had 14 M addresses in use, dec 31 had 17M) 3M = /20 qualify for > /18 >- any org who transfered a /22 can get an additional /22 when the current one >is 80% utilized even if they have utilized less than a 513 addresses in the last year > *( jan 1 had 711 addresses, dec 31 had 820) 109 = /25 >But agin the community will have to accept a four year window, which will >likely do bad things to IPv6 deployment. If you made the threshold a /23, then you could keep the two year window... but they why not just go to RIPE or APNIC and get a /22 from the soft landing policy? I am heartened that you would even consider a /22 cap for needs free transfers. But I don’t think that this conversation should in any way preclude consideration of some kind of soft-landing policy for free pool addresses. Regards, Mike Or we could let the businesses themselves decide how much they want to spend to insure themselves against a potential long-term future for IPv4. Some conservative entities may choose to buy “up to the cap” in this situation, others who think IPv6 is close, or a new transition technology is in the offing, might seek to sell addresses while they have value. It is in the interplay of those transactions that a price will be derived, representing the opinions of all transactors. I think that what you are arguing is that a large number of buyers will have the money and inclination to buy “up to the cap”, resulting in more overall hoarding than if we maintained the needs test for all transfers. I think this would require a kind of conspiracy or at least groupthink which I do not perceive among buyers and sellers in the market. On Thu, Jun 13, 2013 at 10:17 AM, Mike Burns <[email protected]> wrote: Hi Brian, Thanks for your thoughts. No doubt a more vigorous transfer market will lead to more router misconfigurations. I think a knowledgeable middle-man could help mitigate that, and would take business from the guy getting into the game without networking knowledge you mention below. There is real uncertainty when dealing with the registries. A recent transaction took nearly a month to complete, most of which was spent in the back and forth of a justification. It’s always a fingers-crossed situation for buyer and seller. One broker told me she does the “happy dance” every time a deal makes it through justification. Your point about moving to IPv6 is important, because that move is the 800lb gorilla in the room. Nobody knows when the move will happen or how long it will take, but when it happens it is bound to affect IPv4 prices negatively. Who would speculate under these conditions? What if we limited his total purchases to a /12, or his aggregate holdings to a /12, otherwise he would be needs-tested? Regards, Mike From: Brian Jones Sent: Thursday, June 13, 2013 9:30 AM To: Mike Burns Cc: Mike Burns ; [email protected] Subject: Re: [arin-ppml] A Redefinition of IPv4 Need post ARINrun-out(was:Re:Against2013-4) Mike, See inline comments. On Wed, Jun 12, 2013 at 10:05 PM, Mike Burns <[email protected]> wrote: Hi Brian, I understand that there is a danger of overpurchasing (by whomever's definition) that comes from the removal of a needs test for transfers. In most cases we rely on the price of the addresses to provide some check on this practice, as it would for the overpurchasing of any other asset a corporation may choose to invest in. I think we should leave those definition of what an overpurchase is to the buyers, who will have a range of intended purposes, projected growth rates, planning horizons and other considerations. At least with a cap of some sort we limit the overpurchase risk to overall address usage efficiency. A vibrant market is one of the best mechanisms to prevent what you mention-the problem of addresses sitting idle while real need exists. At the risk of contradicting myself, I'm not sure a vibrant market is the best answer for the networking community, but I don't disagree that what you propose would invigorate the market. See my comments below about network stability. As the price of addresses rise and transactional roadblocks diminish, idle addresses will come into the market. As the need rises, the price will rise, driving efficiencies in the utilization of addresses and wringing the most efficiency through the highest and best use of the addresses. I would agree that as demand rises the prices will increase, but maybe, just maybe most folks will be considering the move to IPv6 where these contentions and price increases will not exist. And as I mentioned, due to the needs test requirement, these early IPv4 address transactions almost always involve neophyte parties on either side of the transaction, separated by language, culture, and an ocean. Often these parties are not familiar with their own RIR policy, much less the policy of another region. Most of the time the decision to sell or buy addresses has to overcome corporate inertia and antipathy to new, unusual, and unlikely-to-be-repeated transactions. This means education about the RIRs and their position squarely in the middle of the buyer and the seller. How likely is this transaction to occur for small allocations like the /24 needed by Mr. Ryerse of this thread? I contend that removing the needs requirement will allow for less uncertainty in what is currently a fraught process for both buyers and sellers, leading to more transactions, more price stability, and simpler transactions for all parties, including ARIN, who will avoid the time and effort of needs testing transfers. I appreciate your contention, and it is possible that some of the things you mention may actually pan out, but I do not agree with the "less uncertainty" part of your statement. I would contend removing all needs assessment would create more uncertainty by promoting that anyone can get in the game of brokering IP addresses regardless of their knowledge about networking. Also by increasing the amount of times IP addresses get swapped around the Internet could increase the possibility for networking instability and router misconfiguration issues. -- Brian Regards, Mike ----- Original Message ----- From: Brian Jones To: Mike Burns Cc: [email protected] ; Mike Burns Sent: Wednesday, June 12, 2013 9:28 PM Subject: Re: [arin-ppml] A Redefinition of IPv4 Need post ARINrun-out(was:Re:Against 2013-4) Hi Mike, I suppose it is just my old school thinking that you should be at least "this tall" to ride the ride. Given your explanations below I could relax my requirements for demonstrating technical support need for transfers. I actually didn't realize we were only considering transfers and not the remaining free blocks, so thank you for clarifying that. It still seems that inefficient use of address space could occur when a bidder buys much larger blocks than needed due to the lack of any structured needs requirements. At a minimum a block of addresses could sit idle and unused while needs exists elsewhere. But really IPv6 should be the best solution for those needing addresses moving forward any way... :) Brian On Jun 12, 2013 3:15 PM, "Mike Burns" <[email protected]> wrote: > > Hi Brian, > > Thanks for your input. > > May I ask why you think there should be a requirement for demonstration of minimal technical need for transfers, if the reason is not to prevent hoarding and price manipulation? > > Remember we are talking only about transfers, and not the intelligent allocation of the remaining IPv4 free pool, and that money will be the determining factor in who receives IPv4 addresses under the current transfer policy, so long as the needs test is met. That is, we are already at a point where the highest bidder will get the addresses, irrespective of what his justified need for the addresses is, just that he has met the RIR need test. > > I have been operating under the assumption that the underlying reason for requiring the needs test for transfers which are already priced is to prevent a buyer without needs from damaging the market through hoarding or cornering. I understand that many people simply do not like the idea that address blocks can be bought and sold, and that money has any influence on who gets addresses, but we are beyond that now. > > Regards, > Mike > > > From: Brian Jones > Sent: Wednesday, June 12, 2013 2:54 PM > To: Mike Burns > Cc: [email protected] > Subject: Re: [arin-ppml] A Redefinition of IPv4 Need post ARIN run-out(was:Re:Against 2013-4) > > > Maybe that was utopian thinking on my part. It would be nice to disregard what happens with IPv4 space but that seems to invite some sort of chaos and the last thing needed is more chaos... > > Intelligent allocation of the remaining IPv4 space is important in my opinion. > > From Dave Farmer's email earlier: > "I think the more important issue is an appropriate criteria on the lower-end and for new enterants, the current slow-start for IPv4 isn't going to work, post-ARIN free pool. Yes, I know eliminating need alltogether eliminates that problem, but I'm not sure I can get myself all the way there. I'd like to see some minimal technical criteria that entitles someone to be able to buy up to between a /16 and a /12 and more than just that they have the money to do so. Maybe its just as simple as demonstrating efficient use of at least a /24. If you can't do that then you can only buy a /24, then you utilize it and you qualify for bigger blocks. " > > Regardless of whether the size blocks discussed is agreeable or not, I do agree wth the part about the need for "...minimal technical criteria that entitles someone to be able to buy up to between a /16 and a /12 and more than just that they have the money to do so." > > (Of course I support the idea that we all move to IPv6!) :) > > -- > Brian > > > On Wed, Jun 12, 2013 at 11:20 AM, Mike Burns <[email protected]> wrote: >> >> Hi Brian, Matthew, and Martin, >> >> Can I take your plus ones to indicate support of the cap even in the face of the shell company issue? >> (As well as support of the idea that we should all move to IPv6.) >> >> Regards, >> Mike >> >> >> From: Brian Jones >> Sent: Wednesday, June 12, 2013 11:03 AM >> To: [email protected] >> Subject: Re: [arin-ppml] A Redefinition of IPv4 Need post ARIN run-out (was:Re:Against 2013-4) >> >> >> >> >> >> On Tue, Jun 11, 2013 at 10:42 PM, Martin Hannigan <[email protected]> wrote: >>> >>> On Tue, Jun 11, 2013 at 10:24 PM, cb.list6 <[email protected]> wrote: >>>> >>>> >>>> On Jun 11, 2013 7:15 PM, "Matthew Kaufman" <[email protected]> wrote: >>>> > >>>> > When will we start caring about IPv6 and start ignoring IPv4??? Who cares if people set up shells to acquire v4 space from others? Let 'em, and get v6 deployed already. >>>> > >>>> >>>> +1 >>>> >>>> CB >>> >>> >>> +1 >>> >>> Best, >>> >>> -M >>> >>> >> >> >> +1 >> >> -- >> Brian >> >> >>> >>> >>> _______________________________________________ >>> PPML >>> You are receiving this message because you are subscribed to >>> the ARIN Public Policy Mailing List ([email protected]). >>> Unsubscribe or manage your mailing list subscription at: >>> http://lists.arin.net/mailman/listinfo/arin-ppml >>> Please contact [email protected] if you experience any issues. >> >> >> ________________________________ >> _______________________________________________ >> PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List ([email protected]). >> Unsubscribe or manage your mailing list subscription at: >> http://lists.arin.net/mailman/listinfo/arin-ppml >> Please contact [email protected] if you experience any issues. > > _______________________________________________ PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]). Unsubscribe or manage your mailing list subscription at: http://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected] if you experience any issues. -- _______________________________________________________ Jason Schiller|NetOps|[email protected]|571-266-0006
_______________________________________________ PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]). Unsubscribe or manage your mailing list subscription at: http://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected] if you experience any issues.
