You are deliberately forestalling the possibility of new entrants getting any IPv4 after exhaustion, never mind existing operators for whom IPv4 pays employees' salaries. Is this the right tradeoff for the industry?
New entrants typically want to see predictable prices or else they simply don't enter. Currently, the price for IPv4 addresses is predictable. After a transfer scheme is in place, and speculators take up the remaining free pool, the price of IPv4 will be wildly unpredictable. That situation will block new entrants. However, there is another aspect which involves IPv6. Large ISPs are already deploying IPv6 trials in order to be prepared for the day when they cannot grow their networks with IPv4. That day will probably come a bit sooner, when the price of IPv4 addresses skyrockets due to limited supply. But here's where it impacts potential new entrants. The large ISPs are not deploying IPv6 for a completely separate Internet. We are all including technology to allow the interoperating of the IPv4 and the IPv6 Internet, because we want to be able to connect customers using pure IPv6 networks, and still allow those customers to have full access to the IPv4 Internet. This means, that a new entrant into the Internet business, can realistically use IPv6 technology and expect to be able to buy full connectivity to all IPv4 and IPv6 Internet sites from one of the larger ISPs. The price for IPv6 addresses is predictable (zero) and the price for the IPv6 service will also be predictable since it is being sold in a competitive market. It is highly likely that ISPs will offer IPv6 connectivity at a lower price than IPv4 connnectivity because it reduces the pressure on their legacy IPv4 infrastructure. Rejecting any and all policy changes which enable a market for IPv4 addresses, does not lead to blocking new entrants. It may, in fact, create greater opportunities for new entrants since they will be able to avoid the costs and complexity of supporting both v4 and v6. They will leave that to the larger upstream ISPs, but at the same time they will be able to pay less than an IPv4 entrant would pay. This seems like a win-win situation all around. Please reject this transfer policy. --Michael Dillon