This seems like a very well thought-out policy proposal. As the proposal points out, operational need as a criterion for free allocations only makes sense when there is a pool of unallocated addresses to conserve against excessive, unpriced occupation of number blocks. Once that basic fact no longer holds, needs assessments by the RIR serve no necessary function, but they do add bureaucracy, uncertainty, cost and the potential for arbitrariness to the process of re-allocating v4 numbers among competing uses and users. When the definition of need is based on arbitrarily defined and regularly changing time limits (3 months? 1 year? 3 years?) it illustrates how tenuous the process of needs assessment is. In fact, the concept of "need" is always contingent on price, time horizon, expected value, potential substitutes and a number of other economic factors that are best sorted out in the market. Right now, all demand for IPv4 number blocks competes with all current occupiers of the number space and all other prospective occupiers. It is competitive bidding in the market that should resolve who gets what, just as it does with labor, equipment, etc. If someone is willing to pay to extract number blocks from another holder, I don't see that the RIRs need to second-guess whether they need them or not, any more than they ask whether they actually need the amount of office space they are willing to pay for. The only argument I have heard for continued needs assessments comes what I see as unfounded fears of "speculation" and "hoarding." But these are economically driven phenomena. For these to be fatal objections, opponents of this proposal must believe that substantial acquisitions of number blocks would come from parties who have a) no operational use for the numbers and b) no interest in on-selling them efficiently to third parties who do have a use for them. Further, opponents must also believe that c) IPv6 does not constitute a viable intermediate-term option that acts as a constraint on the price of v4 transactions. I reject all three of these premises. I hope RIPE can cement its reputation as the most progressive RIR and pass this. Milton L. Mueller Professor, Syracuse University School of Information Studies Internet Governance Project http://blog.internetgovernance.org