+1 The RIRs were always stewards of the free pool of addresses, charged with distributing them to those with demonstrated need. This stewardship was a requirement for the allocation of unpriced but scarce resources, to avoid the pitfalls of the Tragedy of the Commons. Upon effective exhaust of the free pool, the steward with the gentlest touch will step back from his stewardship and allow the market to ensure conservation. This is what markets are designed to do, allocate scarce resources efficiently. In addition to conservation, the RIRs were charged with maintaining uniqueness. In order to maintain stewardship of uniqueness, RIPE should simply act as a registrar, registering IPv4 transfers in its Whois directory. Imposing policies which restrict the free trading of addresses will endanger uniqueness as restricted trades continue underground. IPv6 is a barrier to speculators. What could be their plan, to hoard IPv4 addresses with the hope of driving up prices? That would work toward accelerating IPv6 and reducing IPv4 values. There is a natural ceiling to speculation, and there are also a billion IPv4 addresses un-advertised in the routing table. Securing enough IPv4 space to begin dictating pricing would require huge purchases from a large number of disparate sellers, and could not happen quickly or surreptitiously. I was the author of the current ARIN transfer policy, and when I introduced it, I included a limit of a /12, or about a million addresses per year which could be transferred by a single buyer without requiring a needs justification. I included this specifically as an anti-speculation measure, but the ARIN community would not allow any non-needs based transfer, and my proposal was changed to require a needs test for all transfers. This indicated to me that the real bogeyman in the ARIN community wasn't speculators, it was free markets. Is this also a RIPE bogeyman? -----Original Message----- From: Milton L Mueller Sent: Wednesday, March 20, 2013 12:16 PM To: 'address-policy-wg@ripe.net' (address-policy-wg@ripe.net) Subject: Re: [address-policy-wg] 2013-03 New Policy Proposal (No Need -Post-Depletion Reality Adjustment and Cleanup) 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