The End of Needs Assessments in IPv4?

A policy change now being considered by the European IP address registry RIPE-NCC would completely eliminate needs assessments as an eligibility criterion for acquiring IPv4 number blocks. If successful, policy proposal 2013-3 would liberalize the allocation and use of IPv4 number blocks, and open the door to a much more efficient and predictable market for numbers in the waning days of the Internet’s legacy protocol.

The proposal, entitled “No Need – Post-Depletion Reality Adjustment and Cleanup” was drafted by Tore Anderson. According to our careful and systematic research, Anderson is either a Norwegian IPv6 guru who works for Redpill Linpro AS, or a Norwegian singer-songwriter famed for bringing country music to the land of the Vikings. The proposal:

• Removes “Conservation” as a stated goal of the policy.
• Removes all active policy text referring to documentation, evaluation of need, and validation of actual usage for both assignments and allocations.
• Removes all text referring to the slow-start principle.
• Removes all text referring to the assignment window mechanism.
• Removes limitations on size and frequency of sub-allocations.

Traditionally the Regional Internet Registries (RIRs) have required technical assessments of operational need before they would grant anyone the right to use a block of IP numbers. As the proposal points out, operational need as a criterion for free allocations only makes sense when there is a pool of free (as in unpriced), unallocated addresses to conserve against excessive 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 years? 1 year? 3 months?) 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.

As one supporter of the proposal wrote on the RIPE address-policy list:

[RIR address] 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.

Demonstrating just how far the Internet addresssing community has come in the last 5 years, the proposal currently has garnered support and no horrified chorus of opponents, although it is inevitable that such a major change will not be easy.

Should the proposal pass and be implemented in the European region, it would still not be possible for IPv4 number block holders in North America, where a lot of the legacy space is, to transfer their resources to Europe. ARIN’s Number Resource Policy Manual has language requiring a need-based policy at the receiving RIR.