[arin-ppml] Draft Policy ARIN-2019-10: Inter-RIR M&A - Seeking Community Comments

hostmaster at uneedus.com hostmaster at uneedus.com
Thu Jul 18 13:36:04 EDT 2019

Hi, Jordi,

I do not agree with your points, and strongly oppose IPv6 transfers for 
ARIN.  Just because two RIR's have developed a policy to allow this is NOT 
a good reason for ARIN to jump unto that bandwagon.

There are clear costs to allowing IPv6 transfers at ARIN.  They include 
development costs in changing the IT systems at ARIN, the costs of the 
operation of that portion of the reverse DNS on behalf of people who are 
NOT providing any revenue to ARIN as well as staff training.

Unlike with IPv4, there are NO legacy holders or others that are receiving 
IPv6 DNS services from ARIN without payment of fees.  Keeping each ARIN 
/12 completely under the control of ARIN is best, and reduces the overall 
cost of operation by not having to manage or train staff on transfers.

We would have no way to predict or limit the number of reverse queries of 
portions of the ARIN reverse that are transfered to other RIR's. 
Operations involving massive amounts of traffic might choose to move 
to another RIR, leaving ARIN to have to increase circuit capacity or 
otherwise manage that traffic for free.  By not allowing transfers of IPv6 
resources, all traffic is 100% paid for by ARIN fees.

I also see this as forum shopping.  However if forum shopping is allowed, 
it will be the RIR with the best policies and lowest costs who will win 
that battle.  If that battle has to happen, I would like ARIN to be the 
winner, by having policies that keep costs low, and fixing any issues with 
the reverse PKI systems that have been identified.

There is also the idea of "KISS".  By keeping it simple, we know all 
traffic in the ARIN /12's are managed by ARIN, and we do not have to deal 
with many of the "hacks" that have affected IPv4.

While CIDR, NAT, RIR and Directed Transfers have gone a long way to extend 
the life of IPv4, IPv6 does not have the shortage of address space to 
require the use of any of these things.  IPv6 has the promise of bringing 
back the original end to end of each host on the original ARPAnet.  Also, 
when numbers are transfered, would the RIR have to transfer the reserve 
space provided by sparse allocation to the receiving RIR?  If not, this 
will cause fragmented routes when the holders of the transfered space have 
to expand.

As for future ideas, I would like to see a renumbering requirement into a 
larger single block when a member expands their IPv6 space beyond the 
reserved space, so that each member holds but a single block of IPv6.

I believe that all costs of an RIR change should be borne by the party 
wishing to transfer.  The proposal would require ARIN to develop processes 
paid for by all solely for the benefit of those few that want to avold 
renumbering and pass these costs to all members.  I think this is wrong. 
If it is thought that transfers are a good idea, maybe some kind of yearly 
fee for reverse DNS needs to be assessed to compensate ARIN for its 

Also, I honestly doubt that these players that claim to want to move their 
home office without renumbering are actually doing so because of the 
downtime associated with a true hot cut.  I think that in most cases, 
although they are keeping their original IPv6 numbers and moving them 
between RIPE and APNIC, I strongly suspect that individual hosts being 
moved are being renumbered to different /64's within their block when they 
move from LAN to LAN to avoid downtime.  If they can do this, they 
certainly can instead renumber to a new block at ARIN or whatever RIR they 
are desiring to move to.  Of course, there is nothing to prevent those 
desiring to move RIR's from maintaining numbers in more than one RIR while 
the movement of hosts takes place.

Does anyone have any stats as to what percentage of the total members of 
RIPE or APNIC have in fact moved their IPv6 from one RIR to the other? I 
strongly suspect it is less than one percent.  If so, that is grossly 
unfair for such a small number of those transfering their numbers to 
be able to spread that transfer cost across the entire membership of 
those two RIR's.  While APNIC and RIPE might agree to this pass on of 
costs to its members, I do not think that ARIN should do the same.

Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Wed, 17 Jul 2019, JORDI PALET MARTINEZ via ARIN-PPML wrote:

> Hi Jimmy,
> The cost of doing all that has been done already for IPv4 and by other RIRs.
> It is one-time development cost anyway (to adapt the changes to IPv6), so not a giant effort. And by the way, it has been done already to allow that working among RIPE and APNIC, and I believe there is plenty of cooperation among RIRs in order to share developments, engineering, knowledge and so on.
> Furthermore, there is not such human resources cost as all those proceses, as every policy implementation in any RIR, become automated.
> Regarding the cost of a member "leaving" ARIN membership, it is comparable to the reverse case, when a RIPE or APNIC member moves to ARIN. This is something that we need to live with, but is part of the set of services that the RIRs offer, to a global community, not just to a specific region.
> Consequently, I don't think this is a valid argument to object to this proposal.
> Regards,
> Jordi
> @jordipalet
> El 17/7/19 22:17, "ARIN-PPML en nombre de Jimmy Hess" <arin-ppml-bounces at arin.net en nombre de mysidia at gmail.com> escribió:
>    On Mon, Jul 15, 2019 at 11:37 PM Job Snijders <job at ntt.net> wrote:
>    > Even if inter-RIR transfers were permitted, ARIN would still
>    > operationally be responsible for all delegations under the
>    > "0.6.2.ip6.arpa." zone. So, no issue there.
>    [snip]
>    No.... that is exactly one potential issue.    An entity wishing to move
>    their networks around ought to bear costs of their moves;  the RIR
>    such as ARIN should not be subsidizing an entity's choice to move
>    out of region and continue to keep everything nice and convenient for
>    that resource holder by incurring extra costs against the fees paid by
>    other still-in-region members  to help facilitate the operations of some
>    small number of  'wanting to move out'  resource holders;   This
>    is not in the interests of the regional community whom its ARIN's
>    mission to serve  to be in a position of continuing to provide
>    a Reverse DNS service to the entity that moved out after they
>    are no longer an ARIN customer,   And  "fragmenting" in this
>    manner is exactly what this forces upon ARIN.
>    The kind of Reverse DNS Zone that is simplest for RIRs to have
>    software, systems, and process to manage -- is one where all the
>    NS delegations are predictable and match up exactly with database
>    entries created by customers  linked to a direct allocation or assignment.
>    And the requirement to maintain additional, extra nameserver delegations
>    for "transferred blocks"  means  designing, developing, or maintaining,
>    systems, algorithms, and management processes which involve
>    more ARIN staff time being used to operate,  and a
>    greater minimum complexity  than the simplest form
>    (which would meet the simpler requirements of each delegation
>    maintained by an ARIN customer).
>    Aside from the administrative burden that ARIN now would have to
>    maintain an entirely additional set of delegations and database entries
>    which are for out-of-region usage on transferred out V6 space,  and
>    have processes and people to  update these entries from time to time:
>    when the  end user's downstream nameserver addresses change.
>    To keep such a transfer in effect and reverse DNS working properly:
>    ARIN (and therefore other ARIN members) would effectively have to
>    also bear an ongoing cost on behalf of the foreign registrant in perpetuity
>    without compensation for the services,  because that organization will
>    be cancelling their relationship with ARIN and/or no longer be paying
>    any maintenance fee for that block of addresses.
>    Meanwhile....  ARIN continues to have to maintain DNS servers with
>    computational and bandwidth resources allocated
>    to answering queries that come for the reverse DNS range of THAT block
>    transferred out and maintaining a set of nameserver delegations in the
>    reverse DNS zone for the "transferred out" address block in order to do so.
>    And the VOLUME (total number of reverse DNS queries per day) per
>    block  varies with the usage of that block,  size,  etc,
>    so it is non-predictable.
>    ARIN likely needs that entity as a customer while delegating reverse
>    DNS to them,
>    in order to be be able to charge maintenance fees to compensate ARIN for
>    costs of providing the  service of answering the reverse DNS
>    Nameserver  queries.
>    --
>    -JH
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