[arin-ppml] IP leasing policy

Mike Burns mike at iptrading.com
Wed May 29 20:13:10 EDT 2019


Hi Scott and Fernando,



Thank you for the change of subject and the discussion.

Fernando, your vision of how things should be is reasonable and consistent, but archaic in the market era.

We did things your way for decades, people did not return addresses for reasons involving utilization.

Why not audit them? Too expensive and fraught.

The community decided to provide incentives in the form of payment for IPv4 blocks.

We began that in 2010 and since then transfers have provided the bulk of new allocations worldwide.

The lure of lucre brought un- and under-utilized addresses to the market, which by nature elevates them to their most productive use.



That has brought us to the current state. Whereas leasing was always problematical because it allowed the lessor to claim more address space from the RIRs by demonstrating efficient usage of his blocks, now there are basically no free pools at the RIRs, so there shouldn't be the same worries.



In the absence of a policy, leasing is quite openly advertised and is legitimate, although not a valid justification for ARIN to approve more space for the Lessor.

For the present, we should have a policy that recognizes legitimate leasing types (LOA, VPN) and requires the same sorts of assignment and delegation records commonly done by ISPs for their customers.

It should recognize that blocks can be legitimately advertised under un-related ASNs with a valid Letter of Authorization, which must contain certain information.

It could have a process for identifying ARIN members who are participating in a lease policy violation, for notifying them, and for potentially punishing them under RSA terms.



We see more market participants who have a longer view of the duration of the transition to IPv6, and in a time of continually rising IPv4 prices, who can blame address block holders who want to lease their blocks?

At the end of the lease, instead of depreciated and worn-out assets, they could be shiny and more valuable then when the lease started.

(Or they could be blacklisted.)



Regards,
Mike








---- On Wed, 29 May 2019 19:33:25 -0400 Scott Leibrand <scottleibrand at gmail.com> wrote ----



On Wed, May 29, 2019 at 4:11 PM Fernando Frediani <mailto:fhfrediani at gmail.com> wrote:

On 29/05/2019 19:26, Scott Leibrand
      wrote:

(New subject line for a new topic.)



You just described a lease policy: one where
          leasing is not allowed.  Such a policy would have to exist to
          be enforced.  Right now there is no policy, so leasing is
          allowed because it's not prohibited.



No it doesn't. When someone leases IP addressing it proves it
    doesn't have use for its original justification. No one can think
    asking for more IP addressing and justify as "I need them to lease
    them" is something that would be ever accepted. If it is not a
    justification you can give to get more IPs from the RIR than it is
    not a accepted practice.

 



ISPs lease space to their customers all the time, bundled
            with IP connectivity.  Hosting companies do the same.  So do
            VPN providers.  The challenge with a "no leasing allowed"
            policy is differentiating between a valid reassignment of
            space to accompany multihomed IP connectivity, vs. an
            invalid reassignment of space intended primarily as a lease,
            where any IP connectivity provided is incidental, or a fig
            leaf VPN that simply is set up to comply with the policy.




That has nothing to do with the topic and is a totally different
    matter. It is conceptual. ISPs allocate IP address to their
    customers **which are not autonomous system** and cannot get them
    directly from the RIR.





That's not the only way IPs are allocated, reallocated, and assigned in the RIR system.  It's also possible, and common, for an ISP to receive an allocation from ARIN, and reallocate it to multihomed downstream customers who do have their own ASN and are running BGP.  The ISP assigning the space may be the primary provider of IP connectivity for the customer at the time of the reallocation, but may not remain so.  Or they may be one of multiple upstream transit providers, and just happen to be the one from whom it's easiest/cheapest to get the needed IPv4 space.

 

That's the main propose of an ISP Autonomous
    System go to the RIR to ask for IP space, to serve their internal
    needs and customers with Internet Services.
 When IP leases becomes the only service and **to another ASN** which
    inside the rules can ask directly to the RIR is certainly not the
    same thing as an ISP who allocates IP space to their end-user
    customer.




What if IP leases aren't the *only* service, but the IP space is bundled with IP connectivity of some sort?  What kind of IP connectivity is sufficient to make this "an ISP who allocates IP space to their end-user customer" vs. an impermissible case of "IP leases becomes the only service"?



A more tractable policy on leasing might focus on things
            like requiring registration of the downstream recipient of
            any leased space.  There may be other requirements that
            could be meaningfully enforced as well, but you'll need to
            be careful not to try to enforce requirements that impinge
            on the business of legitimate IP transit and hosting
            providers.




That's not legitimate I'm sorry. It's not difficult to think
      things like: 1) Any Autonomous System should always go to the RIR
      and ask for more IP addresses





Such a policy would put most multihomed autonomous systems in violation of your policy at some point in their growth.

 

2) If it has to go around it and get
      from another ASN there is something very wrong with it. Those
      addresses where given **to that ASN** for their internal use or
      end-user customers





The downstream ASN is their end-user customer.  That's why reallocations exist, and not just reassignments.  But even reassignments are often made to ASNs defined as end users (organizations not themselves acting as ISPs and performing further reassignments).



3) If those addresses were given for this
      proposes and someone is not using (internal use or end-user who
      are not ASN) then that ASN doesn't justify for the IP space
      received anymore.





Such a policy would force the reclamation of a lot of legitimately in-use space that is still in use primarily because it's difficult to renumber out of.



Before going ahead and writing a more specific and clear policy
      for that need to find out how ARIN currently reads and apply that.
      Then think in a proper and well written policy to cover where else
      needed.

I find very concerning defenses "as something pretty normal" use
      of IP address for proposes which they were never meant over the
      last decades, be a speculating and monetizing asset rather than
      serve to get people connected to the internet going against
      conversation and justification concepts. I see it seems the recent
      times of IPv4 exhaustion is making many to forget the very basics
      of Internet foundation and treat IP space as his very own asset
      and something irrevocable and unrecoverable.





You seem to have a very limited view of how IPs are allocated, reallocated, and reassigned between legitimate network operators who aren't trying to circumvent the rules.  Such practices have been in place since before IPv6 existed.  It's not about treating IP space as property.  In fact, it's the reverse: historically the use of Provider Assigned space when possible was the norm, and "everyone gets their own IP space from an RIR via direct allocation/assignment or via transfer" is a fairly recent practice (much more common within the last decade or so).



-Scott

On Wed, May 29, 2019 at 2:46
            PM Fernando Frediani <mailto:fhfrediani at gmail.com>
            wrote:

A lease policy should never exist in my opinion and
                registries should stand strong against it for the simple
                reason that IPs are not assets or something that belong
                to a company for it to lease.

Is it always necessary to remind that IP addresses are
                meant to be used by the resource holders who  justified
                for that ? If someone is leasing it it obviously means
                it does not need and justify anymore for that IP space
                and any RIR should recover them immediately. If such a
                policy doesn't exist on its terms it should exist and
                should be discussed to make it sooner.
 I would recommend some Jon Postel reading to those who
                believe "it is Ok to lease IPs" as if they were they
                very own asset as a router or a server that you buy with
                a invoice and you do whatever you like with it.

This type of thing goes pretty much against concepts of
                conservation and justification.
 Imagine if someone asked a RIR more IP address and may
                justify as "I need them in order to lease them". That's
                what a lease policy would walk towards to.
As I mentioned in the other message, the fact the
                people do anyway and the whois doesn't get updated is
                **less important** than having people monetizing IP
                addresses in such way while there are others on waiting
                lists that truly justify for those addresses.

Regards
 Fernando

On
                29/05/2019 18:02, Mike Burns wrote:

Hi Robert,

 

The problem of leasing space
                    before the 12 month waiting period, so as *only*
                    to avoid that period, is small in my experience.

After a year, any such lessor
                    could sell if they wanted to, and they have the same
                    sell/lease incentives as any other ARIN holder.

Do you have evidence that people
                    are monetizing waiting-list addresses prior to the
                    12 month period by leasing them?

 

What you say below, however, is
                    completely correct.

I have tried to direct the
                    community towards the glaring absence of a lease
                    policy at any registry.

I believe it’s time for such a
                    policy, given the market circumstances we find
                    ourselves in.

Such a policy would allow for
                    open leasing, with certain recording requirements
                    for abuse contacts of the lessee, etc.

I think such a policy would be
                    in-scope and would yield, in a negative way, to the
                    desired results of the anti-BGP hacking policy.

 

Regards,

Mike

 

 

 

 

From: Robert Clarke mailto:robert at rjfc.net 
 Sent: Wednesday, May 29, 2019 4:24 PM
 To: Mike Burns mailto:mike at iptrading.com
 Cc: Fernando Frediani mailto:fhfrediani at gmail.com;
                        arin-ppml mailto:arin-ppml at arin.net
 Subject: Re: [arin-ppml] Waiting List
                        IPv4 blocks transferred after issuance


 

Hello Mike,

 


Why are you using John's
                      "waiting list IPv4 blocks transferred" numbers as
                      a baseline for the /19 numbers? This is completely
                      arbitrary and doesn't give any scale as to the
                      problem with fraud. See my earlier reply to John's
                      email in the other thread:


 


"Thanks
                        for sharing. I'd like to note that it can be
                        dangerous to use the blocks transferred via
                        8.2/8.3/9.4 as a metric for abuse. A fraudster
                        that gets past ARIN's scrutiny and obtains IPs
                        with fraudulent information is probably smart
                        enough to lease their IPs as opposed to selling
                        the space outright. There is a huge market for
                        leased space, and those deals happen behind
                        closed doors with no oversight from ARIN. IP
                        addresses go for $0.2-0.5/mo depending on
                        term/IP reputation/size which could lead to
                        $XX,XXX in illicit revenue with no risk of
                        ARIN's scrutiny which would normally occur
                        during the transfer process."


 


Thanks,


 

Robert
                            Clarke







On May 29, 2019, at 8:13
                          AM, Mike Burns <mailto:mike at iptrading.com>
                          wrote:


 

Hi
                            Fernando,


 


Thanks
                            for the discussion.


Many
                            feel as you do, that unused addresses should
                            be returned to ARIN for subsequent
                            distribution to those in need.


Unfortunately,
                            that policy was not successful in bringing
                            unused addresses into actual use by those in
                            need.


The
                            community decided to harness the profit
                            motive to incentive this process, and by all
                            accounts it is working.


 


Unfortunately
                            the profit motive also incentivizes
                            fraudulent plundering of the waiting list
                            pool.


 


So
                            I am happy to discuss the correct balancing
                            of things to prevent fraud but allow the
                            market to continue to drive us towards the
                            desirable ends of accurate registration and
                            efficient use.


 


Since
                            the /19 is the threshold number of sorts for
                            flipping, I could accept a /20 as the
                            maximum size.


I
                            think a 2 year wait is reasonable, but I
                            don’t see the additional benefit as worth
                            the distinction of ARIN space into more
                            classes.


And
                            making it more complicated with multiple
                            waiting periods is even less desirable, IMO.


 


Regards,
 Mike

 


 


 


 


From: ARIN-PPML
                                <mailto:arin-ppml-bounces at arin.net> On
                                  Behalf Of Fernando
                                Frediani
 Sent: Wednesday,
                                May 29, 2019 10:50 AM
 To: mailto:arin-ppml at arin.net
 Subject: Re:
                                [arin-ppml] Waiting List IPv4 blocks
                                transferred after issuance



 


On 29/05/2019
                              11:31, Mike Burns wrote:



Orgs will wait
                              out any period, sitting with unused
                              addresses until they reach the resale
                              date. Not efficient use.



If it's not a
                              legacy resource and if ARIN gets to know
                              about it, it may just recover this
                              addresses even if the resource holder is
                              paying it correctly. That's how it should
                              work.







People will lease
                              unused addresses to others and Whois
                              accuracy will suffer if they can’t resell
                              them. Not accurate registration.



If people lease
                              they prove they have no use for the
                              addresses and again ARIN should recover
                              them at any time. If whois is inaccurate,
                              well it is their fault and not policies
                              fault. They must bind to the current rules
                              not the other way round.







I think we should
                              give everybody currently on the list up to
                              a /19 and then restrict new entries to a
                              /22.



Fair
                            to discuss this scenario, although I still
                            think /19 is too much. Agree on /22 for new
                            entries.
 
 


I think a 5 year
                              resale wait is too long, based on the
                              paltry resales of prior waiting-list
                              subnets smaller than /19.



It
                            may be long, but 2 years seems a little
                            short and 'acceptable' for a fraudster.
                            Perhaps something in between.
 
 
 


I support a /22
                              restriction for new entrants, a /19 max
                              for current list members, and maintenance
                              of the 12 month wait for simplicity’s
                              sake.



What
                            about discuss /22 for new entrants, /20 for
                            current list members and 36, 42 or 48 months
                            for transfers ? Seems more reasonable in my
                            view and cover most aspects of this
                            discussion.
 
 







 


Regards,
 Mike

 


 


 


 


From: ARIN-PPML mailto:arin-ppml-bounces at arin.net On
                                    Behalf Of Fernando
                                  Frediani
 Sent: Wednesday,
                                  May 29, 2019 8:51 AM
 To: mailto:arin-ppml at arin.net
 Subject: Re:
                                  [arin-ppml] Waiting List IPv4 blocks
                                  transferred after issuance



 


+1


On 28/05/2019
                                23:52, Owen DeLong wrote:



Mike, 


 



Yes and no. I
                                  believe that the lack of legacy
                                  holders for any blocks issued under
                                  4.1.8 reduces the need for the market.



 



Defunct
                                  organizations can easily be reclaimed
                                  in this space because they stop paying
                                  their ARIN bill.



 



Eliminating
                                  the resale value of these addresses
                                  won’t really encourage squatting on
                                  them and limiting the size of
                                  organization and size of block that
                                  can benefit from 4.1.8 further helps
                                  to reduce the potential for hoarding.



 



I realize
                                  that as a broker, any address that
                                  can’t be monetized is a lost
                                  opportunity for your organization, but
                                  I think there’s plenty of addresses
                                  out there that haven’t been processed
                                  through 4.1.8, so I don’t think
                                  limiting the resale potential of such
                                  blocks to reduce fraud is a bad idea.



 



Owen



 








On May
                                        28, 2019, at 12:46 , Mike Burns
                                        <mailto:mike at iptrading.com>
                                        wrote:



 


The
                                          percentages of blocks
                                          transferred takes a
                                          significant leap at the /19
                                          size.



Below
                                          that, the percentages are all
                                          below 7%.



At
                                          /19 and above, the percentages
                                          are all above 21%.



Seems
                                          like a natural demarcation for
                                          maximum block size, but prices
                                          do continue to rise.



While
                                          we want to fight fraud, we
                                          should still remember the
                                          underlying reasons for the
                                          Ipv4 transfer market apply to
                                          these addresses as well.



That
                                          is, the market provides
                                          incentives for efficient use
                                          and accurate registration.



 



Regards,
 Mike


 



 



 



 



From: ARIN-PPML
                                              <mailto:arin-ppml-bounces at arin.net> On
                                                Behalf Of John
                                              Curran
 Sent: Tuesday,
                                              May 28, 2019 1:53 PM
 To: ARIN-PPML
                                              List <mailto:arin-ppml at arin.net>
 Subject: [arin-ppml]
                                              Waiting List IPv4 blocks
                                              transferred after issuance
 Importance: High




 



Folks
                                            - 




 




It
                                            occurred to me that it might
                                            be useful to have a quick
                                            summary of waiting list
                                            blocks issued and
                                            subsequently transferred. 




 




Attached
                                            is the distribution (count
                                            per prefix size) of all
                                            blocks that have been issued
                                            via ARIN's waiting list
                                            policy and subsequently
                                            transferred via NRPM
                                            8.2/8.3/8.4 policy.




 




FYI,




/John




 




John
                                              Curran




President
                                              and CEO




American
                                              Registry for Internet
                                              Numbers





 




 




 




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