[arin-ppml] Draft Policy ARIN-2019-18: LIR/ISP Re-Assignment to Non-Connected Networks
Mike Burns
mike at iptrading.com
Tue Oct 1 12:14:50 EDT 2019
Hi Fernando,
I hold so much in the RIPE example because it is the best argument against the needs test.
I have heard over and over what problems would arise if we dropped the needs test here, as it was dropped in RIPE *and* in APNIC.
(APNIC rescinded their decision due to pressure from ARIN, who would not inter-regionally transfer address to ARIN unless the needs test was restored.)
But RIPE did not rescind, and where are the problems that were predicted over and over?
You ask me to prove the lack of problems! You are the ones declaring such problem will ensue, but where are they at RIPE?
You want me to show you how successful the transfer market in RIPE has been? They have more transfers than any other registry!
What is there about the RIPE RIR that makes it so different from ARIN in this respect? They both keep a database of IPv4 holders as their primary role, and operate in a capitalist environment that responds to market forces.
I have never said nor implied that regions are exactly alike, that the RIR system is wrong, or that all policies must be the same, so don't put those words in my mouth.
You say without evidence that leasing will increase pricing. How many leases have you participated in? Can you elucidate how exactly leases will do this, and provide any evidence? You say only IP transfer companies benefit from higher prices. Are you forgetting the benefit to the Lessor? Do you understand basic economics? You might be interested to learn that lease rates have come down dramatically over the last year. How does that fit in with your view?
You ignore the extant lease market when you say that this is not in the interests of the community. Are they not community members?
My arguments are buttressed by the factual experience of dropping the needs test in our sister RIR, the evidence presented by Geoff Huston's article revealing the market's victory over prior "return no longer needed addresses policy", and the evidence of a market for Lessee and Lessors that reveals itself via simple google search.
Regards,
Mike
-----Original Message-----
From: ARIN-PPML <arin-ppml-bounces at arin.net> On Behalf Of Fernando Frediani
Sent: Tuesday, October 01, 2019 11:50 AM
To: arin-ppml at arin.net
Subject: Re: [arin-ppml] Draft Policy ARIN-2019-18: LIR/ISP Re-Assignment to Non-Connected Networks
Why do you hold so much in this RIPE example even though it was already mentioned differences that apply to different regions and mainly that ARIN is not obliged to copy or follow everything that exists in another region.
It is fine and legit to mention it exists over there, but you didn't show the real lack of problems due to the policy being like that over there, you just assumed it for the benefit of your argumentation with no practical examples or anything to back you assumption. If you say Albert is speculating but it seems you are too in this case.
He already mentioned very well the other several issues of allowing leases to exist as for example increase on pricing for all (which is only beneficial to IP transfer companies).
Furthermore as mentioned there are other concerns with regards ARIN giving up some of its roles and passing it to the sole discretion of those who are profiting from the transaction removing any impartiality in analyzing the real justifications for those addresses.
Therefore I have the same view that leasing is not in the interest of the overall community, but only to a few and specific organizations, and there are already proper procedures for properly transfer addresses from one organization to another.
Fernando Frediani
On 01/10/2019 12:27, Mike Burns wrote:
> Hi Albert,
>
> Your first issue is a requirement for operational use as being something descended from heaven. It was simply the best method to fulfil our stewardship duties in a free pool era. That duty was conservation, i.e. efficient use. So naturally, since these were being given away for free, some limit was needed. The limit was operational use. Now the limit is the cost of addresses, and it is a more effective limit than the policy limit you cling to. I have demonstrated this by linking to Geoff Huston's article showing how the market drew addresses off the sidelines. I have pointed out that RIPE has no requirement for operational needs and is functioning quite well. You keep ignoring the RIPE experience, pointedly I think.
>
> Your second issue is the lack of direct relationship between the block user and ARIN. Sorry, that fails because this is the normal hierarchy for ISPs and LIRS at every registry. As an ISP I can assign a block to a connected customer and that customer has no RSA with ARIN. What's the problem? You have revealed a distinction without a difference. The blocks are covered by RSA regardless.
>
> You claim that anybody who doesn't use 50% of their block immediately is a hoarder. There are a lot of hoarders in ARIN by that definition. Sorry, but I took the time to define a speculator and your definition does not match, it's far too broad. As far as the mechanics of it go, we are talking about the same needs tests for leases as for connected customers, so a lessor or an owner has the same incentives towards immediate and efficient use.
>
> And once more, Albert, are you saying RIPE is subject to the many problems you have speculated about, due to the complete absence of a requirement to demonstrate use on operational network? You have gone on and on about how wrong this is, but you can't point to the existence of a resulting problem from dropping the needs test?
>
> Finally, Albert, please do not start the ad hominem attacks on my positions as resulting from selfishness. My arguments stand on their own and should be properly evaluated as if they were anonymously offered. Surely you understand this?
>
> Regards,
> Mike
>
>
>
>
>
>
>
>
> The primary problem I have with the Draft Policy is that it eliminates the "operational use" policy. Leasing is just a side issue. Right now, obtaining addresses in the marketplace for the purposes of leasing them to others is not permitted because of that "operational use" policy.
>
> I also have an issue with another party being inserted into the transaction. The operational use requirement is intended for the party receiving the directed transfer and NOT another unrelated person who is NOT under contract with ARIN. What you propose is that another party that is NOT using the numbers sign the RSA and the lessee never does. In the case of abuse, the fact that the party doing the abuse is not subject to a signed RSA complicates the issues with ARIN enforcement action.
>
> In my opinion, speculators ARE hoarders if they are not putting 50% of the numbers to use at once as the policies generally require. If leasing is permitted, someone willing to pay more for numbers, but is required to wait a while to get someone to use them is tilting the market price higher as opposed to those who want to use the numbers at once being the market price setters.
>
> While I can see your point of view, as you represent those with numbers to "sell", getting more money because of this change of policy. Leasing is not in the interest of the overall community who has a current policy in place to restrict buyers to those that intend to put the IPv4 resources to use at once.
>
> In effect, you are proposing changing the policy, so those with numbers can get more money for them by adding speculators to the market. This is wrong.
>
> Albert Erdmann
> Network Administrator
> Paradise On Line Inc.
>
>
> On Tue, 1 Oct 2019, Mike Burns wrote:
>
>> Albert wrote:
>> It was always understood you were supposed to turn back in unused numbers.
>> The market is one way to do that, by turning your unused addresses over to someone who can use them. Leasing does not meet that standard in my mind.
>>
>> Numbers are for operational networks, not for speculators.
>>
>>
>> Hi Albert and thanks for your thoughts. My I ask why the transfer market turns unused addresses over to someone who can use them, but the leasing market does not? Do you place such a premium on deal format? What if it's a lease-to-own arrangement? What if it's a 10 year lease? What is different, except for financial issues, between transfers and leases, in the context of bringing unused addresses into use on an operational network?
>>
>> Why do you think speculators would be antithetical to using numbers
>> on operational networks? I genuinely do not understand, unless you
>> are referring to that eternal bogeyman, the hoarder. You shouldn't
>> oppose policy in this regard until and unless somebody, somewhere has
>> evidence of IPv4 hoarding by speculators, ever. I define speculator
>> as somebody who invests money into IPv4 addresses seeking to profit
>> from that investment. Can somebody even offer a description of how
>> hoarding would work *in this market* to a speculator's benefit?
>>
>> Regards,
>> Mike
>>
>>
>>
>>
>>
>>
>>
>>
>> On Mon, 30 Sep 2019, Mike Burns wrote:
>>
>>> Hi Fernando,
>>>
>>> Let me address the two items highlighted in your reply below.
>>>
>>> First is the reduction of ARIN to nothing more than a registration operation. What is wrong with that? RFC2050 said the primary purpose of an RIR is registration. We need to keep the numbers unique or everything fails. ARIN should indeed reduce itself to registering transfers and doing what it can to maintain accurate registration per our primary stewardship role. All else is subservient, including conservation. But we have addressed conservation. RIPE has been reduced to a registration operation, to use your term. What is so wrong with RIPE?
>>>
>>> Second is the point that one of the business cases for leasing is for spamming. This is something to consider, but I would like for you to put yourself into the position of a Lessor. The Lessor knows his blocks will lose value if they are blacklisted, so they take steps to mitigate this. For example, one notable lessor charges a $20 fee for every abuse complaint on a leased block. The Lessee pays the $20 fee and most of it is paid to the Lessor as compensation. This disincentivizes spamming on leased blocks. A Lessor who gets tricked into leasing to a spammer will find his block devalued significantly. He can get it delisted one, maybe twice if he can spin a good story. After that, no more for that owner. So the owners have penalties and usage terms built into the lease contract, or they get prepayment for many months in advance, or they lease large blocks which are not appealing to spammers. The point is this is a valid argument against changing policy to support leasin!
> g!
>> , but the problems are long-known and the market has applied corrections. On the other hand, spammers like to hijack too, and having the ability to define a hijack as being non-compliant with a lease policy will enable ARIN to pressure the address holder for a policy violation if pressure from that side helps.
>>> Regards,
>>> Mike
>>>
>>>
>>>
>>> -----Original Message-----
>>> From: ARIN-PPML <arin-ppml-bounces at arin.net> On Behalf Of Fernando
>>> Frediani
>>> Sent: Monday, September 30, 2019 4:36 PM
>>> To: arin-ppml at arin.net
>>> Subject: Re: [arin-ppml] Draft Policy ARIN-2019-18: LIR/ISP
>>> Re-Assignment to Non-Connected Networks
>>>
>>> On 30/09/2019 15:36, hostmaster at uneedus.com wrote:
>>>
>>>> Currently, the ability to obtain IPv4 resources is constrained by
>>>> the requirement to prove to ARIN that you need the addresses for
>>>> your operational use in a network, which will be claimed to be no
>>>> unneeded once the "operational use" requirement is gone, leaving
>>>> ARIN to be nothing more than a registration operation.
>>> Excellent point raised. Couldn't agree more !
>>>> While this is claimed to reduce one problem with leasing IPv4
>>>> addresses (lack of registration and associated abuse contacts) it
>>>> causes other issues. Often network abusers lease addresses for
>>>> abuse, dumping them and leasing others when they get blacklisted.
>>> And this too. Actually this is a well known issue.
>>>>
>>>>
>>>>
>>>> On Mon, 30 Sep 2019, Mike Burns wrote:
>>>>
>>>>> Hi Fernando,
>>>>>
>>>>>
>>>>>
>>>>> You said “RIR is and has always been the one who drives the
>>>>> resources to be efficientlly assigned by analysing justifications
>>>>> not private transfer companies. If an organization is not using
>>>>> resouces efficiently it either may change its resource assignment
>>>>> strategy otherwise it doesn't justify for those addresses anymore
>>>>> and should return them back to the RIR.”
>>>>>
>>>>>
>>>>>
>>>>> There is no policy in ARIN to return un-needed space. IPv4
>>>>> resource holders own something of value, which is what economists
>>>>> call an “alienable asset”. It is possible for such resource
>>>>> holders to return such space to ARIN, but you don’t have to be an
>>>>> economist to understand why they don’t and haven’t for the most part.
>>>>>
>>>>>
>>>>>
>>>>> Your method has been tried, and it was really a good try. The
>>>>> effort was decades-long, yet recognized a failure by the clear
>>>>> evidence of the routing table.
>>>>> So much space allocated, yet not routed. Not enough to be
>>>>> explained away by internal use; this is unconvincing. No, the
>>>>> space sat on the sidelines, it was not returned to ARIN. Until the
>>>>> market provided the missing incentive to action, and that action
>>>>> is also quite visible in the routing table and transfer logs. The
>>>>> profit incentive, the draw of lucre, the absurd effect of price
>>>>> have led to an increase in the efficient use of the IPv4 address universe.
>>>>> Geoff Huston did a good analysis of the source of transferred
>>>>> addresses and showed the market brought many never-routed addresses into efficient use.
>>>>> https://blog.apnic.net/2017/01/09/studying-ipv4-transfer-market-re
>>>>> p
>>>>> o
>>>>> r
>>>>> ted-transfers/
>>>>>
>>>>>
>>>>>
>>>>>
>>>>> You also said “It is pretty reasonable to think that in no RIRs
>>>>> you are able justify more IP space by saying ‘I need these
>>>>> addresses in order to lease them to someone else’. If that is
>>>>> never a possible justification that can be used therefore leases
>>>>> don't make any sense.”
>>>>>
>>>>>
>>>>>
>>>>> Anybody can indeed purchase RIPE addresses via transfer solely for
>>>>> the purpose of leasing them out. That is because RIPE does not
>>>>> have a needs justification for transfers (nor policy forbidding leasing).
>>>>> And that is because, in my opinion, the RIPE community realized
>>>>> that their intrinsic role of conservation would now be undertaken
>>>>> by market forces. These can be relied upon to bring un- and
>>>>> under-utilized addresses to their “highest and best use”, again as
>>>>> economists say.
>>>>>
>>>>>
>>>>>
>>>>> But you do bring up the relevant question in the context of this
>>>>> ARIN policy proposal, which is whether leasing to a “connected”
>>>>> customer is all that different from leasing to a “non-connected”
>>>>> customer when it comes to justifications. In the first case, the
>>>>> ISP normally registers the assignment of this block to his
>>>>> customer in Whois and can use it as justification. In the second
>>>>> there is no such registration requirement and the lease can’t be
>>>>> used as a justification. To me this is a problem, and I think
>>>>> there is a solution.
>>>>>
>>>>>
>>>>>
>>>>> Conservation and Registration are our lodestars. In this case
>>>>> pricing will handle conservation, but what about registration?
>>>>> What about when pricing drives Conservation at the expense of
>>>>> Registration? I am on record as supporting the RIPE model, which
>>>>> allows for lessors to purchase lease inventory, with registered
>>>>> transfers, and also allows them to record leases as assignments
>>>>> that include access to important contact information.
>>>>>
>>>>>
>>>>>
>>>>> The simple and straightforward answer here is to end the
>>>>> needs-test for transfers. RIPE has shown us the way, taken the
>>>>> “risk” and now we can look at years’
>>>>> and thousands of transfers’ worth of data. Anybody see any
>>>>> problems resulting from the dropping of the needs test in RIPE?
>>>>>
>>>>>
>>>>>
>>>>> Absent dropping the needs test for transfers, the logical step in
>>>>> the context of this policy allowing leasing, is to allow certain
>>>>> leases to be used for justifications while at the same time
>>>>> providing policy requiring registration (SWIP) and documentation (Letter Of Agency).
>>>>> It’s my opinion that this carrot and stick approach will induce
>>>>> Lessors to properly register their leases while also providing a
>>>>> clear demarcation of leasing versus hijacking that will empower
>>>>> our community and potentially law enforcement. You want to
>>>>> purchase addresses because you think you can make money in their rental?
>>>>> Fine, show us that you are efficiently using your prior
>>>>> allocations and properly registering assignments.
>>>>>
>>>>>
>>>>>
>>>>> There should be no difference in the way we treat those who assign
>>>>> to “non-connected” or “connected” networks. ARIN calls a VPN a
>>>>> connection. Times have moved on, and any two networks can be
>>>>> easily “connected” for the purposes of policy-compliance only. So
>>>>> why trade the lack of insight into IPv4 block contact information
>>>>> for the maintenance of this fig-leaf?
>>>>>
>>>>>
>>>>>
>>>>> Regards,
>>>>> Mike Burns
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>> From: ARIN-PPML <arin-ppml-bounces at arin.net> On Behalf Of Fernando
>>>>> Frediani
>>>>> Sent: Saturday, September 28, 2019 7:20 PM
>>>>> To: arin-ppml <arin-ppml at arin.net>
>>>>> Subject: Re: [arin-ppml] Draft Policy ARIN-2019-18: LIR/ISP
>>>>> Re-Assignment to Non-Connected Networks
>>>>>
>>>>>
>>>>>
>>>>> I strongly oppose this proposal.
>>>>>
>>>>>
>>>>>
>>>>> Leasing of IP addresses in such way should never be permmited and
>>>>> is a distortion of the way IP addresses must be used by organizations.
>>>>>
>>>>>
>>>>>
>>>>> The main reason is simple: if an organization is "leasing" IP
>>>>> address it is a clear sign that the organization does not have
>>>>> usage for that IP space and as it doesn't justify anymore it
>>>>> should therefore return them back to the RIR in order to be
>>>>> re-assigned to those who really have a need for it, via waiting
>>>>> list or other methods covered by the policies.
>>>>>
>>>>>
>>>>>
>>>>> It is pretty reasonable to think that in no RIRs you are able
>>>>> justify more IP space by saying "I need these addresses in order
>>>>> to lease them to someone else".
>>>>>
>>>>> If that is never a possible justification that can be used
>>>>> therefore leases don't make any sense.
>>>>>
>>>>>
>>>>>
>>>>> If an organization needs further IP space for a temporary project
>>>>> it may just get from the LIR or ISP but if that is not possible
>>>>> and the organization is an Autonomous System it can just go to
>>>>> market and get it transfered permanentlly.
>>>>>
>>>>> Either from the RIR or transfered via market addresses must be
>>>>> justified and leases are nothing but unused address by who is
>>>>> willing to lease.
>>>>>
>>>>>
>>>>>
>>>>> The justification given to allow organizations to facilitate
>>>>> transition to IPv6 does not apply at all as organizations can go
>>>>> directlly to the RIR for that (4.10). Why would it get via a lease
>>>>> bypassing the RIR ?
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>> By allowing leases it is just skipping the RIR's function to
>>>>> fairly re-distribute them and passing it private companies with
>>>>> financial interests.
>>>>>
>>>>>
>>>>>
>>>>> I think 8.5.2 is already properly written and doesn't require any
>>>>> change.
>>>>>
>>>>> Also Non-Connected Networks is not properly defined.
>>>>>
>>>>>
>>>>>
>>>>> Regarding the point about Conservation to be done through market
>>>>> pricing I will skip to comment such absurd thing.
>>>>>
>>>>>
>>>>>
>>>>> Regards
>>>>>
>>>>> Fernando
>>>>>
>>>>>
>>>>>
>>>>> On Tue, 24 Sep 2019, 17:41 ARIN, <info at arin.net> wrote:
>>>>>
>>>>> On 19 September 2019, the ARIN Advisory Council (AC) accepted
>>>>> "ARIN-prop-277: LIR/ISP Re-Assignment to Non-Connected
>>>>> Networks" as a
>>>>> Draft Policy.
>>>>>
>>>>> Draft Policy ARIN-2019-18 is below and can be found at:
>>>>>
>>>>> https://www.arin.net/participate/policy/drafts/2019_18/
>>>>>
>>>>> You are encouraged to discuss all Draft Policies on PPML.
>>>>> The AC will
>>>>> evaluate the discussion in order to assess the conformance
>>>>> of this draft
>>>>> policy with ARIN's Principles of Internet number resource
>>>>> policy as
>>>>> stated in the Policy Development Process (PDP).
>>>>> Specifically, these
>>>>> principles are:
>>>>>
>>>>> * Enabling Fair and Impartial Number Resource Administration
>>>>> * Technically Sound
>>>>> * Supported by the Community
>>>>>
>>>>> The PDP can be found at:
>>>>> https://www.arin.net/participate/policy/pdp/
>>>>>
>>>>> Draft Policies and Proposals under discussion can be found at:
>>>>> https://www.arin.net/participate/policy/drafts/
>>>>>
>>>>> Regards,
>>>>>
>>>>> Sean Hopkins
>>>>> Policy Analyst
>>>>> American Registry for Internet Numbers (ARIN)
>>>>>
>>>>>
>>>>>
>>>>> Draft Policy ARIN-2019-18: LIR/ISP Re-Assignment to
>>>>> Non-Connected Networks
>>>>>
>>>>> Problem Statement:
>>>>>
>>>>> Businesses have a need to lease IPv4 space for limited
>>>>> periods of time,
>>>>> as evidenced by a robust (technically prohibited)
>>>>> subleasing market. The
>>>>> lack of legitimization of the subleasing market hinders
>>>>> innovation,
>>>>> research, reporting, and the development of rules/industry best
>>>>> practices to ensure identifiability and contactability.
>>>>>
>>>>> Policy statement:
>>>>>
>>>>> ORIGINAL POLICY LANGUAGE
>>>>>
>>>>> 2.4. Local Internet Registry (LIR)
>>>>>
>>>>> A Local Internet Registry (LIR) is an IR that primarily
>>>>> assigns address
>>>>> space to the users of the network services that it provides.
>>>>> LIRs are
>>>>> generally Internet Service Providers (ISPs), whose
>>>>> customers are
>>>>> primarily end users and possibly other ISPs.
>>>>>
>>>>> PROPOSED POLICY LANGUAGE
>>>>>
>>>>> A Local Internet Registry (LIR) is an IR that primarily
>>>>> assigns address
>>>>> space to the users of the network services that it provides.
>>>>> LIRs are
>>>>> generally Internet Service Providers (ISPs), whose
>>>>> customers are
>>>>> primarily end users and possibly other ISPs.
>>>>>
>>>>> LIRs may also assign address space to other organizations
>>>>> or customers
>>>>> that request it for use in an operational network.
>>>>>
>>>>> ORIGINAL POLICY LANGUAGE
>>>>>
>>>>> 8.5.2 Operational Use
>>>>>
>>>>> ARIN allocates or assigns number resources to organizations
>>>>> via transfer
>>>>> solely for the purpose of use on an operational network.
>>>>>
>>>>> PROPOSED POLICY LANGUAGE
>>>>>
>>>>> Option 1 : Remove 8.5.2 entirely
>>>>>
>>>>> Option 2 : Edit as follows
>>>>>
>>>>> 8.5.2 Operational Use
>>>>>
>>>>> ARIN allocates or assigns number resources to organizations
>>>>> via transfer
>>>>> solely primarily for the purpose of use on an operational
>>>>> network, but
>>>>> may allocate or assign number resources to organizations
>>>>> for other
>>>>> purposes, including re-assignment to non-connected networks .
>>>>>
>>>>> Comments:
>>>>>
>>>>> Timetable for implementation: Immediate
>>>>>
>>>>> Anything Else:
>>>>>
>>>>> The legitimization of a subleasing market for IPv4 has
>>>>> numerous business
>>>>> and community benefits, including (but not limited to):
>>>>>
>>>>> - Allowing organizations to efficiently utilize IPv4 space
>>>>> without
>>>>> transferring space permanently;
>>>>> - Allowing organizations to obtain IPv4 space for a limited
>>>>> time in
>>>>> order to facilitate transition to IPv6;
>>>>> - Allowing organizations to develop enforceable acceptable
>>>>> use policies
>>>>> in a previously lawless illegitimate space;
>>>>> - Allowing the community to develop reporting and recording
>>>>> standards
>>>>> and/or best practices to the benefit of preserving the
>>>>> integrity of IPv4
>>>>> address space.
>>>>> - We would like to engage further with the ARIN community
>>>>> to discuss the
>>>>> current state of the unauthorized subleasing market, and
>>>>> how this
>>>>> proposed policy change would both update ARIN policies to
>>>>> reflect the
>>>>> reality of the subleasing market, and positively address
>>>>> business and
>>>>> community concerns.
>>>>>
>>>>> _______________________________________________
>>>>> ARIN-PPML
>>>>> You are receiving this message because you are subscribed to
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>>>>> Unsubscribe or manage your mailing list subscription at:
>>>>> https://lists.arin.net/mailman/listinfo/arin-ppml
>>>>> Please contact info at arin.net if you experience any issues.
>>>>>
>>>>>
>>>>>
>>> _______________________________________________
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>>
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