[arin-ppml] Draft Policy ARIN-2019-18: LIR/ISP Re-Assignment to Non-Connected Networks

[Owen DeLong]

Neither in favor nor opposed to the intent of the proposal at this time. I can see both sides…

Allowing this would potentially increase whois accuracy since currently leases are happening without recording or registration.
Allowing this would encourage/normalize this behavior which seems, more often than not, to  have detrimental effects (nefarious cycling).

> On Sep 27, 2019, at 14:20 , Mike Burns <mike at iptrading.com> wrote:
> 
> Hi Bill,
>  
> Off the top of my head…
> There are many temporary needs that can be best met by leasing. Company transitions, renumbering, time-limited projects.

You left out “Maximizing the extent to which one can monetize their excess address space”. (admittedly, this is for the lessor, not the lessee).

> Geolocation needs, some companies need a presence in multiple locations and leasing is easier than dealing with multiple RIRs.

Addresses can be used anywhere, regardless of where they were obtained. This myth continues to circulate, but remains a myth.

> Many lessees need to rotate their addresses for nefarious and less-nefarious reasons.

I’d love to know what these “less nefarious” reasons are. I’m well aware of the nefarious ones.

> Some can’t afford to purchase addresses upfront.

Addresses are selling for less than $20/address at the lower end (/24) of the market.
Leases are running about $5 to $10/address per year.

> There are leases of blocks smaller than /24, although these do involve virtual circuits.

These are permitted under current policy. Virtual or Real doesn’t matter. Connectivity is being provided by the lessor.

> There are business cases where leasing is better than purchasing, for example when there is a lot of uncertainty.
> Leasing is faster and easier than acquiring blocks from RIRs.

I find this _VERY_ hard to believe. I have routinely been able to turn around pre-approvals with RIRs in less than 48 hours.

> Span-regional needs for addresses.

Not sure what you mean here unless it is a rehash of “geolocation”.

> And of course those who need addresses but can’t meet ARIN’s (or APNIC, LACNIC, AFRINIC) justification requirements.

I regard the idea that leases would meet this need as an argument against, not in favor.

The justification requirements are the standards that the community as a whole has come to consensus as the legitimate need for addresses. If you cannot
meet the community standards, the only legitimate solution (IMHO) is to begin a discussion (proposal a policy change) and gain consensus among the
community for your desired change.
 
> I am not sure that leasing addresses involves more money than acquiring them from ARIN, unless it’s from the waiting list.
> In many cases it’s less upfront money.

Leasing is definitely cheaper per address for the first year or so. After that, it’s not so clear.
 
> There are enough need cases to support a growing lease market, the evidence of the need is contained in the presence of the market. Search the internet for IPv4 leasing to confirm this market exists and you can be sure that the need for this service also exists.  

I think need is too strong of a word here. I would replace it with “desire”.

Yes, there is ample indication that some individuals desire leasing and there is a growing (though unclear by how much) market for it.

What is less clear is whether that activity is beneficial to the community as a whole and whether or not it is one that should be normalized/encouraged.
 
> We all know that creating a virtual circuit for fig-leaf purposes is very simple if one wants to do leasing and still be policy compliant.

This is also true. As with any law, policy, or community standard, voluntary compliance by the vast majority is necessary for the system to function. Even the most
powerful regulators depend on voluntary compliance by the majority. The IRS, for example, would be utterly unable to effectively combat a decision by 100% of
US Taxpayers (and businesses) to stop collecting income tax. Obviously, that’s not going to happen, but right now, they enjoy a more than 90% voluntary compliance
rate. I bet if that rate dropped even below 75%, it would be very difficult for them to effectively address the problem.

There will always be outliers and those who choose not to cooperate with any system voluntarily for a variety of reasons and rationalizations.

> So we have a need and little in policy to prevent the need from being addressed. Why not lift our heads from the sand and create policy to make sure that registration is part of this market? Conservation, our other goal, is handled by the mechanism of price.

If you can show a way in which the policy would reduce nefarious cycling or provide other such benefit (and price does NOT suffice here), I’d be more inclined to support the policy. However, as it currently stands, I remain on the fence.

Owen


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