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

Mike Burns mike at iptrading.com
Wed Oct 2 10:10:34 EDT 2019


Hi Albert,

Good questions. 
These addresses are not transferred back to ARIN, any inter-regional transfer into ARIN or out of ARIN requires a needs test for the recipient to demonstrate to its RIR that it has a need.

Addresses in RIPE are not an ARIN issue, but where an address is registered has very little significance. Address can, with very few exceptions, be used anywhere in the world regardless of where they are registered. So the leasing market spans RIRs and regions, and the market is separate from the geographical limits of the RIRs due to the lack of limits on the use of IP addresses geographically.

So really leasing is an issue for the communities of all RIRs, because no RIR is the routing police.

The RIR shopping that is already occurring happens for two reasons primarily. Fee-avoidance and policy-avoidance. You want more members? Lower your fees and policy restrictions. You want less members? Raise your fees and impose harsh policies.
It's just the nature of things.

Regards,
Mike




-----Original Message-----
From: hostmaster at uneedus.com <hostmaster at uneedus.com> 
Sent: Tuesday, October 01, 2019 8:59 PM
To: Mike Burns <mike at iptrading.com>
Cc: 'ARIN-PPML List' <arin-ppml at arin.net>
Subject: RE: [arin-ppml] Draft Policy ARIN-2019-18: LIR/ISP Re-Assignment to Non-Connected Networks

When you talk about obtaining addresses for lease from RIPE, are these addresses then transfered back into ARIN, or are they left with RIPE?

If they are left with RIPE, those addresses are not an ARIN issue.

On the other hand, if they transferred to ARIN, without the required needs review, I think we have a different problem of RIR shopping.

Are these addresses purchased in RIPE being transferred to ARIN?

Albert Erdmann
Network Administrator
Paradise On Line Inc.


On Tue, 1 Oct 2019, Mike Burns wrote:

> Hi Albert,
>
> I do understand networking well, including NAT and RFC1918 and hope I have been clear enough to move forward.
>
> You have an interesting question about how Lessors even get addresses in the first place. Most underlying Lessors are just IPv4 block holders who have acquired the block under policy in the past. Now charged with monetizing unused space, the holder is faced with the decision to hold, sell, or maybe hold and lease. More and more are choosing this third option. So considering that these Lessors have a finite amount of space to lease, they will never develop process and policies that drive efficient address delivery.
>
> Into the breach come lease brokers who do develop these processes and policies, and offer their service to Lessors who chose that third option above.  The lease brokers might have their own holdings to lease out, these may have been acquired in the past under policy, acquired via mergers and acquisitions, or acquired via RIPE transfer. But in order to grow and meet the developing needs of the lease market, the lease broker needs more inventory and so he contracts with address holders who trust the lease broker to weed out spammers, generate bills, issue and revoke LOAs, and collect payments.  The broker develops skills through experience that individual Lessors lack. Mostly this is pre-identifying spammers and protecting the block reputation, which is something both the broker and Lessor want to protect.
>
> You are correct in perceiving the risk of any Lessor who purchased lease inventory and then got stuck with it if prices fall. This is a basic risk assumed by any speculator, which is why many speculators lose money. This risk is particularly important in a market like this, where one single externality (IPv6 adoption) would crush the market.  This risk limits hoarding for reasons clear to you from your question.
>
> You asked some questions to flesh out those who might be looking to lease, and it's not only short-termers. For example we are getting offers to lease for 10 years from some overseas customers. These with penalties, prepayments, and large organizations participating.  It seems like there is frequently concern for new entrants expressed here, and actually one reason to lease is that it is the cheapest way to start. Cheaper than becoming an ARIN member!
>
> The past was indeed a wild-west arena as far as leasing goes. I will tell you why I think this has changed. Primarily there has been a re-alignment of the pricing ratio between leasing and purchasing. Past lease rates may have been as high as $8 per year per address, and in a time where you could purchase for $15, who could make the business case to lease? Pretty few organizations except spammers. So the spammers would take out leases and the lessors would swat them like that arcade game Whack-a-Mole.  Then lease rates dropped close to $3 per year and it takes $20 to buy them. Now it makes much more sense, especially in a market with the IPv6 Sword of Damocles hanging over it.
>
> Lessors are willing to take less money because they think the IPv4 lifetime will exceed previous estimates, IMO.
> With the increased lease inventory and the more numerous business cases to support leasing versus buying, there is more leasing going on.
>
> With leasing or purchasing, the same incentives exist to put addresses to productive use, so arguments about leasing causing addresses to remain on the sideline don't make financial sense to me.
>
> You think this policy would somehow change lease rates, because lessors would not immediately put the addresses to use, and that this is basic economics. Do you think this would be reflected in different lease rates in ARIN and in RIPE?  Once again, we have the experiment to answer your assertion qualitatively. Do you want to research the answer?  Let me say that just like nobody is going to buy more addresses than they think they will need to address their needs, nobody is going to purchase more blocks than they think they will be able to lease. That is basic economics.  That, and the risk you perceived about being left holding the bag when IPv6 transitions.
>
> What this community needs to understand is that the leasing market exists today. It is not something that came out of policy and is not driven by policy. It is driven by business decisions. In ARIN, a port or VPN is the "USB cable" in the transaction. Elsewhere in the world, even that fig leaf is unnecessary.  It's not something you can prevent or forestall with policy, but it is something you can recognize and adapt to. I think the very basic and simple expedient of treating a block-holder's customers the same regardless of connection status, in the context of justifications, would be suitable accommodation to the community's needs as expressed by a growing grey-market for leasing.
>
> Regards,
> Mike
>
>
>
>
>
>
>
> -----Original Message-----
> From: hostmaster at uneedus.com <hostmaster at uneedus.com>
> Sent: Tuesday, October 01, 2019 1:31 PM
> To: Mike Burns <mike at iptrading.com>
> Subject: RE: [arin-ppml] Draft Policy ARIN-2019-18: LIR/ISP 
> Re-Assignment to Non-Connected Networks
>
> I think if you want to advance this, I do not think that you can really use the term "non connected network" because it has other meanings to those of us that actually set up networks.  Maybe a term like "IP leasing agency" would more clearly express what you are trying to do.  I mentioned NAT and RFC1918 because to network designers, those are the most common uses of non connected networks.  I would guess that the 192.168.0.0 network appears in millions of places, none of which are connected to one another as the largest example to those who run networks.
>
> Under current policy, how do you even get the addresses in the first place? Chapter 4 of the policy manual is loaded with requirements that a leasing company would be unable to meet unless it used its first customer data as part of the justification.
>
> While such a business might make it in the short term, eventually if a large IPv6 uptake occurs, you might be stuck with an asset with little or no value.  So there would have a balance between price and risk.  Also how many customers need addresses for short term use other than abusers?
> Those with longer term needs would be better off buying their addresses.
> You are also competing with normal ISP's who also might be willing to provide addresses along with connectivity in the short term.  I use a WISP and one of their larger customer segments is construction trailers, which by nature is short term.
>
> My major objection to leasing is that any numbers that come to market should be reserved for those wanting to put them to use at once, as the current policy supports instead of giving them to those that will wait for the right lease deal.  As for my suggestion that removing the operational use restriction will raise the price, it is basic economics.  Right now, the only "buyers" in ARIN region under the rules are those who have qualified for a given size block.  If leasing companies enter the market, their "buyers" will increase the total number of buyers versus the total number of sellers and this causes the price to rise.
>
> I understand what you want to do, but I do not think leasing IP addresses is in the interest of the community.
>
> Albert
>
>
>
> On Tue, 1 Oct 2019, Mike Burns wrote:
>
>> Hi Albert,
>>
>> Sorry if we have been talking at cross-purposes.
>> I had drafted an off-list message to you to ask you what NAT and RFC1918 had to do with this discussion, but forgot to send it.
>> At least for me, a non-connected network is one that has no real or virtual connection to the owner of the IP block.
>>
>> Leases are accomplished by these owners creating a Letter of Agency explicitly allowing an ASN different from the IP block owner to advertise the addresses. We call this LOA leasing.
>>
>> The second lease method delivers the leased addresses over a VPN, with the address owner doing the advertising and routing.
>>
>> In both connections, the Lessee is connected to the internet.
>>
>> The problem is that leased addresses are not counted by ARIN as being efficiently used for the purposes of justifying a transfer, whereas addresses leased (or otherwise provided) to a customer who has some connection to the IP block owner can be used to justify. So I can lease  you a /24 for $200 per month and provide you with an LOA so that you can advertise the block using your circuits and peers. I would not be able to use that as a justification to transfer new addresses to me to handle new lease opportunities. However, if I created a 64k vpn tunnel to your network, even if I did not deliver the leased block to  you over that connection, and you used an LOA, I would be able to demonstrate to ARIN that the /24 is being efficiently used and use it to justify future purchases. Future purchases for lease opportunities OR for internal use.  This is the problem. Entities that want to address the lease needs of the community are thwarted in this effort by the current interpr!
 e!
> tation of connected versus non-connected networks when it comes to acquiring new blocks for whatever reason.
>>
>> Here are two examples that illuminate why I think current policy is flawed:
>>
>> You want to buy a Windows license but there is a hardware requirement, so you get a USB cord along with the Windows CD. I view the 64k vpn connection  as the USB cord.
>>
>> You want to open a "tag agency" (which privately facilitates the interaction between motorists and the Motor Vehicle department) in the IPv4 market, and offer services to those who don't want to deal with the registry directly for whatever reason, but this policy change is required to allow such a business to thrive.
>>
>> Regards,
>> Mike
>>
>>
>> -----Original Message-----
>> From: hostmaster at uneedus.com <hostmaster at uneedus.com>
>> Sent: Tuesday, October 01, 2019 12:04 PM
>> To: Mike Burns <mike at iptrading.com>
>> Cc: arin-ppml at arin.net
>> Subject: RE: [arin-ppml] Draft Policy ARIN-2019-18: LIR/ISP 
>> Re-Assignment to Non-Connected Networks
>>
>> I do not consider the requirement as "descended from heaven" but merely the current policy which is always the starting point.  Proponents of policy change I believe need to be able to state clearly the reasons why a change from the current policy is desired.
>>
>> So that I can understand what you are trying to change, can you please help me understand what a "non connected network" is in light of what you would like to be able to do, that would appear to be prohibited by the operational use current policy?
>>
>> Non connected to me means no exposure of the numbers to the internet, 
>> except by NAT or a similar gateway.  Much like the regular use of the 
>> RFC
>> 1918 numbers that many use on the lan side of their router.
>>
>> I would not consider the outlet address of a VPN to be a non connected network, since the entire purpose of a VPN is to communicate securely with the internet, using the outlet IP, which might not even be in the same country as the inlet connection.
>>
>> I know there are some that claim to have a need for a unique worldwide addresses on their LAN, I do not think that those internal uses should trump those who which to obtain IPv4 numbering space for active internet use.
>>
>> Maybe the term "non connected network" refers to IPv4 blocks that are part of the property of a leasing company, when that company does not provide any part of internet routing of those blocks.  However, if for example they are leased long term to a major cell phone provider for the outlet side of their 3G, 4G, xG network, those numbers are also really not an "non connected network" either.
>>
>> Please give me some insight into what kind of operation needs to have 
>> an exemption to the current "operational use" requirement in order to 
>> receive
>> IPv4 directed transfers for a "non connected network"
>>
>> While RIPE might be successful in their operations, I do not yet see the problem with the current policy at ARIN.  A little insight as to what you would like to happen here that cannot be done under the current policy would be helpful in understanding the WHY of the draft policy.
>>
>> Albert Erdmann
>> Network Administrator
>> Paradise On Line Inc.
>>
>> On Tue, 1 Oct 2019, 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 lea!
 s!
> i!
>> n!
>>> 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-
>>>>>>> r
>>>>>>> e
>>>>>>> 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
>>>>>>>       the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
>>>>>>>       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.
>>>>>>>
>>>>>>>
>>>>>>>
>>>>> _______________________________________________
>>>>> ARIN-PPML
>>>>> You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
>>>>> 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.
>>>>>
>>>>> _______________________________________________
>>>>> ARIN-PPML
>>>>> You are receiving this message because you are subscribed to the 
>>>>> ARIN Public Policy Mailing List (ARIN-PPML at arin.net).
>>>>> 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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