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

Mon Sep 30 14:02:58 EDT 2019

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-reported-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 <mailto: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.

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