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

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Like Fernando I am also strongly opposed to the leasing of IPv4 addresses 
and oppose getting rid of the "operational use" requirement in 8.5.2.

I really DO NOT CARE what RIPE policy is, since we are discussing ARIN 
policy on this list. I do not agree with RIPE policy on this subject, and 
have no desire whatsoever to move ARIN's policy in the direction of RIPE.

It is wrong to get rid of the "operational use" requirement in  8.5.2.  If 
one wants to have addresses that are not connected to the Internet, they 
can use RFC1918 addresses, the CGNAT block of addresses, or camp out on 
certain class A government space that is not currently being routed.

With 7 billion people on the earth, and only 4.3 billion possible IPv4 
addresses, addresses should be only assigned, allocated and registered by 
ARIN for active use.

All of the proceedures for determining the network size that an 
organization qualifies for goes out the window if leasing is actively 
permitted by ARIN policy, as this wording change is attempting to allow. 
I strongly suspect that should the operational use requirement be struck, 
the next policy proposal will be to remove all the qualification 
requirements in section 4, which will have the effect of turning the IPv4 
market into a free for all.

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.

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.

I realize that some of the larger North American Cellular Carriers also 
have been known to lease IPv4 space, these carriers would be forced to go 
the normal route (and have no problems doing so) if leasing is prohibited.

Fernando spelled out in his statement a lot of other reasons why leasing 
should not be allowed, and why the "operational use" requirement should 
not be permitted to go away to allow leasing.

Albert Erdmann
Network Administrator
Paradise On Line Inc.



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-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> 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
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