[arin-ppml] Draft Policy ARIN-2019-18: LIR/ISP Re-Assignment to Non-Connected Networks
Fernando Frediani
fhfrediani at gmail.com
Mon Sep 30 16:35:35 EDT 2019
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-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
>> 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.
>>
>>
>>
More information about the ARIN-PPML
mailing list