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

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Sticking to the actual draft policy which is being proposed, in a world of 
IPv4 shortages I think that any available numbers available for directed 
transfer continue the current policy of "operational use" in order to 
receive IPv4 directed transfer addresses.  The proposal would allow the 
numbers to be used privately, which in most cases can simply be done 
without ARIN by using the RFC 1918 set of addresses or the ones assigned 
for use in CGN's. This is the current policy the draft is attempting to 
change, and I think that is wrong and vote NO on the Draft Policy for that 
reason.  Leasing is actually just a side issue of getting rid of the 
operational use policy.

This exact policy (8.5.2) is the same one that I have been thinking of 
drafting a Draft Policy amendment to as well.  My idea is that 
"operational use" should also include having and using IPv6. 8.5.2 appears 
in the conditions of receiving directed transfers. I believe that in 
today's world, 8 years after the last /8's were assigned, having and USING 
an IPv6 block of addresses should be a condition of receiving any future 
directed transfer of IPv4 space.

During the discussion of that topic here, it was mentioned how would this 
be enforced?  It could be enforced by proving the ability to exchange data 
using that IPv6 block with ARIN.  That could include email, an ftp or 
website provided by ARIN as a test, or even the use of ARIN Online. 
Check the headers of this message, and you will see I sent it to the list 
via IPv6. I have had IPv6 for 12 years.  If a small company can do it, a 
larger one with the money to pay someone for a directed transfer can 
clearly afford to have IPv6 as well.

I think it is time to use the carrot we have (the right to receive 
additional IPv4 space by ARIN policy) to get organizations to do what is 
right and have and use IPv6 as a condition of using that policy.

Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Mon, 30 Sep 2019, Mike Burns wrote:

> 
> Hi Fernando,
> 
>  
> 
> You asked me some questions so I will reply to them inline, and because we have drifted, this will be my last post on this directly. I mentioned 2050 to highlight the
> unchanging stewardship requirements, conservation and registration, as an effort to demonstrate that your attempts at conservation impact our primary responsibility
> which hasn’t changed although 2050 is superseded.
> 
>  
> 
> It also says: "ISPs are required to utilize address space in an efficient manner.  To this end, ISPs should have documented justification available for each
> assignment. The regional registry may, at any time, ask for this information. If the information is not available, future allocations may be impacted.In extreme
> cases, existing loans may be impacted."
> 
> What's wrong with that statement ? Sounds pretty reasonable to me.
> Why do you wish to reduce substantially the roles of the RIRs and pass them to private companies ?
> 
>  
> 
> My reply:
> 
> I asked you what was wrong with RIPE being reduced to a recordkeeping role but you did not answer. What is wrong with the statement above is that there are no future
> allocations. So what is the threat of audit? That threat used to keep some people in line, but there were never any RIRs who ever asked, at any time, for
> justification of older allocations without evidence of abuse.  So something that never really happened that threatened a toothless consequence is not a good guidepost
> for making policy in today’s era.  That policy failed to bring unutilized addresses into productive  use. A regime of intensive auditing and recovery would have been
> expensive and fraught. Your arguments were made at the time this community decided to allow transfers and they were deemed to be unconvincing. And not just at ARIN.
> Every RIR allows transfers now, no RIR audits and recovers addresses for utilization. Those ideas are dated, but if you think this is the right way forward, you
> should propose a policy designed to recover addresses no longer used for their original purpose and see how it flies.
> 
> I do wish to reduce the role of the RIRS because that role is now redundant, because the role of conservation is now played, and better played, by the market.
> 
> It also defines Conservation as: "Fair distribution of globally unique Internet address space according to the operational needs of the end-users and Internet Service
> Providers operating networks using this address space. Prevention of stockpiling in order to maximize the lifetime of the Internet address space."
> 
> What is wrong with that statement ? Sounds also pretty reasonable.
> Or do you think that only assigning resources to those who can pay more will be the best and more fair way to maximize the lifetime of the Internet address space
> version 4 to those who really need them to get connected ?
> RIRs have been the ones who check these operational needs impartially (with no economic interests in mind) and according to the current policies. Why remove it from
> them and pass to private companies to do ?
> 
>  
> 
> My reply:
> 
> There is nothing wrong with the statement in its appropriate milieu, when it was written, but things have changed.
> 
> Yes, I do think that assigning resources to those who can pay more is the best and most fair way to maximize IPv4 lifetime.
> 
> RIPE has been around longer than ARIN and RIPE does not feel the need to check these operational needs. You keep neglecting that and so I keep reminding you that RIPE
> is an operational RIR without a needs test for years. I am not asking to remove the RIR and replace it with a private company, so I don’t understand your last
> question. There should be no needs tests, nobody doing needs tests, neither RIR nor private company.
> 
> Regards,
> 
> Mike
> 
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