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

Fernando Frediani fhfrediani at gmail.com
Mon Sep 30 16:32:39 EDT 2019


Hello

Why do you use the term "purchase 'RIR' addresses" ? They don't sold 
them and never did it. Most here know well that what we pay are 
administrative fees and we are resource holders. Therefore there is no 
selling of addresses by RIRs as they don't manufacture them.

With regards address return this can be done by the will of Autonomous 
System or by the RIR when policies and contract are applied. Although I 
agree now a days will be rare to see it is possible and would be the 
right thing to do for any organization holding a lot of addresses where 
they don't have justification for it anymore. We are talking about a 
concept.
Still RIRs or NIRs can ask an organization to justify **at any time** 
they need to keep those addresses should they have indications all 
assignments are not justified anymore. This is actually done in other 
RIRs and not something uncommon to happen. Since BCP-12 written by Jon 
Postel himself and others it is there very clear that RIRs "may, at any 
time, ask for this information" and what are the implications. This 
keeps been the way RIRs deal with it in order to assign addresses to 
organizations and is a pretty obvious thing: an organization which 
doesn't justify anymore cannot receive or keep the addresses previously 
assigned (not sold) to them and these address must be re-assigned to 
other organizations.

You mentioned someone is able to transfer address in RIPE without having 
to justify the need of them and because of that he is able to lease 
them. Let's assume this as true. Still if the RIR finds (after the 
transfer is concluded) an organization is not using a fair amount of the 
assignments then the right is to ask them to justify and if they fail 
those addresses should be recovered.
As leases is not a proper use of address by the organization who 
received them from the RIR or by their directly connected customers they 
have no propose to be kept with that organization anymore just for 
speculation. Addresses are not meant to be leased, but to get people 
connected to the internet. As mentioned by Albert whatever the RIPE 
policy differs form ARIN it is not mandatory for ARIN to copy or adopt 
it. And as mentioned in other messages there are differences from both 
scenarios and regions.

With regards pricing and conservation the point is quiet simple: IP 
addresses are never meant to be leased but to get people connected to 
the internet. They must be assigned to those who really need them not to 
those who can pay more. We are not talking a manufactured product that 
you may produce as much as you wish and sell and re-sell in the market 
freely.
And the RIR is the only possible neutral organization able to apply the 
rules equally to anyone following this principles. Why would we as a 
community want to give it over to private companies only interested to 
profit from these transactions and not concerned about if addresses will 
be properly used to get people connected or to be speculated ?

Allowing leases basically skips the ability from the RIR to apply rules 
equally to everyone and ask for justifications whenever needed passing 
it out to private profit driven organizations. Why do we want that to 
happen ?

If someone has usage for IP addresses and cannot get them directly from 
the RIR it can do via permanent transfers. Any other ways don't serve to 
the interests of organizations in the region, but only to a few private 
and specific interests.

Fernando

On 30/09/2019 15:02, 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 
> <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.
>
>     _______________________________________________
>     ARIN-PPML
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