[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
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>>
>>


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