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

Fernando Frediani fhfrediani at gmail.com
Mon Sep 30 17:23:13 EDT 2019


On 30/09/2019 18:06, Mike Burns wrote:
> Hi Fernando,
>
> Let me address the two items highlighted in your reply below.
>
> First is the reduction of ARIN to nothing more than a registration operation. What is wrong with that? RFC2050 said the primary purpose of an RIR is registration. We need to keep the numbers unique or everything fails. ARIN should indeed reduce itself to registering transfers and doing what it can to maintain accurate registration per our primary stewardship role. All else is subservient, including conservation. But we have addressed conservation.  RIPE has been reduced to a registration operation, to use your term. What is so wrong with RIPE?

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 ?

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 ?

>
> Second is the point that one of the business cases for leasing is for spamming. This is something to consider, but I would like for you to put yourself into the position of a Lessor. The Lessor knows  his blocks will lose value if they are blacklisted, so they take steps to mitigate this. For example, one notable lessor charges a $20 fee for every abuse complaint on a leased block. The Lessee pays the $20 fee and most of it is paid to the Lessor as compensation. This disincentivizes spamming on leased blocks. A Lessor who gets tricked into leasing to a spammer will find his block devalued significantly. He can get it delisted one, maybe twice if he can spin a good story. After that, no more for that owner. So the owners have penalties and usage terms built into the lease contract, or they get prepayment for many months in advance, or they lease large blocks which are not appealing to spammers. The point is this is a valid argument against changing policy to support leasing, but the problems are long-known and the market has applied corrections.  On the other hand, spammers like to hijack too, and having the ability to define a hijack as being non-compliant with a lease policy will enable ARIN to pressure the address holder for a policy violation if pressure from that side helps.
This is more a point of view one how the things happen in practice or 
should happen and I personally don't agree with that in full.
>
> Regards,
> Mike
>
>
>
> -----Original Message-----
> From: ARIN-PPML <arin-ppml-bounces at arin.net> On Behalf Of Fernando Frediani
> Sent: Monday, September 30, 2019 4:36 PM
> To: arin-ppml at arin.net
> Subject: Re: [arin-ppml] Draft Policy ARIN-2019-18: LIR/ISP Re-Assignment to Non-Connected Networks
>
> 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-repor
>>> ted-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.
>>>
>>>
>>>
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