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

Mike Burns mike at iptrading.com
Mon Sep 30 18:12:02 EDT 2019

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demonstrate that your attempts at conservation impact our primary responsibility which hasn’t changed although 2050 is superseded.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.






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