[arin-ppml] Change of Use and ARIN (was: Re: AFRINIC And The Stability Of The Internet Number Registry System)

Thu Sep 2 11:59:09 EDT 2021

Hi Fernando,

We tried the method you’ve espoused below for thirty years and the result were a huge amount of wasted address space. Once the market was adopted, many of those addresses found a useful place in the routing table.

This community had debated the option of aggressively reclaiming space based on utilization review as a method of dealing with impending exhaust. The arguments you’ve presented aren’t novel. But for many reasons this community decided that the appropriate method of post-exhaust distribution is the market.

In fact, we didn’t even create a reserve pool because it’s obvious that the existence of free pools alongside a market where addresses trade for money is a recipe for corruption.

Let’s not kid ourselves, what happened in AFRINIC is a free-pool problem, not a leasing problem. The comparison of registration fees to leasing revenue in this thread is completely bogus, except for the free pool. The salient pricing comparison is the price of addresses on the market versus the revenue from leasing them.

The free pool era is dying, let’s put a fork in it as quickly as possible We’ve seen the corruption engendered by the bait of the free pool in multiple registries now, including our own. 

As addresses get more expensive, they sometimes get beyond the reach of the small, the inquisitive, the entrepreneurial enterprises that have historically thrived through connection to the Internet.   Let’s say you’re a small but growing wireless ISP. You want to open a new territory but you don’t have the capital for routers, circuits, radios, advertising, tower rents and IPv4 addresses. You could justify the purchase of addresses but that would mean less money for the other stuff.  Or you could maximize your available capital and minimize risks of territory failure if you chose to lease addresses. There are many circumstances where leasing addresses is a valid business decision and if we want the registry to be accurate we shouldn’t block valid business decisions through arbitrary policies. 

For justification purposes, if leased addresses are assigned and recorded as if there were connectivity, those addresses should be counted utilized when justifying more PURCHASES of addresses. Sometime I will get around to writing a policy proposal for that and it can be argued there more exactingly.

Your old-fashioned method of address distribution would get some addresses to those in need, I will concede that. However, so will leasing addresses, with that demonstration of need being the lease payment. Will  you concede that those who pay to lease addresses need them?

Regards,

Mike

From: ARIN-PPML <arin-ppml-bounces at arin.net> On Behalf Of Fernando Frediani
Sent: Thursday, September 02, 2021 8:16 AM
To: arin-ppml at arin.net
Subject: Re: [arin-ppml] Change of Use and ARIN (was: Re: AFRINIC And The Stability Of The Internet Number Registry System)

Exactly, the right to review is a principle in place and if triggered the resource holder must explain again if he still justify to maintain those resources.

I don't see a need to report any changes afterwards the resources were assigned by the RIR, as long they keep being used according to the current policies. If however the RIR call that organization for a review, they must be able to explain themselves at anytime. This is in the interest of all.

Now, can IP leasing be a justified need one can give to the RIR in order to have some IP space allocated ? Could ever an organization go to the RIR and say: "Please give me more IP space as I am going to use them to lease to other organizations that have the ability to get them directly from the RIR" ?

IP leasing is a real mockery to those who effectively build Internet infrastructure and bring connectivity to people in general and those who justify for receiving IP allocations. What is the point to pretend it is Ok to accept it as a 'normal' practice?
If an organization is able to justify and get IP addresses allocated directly by the RIR, accepting people's leasing practices only force organization who really justify for those IP addresses to have to pay more pay more to a middleman that most possible doesn't built any internet infrastructure if they could just be paying ARIN or any RIR's administrative fees directly and get those resources directly from there.

Therefore if some organization who received a chunk of addresses in the past based in a justification they had to build Internet sudden starts to lease those addresses they should go immediately under a revocation process as they no longer justify for them. Either they use them  for the proposes they justified or give them back to the RIR so the RIR can allocate to others  who really justify.

Transfer of resources (even if there is a transaction in the background) is something different and fine in the current scenario as it facilitates the resources goes to those who really justify for them.

Fernando

Em 01/09/2021 17:35, Chris Woodfield escreveu:

David - 

In addition to the RSA language John cited, Section 12 of the NRPM gives ARIN the right to review an organization’s resource usage at any time for continued  compliance with community-driven policy. I suspect that these reviews are not common, however. What’s more common, in my view, is an organization’s request for additional resources, which must come with justification that currently-held resources are being used in compliance with policy. I do not believe that these are checked against the original requests for consistency, however.

I’d be curious if the clause below can be interpreted as giving organizations a duty to report *any* substantial changes in an organization’s allocation plans if they diverge from the justification filed at the time of the request, or only when such changes would have the effect of putting the organization out of compliance with current policy. I can see the former interpretation being rather troublesome for a large number of organizations, given how often business plans and environments can change over time, as well as adding quite a bit of (IMO unnecessary) overhead to IP allocation managers.

That said, I can see ARIN being quite justified in reclaiming resources if the justification documentation filed with the request had no bearing to the org’s actual plans. I suspect that to be the unspoken subtext of the current controversy, and I absolutely believe that ARIN would and should act similarly in such a scenario (which, in the past, it has).

Regards,,

-Chris

On Sep 1, 2021, at 1:21 PM, John Curran <jcurran at arin.net <mailto:jcurran at arin.net> > wrote:

David - 

Excellent question.   The most important item is for the community to determine its policy goals in this area, and then based on such what requirements/duties belong in policy language in Number Resource Policy Manual (NRPM.)

The ARIN RSA places an explicit duty of “Information and Cooperation” on number resource holders (see below) that can be used to enforce community-developed policy in this area, but the communities thoughts on the appropriate policy really should drive the discussion – 

2.(c) Information and Cooperation. Holder has completed an application provided by ARIN for one or more Services (the “Application”). Holder must (i) promptly notify ARIN if any information provided in the Application changes during the term of this Agreement, and (ii) make reasonable efforts to promptly, accurately, and completely provide any information or cooperation required pursuant to the Service Terms or in response to any inquiry or request made to Holder by ARIN during the term of this Agreement. In addition, Holder shall promptly provide ARIN with complete and accurate information, and cooperation as required by any Service Terms or that ARIN requests in connection with ARIN’s provision of any of the Services to Holder. If Holder does not provide ARIN with such information or cooperation that ARIN requests, ARIN may take such failure into account in evaluating Holder’s subsequent requests for transfer, allocation or assignment of additional number resources, or requests for changes to any Services. 

Note that material breach of Section 2(c) is one of the events that provides ARIN clear right of termination for the RSA and subsequent revocation of the number resources – so let’s be extra careful when considering any reporting/information duties for placement into NRPM.  

Thanks! 

/John

John Curran

President and CEO

American Registry for Internet Numbers

On 1 Sep 2021, at 3:47 PM, David Farmer <farmer at umn.edu <mailto:farmer at umn.edu> > wrote:

I changed the subject line, as this isn't directly related to the dispute between AFRINIC and CI, but more some questions arising from it specifically related to the ARIN registered resources.

----

So, do ARIN resource holders have a duty to report changes in their use of resources? If they do, where does that duty come from in policy or contract language? And, what are the relevant changes that need to be reported?

In my review of these questions;

In the RSA I see where holders are granted, "The right to use the Included Number Resources within the ARIN database" (RSA section 2.b bullet 2). However, I don't see any limitation to that use, such as "originally justified" or any obligation to report a change in such use.

In policy, "An end-user is an organization receiving assignments of IP addresses exclusively for use in its operational networks." (NRPM 2.6), with an exception for incidental or transient use (last paragraph, section 2.5).

Maybe to align end-user requirements with the new Registration Services Agreement we should change that so end-users have to report any use, other than incidental or transient use, outside their organization.

And ISP's have requirements to report the use by their customers that exceed certain levels (NRPM sections 4.2.3.7 and 6.5.5).

So, other than the ISP reporting requirements, I don't see direct reporting obligations for change in use. Further, I don't see any guidance to what might be a material change in use that is in need of reporting, as I'm sure we don't want ARIN Staff tied up with reports of all possible changes, most of which are probably irrelevant. 

Are there reporting requirements I'm missing? Maybe implied or indirect requirement?

Should something be added to ARIN's policies explicitly stating requirements for reporting a change in the use of resources?

Thanks

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