[arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit Requirement

[Isaiah Olson]

I am opposed to this proposal and would in fact like to see a policy 
proposal that strengthens the requirement to provide actual network 
services in order to receive additional address space. I agree that the 
current policy is unclear and possibly causing confusion for ARIN staff 
processing transfers when leasing is involved, and that updating it to 
prevent abuse of resources without affecting operational networks is a 
complex task. Despite the difficulty, I hope the community can converge 
on a proposal to that end. Questions of fig leaves and fraudulent intent 
are best left to the courts to interpret, but there cannot be 
accountability for fraud without clear policy.

In relation to this particular proposal, I would ask the community to 
consider the consequences of implementation. Some have suggested that 
the current policy can be evaded with simple "fig leaves" to present the 
illusion of the provision of network services. I am not so sure. Under 
the current policy, I would certainly not be comfortable requesting an 
additional /23 or /22 from the waiting list for "VPN Services" and 
proceeding to lease that space out to be announced elsewhere while 
maintaining a VPN link for appearances. If this policy were to be 
adopted, there would be absolutely nothing fraudulent about requesting a 
/22 for the purposes of leasing it to be announced on completely 
unrelated networks. Given the dozens of emails that I have received in 
the last several months offering to buy or lease my current IPv4 block, 
I am confident that I could immediately find lessees and be ready to 
request additional space from ARIN as soon as the six month waiting 
period has expired. Further, as it has been recently pointed out, this 
economies of scale only get better as you obtain more and more space, as 
my fees would cap out quickly at $2000/year in around two years which is 
easily subsidized with the leasing revenue from 4,096+ addresses. I am 
uncomfortable with the idea that anyone with the time to set up a 
corporation whose business model is "holding IPv4 resources and leasing 
them out" could effectively loot the waiting list for thousands of 
addresses in a couple short years. Given the current price explosion in 
the IPv4 transfer market, I feel that this risk posed by this proposal 
to the integrity of the waiting list is very tangible. Additionally, 
basic economics of supply and demand show that opening up the transfer 
market for speculation and investment without requiring even the 
appearance of an operational network has the potential to cause prices 
to skyrocket to even more absurd levels.

Lastly, I also agree with others that the actual proposed policy 
language is flawed, "users of the network" is incredibly vague and it's 
unclear whether "network" refers to the Internet shared resource as a 
whole (global DFZ) or any network.

Isaiah Olson
Olson Tech, LLC

> Policy statement:
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> “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.”
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> “2.4. Local Internet Registry (LIR) A Local Internet Registry (LIR) is an IR that primarily assigns address space to users of the network. LIRs are generally Internet Service Providers (ISPs), whose customers are primarily end users and possibly other ISPs.”