[arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit Requirement
Mike Burns
mike at iptrading.com
Tue Sep 21 20:43:01 EDT 2021
Hi Isaiah,
I'm sorry I missed your reply but I want to answer it.
But I'm worried about formatting. Here goes....
---- On Tue, 21 Sep 2021 20:00:09 -0400 Isaiah Olson <Isaiah at olson-network.com> wrote ----
Nonetheless your objection was that this
proposal somehow would not distribute resources in accordance
with policy, I think your objection was addressed completely.
You are certainly correct that my initial objection was unclear.
Specifically, I do not believe that this policy is compatible with
section 4.2 of the PDP process, nor 4.3 as of this moment.
Compliance with the NRPM would seem to be irrelevant since the
policy proposal would change the NRPM.
Mike-OK, I think the fact that the policy was reviewed by the AC and deemed a draft policy counters your argument that it's not compatible with any aspect of the policy development process.
You are drifting. I never made the
argument you are saying I made regarding any benefit of leasing
to RIPE.
I said in response to Noah, and you now agree, that
allowing leasing will not in fact lead to the demise of an
RIR.
I take it you agree that Noah's objection in this regard
has been addressed.
You are the one who opened the door to the RIPE situation,
although I would have certainly cited the research from my first
email regardless. Although you may have addressed the extreme
example brought up by Noah, you have failed to address any of the
concerns I have raised about the results of the RIPE policy. If
I've put words in your mouth, I apologize. However, I am asking
you directly to address whether you consider the policy
implementation in RIPE to have been beneficial to the Internet
community, both in the region and as a whole, because I would
argue the data says otherwise.
Mike- I have seen the data about transfers being the source of miscreants and frankly it makes sense even without that report. Where else are miscreants going to get their addresses? (RPKI is putting a dent in hijacks) And I would also concede that the ratio of miscreants among Lessees is very high. However I find RIPE's transfer policies to have been generally successful and they put the lie to the fear of market-moving speculators taking advantage of no needs-testing to buy and hoard addresses in RIPE. On the contrary I find that RIPE has a thriving market in IPv4 transfers, mostly smaller blocks, which I regard as a healthy sign. But you can lease your addresses out here in ARIN. It's just that in RIPE you can buy addresses just for that purpose. This policy would change things so that other businesses could enter the leasing business and address the needs of the market, or fail if those needs don't materialize. It's my hope that leasing professionals could help clean things up substantially.
OK the waiting list is rock solid, but my
wisp needs a /21, what now? My point remains, the waiting list
is not appropriate for all those in need, and if there were
alternatives then there would be no market for leases to begin
with. I can spend all day giving examples of legitimate lessees.
I think you should concede that there are legitimate business
cases where leases make more sense for the recipient.
The waiting list may not be appropriate for all needs, but it
certainly fills in many of the gaps you are arguing necessitate
leasing. The edge cases you note may make for a compelling
argument for expanding wait list eligibility, but I don't find
them compelling enough to justify a RIR-wide policy change to
allow leased addresses to be considered as justification, a policy
which has the potential for considerable negative side effects to
the community. The existence of a market for leasing does not
equate to a necessity for the ARIN community to enable and
subsidize the practice by changing policy in this way. I would
certainly concede that legitimate business cases for leasing IPv4
do exist. Unfortunately, there is a dearth of reputable research
into the leasing market, so I will refrain from making any
assertions about the proportion of legitimate to non-legitimate
use cases. Regardless, the existence of legitimate use cases
doesn't strike me as a compelling reason to support this policy.
Mike- if there are only edge cases, there is no leasing business to begin with. But leasing is growing from my perspective.
I believe you have conceded that my
assertion is correct.
With regards to your assertions about the composition of the pool
of lessors, I would agree that you are correct. I do not concede
or agree in any way that your assertion supports implementation of
this particular policy. I do not support the concept of LIRs
acquiring new space solely to lease off-network, and I would
prefer that the pool available for leasing off-network dwindles
over time until as much space as possible can be brought under
terms that explicitly disallow the practice. For networks smaller
than /20, the waiting list provides an acceptable alternative and
it appears that the current rate of revocations is approximately
matched to the demand on the waiting list, for networks larger
than /20, I assert that what you propose would only exacerbate the
difficulty of obtaining a block at a reasonable price.
Mike- Isaiah, you lost me here when you talk about the pool for leasing diminishing. How is that going to happen if the incumbents don't sell? There are many networks larger than /20 that I lease to, so the waiting list limits are not really anything like a deciding factor. You can't even get a /21 from the waiting list. The waiting list is nice for small and new networks with small needs, but it really doesn't affect the leasing business that much.
That is the current policy, to disallow
justification without a circuit, so your objection to this
proposal means you prefer no leasing policy.
You are correct here, I certainly prefer a no leasing policy,
specifically one that is stronger than the current policy, but I
still prefer the current policy to what you propose. I do not
believe it is legally or economically feasible for ARIN to
retroactively reclaim resources that are currently being leased
off-network, but I don't consider anything you've presented here
as a compelling argument to officially sanction the practice
regardless of the historical inequalities.
I consider this also a concession that
what I said is true about "providing an incentive" which is as
far as I went.
You're going to need to go further if you want to garner any
significant community support for this proposal.
I agree with your first contention, that
this policy could in fact lead to price increases on the
transfer market.
But the basic math you refer to is the linkage between the
transfer market and the lease market.
Transfer prices have doubled this year, lease rates have
not doubled, they haven't risen anywhere nearly as quickly.
I think the lack of ability to purchase blocks to feed the
lease market in ARIN serves to loosen that coupling between
the lease and transfer market.
Thanks for phrasing it as "if networks choose to lease", as
that is a clear understanding of the way things work
currently.
Lessors and lessees are choosing to engage in leasing
because they both see an advantage.
So let me admit my assertion that lease rates would drop with
this policy is just an assumption and not an assertion.
I would agree with your assertion that the linkage between the
transfer market and the leasing market is loose. I expect that
there will be a corresponding increase in lease prices over time.
If you have any historical data to contradict that expectation,
I'd certainly be open to hearing it. If networks choose to lease
when there are alternatives available, I am unconcerned if they
must pay more, even significantly more in the far flung future
when the leasing pool has dwindled, because that is the price they
are choosing to pay for the flexibility associated with a lease.
Thanks, I think we understand that you do
not support the policy but I don't think that you overcame my
assertion this time.
Because currently there is no "justification benefit" for
accurate registration, but this policy would create one.
I don't understand what you are asserting here. There is
currently a requirement to accurately report re-allocations. The
only benefit I see is to networks that are currently non-compliant
with that policy. If networks are failing to meet those
obligations, I would argue a better policy proposal would be one
to strengthen the penalties related to non-compliance with that
policy, rather than rewarding non-complaint networks.
Mike- What I am saying is that if I am an ARIN lessor there is no financial incentive to accurately SWIP the assignment to the Lessee, although I am totally with you that this should be done for many reasons. But if the lessor wants to justify any future address purchases, he will need to provide evidence of assignment to the Lessee. This policy provides incentive for accurate registration of leases that currently does not exist. I probably should have led with that. But if you think a policy proposal to strengthen penalties against registering assigments is the better way to go, have at it.
Regards,
Mike
- Isaiah
On 9/21/2021 6:17 PM, Mike Burns wrote:
Hi Isaiah,
Thanks, replies inline.
---- On Tue, 21 Sep 2021 18:56:05 -0400 Isaiah Olson mailto:Isaiah at olson-network.com wrote
----
Hi Mike,
Thanks for your reply. I would be happy to address each of
your assertions.
> That RIPE situation is an unfortunate artifact of
their reserve pool
> for new entrants.
>
> Can you share the percent of those /24s that begin
with 185?
Roughly 17% of the RIPE IP space that I have on my list
comes from that
block. I would hardly agree that the statistically
significant disparity
in transfer market abuse activity across all RIPE IP
ranges is solely an
artifact of this single block.
> First you wrote “The onus is not on ARIN to sanctify
practices that
> some are already engaging in, but rather to
distribute number
> resources in accordance with community developed
policy.”
>
> My answer is that this policy proposal continues to
distribute number
> resources in accordance with community developed
policy.
It will be community policy if and when it is adopted
through this PDP,
which seems unlikely at this point since you are the only
person arguing
in favor and I don't find your arguments particularly
convincing since
they are not backed up by any hard data. Whether the
policy comports
with the goals of the PDP itself is a different question.
Mike-Nonetheless your objection was that this proposal
somehow would not distribute resources in accordance with
policy, I think your objection was addressed completely.
> I would agree with you, but that doesn’t mean we
should ignore
> relevant data from our sister registry, and I brought
up RIPE to deal
> with Noah’s objection about what will happen should
this policy pass
What relevant data have you provided from RIPE which
justifies your
initial assertion? Certainly you may have rejected Noah's
concern that
the RIR would collapse, given the fact that RIPE still
exists, but I
haven't seen any compelling data cited here that shows any
benefit to
the RIPE community due to their policy and I have provided
data which
shows quite the opposite. A lack of immediate negative
effects is hardly
sufficient data to declare that RIPE policy hasn't caused
negative long
term effects, of which we may not have yet seen the full
impact.
Mike-You are drifting. I never made the argument you
are saying I made regarding any benefit of leasing to
RIPE.
I said in response to Noah, and you now agree, that
allowing leasing will not in fact lead to the demise of an
RIR.
I take it you agree that Noah's objection in this
regard has been addressed.
> Then you won’t have to worry about leasing, because
you claim there is
> no market for it. The waiting list is not a guaranty,
and has an
> unpredictable schedule for address delivery. I gave
an example of a
> WISP seeking to try out a new area, and why leasing
addresses might be
> quite attractive to that WISP for entirely legitimate
reasons.
I would not consider the current waiting list
distributions
unpredictable, in fact I would argue it's quite the
opposite in
practice. Speaking from personal experience on the waiting
list before
ARIN moved to quarterly distributions, I waited only four
months to
receive a block. Under the last several quarterly
distributions, nearly
every request on the list has been fulfilled in each
distribution,
resulting in a consistent distribution schedule of 3-6
months for the
last several distributions. The oldest request currently
on the list is
from 07/01/2021. I would ask ARIN to please provide some
hard data about
this process for the community to consider when evaluating
this policy,
because I do not believe the current reality of the
waiting list agrees
with your assertions. If and when that changes, I would
possibly be open
to re-considering my position on the matter.
With regards to leasing, I did not assert that there is no
market for
leasing, but rather that alternatives to leasing do exist
and you are
casting them in an a light that I do not believe reflects
the reality of
the situation. Under current policy, your WISP example is
free to apply
to the waiting list for the block it needs to try out the
new area, and
either return or re-purpose it if services in that new
area don't work
out. I don't find a compelling argument here for the
necessity of
leasing addresses.
Mike- OK the waiting list is rock solid, but my wisp
needs a /21, what now? My point remains, the waiting list
is not appropriate for all those in need, and if there
were alternatives then there would be no market for leases
to begin with. I can spend all day giving examples of
legitimate lessees. I think you should concede that there
are legitimate business cases where leases make more sense
for the recipient.
> Opposing this policy means the only lessors are the
lucky incumbents.
If the lucky incumbents choose to retain their IPv4 space
and lease it,
that is certainly their choice to make. However, under the
current
policy you propose to change, they may not consider leased
addresses as
justification for additional space. I feel the current
policy strikes a
perfectly appropriate balance. If a network has leased
space available
to reclaim when leases expire, it is inappropriate for
them to seek
additional allocations from the RIR. If they have
over-leased their
space such that they cannot operate their network until
someone's lease
expires, then they should not expect the ARIN community to
subsidize
their lack of foresight with additional addresses.
Transfers in such a
situation are a different matter and I would certainly
consider this
policy in a different light if leasing space were to be
exempted as
justification for waiting list request.
Mike- I believe you have conceded that my assertion is
correct.
> Opposing this policy means a lack of policy is
preferred, despite the
> open practice of leasing.
As I originally stated in my first e-mail, I do not prefer
the lack of
policy or the insufficiency of the current policy. I would
instead
prefer to see the policy explicitly strengthened to
disallow off-network
leasing as justification for additional requests, despite
the fact that
ARIN has made it clear that they consider the current
policy to prohibit
using such addresses as justification.
Mike - That is the current policy, to disallow
justification without a circuit, so your objection to
this proposal means you prefer no leasing policy.
> Opposing this policy provides incentive for
registry-shopping and
> address outflow.
I agree that RIR-shopping is a concern and there is a real
chance that
strict policy against leasing in the ARIN region may
encourage the
practice. However, I don't believe this should be the
concern of the
ARIN community in deciding how to allocate resources in
our corner of
the world. If other RIR communities want to make other
decisions, they
are endowed with that freedom under the current system. I
don't think
"everyone is jumping off the bridge so we should too"
makes for a good
argument. What would convince me is hard data that shows
how the RIPE
community has benefited from the elimination of the
needs-test in the
transfer process, or data that demonstrates what tangible
issue your
policy proposal would solve in the ARIN region. "Current
ARIN policy
prevents the use of leased-out addresses as evidence of
utilization"
doesn't strike me as a complete problem statement.
Mike-I consider this also a concession that what I said
is true about "providing an incentive" which is as far as
I went.
> Opposing this policy reduces the lessor pool and
drives up lease rates.
This argument cuts both ways. I would argue that
supporting the policy
drives up transfer market prices by increasing speculation
by entities
that have no stake in the shared Internet resource aside
from the rights
to use IPv4 addresses. Basic math tells us that higher
prices in the
transfer markets will result in higher prices in the
leasing market, as
well as resulting in fewer blocks available to networks
who wish to
obtain space directly from the RIR via transfers. I do not
see this as a
benefit to the community. As I have stated before, I am
unmotivated by
the impacts on lessees/lessors of keeping the current
policy or
strengthening the requirement to provision actual services
on an
operational network. If networks choose to lease, they may
pay more,
which is a similar situation for any capital-intensive
resource that is
subject to leasing. Developing policy to keep lease rates
low is not the
concern of the ARIN community or this PDP, but rather
developing policy
that supports efficient and technically competent
administration of the
region's resources.
Mike- I agree with your first contention, that this
policy could in fact lead to price increases on the
transfer market.
But the basic math you refer to is the linkage between
the transfer market and the lease market.
Transfer prices have doubled this year, lease rates
have not doubled, they haven't risen anywhere nearly as
quickly.
I think the lack of ability to purchase blocks to feed
the lease market in ARIN serves to loosen that coupling
between the lease and transfer market.
Thanks for phrasing it as "if networks choose to
lease", as that is a clear understanding of the way things
work currently.
Lessors and lessees are choosing to engage in leasing
because they both see an advantage.
So let me admit my assertion that lease rates would
drop with this policy is just an assumption and not an
assertion.
> Opposing this policy dis-incentivizes accurate
registration
If networks choose to report inaccurate or fraudulent SWIP
data in order
to evade the requirements of the current policy, then they
are not
allocating addresses in accordance with ARIN policy and
could be subject
to enforcement actions from ARIN. Although I wish ARIN was
more
aggressive in maintaining an accurate WHOIS database and
abuse contacts,
I would argue that the current situation in the ARIN
region is quite
good compared to other RIRs in this respect, since there
has been a
regular review process to ensure database accuracy for
many years.
Either way, this policy proposal doesn't fundamentally
change reporting
requirements, but simply blesses networks who currently
have "something
to hide" to report their usage accurately. Certainly, I
can see how the
policy benefits the community in this limited sense.
Still, I am
unconvinced that the net effects would be positive and I
do not support
the policy.
Mike - Thanks, I think we understand that you do not
support the policy but I don't think that you overcame my
assertion this time.
Because currently there is no "justification benefit"
for accurate registration, but this policy would create
one.
Regards,
Mike
- Isaiah
On 9/21/2021 4:29 PM, Mike Burns wrote:
>
> Hi Isaiah,
>
> That RIPE situation is an unfortunate artifact of
their reserve pool
> for new entrants.
>
> Can you share the percent of those /24s that begin
with 185?
>
> You didn’t support Noah’s theory that this policy
proposal would lead
> to the demise of RIRs, so let’s address your
particular objections.
>
> First you wrote “The onus is not on ARIN to sanctify
practices that
> some are already engaging in, but rather to
distribute number
> resources in accordance with community developed
policy.”
>
> My answer is that this policy proposal continues to
distribute number
> resources in accordance with community developed
policy.
>
> Second you wrote:” If other RIR communities choose to
make other
> decisions, that doesn't make it the correct decision
for the ARIN region.”
>
> I would agree with you, but that doesn’t mean we
should ignore
> relevant data from our sister registry, and I brought
up RIPE to deal
> with Noah’s objection about what will happen should
this policy pass”
>
> Third you wrote “There is a waiting list available
for legitimate new
> entrants, and I don't buy the argument that networks
with greater than
> a /20 cannot afford the capital outlay to purchase a
block.”
>
> Then you won’t have to worry about leasing, because
you claim there is
> no market for it. The waiting list is not a guaranty,
and has an
> unpredictable schedule for address delivery. I gave
an example of a
> WISP seeking to try out a new area, and why leasing
addresses might be
> quite attractive to that WISP for entirely legitimate
reasons.
>
> I feel I have addressed what I see as the objections
you have noted.
>
> Now, why not try to actually address even one of my
assertions and
> tell me where it fails?
>
> “Opposing this policy means the only lessors are the
lucky incumbents.
>
> Opposing this policy means a lack of policy is
preferred, despite the
> open practice of leasing.
>
> Opposing this policy provides incentive for
registry-shopping and
> address outflow.
>
> Opposing this policy reduces the lessor pool and
drives up lease rates.
>
> Opposing this policy dis-incentivizes accurate
registration”
>
> Regards,
> Mike
>
> *From:* Isaiah Olson <mailto:isaiah at olson-network.com>
> *Sent:* Tuesday, September 21, 2021 5:07 PM
> *To:* Mike Burns <mailto:mike at iptrading.com>;
'Noah' <mailto:noah at neo.co.tz>
> *Cc:* 'ARIN-PPML List' <mailto:arin-ppml at arin.net>
> *Subject:* Draft Policy ARIN-2021-6: Remove Circuit
Requirement
>
> Mike,
>
> I would hardly say it's time for a funeral in RIPE,
but I would ask,
> do you think it's a coincidence that roughly 75% of
the /24 blocks
> that I have blackholed on my network for spamming my
email server are
> registered to anonymous hosting companies in the RIPE
region? I don't
> agree that the results of the RIPE policy speak for
themselves, and I
> would love to see more data aggregated by some of the
more talented
> internet sleuths on here regarding the proportion of
abuse activity
> split up by RIR. I also disagree with all five of
your assumptions
> about opposing this policy. The onus is not on ARIN
to sanctify
> practices that some are already engaging in, but
rather to distribute
> number resources in accordance with community
developed policy. If
> other RIR communities choose to make other decisions,
that doesn't
> make it the correct decision for the ARIN region. I
don't support any
> policy that amplifies the practice of leasing because
I reject your
> arguments about the necessity of the practice. There
is a waiting list
> available for legitimate new entrants, and I don't
buy the argument
> that networks with greater than a /20 cannot afford
the capital outlay
> to purchase a block. Please feel free to provide any
data you can to
> back up your five assertions. For my assertion,
please consider the
> following:
>
> Prefixes exchanged within the RIPE region as sales
originate have
> the highest fraction of blacklisted IPs, which is
statistically
> significant.
>
> Source:
> https://eprints.lancs.ac.uk/id/eprint/139789/1/VGiotsas_PAM2020_IPv4_Transfers_abuse.pdf
> <https://eprints.lancs.ac.uk/id/eprint/139789/1/VGiotsas_PAM2020_IPv4_Transfers_abuse.pdf>
>
> - Isaiah
>
> On 9/21/2021 3:24 PM, Mike Burns wrote:
>
> I am in total agreement with your sentiment and the
requirement
> for a circuit should continue to stand.
>
> Any policy that removes such a requirement would
render the
> management of Internet Number Resources by the
registry useless
> and thereby essentially lead to no need for the
registry after all.
>
> Noah
>
> Hi Noah,
>
> Are you aware that there has been no needs-test for
RIPE transfers
> for many years and the RIR system hasn’t collapsed?
>
> To make it clear, in RIPE you can purchase address
space with the
> sole purpose of leasing it out. And you have been
able to do that
> for many years now. Plainly, openly, within all
policy. So please
> let us know where to send the flowers for RIPE’s
funeral. That
> goes for others who predict that bad things will
follow from
> adopting this policy, please keep RIPE’s example in
mind to
> provide a reality check. The experiment has already
been performed.
>
> Owen has already pointed out the futility of the
circuit
> requirement in practice, yet you think that’s what
keeps the RIR
> system functional?
>
> Opposing this policy means the only lessors are the
lucky incumbents.
>
> Opposing this policy means a lack of policy is
preferred, despite
> the open practice of leasing.
>
> Opposing this policy provides incentive for
registry-shopping and
> address outflow.
>
> Opposing this policy reduces the lessor pool and
drives up lease
> rates.
>
> Opposing this policy dis-incentivizes accurate
registration.
>
> Let me know if any of these assertions require
amplification, I
> guess some may not be clear but this is already too
long.
>
> Regards,
> Mike
>
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