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

[Owen DeLong]

> On Sep 21, 2021, at 12:25 , Isaiah Olson <isaiah at olson-network.com> wrote:
> 
> 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.

There’s nothing fraudulent about it today…

Many providers allow their clients to announce their more specifics through second providers even if they do maintain a connection to the customer in question.

Many providers allow customers willing to put enough dollars into the process to effectively lease the addresses for use with another provider to avoid renumbering when they switch.

These types of transactions have been going on for decades without anyone complaining about them.

Admittedly, the way in which certain IPv4 leasing companies are going about it is a somewhat pathological extreme of these forms of leasing, but it will be very hard to design a policy which prohibits that extreme without also impacting these other mechanisms generally perceived as “legitimate”.

I’ve given it significant thought. I know others have given it significant thought as well. Unfortunately, there is a limit to the details I can disclose about that thought process as it is subject to the NDA I signed during my tenure on a certain policy-oriented body in the ARIN region. In my thinking on this process, I have been unable to come up with language that would specifically preclude the activities you want to preclude without damaging other “legitimate” activities you probably don’t want to prevent.

As such, I put this idea i the “too hard to be useful” bucket some yard back and accept the reality that we are unlikely to meaningfully prevent leasing even if we are able to continue to look askance at it as a grey area.

> 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.

I would expect any network, as ARIN number resources have always been available to be used on any network and not just the so-called global DFZ.


Owen