[arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit Requirement
Isaiah Olson
isaiah at olson-network.com
Wed Sep 22 10:56:10 EDT 2021
I understand your argument here now, I still don't see any meaningful
reason to financially reward networks who are currently non-compliant
with existing policy. I don't agree with your characterization that
there is no financial incentive existing either. Networks who are
non-compliant with their reporting requirements could, in the worst case
scenario, be subject to having their space reclaimed by ARIN. I would
argue this means that, in practice, the stick is already available in
policy, ARIN is just not using it on a widespread basis at this time.
- Isaiah
On 9/22/2021 9:43 AM, Mike Burns wrote:
>
> 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.
>
> - Isaiah
>
> Good morning Isaiah,
>
> This policy will create a financial benefit for accurate registration
> of leased addresses that currently does not exist. I lease addresses
> out, but there is no financial incentive for me to register those
> leases in any way at ARIN. However if I wanted to purchase more
> addresses to meet the needs of more lessees, then I would have a
> financial incentive for accurate registration. I am not arguing that
> this should be required, I think we all should strive for accurate
> registration. But I see financial incentives as meaningful, they are
> driving the IPv4 distribution system today.
>
> It’s the carrot approach, but you can try the stick to see if that
> would encourage more accurate assignments.
>
> Regards,
> Mike
>
> *From:* Isaiah Olson <Isaiah at olson-network.com>
> *Sent:* Tuesday, September 21, 2021 8:00 PM
> *To:* Mike Burns <mike at iptrading.com>
> *Cc:* 'ARIN-PPML List' <arin-ppml at arin.net>
> *Subject:* Re: Draft Policy ARIN-2021-6: Remove Circuit Requirement
>
> 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.
>
> 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.
>
> 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.
>
> 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.
>
> 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.
>
> - 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
> <Isaiah at olson-network.com> <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 <isaiah at olson-network.com
> <mailto:isaiah at olson-network.com>>
> > *Sent:* Tuesday, September 21, 2021 5:07 PM
> > *To:* Mike Burns <mike at iptrading.com
> <mailto:mike at iptrading.com>>; 'Noah' <noah at neo.co.tz
> <mailto:noah at neo.co.tz>>
> > *Cc:* 'ARIN-PPML List' <arin-ppml at arin.net
> <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>
>
> >
> <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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