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

[David Farmer]

First, I do not support this policy as written. However, I do support
allowing leasing or loaning of IPv4 address space independent of providing
connectivity, and probably allowing leasing or loaning of addresses as
justification for at least the transfer of additional addresses, through
purchase in most cases, and probably not by obtaining addresses from the
waiting list, or the reserved blocks of IPv4. Let me address my objection
to this policy language, fundamentally my objection is that by changing the
definition of an LIR that change applies to both IPv4 and IPv6. I would
rather not make changes impacting IPv6 while enabling the leasing or
loaning of IPv4 addresses, which I think is necessary at this point.

I have a question for those that oppose the leasing or loaning of IPv4
addresses to other entities absent connectivity; Is it the rent-paying or
that lack of connectivity provided with the addresses that offend you? Or,
both?

How about an end-user that wants to loan a business partner, another
end-user let's say, IPv4 address in order to ensure they can do business
with that business partner over the Internet? Would this offend you? It is
easy to see how this might be in the business interests of the end-user
that has extra addresses. However, the end-user may not want to transfer
the addresses to their business partner, as they may want to be able to
provide them to a different business partner in the future. In this
example, there isn't necessarily rent-paying but there is no connectivity
at least directly.

As the per megabit cost of bandwidth continues decreasing, especially in
bulk, and the cost of proving the necessary IPv4 addresses to use the
bandwidth is increasing, many providers are being forced to charge their
customers separately for IPv4 addresses in order to be competitive in the
bandwidth marketplace. They, therefore, are being forced to charge their
customers' rent on the IPv4 addresses the customers need, it is frequently
no longer viable to include IPv4 address costs in the bandwidth costs as
has been done in the past. For example, we heard in a different thread
about a WISP that used to have a /20 from their upstream provider and that
provider took back the addresses, presumably to use the addresses in a more
profitable manner. And, the WISP is having a hard time finding replacement
addresses, this unfortunately is a common story. In this example, there is
rent-paying, and connectivity is provided.

For the the other permutations, rent-paying without connectivity has been
discussed extensively so far, and as mentioned above connectivity without
rent-paying has serious economic forces going against that option.

Some of you may counter that we should have never allowed the sale and
monetization of IPv4 resources through transfers in the first place and
suggest we should have had large-scale forced revocation, well I think the
situation with Afrinic and CI is the perfect counterexample to the
feasibility of that as an option.

Thanks



-- 
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David Farmer               Email:farmer at umn.edu
Networking & Telecommunication Services
Office of Information Technology
University of Minnesota
2218 University Ave SE        Phone: 612-626-0815
Minneapolis, MN 55414-3029   Cell: 612-812-9952
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