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

Noah noah at neo.co.tz
Tue Sep 21 17:14:03 EDT 2021

On Tue, Sep 21, 2021 at 11:24 PM Mike Burns <mike at iptrading.com> 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?

Transfers are generally a prerogative of brokers who don't necessarily
provide any form of network services. It does make sense for a broker to
defend this model.

> To make it clear, in RIPE you can purchase address space with the sole
> purpose of leasing it out.

 What happens in RIPE does not have to trickle down to ARIN or any other
region for that matter.

> 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.

How so, last I checked, as an LIR, we continue to sub-allocate/assign every
end-user we bring online through every circuit.  For end-users who need
more than we can sub-allocate, we refer them to the RIR for such needs. The
RIR system has in place policies that have worked for decades so well to
the best interest of the community and the internet as we know it.

> Opposing this policy means a lack of policy is preferred, despite the open
> practice of leasing.

There is already a policy. What do you mean lack of policy yet there is
already a policy which has worked well until you folks want to now remove
the need for a circuit so that those of you who benefit from the no circuit
based service of IPv$ can expand the scope of your business model beyond
just RIPE and provide IPv4 a much longer lifeline.

> Opposing this policy provides incentive for registry-shopping and address
> outflow.

What registry shopping. The widely known practise has always been RIR <>
LIR <> END-USER. This has worked and continues too.

> Opposing this policy reduces the lessor pool and drives up lease rates.

If your business model is to profit from leasing and not the IP related
services which include connectivity, then yes. LIR who focus on providing
services and using integers as a means to do so, dont worry much about
lease rates since 99% LIR businesses are not those of IPv4 brokerage or
leasing with no service.

Opposing this policy dis-incentivizes accurate registration.

99% of LIR business models are such that LIR's provide IP related services
that require a numbered circuit. Majority of LIR around the world follow
this school of thought.

Only a handful of profit minded IPv4 brokers and those who subscribe to the
IPv4 leasing business model; are into this flawed draft policy whose aim is
to profit off limited IPv4 addresses without necessarily providing Internet
based services.

Worse of it is that, we have experienced purported LIR running an IPv$
enterprise without offering any circuit based service. The entity's annual
membership contribution to the RIR is hardly $15K yet holds millions of
IPv4 addresses it hoards so that it can go about leasing them for
significant figures of $30 per IPv4 address.

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