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

Isaiah Olson Isaiah at olson-network.com
Tue Sep 21 20:00:09 EDT 2021


> 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>* 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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