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

Mike Burns mike at iptrading.com
Tue Sep 21 20:43:01 EDT 2021


Hi Isaiah,



I'm sorry I missed your reply but I want to answer it.

But I'm worried about formatting. Here goes....









---- On Tue, 21 Sep 2021 20:00:09 -0400 Isaiah Olson <Isaiah at olson-network.com> wrote ----





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.








Mike-OK, I think the fact that the policy was reviewed by the AC and deemed a draft policy counters your argument that it's not compatible with any aspect of the policy development process. 



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.

 

Mike- I have seen the data about transfers being the source of miscreants and frankly it makes sense even without that report. Where else are miscreants going to get their addresses? (RPKI is putting a dent in hijacks) And I would also concede that the ratio of miscreants among Lessees is very high. However I find RIPE's transfer policies to have been generally successful and they put the lie to the fear of market-moving speculators taking advantage of no needs-testing to buy and hoard addresses in RIPE. On the contrary I find that RIPE has a thriving market in IPv4 transfers, mostly smaller blocks, which I regard as a healthy sign. But you can lease your addresses out here in ARIN. It's just that in RIPE you can buy addresses just for that purpose. This policy would change things so that other businesses could enter the leasing business and address the needs of the market, or fail if those needs don't materialize.  It's my hope that leasing professionals could help clean things up substantially.


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.




Mike- if there are only edge cases, there is no leasing business to begin with. But leasing is growing from my perspective.


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.




Mike- Isaiah, you lost me here when you talk about the pool for leasing diminishing. How is that going to happen if the incumbents don't sell? There are many networks larger than /20 that I lease to, so the waiting list limits are not really anything like a deciding factor. You can't even get a /21 from the waiting list. The waiting list is nice for small and new networks with small needs, but it really doesn't affect the leasing business that much.



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.

Mike- What I am saying is that if I am an ARIN lessor there is no financial incentive to accurately SWIP the assignment to the Lessee, although I am totally with you that this should be done for many reasons. But if the lessor wants to justify any future address purchases, he will need to provide evidence of assignment to the Lessee. This policy provides incentive for accurate registration of leases that currently does not exist.  I probably should have led with that.  But if you think a policy proposal to strengthen penalties against registering assigments is the better way to go, have at it. 



Regards,

Mike













- 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 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 <mailto:isaiah at olson-network.com> 
 > *Sent:* Tuesday, September 21, 2021 5:07 PM 
 > *To:* Mike Burns <mailto:mike at iptrading.com>;
              'Noah' <mailto:noah at neo.co.tz> 
 > *Cc:* 'ARIN-PPML List' <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> 
 > 
 > - 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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