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

Isaiah Olson Isaiah at olson-network.com
Tue Sep 21 22:04:30 EDT 2021


Hi 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 confusing Draft Policy with Recommended Draft Policy status. 
Your proposal is within the scope of the PDP, thus it was posted here. 
That doesn't mean it's in line with the PDP principles to be recommended 
for adoption by the AC, the discussion on this list is intended to 
determine that.

> 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.

I think it's pretty difficult to get an accurate picture of the problem 
here. Most of the abusive networks that I find originating in RIPE tend 
to have many different ASNs and /24 blocks which all trace back to a 
common upstream ASN. I don't know if lots of small blocks changing hands 
is evidence of a healthy market for new entrants or a healthy market for 
abuse. However, I concede that the current policy in RIPE has not 
produced the extreme results that were predicted by some when the change 
was being made in the short term. I do believe this will change in the 
long run, but it remains to be seen.

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

I'm not trying to argue that there is no market for leasing, or that 
only edge cases might be interested in the flexibility it provides. 
Rather, I am arguing that it is not in the best interest of the 
community to modify policy to allow the practice to be officially 
sanctioned and considered as justified need for additional resources. If 
private organizations with existing holdings want to offer the 
flexibility of an off-network lease agreement, that is their choice, but 
I consider it to be tantamount to an admission by that organization that 
they are no longer using that space on their operational network and 
therefore have no justified need based on the space. It's in use on 
someone else's network, until such a time as they take it back and begin 
using it on their own network again, at which point it makes sense to me 
that they could offer it as justification for additional space.

> 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.

You would certainly be in a better position than I to say who is 
interested in leasing. Regardless of the market for the service, as you 
have already mentioned, there is a large proportion of abuse activity 
with leased addresses and I don't find the legitimate use cases 
compelling enough to outweigh the potential for an ever increasing 
number of addresses to fall into the hands of abusive networks. I firmly 
believe that the "skin in the game" of operating a network that is 
affected by IPv4 scarcity, IPv6 deployment, and the growth of the global 
routing table is an important requirement and it was included in the 
policy for a reason. I don't support the idea of any company acting as a 
pseudo-RIR, acting without the same oversight as the current RIR system, 
however imperfect it may be. I don't think the relatively low annual 
costs and quick amortization of any IPv4 block acquired for leasing 
provides any incentive for such an IPv4 landlord to clean up anything, 
or provide any more accurate re-allocation data than we currently are 
getting with the systems in place now.

> 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.

There is no financial incentive, but there is a policy requirement to 
accurately report re-allocations and re-assignments larger than /29. 
This means that the lessor in your example is non-compliant with the 
policy if they fail to report the re-assignment accurately regardless of 
the lack of significant financial incentive or penalty. This isn't an 
optional thing that the organization can just choose not to do. If they 
are misreporting or misrepresenting their leased space to ARIN in order 
to justify more resources or conceal leasing they don't want ARIN to 
know about, they are committing fraud. I have never proposed penalizing 
registering assignments, quite the opposite I proposed stiffening the 
penalties for networks who fail to report re-assignments and 
re-allocations accurately, especially with the intent to defraud the 
community of resources they aren't entitled to hold under current policy.

Lastly, I just want to reiterate that my primary objection with this 
policy proposal is due to the potential for a deleterious effect on the 
waiting list system and a replay of the past controversies there with 
leasing this time instead of transfers. Although I do not support the 
practice of leasing or the use of leased resources to justify paid 
transfers, I admit that the community may differ from me on that point 
and that there are real economic arguments in favor of such a standalone 
proposal. Regardless, I hope this policy will be amended to specify that 
leased addresses cannot be considered as justified need for waiting list 
requests.

- Isaiah

On 9/21/2021 7:43 PM, Mike Burns wrote:
> 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
>         <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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