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

Mike Burns mike at iptrading.com
Tue Sep 21 22:25:22 EDT 2021


Hi Isaiah,



Thank you for your thoughtful response. I don't think the proposal is not in accord with any provisions of the PDP.



We can agree to disagree on certain issues, but we agree on one thing, the last thing in your message.

"Regardless, I hope this policy will be amended to specify that
      leased addresses cannot be considered as justified need for
      waiting list requests."



I am in full agreement here, but I am not sure how best to word this. I am absolutely against free pool addresses being acquired with the intention of leasing them out, or for leased-out addresses to justify waiting list address allocations. I wish the free pool was gone, but it must be protected while it exists.

The intention of this proposal was to allow parties who want to take the risk of purchasing addresses to be able to do so just as if they were connected to their clients via a physical or even virtual circuit. If this tier of distribution is restricted to lucky incumbents, they are the only beneficiaries of maintaining the current situation.

Them and RIPE.


I am happy to consider your deeper concerns about a pseudo-RIR and the frequency of abuse among lessees, those to me are the salient arguments. Those, and any waiting-list implications especially.



Maybe tomorrow.


Regards,

Mike

 









---- On Tue, 21 Sep 2021 22:04:30 -0400 Isaiah Olson <Isaiah at olson-network.com> wrote ----



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 mailto: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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