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

Isaiah Olson isaiah at olson-network.com
Wed Sep 22 10:56:10 EDT 2021


I understand your argument here now, I still don't see any meaningful 
reason to financially reward networks who are currently non-compliant 
with existing policy. I don't agree with your characterization that 
there is no financial incentive existing either. Networks who are 
non-compliant with their reporting requirements could, in the worst case 
scenario, be subject to having their space reclaimed by ARIN. I would 
argue this means that, in practice, the stick is already available in 
policy, ARIN is just not using it on a widespread basis at this time.

- Isaiah

On 9/22/2021 9:43 AM, Mike Burns wrote:
>
> Because currently there is no "justification benefit" for accurate 
> registration, but this policy would create one.
>
> I don't understand what you are asserting here. There is currently a 
> requirement to accurately report re-allocations. The only benefit I 
> see is to networks that are currently non-compliant with that policy. 
> If networks are failing to meet those obligations, I would argue a 
> better policy proposal would be one to strengthen the penalties 
> related to non-compliance with that policy, rather than rewarding 
> non-complaint networks.
>
> - Isaiah
>
> Good morning Isaiah,
>
> This policy will create a financial benefit for accurate registration 
> of leased addresses that currently does not exist. I lease addresses 
> out, but there is no financial incentive for me to register those 
> leases in any way at ARIN. However if I wanted to purchase more 
> addresses to meet the needs of more lessees, then I would have a 
> financial incentive for accurate registration. I am not arguing that 
> this should be required, I think we all should strive for accurate 
> registration. But I see financial incentives as meaningful, they are 
> driving the IPv4 distribution system today.
>
> It’s the carrot approach, but you can try the stick to see if that 
> would encourage more accurate assignments.
>
> Regards,
> Mike
>
> *From:* Isaiah Olson <Isaiah at olson-network.com>
> *Sent:* Tuesday, September 21, 2021 8:00 PM
> *To:* Mike Burns <mike at iptrading.com>
> *Cc:* 'ARIN-PPML List' <arin-ppml at arin.net>
> *Subject:* Re: Draft Policy ARIN-2021-6: Remove Circuit Requirement
>
>     Nonetheless your objection was that this proposal somehow would
>     not distribute resources in accordance with policy, I think your
>     objection was addressed completely.
>
> You are certainly correct that my initial objection was unclear. 
> Specifically, I do not believe that this policy is compatible with 
> section 4.2 of the PDP process, nor 4.3 as of this moment. Compliance 
> with the NRPM would seem to be irrelevant since the policy proposal 
> would change the NRPM.
>
>     You are drifting. I never made the argument you are saying I made
>     regarding any benefit of leasing to RIPE.
>
>     I said in response to Noah, and you now agree, that allowing
>     leasing will not in fact lead to the demise of an RIR.
>
>     I take it you agree that Noah's objection in this regard has been
>     addressed.
>
> You are the one who opened the door to the RIPE situation, although I 
> would have certainly cited the research from my first email 
> regardless. Although you may have addressed the extreme example 
> brought up by Noah, you have failed to address any of the concerns I 
> have raised about the results of the RIPE policy. If I've put words in 
> your mouth, I apologize. However, I am asking you directly to address 
> whether you consider the policy implementation in RIPE to have been 
> beneficial to the Internet community, both in the region and as a 
> whole, because I would argue the data says otherwise.
>
>     OK the waiting list is rock solid, but my wisp needs a /21, what
>     now? My point remains, the waiting list is not appropriate for all
>     those in need, and if there were alternatives then there would be
>     no market for leases to begin with. I can spend all day giving
>     examples of legitimate lessees. I think you should concede that
>     there are legitimate business cases where leases make more sense
>     for the recipient.
>
> The waiting list may not be appropriate for all needs, but it 
> certainly fills in many of the gaps you are arguing necessitate 
> leasing. The edge cases you note may make for a compelling argument 
> for expanding wait list eligibility, but I don't find them compelling 
> enough to justify a RIR-wide policy change to allow leased addresses 
> to be considered as justification, a policy which has the potential 
> for considerable negative side effects to the community. The existence 
> of a market for leasing does not equate to a necessity for the ARIN 
> community to enable and subsidize the practice by changing policy in 
> this way. I would certainly concede that legitimate business cases for 
> leasing IPv4 do exist. Unfortunately, there is a dearth of reputable 
> research into the leasing market, so I will refrain from making any 
> assertions about the proportion of legitimate to non-legitimate use 
> cases. Regardless, the existence of legitimate use cases doesn't 
> strike me as a compelling reason to support this policy.
>
>     I believe you have conceded that my assertion is correct.
>
> With regards to your assertions about the composition of the pool of 
> lessors, I would agree that you are correct. I do not concede or agree 
> in any way that your assertion supports implementation of this 
> particular policy. I do not support the concept of LIRs acquiring new 
> space solely to lease off-network, and I would prefer that the pool 
> available for leasing off-network dwindles over time until as much 
> space as possible can be brought under terms that explicitly disallow 
> the practice. For networks smaller than /20, the waiting list provides 
> an acceptable alternative and it appears that the current rate of 
> revocations is approximately matched to the demand on the waiting 
> list, for networks larger than /20, I assert that what you propose 
> would only exacerbate the difficulty of obtaining a block at a 
> reasonable price.
>
>     That is the current policy, to disallow justification without a
>     circuit, so  your objection to this proposal means you prefer no
>     leasing policy.
>
> You are correct here, I certainly prefer a no leasing policy, 
> specifically one that is stronger than the current policy, but I still 
> prefer the current policy to what you propose. I do not believe it is 
> legally or economically feasible for ARIN to retroactively reclaim 
> resources that are currently being leased off-network, but I don't 
> consider anything you've presented here as a compelling argument to 
> officially sanction the practice regardless of the historical 
> inequalities.
>
>     I consider this also a concession that what I said is true about
>     "providing an incentive" which is as far as I went.
>
> You're going to need to go further if you want to garner any 
> significant community support for this proposal.
>
>     I agree with your first contention, that this policy could in fact
>     lead to price increases on the transfer market.
>
>     But the basic math you refer to is the linkage between the
>     transfer market and the lease market.
>
>     Transfer prices have doubled this year, lease rates have not
>     doubled, they haven't risen anywhere nearly as quickly.
>
>     I think the lack of ability to purchase blocks to feed the lease
>     market in ARIN serves to loosen that coupling between the lease
>     and transfer market.
>
>     Thanks for phrasing it as "if networks choose to lease", as that
>     is a clear understanding of the way things work currently.
>
>     Lessors and lessees are choosing to engage in leasing because they
>     both see an advantage.
>
>     So let me admit my assertion that lease rates would drop with this
>     policy is just an assumption and not an assertion.
>
> I would agree with your assertion that the linkage between the 
> transfer market and the leasing market is loose. I expect that there 
> will be a corresponding increase in lease prices over time. If you 
> have any historical data to contradict that expectation, I'd certainly 
> be open to hearing it. If networks choose to lease when there are 
> alternatives available, I am unconcerned if they must pay more, even 
> significantly more in the far flung future when the leasing pool has 
> dwindled, because that is the price they are choosing to pay for the 
> flexibility associated with a lease.
>
>     Thanks, I think we understand that you do not support the policy
>     but I don't think that you overcame my assertion this time.
>     Because currently there is no "justification benefit" for accurate
>     registration, but this policy would create one.
>
> I don't understand what you are asserting here. There is currently a 
> requirement to accurately report re-allocations. The only benefit I 
> see is to networks that are currently non-compliant with that policy. 
> If networks are failing to meet those obligations, I would argue a 
> better policy proposal would be one to strengthen the penalties 
> related to non-compliance with that policy, rather than rewarding 
> non-complaint networks.
>
> - Isaiah
>
> On 9/21/2021 6:17 PM, Mike Burns wrote:
>
>     Hi Isaiah,
>
>     Thanks, replies inline.
>
>     ---- On Tue, 21 Sep 2021 18:56:05 -0400 *Isaiah Olson
>     <Isaiah at olson-network.com> <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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