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

Tom Fantacone tom at iptrading.com
Wed Sep 22 11:58:24 EDT 2021


I support the policy, with the caveat mentioned by others that leased addresses shouldn't be a justification to go on the waiting list.



With address scarcity, leasing is becoming more widespread and this policy encourages more accurate SWIPs of the addresses in use.



There's been some intimation in this discussion that because the proposal came from a broker it deserves greater scrutiny with an eye towards nefarious profit motives.  Proposals should be evaluated and discussed based solely on their merits, not on who proposes them or any imputed motivation.  Nonetheless, as a broker who has dealt with hundreds of organizations seeking IPv4 space, I can state that more and more of these organizations are considering leasing IPv4 as their only viable option.  Yes, some can go on the waiting list, but only if they can wait 3-4 months and don't already have a /20 of space.  Yes, some can purchase IPv4 on the transfer market, but prices have risen considerably and some of the small to mid-sized ISPs I deal with who have received transfers in the past no longer have the budget for it.  For more and more orgs, leasing is the only economical way to go.



As far as brokering leases goes, it's not a very desirable market for us, and most of the others I know in the broker community feel the same way.  Some just won't touch it.  Brokering a lease takes a lot more effort than brokering a transfer, and generates a much smaller fee.  When we do it, it's usually to help out a prior IPv4 transfer client who needs to lease space to keep their network operational.  Not that financial gain should be an issue, but FYI, it's practically done as a public service.  The reason a broker would initiate this proposal is that he sees a need for it based on his experience with hundreds of real world cases.



Regards,



Tom Fantacone







---- On Wed, 22 Sep 2021 08:32:36 -0400 John Curran <jcurran at arin.net> wrote ----



On 21 Sep 2021, at 10:25 PM, Mike Burns <mailto:mike at iptrading.com> wrote:

 



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.  ...








Mike  -



If that is a desired policy goal, then one possible way such a result could be achieved by the explicit definition of the term “operational need” and then referencing that term in the waiting list policy.   In this manner, generalization of LIR would not
 create ambiguities in application of waiting list issuance. 



(I am certain there are many other ways to accomplish such a result, but provide the above as one possible approach in order to be responsive to your query and further discussion your policy goal.   Also note that parties purchasing rights to IP address
 blocks via specified transfers (NRPM 8.3 and 8.4) must per NRPM 8.5 have “operational use” – i.e. any transfers of number resources must be solely for the purpose of use on an operational network – and so doing an overall definition of that term instead and
 adjusting references is also a possible if that aligns with your policy goal.) 



Best wishes,

/John



John Curran

President and CEO

American Registry for Internet Numbers







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