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

John Santos john at egh.com
Wed Sep 22 12:48:58 EDT 2021


"rent seeking" is exactly the term I was looking for to describe this situation. 
  It is generally regarded as detrimental to an economy.  See: 
<https://en.wikipedia.org/wiki/Rent-seeking>


On 9/22/2021 12:17 PM, Chris Woodfield wrote:
> I believe that IP resources are a public good, and as such, must be managed in a 
> way that is equitable as practically possible.
> 
> For 30+ years, before the existence of ARIN - a cornerstone of equitable 
> management of this particular public good has been that IP blocks should be 
> registered by operators, and that organizations that hold allocations should be 
> holding them because they have an operational need for them to run their and/or 
> their connectivity customer’s networks.
> 
> With this proposal in the NRPM, an entirely new type of LIR will be allowed to 
> exist, one that does not operate a network and does not use the address space 
> for its own needs, instead utilizing the allocated space purely as a source of 
> lease income. Even more so, that type of organization has multiple business 
> benefits: it can officially hold address allocations whose transfer value is 
> virtually guaranteed to go up over time, while at the same time earning income 
> via leases. Sounds like a great business opportunity, to be honest.
> 
> However, I fear that such organizations will create severe distortions in the 
> transfer market, as these organizations will be able to acquire resources with 
> virtually no limit to their holdings, and will be able to acquire new space as 
> quickly as they’re able to lease it out. Thus, those who wish to obtain their 
> own addresses will find doing so increasingly difficult and expensive, and will 
> find themselves with little choice but to... lease addresses from this type of 
> organization. Thus furthering the extent of the market distortion.
> 
> In many other business, we refer to this as “rent seeking”, and is not looked 
> upon favorably.
> 
> Hopefully, this sufficiently explains why I “don’t like leasing”.
> 
> Thanks,
> 
> -Chris
> 
>> On Sep 22, 2021, at 8:50 AM, Mike Burns <mike at iptrading.com 
>> <mailto:mike at iptrading.com>> wrote:
>>
>> Hi Chris,
>> I am still unclear. So the “risk” you refer to is the inability to purchase 
>> new blocks using leases as justification?
>> I’m not entirely sure how that constitutes a risk, unless you mean they will 
>> run out of addresses they need for themselves. Is that their risk?
>> It seems like you are objecting to a proposal to allow using leased addresses 
>> as justification by simply stating that you don’t like leasing.
>> Why can’t you stand behind this distribution method, can you be clear on your 
>> objection to leasing?
>> Because certainly this proposal facilitates leasing.
>> I guess we are coming to the crux of things now, I’ve asked a few people who 
>> have opposed this policy why, and for some it comes down to disapproving of 
>> leasing. Now I’ve asked why.
>> A good reason, to me, is that leasing often serves the needs of miscreants. 
>> But leasing is allowed, so miscreants are currently being served. My 
>> experience tells me that miscreants have the advantage over most incumbent 
>> lessors, who are generally not in the business of leasing addresses.
>> ARIN policy prevents newcomers into the leasing business, and I think 
>> professional lessors will provide some balance against miscreants if they were 
>> allowed to enter that market.
>> Regards,
>> Mike
>> *From:*Chris Woodfield <chris at semihuman.com <mailto:chris at semihuman.com>>
>> *Sent:*Wednesday, September 22, 2021 11:33 AM
>> *To:*PPML <arin-ppml at arin.net <mailto:arin-ppml at arin.net>>
>> *Cc:*Owen DeLong <owen at delong.com <mailto:owen at delong.com>>; Mike Burns 
>> <mike at iptrading.com <mailto:mike at iptrading.com>>
>> *Subject:*Re: [arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit Requirement
>> I’m speaking to the risk that an organization that engages in leasing address 
>> blocks without providing related connectivity services. Given that these 
>> blocks cannot currently be used as justification for additional space, an 
>> organization that does so would not qualify for additional space should they 
>> require it, unless they are falsifying the nature of the allocations in their 
>> justification documentation (which, of course, is a policy violation that 
>> could lead to that organizations’s allocations being reclaimed if discovered).
>> This policy proposal, per the problem statement, is explicitly aimed at 
>> removing that risk, and as such, putting ARIN’s stamp of approval on this type 
>> of lease practice, and in fact, allows organizations to require additional 
>> space which it could then lease out, without the need to provide the network 
>> services associated with the blocks being leased. Which is a type of IP block 
>> monetization that I simply cannot stand behind.
>> As such, I remain opposed to this proposal.
>> -C
>>
>>
>>> On Sep 22, 2021, at 7:00 AM, Mike Burns <mike at iptrading.com 
>>> <mailto:mike at iptrading.com>> wrote:
>>> Hi Chris,
>>> Can you be more specific on which inherent risk this policy would remove?
>>> Somebody +1’d this, but I don’t understand what you mean.
>>> I don’t even know which party’s risk is being commented on.
>>> Regards,
>>> Mike
>>> *From:*ARIN-PPML <arin-ppml-bounces at arin.net 
>>> <mailto:arin-ppml-bounces at arin.net>>*On Behalf Of*Chris Woodfield
>>> *Sent:*Tuesday, September 21, 2021 9:21 PM
>>> *To:*Owen DeLong <owen at delong.com <mailto:owen at delong.com>>
>>> *Cc:*PPML <arin-ppml at arin.net <mailto:arin-ppml at arin.net>>
>>> *Subject:*Re: [arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit Requirement
>>>> On Sep 21, 2021, at 10:22 AM, Owen DeLong <owen at delong.com 
>>>> <mailto:owen at delong.com>> wrote:
>>>> This policy doesn’t affect that… Leasing of address space you already have 
>>>> is permitted under current policy and cannot be grounds for revocation of 
>>>> address space.
>>>> The change in this policy proposal is not to permit or deny leasing, but to 
>>>> permit leased addresses to be considered utilized for purposes of 
>>>> determining eligibility for additional address acquisition.
>>> You are correct that the proposal may not permit or prohibit leasing, but it 
>>> does (intentionally, per the problem statement) remove one of the inherent 
>>> risks of the practice, and as such, in my view, is effectively an endorsement.
>>> As such, my opposition stands.
>>> -C
>>>
>>>
>>>
>>>> Owen
>>>>
>>>>
>>>>
>>>>> On Sep 21, 2021, at 08:22 , Chris Woodfield <chris at semihuman.com 
>>>>> <mailto:chris at semihuman.com>> wrote:
>>>>> Writing in opposition. I do not support the practice of leasing IP address 
>>>>> resources. Organizations who have received larger amounts of IP address 
>>>>> space than what they are efficiently utilizing are free to relieve 
>>>>> themselves of their excess space via the transfer market.
>>>>> Thanks,
>>>>> -Chris
>>>>>
>>>>>
>>>>>
>>>>>> On Sep 21, 2021, at 8:06 AM, ARIN <info at arin.net <mailto:info at arin.net>> 
>>>>>> wrote:
>>>>>> On 16 September 2021, the ARIN Advisory Council (AC) accepted 
>>>>>> "ARIN-prop-302: Remove Circuit Requirement " as a Draft Policy.
>>>>>> Draft Policy ARIN-2021-6 is below and can be found at:
>>>>>> https://www.arin.net/participate/policy/drafts/2021_6/ 
>>>>>> <https://www.arin.net/participate/policy/drafts/2021_6/>
>>>>>> You are encouraged to discuss all Draft Policies on PPML. The AC will 
>>>>>> evaluate the discussion in order to assess the conformance of this draft 
>>>>>> policy with ARIN's Principles of Internet number resource policy as stated 
>>>>>> in the Policy Development Process (PDP). Specifically, these principles are:
>>>>>> * Enabling Fair and Impartial Number Resource Administration
>>>>>> * Technically Sound
>>>>>> * Supported by the Community
>>>>>> The PDP can be found at:
>>>>>> https://www.arin.net/participate/policy/pdp/ 
>>>>>> <https://www.arin.net/participate/policy/pdp/>
>>>>>> Draft Policies and Proposals under discussion can be found at:
>>>>>> https://www.arin.net/participate/policy/drafts/ 
>>>>>> <https://www.arin.net/participate/policy/drafts/>
>>>>>> Regards,
>>>>>> Sean Hopkins
>>>>>> Senior Policy Analyst
>>>>>> American Registry for Internet Numbers (ARIN)
>>>>>> Draft Policy ARIN-2021-6: Remove Circuit Requirement
>>>>>> Problem Statement:
>>>>>> Current ARIN policy prevents the use of leased-out addresses as evidence 
>>>>>> of utilization.
>>>>>> Policy statement:
>>>>>> Replace
>>>>>> “2.4. Local Internet Registry (LIR) A Local Internet Registry (LIR) is an 
>>>>>> IR that primarily assigns address space to the users of the network 
>>>>>> services that it provides. LIRs are generally Internet Service Providers 
>>>>>> (ISPs), whose customers are primarily end users and possibly other ISPs.”
>>>>>> with
>>>>>> “2.4. Local Internet Registry (LIR) A Local Internet Registry (LIR) is an 
>>>>>> IR that primarily assigns address space to users of the network. LIRs are 
>>>>>> generally Internet Service Providers (ISPs), whose customers are primarily 
>>>>>> end users and possibly other ISPs.”
>>>>>> Timetable for implementation: Immediate
>>>>>> _______________________________________________
>>>>>> ARIN-PPML
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>>>>> _______________________________________________
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> 
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-- 
John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539


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