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

Owen DeLong owen at delong.com
Wed Sep 22 22:07:48 EDT 2021

> On Sep 22, 2021, at 09:17 , Chris Woodfield <chris at semihuman.com> 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. 

How is it equitable to allow those providing connectivity services to gouge their customers with huge leasing prices per IP address while denying customers access to addresses at lower lease prices from independent providers?

Since it is “clearly out of scope” and “restraint of trade” to even so much as discuss preventing this price gouging by ARIN’s connectivity-providing members, what better and more equitable alternative can you propose?

> 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.

Yeah, that all went out the window when ARIN promised not to revoke for lack of continuing demonstrated need and legitimized the process of transferring addresses for money.

The reality is that any pretense at being able to prevent it through a lack of legitimizing it was inherently bound to fail due to the lack of legal authority on the part of the RIRs and that lack of legal authority is, in fact a good thing because those with guns have proven themselves to be inherently bad at resource management for the common good.

> 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.

Not true. That type of LIR is already allowed to exist, they just can’t expand by acquiring additional space in the ARIN region. Instead, they have to set up a VPS in Europe ($10/month) and acquire their additional addresses through an inter-RIR transfer to RIPE. Since ARIN’s only check and balance on an outbound transfer to RIPE is on the supplier side and they do nothing to validate any policy compliance on the recipient (that is left to RIPE and RIPEs policies are applied), this is not a problem at all.

> 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.

Since such organizations have existed for years in RIPE and have not created those distortions, I have to question your basis for that fear (another word for which is unfounded assumption).

You imply that this would create some new ability to engage in this activity… It will not. It will merely remove a step from the process (namely the 8.4->RIPE step). Everything else is already happening whether you realize it or not.

> In many other business, we refer to this as “rent seeking”, and is not looked upon favorably.

It seems to be the business model of the entire mobile gaming industry.
It seems to be the most prevalent business model of real-estate today.
It seems to be common place with equipment acquisition by the very type of LIRs you champion as legitimate over those that do not provide connectivity with their leases.

Further, I’ve already posted evidence of the price gouging and rent seeking for addresses by those LIRs compared to much lower prices from LIRs that do not provide connectivity, so I think your fears (unqualified assumptions) have been largely debunked at this point.

> Hopefully, this sufficiently explains why I “don’t like leasing”. 

It explains it, but if you will open your eyes to the reality around you and realize that the assumptions built into your view are not factual, I hope it will allow you to reconsider your position in light of the facts.

I’m sure this looks like a 180 from the Owen you have known for years… It is. I’ve seen the facts presented above and altered my position on that basis. IPv4 leasing is inevitable just as IPv4 transfers were. I recognized them as the necessary evil that they were in 2009 and consider leasing to be an inevitable corollary evil that there is no point in pretending we can prevent as well.


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