[arin-ppml] FW: Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations
scott at solarnetone.org
scott at solarnetone.org
Fri Mar 18 11:22:58 EDT 2022
Mike,
>
> The primary value of the leasing company is that they are allowing the
> effective financing of Ipv4 address space through the taking-on of risk in
> the initial investment. Currently there is no vehicle for this, and the
> result is that smaller, newer, less-capitalized companies are required to
> pay in full, up-front, for address blocks.
>
Seems as though the little guy can meet these needs with 4.10, for only
the cost of annual membership. I certainly was able to, realizing a cost
savings over upstream LIR provided addresses.
Scott
> Regards,
>
> Mike
>
>
>
> From: ARIN-PPML <arin-ppml-bounces at arin.net> On Behalf Of Holden Karau
> Sent: Thursday, March 17, 2022 7:29 PM
> To: andrew.dul at quark.net
> Cc: arin-ppml <arin-ppml at arin.net>
> Subject: Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6:
> Permit IPv4 Leased Addresses for Purposes of Determining Utilization for
> Future Allocations
>
>
>
> Wait so some company could come to ARIN and ask for a block of IP addresses
> using leasing as the justification and then turn around and lease them.
>
>
>
> What value is the leasing company providing? It seems like a solid way to
> get a bunch of LLCs formed to acquire IP addresses from the waiting list and
> then make money for doing ~nothing.
>
>
>
> On Thu, Mar 17, 2022 at 4:18 PM Andrew Dul <andrew.dul at quark.net> wrote:
>
> The draft policy as currently written does not provide any
> additional limits against speculation. As drafted, it allows
> any organization (including those who do not operate networks)
> to obtain IPv4 addresses for the purpose of leasing.
>
>
>
> With that policy change what types of limits does the community think
> would be needed?
>
>
>
> Thanks,
>
> Andrew
>
>
>
> On 3/17/2022 3:00 PM, Scott Leibrand wrote:
>
> +1 to both Owen and David Farmer's comments. Leasing IPv4
> space is likely the best solution for some networks that
> need those addresses to operate their network. If an
> organization wants to acquire and lease out IPv4 space
> without providing bundled IPv4 transit, that should be
> allowed by policy. It might be useful for ARIN policy to
> try to slightly dampen speculation by requiring that
> organizations seeking to acquire large blocks of IPv4
> space demonstrate that their current holdings are being
> efficiently used by the organization they're registered to
> in whois. I am not sure if this policy proposal does that
> to my satisfaction, but once we ensure it does so, I would
> likely support it.
>
>
>
> -Scott
>
>
>
> On Thu, Mar 17, 2022 at 1:33 PM Owen DeLong via ARIN-PPML
> <arin-ppml at arin.net> wrote:
>
>
>
>
>
> On Mar 16, 2022, at 15:22 , Fernando
> Frediani <fhfrediani at gmail.com> wrote:
>
>
>
> Hi David
>
> If I understand correctly you seem to have a view
> that there should be a ARIN policy to permit IPv4
> leasing just because it is a reality and we kind of
> have to accept it in our days. No we don't, and
> that's for many different reasons.
>
> Well, of course, you are free to deny reality as much as
> you want. Many people do. It’s not particularly helpful in
> the discussion, however.
>
>
>
> I am used to see people saying the brokers are
> doing a good thing for the community by
> facilitating the things which in reality is
> the opposite. It may look like a good things,
> but the real beneficiaries are only them who
> profit from it without much concern of what is
> fair or not to most organizations involved.
>
>
>
> You are actually mistaken here. I used to think as you do,
> actually. I was very resistant to the first “specified
> transfer” policies because of some of the reasons you
> describe. However, what you are failing to recognize is
> that:
>
> + Brokers and specified transfers were going to happen
> with or without the RIRs. If they happened without the
> RIRs,
>
> there’d be no accurate record of who was using which
> address space and the provenance of addresses would be
>
> very difficult to support or defend.
>
>
>
> * Benefit to the community from brokers: (ethical) brokers
> are familiar with the rules in the RIRs in which
>
> they operate and can assist their customers in accurate
> and compliant registration updates and
>
> aid in keeping the allocation database(s) accurate.
>
>
>
> + With the economic realities of IPv4 addresses becoming
> progressively more and more expensive and the advent
>
> of ISPs with limited IPv4 resources available, it is
> inevitable that more and more IP service providers will be
>
> doing one or more of the following:
>
>
>
> + Separate surcharges for IPv4 addresses
>
> + Expecting customers to supply their own IPv4 addresses
>
> + Surcharges for IPv4 services
>
> + IPv4 “installation charges” large enough to cover the
> procurement of addresses
>
>
>
> * Brokers assist ISPs and customers in many of the above
> circumstances.
>
>
>
> + With a variety of organizations holding IPv4 addresses
> that may or may not even known they have them and whose
>
> IPv4 resources may vastly exceed their needs, it is
> (arguably) desirable to have those addresses be
> transferred to parties
>
> that have current need for IPv4 addresses.
>
>
>
> * Brokers provide a valuable service to the community
> identifying and marketing these resources
>
> * Paid transfers provide an incentive for entities to make
> more efficient use of the resources they have in order
>
> to monetize the resources they no longer need. Brokers are
> frequently able to assist in this process.
>
>
>
> + With the high cost of acquisition, IPv4 addresses have
> become a capital intensive part of any network-dependent
>
> business model that must support IPv4. Further, there is
> some risk that this capital outlay may be fore a resource
>
> which will abruptly and quickly lose its value and no
> longer be needed well before it can be amortized as a
> capital
>
> expenditure. As such, it may make sense for some entities
> to transfer that risk to another organization by using
>
> a lease structure instead of purchasing the addresses
> outright.
>
>
>
> * Brokers that provide IPv4 leasing in an ethical and
> policy compliant way provide a valuable service
>
> to these businesses. Yes, their price per address may
> eventually be more than it would have cost
>
> them to purchase the addresses, but the same is true of
> virtually any rental situation. On the other hand,
>
> that excess helps offset the risk that the lessor is
> taking by owning a resource that may or may not remain
>
> valuable and may or may not continue to produce revenue.
>
> IP Leasing is very different from IP Transfer
> which I see not problem they continue doing
> it. IP Transfer at least we have some
> guarantees that the directly receiving
> organization really justify for them and that
> is a quiet important (I would say fundamental)
> point to look at, because that is fairer to
> everyone involved. What guarantees we have
> when a IP Leasing is done in that sense, that
> fairness start to lack here.
>
> If we set the policies up correctly, we should have the
> same exact guarantees on a lease.
>
>
>
> If $ISP acquires a /10 through transfer and then issues
> various subordinate prefixes to their customer, the only
> guarantee
>
> you have that $ISP’s customers who receive the addresses
> really justify them is that $ISP says so. We generally
> trust $ISP
>
> to act in good faith.
>
>
>
> If $LESSOR acquires a /10 through transfer and then leases
> various subordinate prefixes to their customers, we have
> pretty
>
> much the same guarantee with the additional bit that
> $CUSTOMER is at least willing to pay enough for the
> addresses to $LESSOR
>
> to make the lease make sense. In general, I think it is
> somewhat safe to assume that $CUSTOMER is not going to
> make a
>
> monthly recurring payment to $LESSOR for something they
> don’t intend to use. If one’s intent is to deprive the
> market and
>
> inflate the price, then the risk profile for such a
> transaction is vastly more favorable if you purchase
> rather than lease.
>
>
>
> Sure, there could be lessors that don’t get reasonable
> justification for allocations from their customers, but
> there are most
>
> certainly ISPs in that category as well. Either way,
> you’ve got very little assurance. A lessor can provide
> just as much
>
> justification to an RIR for the addresses they will
> allocate to leases as an ISP can for addresses they will
> lease to their
>
> customers. The only difference is a lease with
> connectivity from the same company or a lease from a
> company other than
>
> the one(s) providing connectivity.
>
> People see the brokers are doing a favor to
> organizations in general by facilitating they
> get some chunks of IPv4, but that in reality
> makes the cost of IPv4 for both leasing and
> transfer more and more expensive as it makes
> organization even more dependent from
> these those crumbs that seem to be offered
> with good intention but in reality it is
> feeding a system that is contrary the
> interests to most organizations involved.
>
> Just as you are free to mount, balance, and rotate your
> own tires, or, you can go to a tire store and have them
> perform that service for a fee, brokers provide a service
> for a fee. If you want to obtain addresses in the transfer
> market without a broker, you’re still free to do that.
> Brokers are not driving the cost of IPv4… The scarcity and
> difficulty of operating with IPv4 is driving the cost of
> IPv4. Brokers are along for the ride providing a service
> and collecting a fee for that service. Whether that fee is
> reasonable or not is (and should be) entirely in the eye
> of the customer. Customers are always free to walk away
> and find a different supplier or look for their addresses
> independently.
>
> It may sound a cliche but IPv4 is over and
> organizations must learn how to survive with
> what they have, reinvent themselves and make
> better used of their IPv4 resources, deploy a
> proper CGNAT, deploy IPv6 either they like it
> or not, etc. If an organization have so little
> or none and need some minimal amount is fine
> they seek for a Transfer of a minimal amount
> with the help of brokers.
>
> I agree. However, the increasing cost of IPv4 is a natural
> and organic part of that process and sticking our heads in
> the sand and pretending that it is not the economic
> reality of how the current world works will not help
> anyone. Not the community, not organizations that are
> short on IPv4 resources, and not the RIRs who are only
> useful so long as their databases provide a reasonably
> accurate reflection of the actual utilization of the
> address space and who controls it.
>
>
>
> A broker is an LIR just like an ISP. Since ISPs are now
> charging for addresses independent of connectivity and
> bandwidth, it only makes sense that customers can shop for
> them separately from different suppliers. Just like you
> can buy tires for your car from the dealership or from
> some other store that sells and supports tires, IPv4
> addresses are moving that way as well. The RIRs can either
> recognize this and adapt to it with policies that make
> sense and preserve some of the things you’ve outlined as
> concerns above, or, they can simply deny the reality of
> IPv4 leasing and lose track of how addresses are actually
> managed for some significant chunks of the internet.
>
> Encouraging IP Leasing as if it were something
> normal just "because it exists today" is a
> shot in the foot that in the long term only
> worsens the existing scenario, it feeds a
> market without much discretion increasing
> final prices for everyone and what is the
> worst of all, creates even more unfairness for
> everyone who has always submitted to the rules
> we have until today for distributing addresses
> to those who really have a real justification
> to keep control of that resource that does not
> belong to them.
>
> I don’t believe that a policy that merely allows IPv4
> leasing can be said to encourage it. Rather, it permits
> it, recognizes that it exists and is not going to stop
> existing just because policy pretends it can’t exist.
>
>
>
> The market is not likely to be significantly swayed by
> policy in terms of pricing, with the exception that
> AFRINIC has been able to preserve a devalued price on
> addresses within their region due to their restrictive
> lack of a transfer policy for moving addresses to/from
> AFRINIC. However, while this has the effect of keeping
> AFRINIC IPv4 addresses less expensive on the open market,
> it also leads to a significant amount of utilization of
> those addresses outside of policy and quite a bit of
> hoarding of addresses by some of AFRINIC’s largest
> members. ARIN’s counsel has advised against naming names
> here, so I won’t, but if you want names, contact me off
> list.
>
>
>
> Owen
>
>
>
> Regards
> Fernando
>
> On 16/03/2022 13:09, David Farmer via
> ARIN-PPML wrote:
>
> Yes, bundling IPv4 addresses with
> bandwidth is permitted, and in the past
> was common practice, heck even the
> expected practice. However, the fact
> that IPv4 address demand isn't
> decreasing significantly, the costs to
> acquire new IPv4 addresses are
> increasing significantly, and with the
> increasing commoditization of bandwidth,
> it is no longer economically viable to
> bundle bandwidth, and its associated
> connectivity, with IPv4 addressing. This
> is driving a structural separation of
> bandwidth, connectivity, and IPv4
> addressing, from each other, instead of
> bundling them together as in the past.
>
>
>
> Let me state that differently; ISPs are being
> driven, buy cost conscience consumers, to
> separate the costs of bandwidth and the costs
> of the IPv4 addresses needed to utilize the
> bandwidth from each other. Minimally this
> separation is achieved by accounting for the
> costs on separate line items of a common bill
> from a single provider. However, price
> competition for bandwidth and IPv4 addresses
> separately will inevitably drive a structural
> separation between the two. Consumers will
> want the best price they can get for bandwidth
> and the best price they can get for IPv4
> addresses, regardless of whether they come
> from a single provider or not.
>
>
>
> Some may argue this is being driven by the
> existence of address brokers, and their desire
> to make money, I disagree. While address
> brokers making money is the grease that keeps
> this machine working, the need for the machine
> is driven by; IPv4 free pool exhaustion, the
> increasing cost of IPv4 addresses, and the
> lack of adoption of IPv6.
>
> In other words, address brokers wouldn't exist
> if there wasn't a demand for their services.
>
>
>
> In short, the economic conditions that allowed
> for and even encouraged the bundling of IPv4
> addresses with bandwidth and connectivity no
> longer exist, that world is gone. While I have
> not personally yet determined if I support
> this particular policy text, nevertheless, the
> time has come to recognize the next step in
> this inextricable evolution of IPv4 address
> policy by the ARIN policy community and permit
> IPv4 leasing.
>
>
>
> Thanks.
>
>
>
> On Fri, Mar 11, 2022 at 5:05 PM John Santos
> <john at egh.com> wrote:
>
> I disagree. The addresses are
> useless unless they ALSO purchase
> access and
> routing from another network
> operator. How is this cheaper?
>
> It is and always has been allowed
> to lease bundled access of
> addresses and
> connectivity from a LIR, without
> any expense for purchasing those
> addresses.
>
>
> On 3/11/2022 12:13 PM, Tom
> Fantacone wrote:
> > I support the proposal as
> written.
> >
> > It facilitates the provision of
> a valuable service to a large
> swath of the ARIN
> > community, namely the ability of
> network operators with an
> operational need to
> > lease IPv4 addresses from 3rd
> party lessors at a fraction of the
> cost of
> > purchasing those addresses. Too
> often we have seen network
> operators justify
> > their need for IPv4 space only
> to find that they can't afford to
> make the
> > purchase. They end up using
> CGNAT or some other sub-optimal
> solution.
> >
> > Bill, regarding your point "B",
> by providing IPv4 leasing, these
> 3rd parties are
> > certainly performing a function
> that ARIN does not.
> >
> >
> >
> > ---- On Thu, 10 Mar 2022
> 17:46:36 -0500 *William Herrin
> <bill at herrin.us>* wrote ----
> >
> > On Wed, Mar 9, 2022 at 8:24
> PM ARIN
> <info at arin.net <mailto:info at arin.net>>
> > wrote:
> > > * ARIN-2021-6: Permit
> IPv4 Leased Addresses for Purposes
> of Determining
> > Utilization for Future
> Allocations
> >
> > I continue to OPPOSE this
> proposal because:
> >
> > A) It asks ARIN to
> facilitate blatant and
> unapologetic rent-seeking
> > behavior with changes to
> public policy.
> >
> > B) It proposes that third
> parties perform precisely and only
> the
> > functions that ARIN itself
> performs without any credible
> compliance
> > mechanism to assure the
> third party performs to ARIN's
> standards or in
> > accordance with the
> community's established number
> policy.
> >
> > Regards,
> > Bill Herrin
> >
> >
> > --
> > William Herrin
> >
> bill at herrin.us <mailto:bill at herrin.us>
> >
> https://bill.herrin.us/ <https://bill.herrin.us/>
> >
> _______________________________________________
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> _______________________________________________
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> --
> John Santos
> Evans Griffiths & Hart, Inc.
> 781-861-0670 ext 539
> _______________________________________________
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> --
>
> ===============================================
> David Farmer
> Email:farmer at umn.edu
> Networking & Telecommunication Services
> Office of Information Technology
> University of Minnesota
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