[arin-ppml] FW: Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations
Mike Burns
mike at iptrading.com
Fri Mar 18 11:38:56 EDT 2022
Hi Scott,
Sorry, I misinterpreted your statement and missed your point.
Which I guess was that the little guy should be concentrating on transitioning to IPv6 and can thus acquire "free" addresses from the 4.10 pool.
Fair enough.
Regards,
Mike
-----Original Message-----
From: scott at solarnetone.org <scott at solarnetone.org>
Sent: Friday, March 18, 2022 11:23 AM
To: Mike Burns <mike at iptrading.com>
Cc: arin-ppml at arin.net
Subject: Re: [arin-ppml] FW: Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations
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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