[arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

Fernando Frediani fhfrediani at gmail.com
Mon Mar 21 08:30:24 EDT 2022


You may repeat 1000 times and still it will not become a true that when 
someone sell connectivity they lease IP addresses. When someone buys 
connectivity having an IP address is a condition for them to receive the 
connectivity services they are buying and the real propose of keeping IP 
addresses justified to the RIR.
There is a big and clear difference in one case and in the other which 
the build of Internet infrastructure and the service provision which is 
the main reason to justify the addresses.

Fernando

Em 20/03/2022 20:25, Owen DeLong via ARIN-PPML escreveu:
> Leasing involves a contract for services, just like an ISP.
>
> It’s no more arms length than leasing addresses to someone you sell connectivity to, you have a nearly identical contractual relationship.
>
> In fact, many ISPs charge for former customers to retain their addresses after they terminate their connectivity. How does that differ from a company which leases addresses without connectivity?
>
> I’m currently neither in favor of nor opposed to the proposed policy as written. I think it needs work before it’s ready to be a policy.
>
> However, I am in favor of formalizing the practice of leasing in policy since it is the economic reality of IPv4 for the foreseeable future, whether it is formalized in policy or not.
>
> Owen
>
>
>> On Mar 18, 2022, at 16:13, Michael Peddemors <michael at linuxmagic.com> wrote:
>>
>> I oppose..
>>
>> This removes ARIN's governance of IPv4 resources completely.  And in a worst case scenario a single party could buy up all of the IPv4 resources in theory, and effectively control the internet.
>>
>> "Leasing" is for to wide of a definition, and needs to be better described before even considering this.
>>
>> "leasing" is not a usage, IMHO in terms of the original mandate of ARIN, without a fixed customer base for services (eg, it could be said every ISP leases IPs to their customers) which is very different than saying we rent the IP(s) to arm's length parties.
>>
>> On 2022-03-17 17:23, Owen DeLong via ARIN-PPML wrote:
>>> Actually, they’d be doing all of the same things any other LIR does with the exception of providing bandwidth and connectivity services.
>>> They’d still be responsible for getting a reasonable justification from the customer, validating that justification, registering the addresses properly in whois, etc.
>>> It might be a bit less overhead than being an ISP, but ISPs are increasingly short on IPv4 addresses and asking customers to get their own.
>>> Many customers are unable to make the capital outlay necessary to purchase the addresses they need, but do have the cash flow to support a lease.
>>> Many customers have a desire not to take the risk of a large capital outlay for a necessary component which may abruptly lose its value in the near to medium term.
>>> This situation will only get worse as the cost of IPv4 addresses continues to rise and as IPv6 deployment continues.
>>> Owen
>>>> On Mar 17, 2022, at 16:28 , Holden Karau <holden at pigscanfly.ca <mailto:holden at pigscanfly.ca>> wrote:
>>>>
>>>> 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 <mailto: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 <mailto:arin-ppml at arin.net>> wrote:
>>>>>
>>>>>
>>>>>
>>>>>>         On Mar 16, 2022, at 15:22 , Fernando Frediani
>>>>>>         <fhfrediani at gmail.com <mailto: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
>>>>>>>         <mailto: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 <mailto:bill at herrin.us>>* wrote ----
>>>>>>>             >
>>>>>>>             >     On Wed, Mar 9, 2022 at 8:24 PM ARIN
>>>>>>>             <info at arin.net
>>>>>>>             <mailto:info at arin.net> <mailto: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> <mailto:bill at herrin.us
>>>>>>>             <mailto:bill at herrin.us>>
>>>>>>>             > https://bill.herrin.us/
>>>>>>>             <https://bill.herrin.us/> <https://bill.herrin.us/
>>>>>>>             <https://bill.herrin.us/>>
>>>>>>>             >  _______________________________________________
>>>>>>>             >     ARIN-PPML
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>>>>>>>             >
>>>>>>>             > _______________________________________________
>>>>>>>             > ARIN-PPML
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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
>>>>>>>         <mailto:Email%3Afarmer at umn.edu>
>>>>>>>         Networking & Telecommunication Services
>>>>>>>         Office of Information Technology
>>>>>>>         University of Minnesota
>>>>>>>         2218 University Ave SE        Phone: 612-626-0815
>>>>>>>         Minneapolis, MN 55414-3029   Cell: 612-812-9952
>>>>>>>         ===============================================
>>>>>>>
>>>>>>>         _______________________________________________
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>>
>>
>> -- 
>> "Catch the Magic of Linux..."
>> ------------------------------------------------------------------------
>> Michael Peddemors, President/CEO LinuxMagic Inc.
>> Visit us at http://www.linuxmagic.com @linuxmagic
>> A Wizard IT Company - For More Info http://www.wizard.ca
>> "LinuxMagic" a Registered TradeMark of Wizard Tower TechnoServices Ltd.
>> ------------------------------------------------------------------------
>> 604-682-0300 Beautiful British Columbia, Canada
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> _______________________________________________
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