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<p>Hello</p>
<p>Why do you use the term "purchase 'RIR' addresses" ? They don't
sold them and never did it. Most here know well that what we pay
are administrative fees and we are resource holders. Therefore
there is no selling of addresses by RIRs as they don't manufacture
them.</p>
<p>With regards address return this can be done by the will of
Autonomous System or by the RIR when policies and contract are
applied. Although I agree now a days will be rare to see it is
possible and would be the right thing to do for any organization
holding a lot of addresses where they don't have justification for
it anymore. We are talking about a concept. <br>
Still RIRs or NIRs can ask an organization to justify **at any
time** they need to keep those addresses should they have
indications all assignments are not justified anymore. This is
actually done in other RIRs and not something uncommon to happen.
Since BCP-12 written by Jon Postel himself and others it is there
very clear that RIRs "may, at any time, ask for this information"
and what are the implications. This keeps been the way RIRs deal
with it in order to assign addresses to organizations and is a
pretty obvious thing: an organization which doesn't justify
anymore cannot receive or keep the addresses previously assigned
(not sold) to them and these address must be re-assigned to other
organizations.<br>
</p>
<p>You mentioned someone is able to transfer address in RIPE without
having to justify the need of them and because of that he is able
to lease them. Let's assume this as true. Still if the RIR finds
(after the transfer is concluded) an organization is not using a
fair amount of the assignments then the right is to ask them to
justify and if they fail those addresses should be recovered.<br>
As leases is not a proper use of address by the organization who
received them from the RIR or by their directly connected
customers they have no propose to be kept with that organization
anymore just for speculation. Addresses are not meant to be
leased, but to get people connected to the internet. As mentioned
by Albert whatever the RIPE policy differs form ARIN it is not
mandatory for ARIN to copy or adopt it. And as mentioned in other
messages there are differences from both scenarios and regions.<br>
</p>
<p>With regards pricing and conservation the point is quiet simple:
IP addresses are never meant to be leased but to get people
connected to the internet. They must be assigned to those who
really need them not to those who can pay more. We are not talking
a manufactured product that you may produce as much as you wish
and sell and re-sell in the market freely.<br>
And the RIR is the only possible neutral organization able to
apply the rules equally to anyone following this principles. Why
would we as a community want to give it over to private companies
only interested to profit from these transactions and not
concerned about if addresses will be properly used to get people
connected or to be speculated ?<br>
</p>
<p>Allowing leases basically skips the ability from the RIR to apply
rules equally to everyone and ask for justifications whenever
needed passing it out to private profit driven organizations. Why
do we want that to happen ?<br>
</p>
<p>If someone has usage for IP addresses and cannot get them
directly from the RIR it can do via permanent transfers. Any other
ways don't serve to the interests of organizations in the region,
but only to a few private and specific interests.<br>
<br>
Fernando<br>
</p>
<div class="moz-cite-prefix">On 30/09/2019 15:02, Mike Burns wrote:<br>
</div>
<blockquote type="cite"
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<div class="WordSection1">
<p class="MsoNormal">Hi Fernando,<o:p></o:p></p>
<p class="MsoNormal"><o:p> </o:p></p>
<p class="MsoNormal">You said “RIR is and has always been the
one who drives the resources to be efficientlly assigned by
analysing justifications not private transfer companies. If an
organization is not using resouces efficiently it either may
change its resource assignment strategy otherwise it doesn't
justify for those addresses anymore and should return them
back to the RIR.”<o:p></o:p></p>
<p class="MsoNormal"><o:p> </o:p></p>
<p class="MsoNormal">There is no policy in ARIN to return
un-needed space. IPv4 resource holders own something of
value, which is what economists call an “alienable asset”. It
is possible for such resource holders to return such space to
ARIN, but you don’t have to be an economist to understand why
they don’t and haven’t for the most part.<o:p></o:p></p>
<p class="MsoNormal"><o:p> </o:p></p>
<p class="MsoNormal">Your method has been tried, and it was
really a good try. The effort was decades-long, yet recognized
a failure by the clear evidence of the routing table. So much
space allocated, yet not routed. Not enough to be explained
away by internal use; this is unconvincing. No, the space sat
on the sidelines, it was not returned to ARIN. Until the
market provided the missing incentive to action, and that
action is also quite visible in the routing table and transfer
logs. The profit incentive, the draw of lucre, the absurd
effect of price have led to an increase in the efficient use
of the IPv4 address universe. Geoff Huston did a good
analysis of the source of transferred addresses and showed the
market brought many never-routed addresses into efficient use.
<a
href="https://blog.apnic.net/2017/01/09/studying-ipv4-transfer-market-reported-transfers/"
moz-do-not-send="true">https://blog.apnic.net/2017/01/09/studying-ipv4-transfer-market-reported-transfers/</a><o:p></o:p></p>
<p class="MsoNormal"><o:p> </o:p></p>
<p class="MsoNormal">You also said “It is pretty reasonable to
think that in no RIRs you are able justify more IP space by
saying ‘I need these addresses in order to lease them to
someone else’. If that is never a possible justification that
can be used therefore leases don't make any sense.”<o:p></o:p></p>
<p class="MsoNormal"><o:p> </o:p></p>
<p class="MsoNormal">Anybody can indeed purchase RIPE addresses
via transfer solely for the purpose of leasing them out. That
is because RIPE does not have a needs justification for
transfers (nor policy forbidding leasing). And that is
because, in my opinion, the RIPE community realized that their
intrinsic role of conservation would now be undertaken by
market forces. These can be relied upon to bring un- and
under-utilized addresses to their “highest and best use”,
again as economists say.<o:p></o:p></p>
<p class="MsoNormal"><o:p> </o:p></p>
<p class="MsoNormal">But you do bring up the relevant question
in the context of this ARIN policy proposal, which is whether
leasing to a “connected” customer is all that different from
leasing to a “non-connected” customer when it comes to
justifications. In the first case, the ISP normally registers
the assignment of this block to his customer in Whois and can
use it as justification. In the second there is no such
registration requirement and the lease can’t be used as a
justification. To me this is a problem, and I think there is
a solution.<o:p></o:p></p>
<p class="MsoNormal"><o:p> </o:p></p>
<p class="MsoNormal">Conservation and Registration are our
lodestars. In this case pricing will handle conservation, but
what about registration? What about when pricing drives
Conservation at the expense of Registration? I am on record
as supporting the RIPE model, which allows for lessors to
purchase lease inventory, with registered transfers, and also
allows them to record leases as assignments that include
access to important contact information.<o:p></o:p></p>
<p class="MsoNormal"><o:p> </o:p></p>
<p class="MsoNormal">The simple and straightforward answer here
is to end the needs-test for transfers. RIPE has shown us the
way, taken the “risk” and now we can look at years’ and
thousands of transfers’ worth of data. Anybody see any
problems resulting from the dropping of the needs test in
RIPE?<o:p></o:p></p>
<p class="MsoNormal"><o:p> </o:p></p>
<p class="MsoNormal">Absent dropping the needs test for
transfers, the logical step in the context of this policy
allowing leasing, is to allow certain leases to be used for
justifications while at the same time providing policy
requiring registration (SWIP) and documentation (Letter Of
Agency). It’s my opinion that this carrot and stick approach
will induce Lessors to properly register their leases while
also providing a clear demarcation of leasing versus hijacking
that will empower our community and potentially law
enforcement. You want to purchase addresses because you think
you can make money in their rental? Fine, show us that you
are efficiently using your prior allocations and properly
registering assignments. <o:p></o:p></p>
<p class="MsoNormal"><o:p> </o:p></p>
<p class="MsoNormal">There should be no difference in the way we
treat those who assign to “non-connected” or “connected”
networks. ARIN calls a VPN a connection. Times have moved on,
and any two networks can be easily “connected” for the
purposes of policy-compliance only. So why trade the lack of
insight into IPv4 block contact information for the
maintenance of this fig-leaf?<o:p></o:p></p>
<p class="MsoNormal"><o:p> </o:p></p>
<p class="MsoNormal">Regards,<br>
Mike Burns<o:p></o:p></p>
<p class="MsoNormal"><o:p> </o:p></p>
<p class="MsoNormal"><o:p> </o:p></p>
<p class="MsoNormal"><o:p> </o:p></p>
<p class="MsoNormal"><o:p> </o:p></p>
<p class="MsoNormal"><o:p> </o:p></p>
<p class="MsoNormal"><o:p> </o:p></p>
<p class="MsoNormal"><o:p> </o:p></p>
<p class="MsoNormal"><b>From:</b> ARIN-PPML
<a class="moz-txt-link-rfc2396E" href="mailto:arin-ppml-bounces@arin.net"><arin-ppml-bounces@arin.net></a> <b>On Behalf Of </b>Fernando
Frediani<br>
<b>Sent:</b> Saturday, September 28, 2019 7:20 PM<br>
<b>To:</b> arin-ppml <a class="moz-txt-link-rfc2396E" href="mailto:arin-ppml@arin.net"><arin-ppml@arin.net></a><br>
<b>Subject:</b> Re: [arin-ppml] Draft Policy ARIN-2019-18:
LIR/ISP Re-Assignment to Non-Connected Networks<o:p></o:p></p>
<p class="MsoNormal"><o:p> </o:p></p>
<div>
<p class="MsoNormal">I strongly oppose this proposal.<o:p></o:p></p>
<div>
<p class="MsoNormal"><o:p> </o:p></p>
</div>
<div>
<p class="MsoNormal">Leasing of IP addresses in such way
should never be permmited and is a distortion of the way
IP addresses must be used by organizations.<o:p></o:p></p>
</div>
<div>
<p class="MsoNormal"><o:p> </o:p></p>
</div>
<div>
<p class="MsoNormal">The main reason is simple: if an
organization is "leasing" IP address it is a clear sign
that the organization does not have usage for that IP
space and as it doesn't justify anymore it should
therefore return them back to the RIR in order to be
re-assigned to those who really have a need for it, via
waiting list or other methods covered by the policies.<o:p></o:p></p>
</div>
<div>
<p class="MsoNormal"><o:p> </o:p></p>
</div>
<div>
<p class="MsoNormal">It is pretty reasonable to think that
in no RIRs you are able justify more IP space by saying "I
need these addresses in order to lease them to someone
else".<o:p></o:p></p>
</div>
<div>
<p class="MsoNormal">If that is never a possible
justification that can be used therefore leases don't make
any sense.<o:p></o:p></p>
</div>
<div>
<p class="MsoNormal"><o:p> </o:p></p>
</div>
<div>
<p class="MsoNormal">If an organization needs further IP
space for a temporary project it may just get from the LIR
or ISP but if that is not possible and the organization is
an Autonomous System it can just go to market and get it
transfered permanentlly.<o:p></o:p></p>
</div>
<div>
<p class="MsoNormal">Either from the RIR or transfered via
market addresses must be justified and leases are nothing
but unused address by who is willing to lease.<o:p></o:p></p>
</div>
<div>
<p class="MsoNormal"><o:p> </o:p></p>
</div>
<div>
<p class="MsoNormal">The justification given to allow
organizations to facilitate transition to IPv6 does not
apply at all as organizations can go directlly to the RIR
for that (4.10). Why would it get via a lease bypassing
the RIR ?<o:p></o:p></p>
</div>
<div>
<p class="MsoNormal"><o:p> </o:p></p>
</div>
<div>
<p class="MsoNormal"><o:p> </o:p></p>
</div>
<div>
<p class="MsoNormal">By allowing leases it is just skipping
the RIR's function to fairly re-distribute them and
passing it private companies with financial interests.<o:p></o:p></p>
</div>
<div>
<p class="MsoNormal"><o:p> </o:p></p>
</div>
<div>
<p class="MsoNormal">I think 8.5.2 is already properly
written and doesn't require any change.<o:p></o:p></p>
</div>
<div>
<p class="MsoNormal">Also Non-Connected Networks is not
properly defined.<o:p></o:p></p>
</div>
<div>
<p class="MsoNormal"><o:p> </o:p></p>
</div>
<div>
<p class="MsoNormal">Regarding the point about Conservation
to be done through market pricing I will skip to comment
such absurd thing.<o:p></o:p></p>
</div>
<div>
<p class="MsoNormal"><o:p> </o:p></p>
</div>
<div>
<p class="MsoNormal">Regards<o:p></o:p></p>
</div>
<div>
<p class="MsoNormal">Fernando<o:p></o:p></p>
</div>
</div>
<p class="MsoNormal"><o:p> </o:p></p>
<div>
<div>
<p class="MsoNormal">On Tue, 24 Sep 2019, 17:41 ARIN, <<a
href="mailto:info@arin.net" moz-do-not-send="true">info@arin.net</a>>
wrote:<o:p></o:p></p>
</div>
<blockquote style="border:none;border-left:solid #CCCCCC
1.0pt;padding:0in 0in 0in
6.0pt;margin-left:4.8pt;margin-right:0in">
<p class="MsoNormal">On 19 September 2019, the ARIN Advisory
Council (AC) accepted <br>
"ARIN-prop-277: LIR/ISP Re-Assignment to Non-Connected
Networks" as a <br>
Draft Policy.<br>
<br>
Draft Policy ARIN-2019-18 is below and can be found at:<br>
<br>
<a
href="https://www.arin.net/participate/policy/drafts/2019_18/"
target="_blank" moz-do-not-send="true">https://www.arin.net/participate/policy/drafts/2019_18/</a><br>
<br>
You are encouraged to discuss all Draft Policies on PPML.
The AC will <br>
evaluate the discussion in order to assess the conformance
of this draft <br>
policy with ARIN's Principles of Internet number resource
policy as <br>
stated in the Policy Development Process (PDP).
Specifically, these <br>
principles are:<br>
<br>
* Enabling Fair and Impartial Number Resource
Administration<br>
* Technically Sound<br>
* Supported by the Community<br>
<br>
The PDP can be found at:<br>
<a href="https://www.arin.net/participate/policy/pdp/"
target="_blank" moz-do-not-send="true">https://www.arin.net/participate/policy/pdp/</a><br>
<br>
Draft Policies and Proposals under discussion can be found
at:<br>
<a href="https://www.arin.net/participate/policy/drafts/"
target="_blank" moz-do-not-send="true">https://www.arin.net/participate/policy/drafts/</a><br>
<br>
Regards,<br>
<br>
Sean Hopkins<br>
Policy Analyst<br>
American Registry for Internet Numbers (ARIN)<br>
<br>
<br>
<br>
Draft Policy ARIN-2019-18: LIR/ISP Re-Assignment to
Non-Connected Networks<br>
<br>
Problem Statement:<br>
<br>
Businesses have a need to lease IPv4 space for limited
periods of time, <br>
as evidenced by a robust (technically prohibited)
subleasing market. The <br>
lack of legitimization of the subleasing market hinders
innovation, <br>
research, reporting, and the development of rules/industry
best <br>
practices to ensure identifiability and contactability.<br>
<br>
Policy statement:<br>
<br>
ORIGINAL POLICY LANGUAGE<br>
<br>
2.4. Local Internet Registry (LIR)<br>
<br>
A Local Internet Registry (LIR) is an IR that primarily
assigns address <br>
space to the users of the network services that it
provides. LIRs are <br>
generally Internet Service Providers (ISPs), whose
customers are <br>
primarily end users and possibly other ISPs.<br>
<br>
PROPOSED POLICY LANGUAGE<br>
<br>
A Local Internet Registry (LIR) is an IR that primarily
assigns address <br>
space to the users of the network services that it
provides. LIRs are <br>
generally Internet Service Providers (ISPs), whose
customers are <br>
primarily end users and possibly other ISPs.<br>
<br>
LIRs may also assign address space to other organizations
or customers <br>
that request it for use in an operational network.<br>
<br>
ORIGINAL POLICY LANGUAGE<br>
<br>
8.5.2 Operational Use<br>
<br>
ARIN allocates or assigns number resources to
organizations via transfer <br>
solely for the purpose of use on an operational network.<br>
<br>
PROPOSED POLICY LANGUAGE<br>
<br>
Option 1 : Remove 8.5.2 entirely<br>
<br>
Option 2 : Edit as follows<br>
<br>
8.5.2 Operational Use<br>
<br>
ARIN allocates or assigns number resources to
organizations via transfer <br>
solely primarily for the purpose of use on an operational
network, but <br>
may allocate or assign number resources to organizations
for other <br>
purposes, including re-assignment to non-connected
networks .<br>
<br>
Comments:<br>
<br>
Timetable for implementation: Immediate<br>
<br>
Anything Else:<br>
<br>
The legitimization of a subleasing market for IPv4 has
numerous business <br>
and community benefits, including (but not limited to):<br>
<br>
- Allowing organizations to efficiently utilize IPv4 space
without <br>
transferring space permanently;<br>
- Allowing organizations to obtain IPv4 space for a
limited time in <br>
order to facilitate transition to IPv6;<br>
- Allowing organizations to develop enforceable acceptable
use policies <br>
in a previously lawless illegitimate space;<br>
- Allowing the community to develop reporting and
recording standards <br>
and/or best practices to the benefit of preserving the
integrity of IPv4 <br>
address space.<br>
- We would like to engage further with the ARIN community
to discuss the <br>
current state of the unauthorized subleasing market, and
how this <br>
proposed policy change would both update ARIN policies to
reflect the <br>
reality of the subleasing market, and positively address
business and <br>
community concerns.<br>
<br>
_______________________________________________<br>
ARIN-PPML<br>
You are receiving this message because you are subscribed
to<br>
the ARIN Public Policy Mailing List (<a
href="mailto:ARIN-PPML@arin.net" target="_blank"
moz-do-not-send="true">ARIN-PPML@arin.net</a>).<br>
Unsubscribe or manage your mailing list subscription at:<br>
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href="https://lists.arin.net/mailman/listinfo/arin-ppml"
target="_blank" moz-do-not-send="true">https://lists.arin.net/mailman/listinfo/arin-ppml</a><br>
Please contact <a href="mailto:info@arin.net"
target="_blank" moz-do-not-send="true">info@arin.net</a>
if you experience any issues.<o:p></o:p></p>
</blockquote>
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