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<p>Hi Mike,</p>
<p>
<blockquote type="cite">OK, I think the fact that the policy was
reviewed by the AC and deemed a draft policy counters your
argument that it's not compatible with any aspect of the policy
development process. <br>
</blockquote>
</p>
<p>You are confusing Draft Policy with Recommended Draft Policy
status. Your proposal is within the scope of the PDP, thus it was
posted here. That doesn't mean it's in line with the PDP
principles to be recommended for adoption by the AC, the
discussion on this list is intended to determine that.<br>
</p>
<p>
<blockquote type="cite">I have seen the data about transfers being
the source of miscreants and frankly it makes sense even without
that report. Where else are miscreants going to get their
addresses? (RPKI is putting a dent in hijacks) And I would also
concede that the ratio of miscreants among Lessees is very high.
However I find RIPE's transfer policies to have been generally
successful and they put the lie to the fear of market-moving
speculators taking advantage of no needs-testing to buy and
hoard addresses in RIPE. On the contrary I find that RIPE has a
thriving market in IPv4 transfers, mostly smaller blocks, which
I regard as a healthy sign. But you can lease your addresses out
here in ARIN. It's just that in RIPE you can buy addresses just
for that purpose. This policy would change things so that other
businesses could enter the leasing business and address the
needs of the market, or fail if those needs don't materialize.
It's my hope that leasing professionals could help clean things
up substantially.</blockquote>
</p>
<p>I think it's pretty difficult to get an accurate picture of the
problem here. Most of the abusive networks that I find originating
in RIPE tend to have many different ASNs and /24 blocks which all
trace back to a common upstream ASN. I don't know if lots of small
blocks changing hands is evidence of a healthy market for new
entrants or a healthy market for abuse. However, I concede that
the current policy in RIPE has not produced the extreme results
that were predicted by some when the change was being made in the
short term. I do believe this will change in the long run, but it
remains to be seen.</p>
<p>
<blockquote type="cite">if there are only edge cases, there is no
leasing business to begin with. But leasing is growing from my
perspective.</blockquote>
</p>
<p>I'm not trying to argue that there is no market for leasing, or
that only edge cases might be interested in the flexibility it
provides. Rather, I am arguing that it is not in the best interest
of the community to modify policy to allow the practice to be
officially sanctioned and considered as justified need for
additional resources. If private organizations with existing
holdings want to offer the flexibility of an off-network lease
agreement, that is their choice, but I consider it to be
tantamount to an admission by that organization that they are no
longer using that space on their operational network and therefore
have no justified need based on the space. It's in use on someone
else's network, until such a time as they take it back and begin
using it on their own network again, at which point it makes sense
to me that they could offer it as justification for additional
space.</p>
<p>
<blockquote type="cite">Isaiah, you lost me here when you talk
about the pool for leasing diminishing. How is that going to
happen if the incumbents don't sell? There are many networks
larger than /20 that I lease to, so the waiting list limits are
not really anything like a deciding factor. You can't even get a
/21 from the waiting list. The waiting list is nice for small
and new networks with small needs, but it really doesn't affect
the leasing business that much.</blockquote>
</p>
<p>You would certainly be in a better position than I to say who is
interested in leasing. Regardless of the market for the service,
as you have already mentioned, there is a large proportion of
abuse activity with leased addresses and I don't find the
legitimate use cases compelling enough to outweigh the potential
for an ever increasing number of addresses to fall into the hands
of abusive networks. I firmly believe that the "skin in the game"
of operating a network that is affected by IPv4 scarcity, IPv6
deployment, and the growth of the global routing table is an
important requirement and it was included in the policy for a
reason. I don't support the idea of any company acting as a
pseudo-RIR, acting without the same oversight as the current RIR
system, however imperfect it may be. I don't think the relatively
low annual costs and quick amortization of any IPv4 block acquired
for leasing provides any incentive for such an IPv4 landlord to
clean up anything, or provide any more accurate re-allocation data
than we currently are getting with the systems in place now.</p>
<p>
<blockquote type="cite">What I am saying is that if I am an ARIN
lessor there is no financial incentive to accurately SWIP the
assignment to the Lessee, although I am totally with you that
this should be done for many reasons. But if the lessor wants to
justify any future address purchases, he will need to provide
evidence of assignment to the Lessee. This policy provides
incentive for accurate registration of leases that currently
does not exist. I probably should have led with that. But if
you think a policy proposal to strengthen penalties against
registering assigments is the better way to go, have at it. <br>
</blockquote>
</p>
<p>There is no financial incentive, but there is a policy
requirement to accurately report re-allocations and re-assignments
larger than /29. This means that the lessor in your example is
non-compliant with the policy if they fail to report the
re-assignment accurately regardless of the lack of significant
financial incentive or penalty. This isn't an optional thing that
the organization can just choose not to do. If they are
misreporting or misrepresenting their leased space to ARIN in
order to justify more resources or conceal leasing they don't want
ARIN to know about, they are committing fraud. I have never
proposed penalizing registering assignments, quite the opposite I
proposed stiffening the penalties for networks who fail to report
re-assignments and re-allocations accurately, especially with the
intent to defraud the community of resources they aren't entitled
to hold under current policy.</p>
<p>Lastly, I just want to reiterate that my primary objection with
this policy proposal is due to the potential for a deleterious
effect on the waiting list system and a replay of the past
controversies there with leasing this time instead of transfers.
Although I do not support the practice of leasing or the use of
leased resources to justify paid transfers, I admit that the
community may differ from me on that point and that there are real
economic arguments in favor of such a standalone proposal.
Regardless, I hope this policy will be amended to specify that
leased addresses cannot be considered as justified need for
waiting list requests.<br>
</p>
<p>- Isaiah<br>
</p>
<div class="moz-cite-prefix">On 9/21/2021 7:43 PM, Mike Burns wrote:<br>
</div>
<blockquote type="cite"
cite="mid:17c0af4b2d8.fd0a2c1b364929.8026168761938011426@iptrading.com">
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<div>Hi Isaiah,<br>
</div>
<div><br>
</div>
<div>I'm sorry I missed your reply but I want to answer it.<br>
</div>
<div>But I'm worried about formatting. Here goes....<br>
</div>
<div><br>
</div>
<div><br>
</div>
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<div id="Zm-_Id_-Sgn1">---- On Tue, 21 Sep 2021 20:00:09 -0400
<b>Isaiah Olson <a class="moz-txt-link-rfc2396E" href="mailto:Isaiah@olson-network.com"><Isaiah@olson-network.com></a></b> wrote
----<br>
</div>
<div><br>
</div>
<blockquote style="margin: 0px;">
<div>
<p><br>
</p>
<blockquote>Nonetheless your objection was that this
proposal somehow would not distribute resources in
accordance with policy, I think your objection was
addressed completely.<br>
</blockquote>
<div>You are certainly correct that my initial objection
was unclear. Specifically, I do not believe that this
policy is compatible with section 4.2 of the PDP
process, nor 4.3 as of this moment. Compliance with the
NRPM would seem to be irrelevant since the policy
proposal would change the NRPM.<br>
</div>
</div>
</blockquote>
</div>
<div><br>
</div>
<div><br>
</div>
<div>Mike-OK, I think the fact that the policy was reviewed by
the AC and deemed a draft policy counters your argument that
it's not compatible with any aspect of the policy development
process. <br>
</div>
<div><br>
</div>
<div class="zmail_extra" data-zbluepencil-ignore="true">
<blockquote style="margin: 0px;">
<div>
<p>You are drifting. I never made the argument you are
saying I made regarding any benefit of leasing to RIPE.<br>
</p>
<blockquote>
<div> <br>
</div>
<div>I said in response to Noah, and you now agree, that
allowing leasing will not in fact lead to the demise
of an RIR.<br>
</div>
<div>I take it you agree that Noah's objection in this
regard has been addressed.<br>
</div>
</blockquote>
<div>You are the one who opened the door to the RIPE
situation, although I would have certainly cited the
research from my first email regardless. Although you
may have addressed the extreme example brought up by
Noah, you have failed to address any of the concerns I
have raised about the results of the RIPE policy. If
I've put words in your mouth, I apologize. However, I am
asking you directly to address whether you consider the
policy implementation in RIPE to have been beneficial to
the Internet community, both in the region and as a
whole, because I would argue the data says otherwise.<br>
</div>
<div> <br>
</div>
<p>Mike- I have seen the data about transfers being the
source of miscreants and frankly it makes sense even
without that report. Where else are miscreants going to
get their addresses? (RPKI is putting a dent in hijacks)
And I would also concede that the ratio of miscreants
among Lessees is very high. However I find RIPE's
transfer policies to have been generally successful and
they put the lie to the fear of market-moving
speculators taking advantage of no needs-testing to buy
and hoard addresses in RIPE. On the contrary I find that
RIPE has a thriving market in IPv4 transfers, mostly
smaller blocks, which I regard as a healthy sign. But
you can lease your addresses out here in ARIN. It's just
that in RIPE you can buy addresses just for that
purpose. This policy would change things so that other
businesses could enter the leasing business and address
the needs of the market, or fail if those needs don't
materialize. It's my hope that leasing professionals
could help clean things up substantially.</p>
<p><br>
</p>
<blockquote>OK the waiting list is rock solid, but my wisp
needs a /21, what now? My point remains, the waiting
list is not appropriate for all those in need, and if
there were alternatives then there would be no market
for leases to begin with. I can spend all day giving
examples of legitimate lessees. I think you should
concede that there are legitimate business cases where
leases make more sense for the recipient.<br>
</blockquote>
<p><br>
</p>
<p>The waiting list may not be appropriate for all needs,
but it certainly fills in many of the gaps you are
arguing necessitate leasing. The edge cases you note may
make for a compelling argument for expanding wait list
eligibility, but I don't find them compelling enough to
justify a RIR-wide policy change to allow leased
addresses to be considered as justification, a policy
which has the potential for considerable negative side
effects to the community. The existence of a market for
leasing does not equate to a necessity for the ARIN
community to enable and subsidize the practice by
changing policy in this way. I would certainly concede
that legitimate business cases for leasing IPv4 do
exist. Unfortunately, there is a dearth of reputable
research into the leasing market, so I will refrain from
making any assertions about the proportion of legitimate
to non-legitimate use cases. Regardless, the existence
of legitimate use cases doesn't strike me as a
compelling reason to support this policy.<br>
</p>
</div>
</blockquote>
</div>
<div>Mike- if there are only edge cases, there is no leasing
business to begin with. But leasing is growing from my
perspective.</div>
<div class="zmail_extra" data-zbluepencil-ignore="true">
<blockquote style="margin: 0px;">
<div>
<blockquote><br>
</blockquote>
<div>I believe you have conceded that my assertion is
correct.<br>
</div>
<p><br>
</p>
<p>With regards to your assertions about the composition
of the pool of lessors, I would agree that you are
correct. I do not concede or agree in any way that your
assertion supports implementation of this particular
policy. I do not support the concept of LIRs acquiring
new space solely to lease off-network, and I would
prefer that the pool available for leasing off-network
dwindles over time until as much space as possible can
be brought under terms that explicitly disallow the
practice. For networks smaller than /20, the waiting
list provides an acceptable alternative and it appears
that the current rate of revocations is approximately
matched to the demand on the waiting list, for networks
larger than /20, I assert that what you propose would
only exacerbate the difficulty of obtaining a block at a
reasonable price.<br>
</p>
</div>
</blockquote>
</div>
<div>Mike- Isaiah, you lost me here when you talk about the pool
for leasing diminishing. How is that going to happen if the
incumbents don't sell? There are many networks larger than /20
that I lease to, so the waiting list limits are not really
anything like a deciding factor. You can't even get a /21 from
the waiting list. The waiting list is nice for small and new
networks with small needs, but it really doesn't affect the
leasing business that much.<br>
</div>
<div class="zmail_extra" data-zbluepencil-ignore="true">
<blockquote style="margin: 0px;">
<p><br>
</p>
<blockquote>That is the current policy, to disallow
justification without a circuit, so your objection to
this proposal means you prefer no leasing policy.<br>
</blockquote>
<p><br>
</p>
<p>You are correct here, I certainly prefer a no leasing
policy, specifically one that is stronger than the current
policy, but I still prefer the current policy to what you
propose. I do not believe it is legally or economically
feasible for ARIN to retroactively reclaim resources that
are currently being leased off-network, but I don't
consider anything you've presented here as a compelling
argument to officially sanction the practice regardless of
the historical inequalities.<br>
</p>
<p><br>
</p>
<blockquote>I consider this also a concession that what I
said is true about "providing an incentive" which is as
far as I went.<br>
</blockquote>
<p><br>
</p>
<p>You're going to need to go further if you want to garner
any significant community support for this proposal.<br>
</p>
<p><br>
</p>
<blockquote>
<div>I agree with your first contention, that this policy
could in fact lead to price increases on the transfer
market.<br>
</div>
<div> <br>
</div>
<div>But the basic math you refer to is the linkage
between the transfer market and the lease market.<br>
</div>
<div>Transfer prices have doubled this year, lease rates
have not doubled, they haven't risen anywhere nearly as
quickly.<br>
</div>
<div>I think the lack of ability to purchase blocks to
feed the lease market in ARIN serves to loosen that
coupling between the lease and transfer market.<br>
</div>
<div>Thanks for phrasing it as "if networks choose to
lease", as that is a clear understanding of the way
things work currently.<br>
</div>
<div>Lessors and lessees are choosing to engage in leasing
because they both see an advantage.<br>
</div>
<div>So let me admit my assertion that lease rates would
drop with this policy is just an assumption and not an
assertion.<br>
</div>
</blockquote>
<p><br>
</p>
<p>I would agree with your assertion that the linkage
between the transfer market and the leasing market is
loose. I expect that there will be a corresponding
increase in lease prices over time. If you have any
historical data to contradict that expectation, I'd
certainly be open to hearing it. If networks choose to
lease when there are alternatives available, I am
unconcerned if they must pay more, even significantly more
in the far flung future when the leasing pool has
dwindled, because that is the price they are choosing to
pay for the flexibility associated with a lease.<br>
</p>
<p><br>
</p>
<blockquote>Thanks, I think we understand that you do not
support the policy but I don't think that you overcame my
assertion this time.<br>
Because currently there is no "justification benefit" for
accurate registration, but this policy would create one.</blockquote>
<p><br>
</p>
<p>I don't understand what you are asserting here. There is
currently a requirement to accurately report
re-allocations. The only benefit I see is to networks that
are currently non-compliant with that policy. If networks
are failing to meet those obligations, I would argue a
better policy proposal would be one to strengthen the
penalties related to non-compliance with that policy,
rather than rewarding non-complaint networks.<br>
</p>
<p>Mike- What I am saying is that if I am an ARIN lessor
there is no financial incentive to accurately SWIP the
assignment to the Lessee, although I am totally with you
that this should be done for many reasons. But if the
lessor wants to justify any future address purchases, he
will need to provide evidence of assignment to the Lessee.
This policy provides incentive for accurate registration
of leases that currently does not exist. I probably
should have led with that. But if you think a policy
proposal to strengthen penalties against registering
assigments is the better way to go, have at it. <br>
</p>
</blockquote>
</div>
<div>Regards,<br>
</div>
<div>Mike<br>
</div>
<div><br>
</div>
<div class="zmail_extra" data-zbluepencil-ignore="true">
<blockquote style="margin: 0px;">
<div><br>
</div>
<div><br>
</div>
<div><br>
</div>
<div><br>
</div>
<div><br>
</div>
<div>- Isaiah<br>
</div>
<div class="x_1864698721moz-cite-prefix">On 9/21/2021 6:17
PM, Mike Burns wrote:<br>
</div>
<blockquote>
<div style="font-family : Verdana, Arial, Helvetica,
sans-serif; font-size : 10pt;">
<div>Hi Isaiah,<br>
</div>
<div><br>
</div>
<div>Thanks, replies inline.<br>
</div>
<div><br>
</div>
<div class="x_1864698721zmail_extra_hr"
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</div>
<div class="x_1864698721zmail_extra">
<div><br>
</div>
<div id="x_1864698721Zm-_Id_-Sgn1">---- On Tue, 21 Sep
2021 18:56:05 -0400 <b>Isaiah Olson <a
class="x_1864698721moz-txt-link-rfc2396E"
href="mailto:Isaiah@olson-network.com"
target="_blank" moz-do-not-send="true"><Isaiah@olson-network.com></a></b>
wrote ----<br>
</div>
<div><br>
</div>
<blockquote style="margin : 0px;">
<div>Hi Mike, <br>
<br>
Thanks for your reply. I would be happy to address
each of your assertions. <br>
<br>
> That RIPE situation is an unfortunate
artifact of their reserve pool <br>
> for new entrants. <br>
> <br>
> Can you share the percent of those /24s that
begin with 185? <br>
Roughly 17% of the RIPE IP space that I have on my
list comes from that <br>
block. I would hardly agree that the statistically
significant disparity <br>
in transfer market abuse activity across all RIPE
IP ranges is solely an <br>
artifact of this single block. <br>
<br>
> First you wrote “The onus is not on ARIN to
sanctify practices that <br>
> some are already engaging in, but rather to
distribute number <br>
> resources in accordance with community
developed policy.” <br>
> <br>
> My answer is that this policy proposal
continues to distribute number <br>
> resources in accordance with community
developed policy. <br>
It will be community policy if and when it is
adopted through this PDP, <br>
which seems unlikely at this point since you are
the only person arguing <br>
in favor and I don't find your arguments
particularly convincing since <br>
they are not backed up by any hard data. Whether
the policy comports <br>
with the goals of the PDP itself is a different
question.</div>
<div><br>
</div>
<div><br>
</div>
<div>Mike-Nonetheless your objection was that this
proposal somehow would not distribute resources in
accordance with policy, I think your objection was
addressed completely.<br>
<br>
> I would agree with you, but that doesn’t mean
we should ignore <br>
> relevant data from our sister registry, and I
brought up RIPE to deal <br>
> with Noah’s objection about what will happen
should this policy pass <br>
What relevant data have you provided from RIPE
which justifies your <br>
initial assertion? Certainly you may have rejected
Noah's concern that <br>
the RIR would collapse, given the fact that RIPE
still exists, but I <br>
haven't seen any compelling data cited here that
shows any benefit to <br>
the RIPE community due to their policy and I have
provided data which <br>
shows quite the opposite. A lack of immediate
negative effects is hardly <br>
sufficient data to declare that RIPE policy hasn't
caused negative long <br>
term effects, of which we may not have yet seen
the full impact.</div>
<div><br>
</div>
<div><br>
</div>
<div>Mike-You are drifting. I never made the
argument you are saying I made regarding any
benefit of leasing to RIPE.<br>
</div>
<div>I said in response to Noah, and you now agree,
that allowing leasing will not in fact lead to the
demise of an RIR.<br>
</div>
<div>I take it you agree that Noah's objection in
this regard has been addressed.<br>
</div>
</blockquote>
</div>
<div><br>
</div>
<div class="x_1864698721zmail_extra">
<blockquote style="margin : 0px;">
<div><br>
<br>
> Then you won’t have to worry about leasing,
because you claim there is<br>
> no market for it. The waiting list is not a
guaranty, and has an <br>
> unpredictable schedule for address delivery.
I gave an example of a <br>
> WISP seeking to try out a new area, and why
leasing addresses might be <br>
> quite attractive to that WISP for entirely
legitimate reasons. <br>
I would not consider the current waiting list
distributions <br>
unpredictable, in fact I would argue it's quite
the opposite in <br>
practice. Speaking from personal experience on the
waiting list before <br>
ARIN moved to quarterly distributions, I waited
only four months to <br>
receive a block. Under the last several quarterly
distributions, nearly <br>
every request on the list has been fulfilled in
each distribution, <br>
resulting in a consistent distribution schedule of
3-6 months for the <br>
last several distributions. The oldest request
currently on the list is <br>
from 07/01/2021. I would ask ARIN to please
provide some hard data about <br>
this process for the community to consider when
evaluating this policy, <br>
because I do not believe the current reality of
the waiting list agrees <br>
with your assertions. If and when that changes, I
would possibly be open <br>
to re-considering my position on the matter. <br>
<br>
With regards to leasing, I did not assert that
there is no market for <br>
leasing, but rather that alternatives to leasing
do exist and you are <br>
casting them in an a light that I do not believe
reflects the reality of <br>
the situation. Under current policy, your WISP
example is free to apply <br>
to the waiting list for the block it needs to try
out the new area, and <br>
either return or re-purpose it if services in that
new area don't work <br>
out. I don't find a compelling argument here for
the necessity of <br>
leasing addresses. <br>
</div>
<div><br>
</div>
<div><br>
</div>
<div>Mike- OK the waiting list is rock solid, but my
wisp needs a /21, what now? My point remains, the
waiting list is not appropriate for all those in
need, and if there were alternatives then there
would be no market for leases to begin with. I can
spend all day giving examples of legitimate
lessees. I think you should concede that there are
legitimate business cases where leases make more
sense for the recipient.<br>
</div>
<div><br>
</div>
<div><br>
> Opposing this policy means the only lessors
are the lucky incumbents.<br>
If the lucky incumbents choose to retain their
IPv4 space and lease it, <br>
that is certainly their choice to make. However,
under the current <br>
policy you propose to change, they may not
consider leased addresses as <br>
justification for additional space. I feel the
current policy strikes a <br>
perfectly appropriate balance. If a network has
leased space available <br>
to reclaim when leases expire, it is inappropriate
for them to seek <br>
additional allocations from the RIR. If they have
over-leased their <br>
space such that they cannot operate their network
until someone's lease <br>
expires, then they should not expect the ARIN
community to subsidize <br>
their lack of foresight with additional addresses.
Transfers in such a <br>
situation are a different matter and I would
certainly consider this <br>
policy in a different light if leasing space were
to be exempted as <br>
justification for waiting list request. <br>
</div>
<div><br>
</div>
<div><br>
</div>
<div>Mike- I believe you have conceded that my
assertion is correct.<br>
</div>
<div><br>
</div>
<div><br>
> Opposing this policy means a lack of policy
is preferred, despite the<br>
> open practice of leasing. <br>
As I originally stated in my first e-mail, I do
not prefer the lack of <br>
policy or the insufficiency of the current policy.
I would instead <br>
prefer to see the policy explicitly strengthened
to disallow off-network <br>
leasing as justification for additional requests,
despite the fact that <br>
ARIN has made it clear that they consider the
current policy to prohibit <br>
using such addresses as justification.</div>
<div><br>
</div>
<div><br>
</div>
<div>Mike - That is the current policy, to disallow
justification without a circuit, so your
objection to this proposal means you prefer no
leasing policy.<br>
</div>
<div><br>
</div>
<div><br>
</div>
<div><br>
<br>
> Opposing this policy provides incentive for
registry-shopping and<br>
> address outflow. <br>
I agree that RIR-shopping is a concern and there
is a real chance that <br>
strict policy against leasing in the ARIN region
may encourage the <br>
practice. However, I don't believe this should be
the concern of the <br>
ARIN community in deciding how to allocate
resources in our corner of <br>
the world. If other RIR communities want to make
other decisions, they <br>
are endowed with that freedom under the current
system. I don't think <br>
"everyone is jumping off the bridge so we should
too" makes for a good <br>
argument. What would convince me is hard data that
shows how the RIPE <br>
community has benefited from the elimination of
the needs-test in the <br>
transfer process, or data that demonstrates what
tangible issue your <br>
policy proposal would solve in the ARIN region.
"Current ARIN policy <br>
prevents the use of leased-out addresses as
evidence of utilization" <br>
doesn't strike me as a complete problem statement.</div>
<div><br>
</div>
<div><br>
</div>
<div>Mike-I consider this also a concession that
what I said is true about "providing an incentive"
which is as far as I went.<br>
<br>
> Opposing this policy reduces the lessor pool
and drives up lease rates. <br>
This argument cuts both ways. I would argue that
supporting the policy <br>
drives up transfer market prices by increasing
speculation by entities <br>
that have no stake in the shared Internet resource
aside from the rights <br>
to use IPv4 addresses. Basic math tells us that
higher prices in the <br>
transfer markets will result in higher prices in
the leasing market, as <br>
well as resulting in fewer blocks available to
networks who wish to <br>
obtain space directly from the RIR via transfers.
I do not see this as a <br>
benefit to the community. As I have stated before,
I am unmotivated by <br>
the impacts on lessees/lessors of keeping the
current policy or <br>
strengthening the requirement to provision actual
services on an <br>
operational network. If networks choose to lease,
they may pay more, <br>
which is a similar situation for any
capital-intensive resource that is <br>
subject to leasing. Developing policy to keep
lease rates low is not the <br>
concern of the ARIN community or this PDP, but
rather developing policy <br>
that supports efficient and technically competent
administration of the <br>
region's resources. <br>
</div>
<div><br>
</div>
<div>Mike- I agree with your first contention, that
this policy could in fact lead to price increases
on the transfer market.<br>
</div>
<div>But the basic math you refer to is the linkage
between the transfer market and the lease market.<br>
</div>
<div>Transfer prices have doubled this year, lease
rates have not doubled, they haven't risen
anywhere nearly as quickly.<br>
</div>
<div>I think the lack of ability to purchase blocks
to feed the lease market in ARIN serves to loosen
that coupling between the lease and transfer
market.<br>
</div>
<div>Thanks for phrasing it as "if networks choose
to lease", as that is a clear understanding of the
way things work currently.<br>
</div>
<div>Lessors and lessees are choosing to engage in
leasing because they both see an advantage.<br>
</div>
<div>So let me admit my assertion that lease rates
would drop with this policy is just an assumption
and not an assertion.<br>
</div>
</blockquote>
</div>
<div><br>
</div>
<div class="x_1864698721zmail_extra">
<blockquote style="margin : 0px;">
<div><br>
</div>
<div><br>
> Opposing this policy dis-incentivizes
accurate registration<br>
If networks choose to report inaccurate or
fraudulent SWIP data in order <br>
to evade the requirements of the current policy,
then they are not <br>
allocating addresses in accordance with ARIN
policy and could be subject <br>
to enforcement actions from ARIN. Although I wish
ARIN was more <br>
aggressive in maintaining an accurate WHOIS
database and abuse contacts, <br>
I would argue that the current situation in the
ARIN region is quite <br>
good compared to other RIRs in this respect, since
there has been a <br>
regular review process to ensure database accuracy
for many years. <br>
Either way, this policy proposal doesn't
fundamentally change reporting <br>
requirements, but simply blesses networks who
currently have "something <br>
to hide" to report their usage accurately.
Certainly, I can see how the <br>
policy benefits the community in this limited
sense. Still, I am <br>
unconvinced that the net effects would be positive
and I do not support <br>
the policy.</div>
<div><br>
</div>
<div>Mike - Thanks, I think we understand that you
do not support the policy but I don't think that
you overcame my assertion this time.<br>
</div>
<div>Because currently there is no "justification
benefit" for accurate registration, but this
policy would create one.<br>
</div>
</blockquote>
</div>
<div><br>
</div>
<div><br>
</div>
<div>Regards,<br>
Mike</div>
<div><br>
</div>
<div class="x_1864698721zmail_extra">
<blockquote style="margin : 0px;">
<div><br>
</div>
<div><br>
</div>
<div><br>
<br>
- Isaiah<br>
<br>
On 9/21/2021 4:29 PM, Mike Burns wrote: <br>
> <br>
> Hi Isaiah, <br>
> <br>
> That RIPE situation is an unfortunate
artifact of their reserve pool <br>
> for new entrants. <br>
> <br>
> Can you share the percent of those /24s that
begin with 185? <br>
> <br>
> You didn’t support Noah’s theory that this
policy proposal would lead <br>
> to the demise of RIRs, so let’s address your
particular objections. <br>
> <br>
> First you wrote “The onus is not on ARIN to
sanctify practices that <br>
> some are already engaging in, but rather to
distribute number <br>
> resources in accordance with community
developed policy.” <br>
> <br>
> My answer is that this policy proposal
continues to distribute number <br>
> resources in accordance with community
developed policy. <br>
> <br>
> Second you wrote:” If other RIR communities
choose to make other <br>
> decisions, that doesn't make it the correct
decision for the ARIN region.” <br>
> <br>
> I would agree with you, but that doesn’t mean
we should ignore <br>
> relevant data from our sister registry, and I
brought up RIPE to deal <br>
> with Noah’s objection about what will happen
should this policy pass” <br>
> <br>
> Third you wrote “There is a waiting list
available for legitimate new <br>
> entrants, and I don't buy the argument that
networks with greater than <br>
> a /20 cannot afford the capital outlay to
purchase a block.” <br>
> <br>
> Then you won’t have to worry about leasing,
because you claim there is <br>
> no market for it. The waiting list is not a
guaranty, and has an <br>
> unpredictable schedule for address delivery.
I gave an example of a <br>
> WISP seeking to try out a new area, and why
leasing addresses might be <br>
> quite attractive to that WISP for entirely
legitimate reasons. <br>
> <br>
> I feel I have addressed what I see as the
objections you have noted. <br>
> <br>
> Now, why not try to actually address even one
of my assertions and <br>
> tell me where it fails? <br>
> <br>
> “Opposing this policy means the only lessors
are the lucky incumbents. <br>
> <br>
> Opposing this policy means a lack of policy
is preferred, despite the <br>
> open practice of leasing. <br>
> <br>
> Opposing this policy provides incentive for
registry-shopping and <br>
> address outflow. <br>
> <br>
> Opposing this policy reduces the lessor pool
and drives up lease rates. <br>
> <br>
> Opposing this policy dis-incentivizes
accurate registration” <br>
> <br>
> Regards, <br>
> Mike <br>
> <br>
> *From:* Isaiah Olson <<a
href="mailto:isaiah@olson-network.com"
target="_blank" moz-do-not-send="true">isaiah@olson-network.com</a>>
<br>
> *Sent:* Tuesday, September 21, 2021 5:07 PM <br>
> *To:* Mike Burns <<a
href="mailto:mike@iptrading.com" target="_blank"
moz-do-not-send="true">mike@iptrading.com</a>>;
'Noah' <<a href="mailto:noah@neo.co.tz"
target="_blank" moz-do-not-send="true">noah@neo.co.tz</a>>
<br>
> *Cc:* 'ARIN-PPML List' <<a
href="mailto:arin-ppml@arin.net" target="_blank"
moz-do-not-send="true">arin-ppml@arin.net</a>>
<br>
> *Subject:* Draft Policy ARIN-2021-6: Remove
Circuit Requirement <br>
> <br>
> Mike, <br>
> <br>
> I would hardly say it's time for a funeral in
RIPE, but I would ask, <br>
> do you think it's a coincidence that roughly
75% of the /24 blocks <br>
> that I have blackholed on my network for
spamming my email server are <br>
> registered to anonymous hosting companies in
the RIPE region? I don't <br>
> agree that the results of the RIPE policy
speak for themselves, and I <br>
> would love to see more data aggregated by
some of the more talented <br>
> internet sleuths on here regarding the
proportion of abuse activity <br>
> split up by RIR. I also disagree with all
five of your assumptions <br>
> about opposing this policy. The onus is not
on ARIN to sanctify <br>
> practices that some are already engaging in,
but rather to distribute <br>
> number resources in accordance with community
developed policy. If <br>
> other RIR communities choose to make other
decisions, that doesn't <br>
> make it the correct decision for the ARIN
region. I don't support any <br>
> policy that amplifies the practice of leasing
because I reject your <br>
> arguments about the necessity of the
practice. There is a waiting list <br>
> available for legitimate new entrants, and I
don't buy the argument <br>
> that networks with greater than a /20 cannot
afford the capital outlay <br>
> to purchase a block. Please feel free to
provide any data you can to <br>
> back up your five assertions. For my
assertion, please consider the <br>
> following: <br>
> <br>
> Prefixes exchanged within the RIPE region as
sales originate have <br>
> the highest fraction of blacklisted IPs,
which is statistically <br>
> significant. <br>
> <br>
> Source: <br>
> <a
href="https://eprints.lancs.ac.uk/id/eprint/139789/1/VGiotsas_PAM2020_IPv4_Transfers_abuse.pdf"
target="_blank" moz-do-not-send="true">https://eprints.lancs.ac.uk/id/eprint/139789/1/VGiotsas_PAM2020_IPv4_Transfers_abuse.pdf</a>
<br>
> <<a
href="https://eprints.lancs.ac.uk/id/eprint/139789/1/VGiotsas_PAM2020_IPv4_Transfers_abuse.pdf"
target="_blank" moz-do-not-send="true">https://eprints.lancs.ac.uk/id/eprint/139789/1/VGiotsas_PAM2020_IPv4_Transfers_abuse.pdf</a>>
<br>
> <br>
> - Isaiah <br>
> <br>
> On 9/21/2021 3:24 PM, Mike Burns wrote: <br>
> <br>
> I am in total agreement with your sentiment
and the requirement <br>
> for a circuit should continue to stand. <br>
> <br>
> Any policy that removes such a requirement
would render the <br>
> management of Internet Number Resources by
the registry useless <br>
> and thereby essentially lead to no need for
the registry after all. <br>
> <br>
> Noah <br>
> <br>
> Hi Noah, <br>
> <br>
> Are you aware that there has been no
needs-test for RIPE transfers <br>
> for many years and the RIR system hasn’t
collapsed? <br>
> <br>
> To make it clear, in RIPE you can purchase
address space with the <br>
> sole purpose of leasing it out. And you have
been able to do that <br>
> for many years now. Plainly, openly, within
all policy. So please <br>
> let us know where to send the flowers for
RIPE’s funeral. That <br>
> goes for others who predict that bad things
will follow from <br>
> adopting this policy, please keep RIPE’s
example in mind to <br>
> provide a reality check. The experiment has
already been performed. <br>
> <br>
> Owen has already pointed out the futility of
the circuit <br>
> requirement in practice, yet you think
that’s what keeps the RIR <br>
> system functional? <br>
> <br>
> Opposing this policy means the only lessors
are the lucky incumbents. <br>
> <br>
> Opposing this policy means a lack of policy
is preferred, despite <br>
> the open practice of leasing. <br>
> <br>
> Opposing this policy provides incentive for
registry-shopping and <br>
> address outflow. <br>
> <br>
> Opposing this policy reduces the lessor pool
and drives up lease <br>
> rates. <br>
> <br>
> Opposing this policy dis-incentivizes
accurate registration. <br>
> <br>
> Let me know if any of these assertions
require amplification, I <br>
> guess some may not be clear but this is
already too long. <br>
> <br>
> Regards, <br>
> Mike <br>
> <br>
</div>
</blockquote>
</div>
<div><br>
</div>
</div>
<div><br>
</div>
</blockquote>
</blockquote>
</div>
<div><br>
</div>
</div>
<br>
</blockquote>
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