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<p>I understand your argument here now, I still don't see any
meaningful reason to financially reward networks who are currently
non-compliant with existing policy. I don't agree with your
characterization that there is no financial incentive existing
either. Networks who are non-compliant with their reporting
requirements could, in the worst case scenario, be subject to
having their space reclaimed by ARIN. I would argue this means
that, in practice, the stick is already available in policy, ARIN
is just not using it on a widespread basis at this time.<br>
</p>
<p>- Isaiah<br>
</p>
<div class="moz-cite-prefix">On 9/22/2021 9:43 AM, Mike Burns wrote:<br>
</div>
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<p class="MsoNormal">Because currently there is no
"justification benefit" for accurate registration, but this
policy would create one.<o:p></o:p></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.<o:p></o:p></p>
<p>- Isaiah<o:p></o:p></p>
<p><o:p> </o:p></p>
<p>Good morning Isaiah,<o:p></o:p></p>
<p>This policy will create a financial benefit for accurate
registration of leased addresses that currently does not
exist. I lease addresses out, but there is no financial
incentive for me to register those leases in any way at ARIN.
However if I wanted to purchase more addresses to meet the
needs of more lessees, then I would have a financial incentive
for accurate registration. I am not arguing that this should
be required, I think we all should strive for accurate
registration. But I see financial incentives as meaningful,
they are driving the IPv4 distribution system today. <o:p></o:p></p>
<p>It’s the carrot approach, but you can try the stick to see if
that would encourage more accurate assignments.<o:p></o:p></p>
<p>Regards,<br>
Mike<o:p></o:p></p>
<p><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>
<div>
<div style="border:none;border-top:solid #E1E1E1
1.0pt;padding:3.0pt 0in 0in 0in">
<p class="MsoNormal"><b>From:</b> Isaiah Olson
<a class="moz-txt-link-rfc2396E" href="mailto:Isaiah@olson-network.com"><Isaiah@olson-network.com></a> <br>
<b>Sent:</b> Tuesday, September 21, 2021 8:00 PM<br>
<b>To:</b> Mike Burns <a class="moz-txt-link-rfc2396E" href="mailto:mike@iptrading.com"><mike@iptrading.com></a><br>
<b>Cc:</b> 'ARIN-PPML List' <a class="moz-txt-link-rfc2396E" href="mailto:arin-ppml@arin.net"><arin-ppml@arin.net></a><br>
<b>Subject:</b> Re: Draft Policy ARIN-2021-6: Remove
Circuit Requirement<o:p></o:p></p>
</div>
</div>
<p class="MsoNormal"><o:p> </o:p></p>
<blockquote style="margin-top:5.0pt;margin-bottom:5.0pt">
<p class="MsoNormal">Nonetheless your objection was that this
proposal somehow would not distribute resources in
accordance with policy, I think your objection was addressed
completely.<o:p></o:p></p>
</blockquote>
<p class="MsoNormal">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.<o:p></o:p></p>
<blockquote style="margin-top:5.0pt;margin-bottom:5.0pt">
<p class="MsoNormal">You are drifting. I never made the
argument you are saying I made regarding any benefit of
leasing to RIPE.<o:p></o:p></p>
<div>
<p class="MsoNormal">I said in response to Noah, and you now
agree, that allowing leasing will not in fact lead to the
demise of an RIR.<o:p></o:p></p>
</div>
<div>
<p class="MsoNormal">I take it you agree that Noah's
objection in this regard has been addressed.<o:p></o:p></p>
</div>
</blockquote>
<p class="MsoNormal">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.<o:p></o:p></p>
<blockquote style="margin-top:5.0pt;margin-bottom:5.0pt">
<p class="MsoNormal">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.<o:p></o:p></p>
</blockquote>
<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.<o:p></o:p></p>
<blockquote style="margin-top:5.0pt;margin-bottom:5.0pt">
<p class="MsoNormal">I believe you have conceded that my
assertion is correct.<o:p></o:p></p>
</blockquote>
<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.<o:p></o:p></p>
<blockquote style="margin-top:5.0pt;margin-bottom:5.0pt">
<p class="MsoNormal">That is the current policy, to disallow
justification without a circuit, so your objection to this
proposal means you prefer no leasing policy.<o:p></o:p></p>
</blockquote>
<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.<o:p></o:p></p>
<blockquote style="margin-top:5.0pt;margin-bottom:5.0pt">
<p class="MsoNormal">I consider this also a concession that
what I said is true about "providing an incentive" which is
as far as I went.<o:p></o:p></p>
</blockquote>
<p>You're going to need to go further if you want to garner any
significant community support for this proposal.<o:p></o:p></p>
<blockquote style="margin-top:5.0pt;margin-bottom:5.0pt">
<p class="MsoNormal">I agree with your first contention, that
this policy could in fact lead to price increases on the
transfer market.<o:p></o:p></p>
<div>
<p class="MsoNormal">But the basic math you refer to is the
linkage between the transfer market and the lease market.<o:p></o:p></p>
</div>
<div>
<p class="MsoNormal">Transfer prices have doubled this year,
lease rates have not doubled, they haven't risen anywhere
nearly as quickly.<o:p></o:p></p>
</div>
<div>
<p class="MsoNormal">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.<o:p></o:p></p>
</div>
<div>
<p class="MsoNormal">Thanks for phrasing it as "if networks
choose to lease", as that is a clear understanding of the
way things work currently.<o:p></o:p></p>
</div>
<div>
<p class="MsoNormal">Lessors and lessees are choosing to
engage in leasing because they both see an advantage.<o:p></o:p></p>
</div>
<p class="MsoNormal">So let me admit my assertion that lease
rates would drop with this policy is just an assumption and
not an assertion.<o:p></o:p></p>
</blockquote>
<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.<o:p></o:p></p>
<blockquote style="margin-top:5.0pt;margin-bottom:5.0pt">
<p class="MsoNormal">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.<o:p></o:p></p>
</blockquote>
<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.<o:p></o:p></p>
<p>- Isaiah<o:p></o:p></p>
<div>
<p class="MsoNormal">On 9/21/2021 6:17 PM, Mike Burns wrote:<o:p></o:p></p>
</div>
<blockquote style="margin-top:5.0pt;margin-bottom:5.0pt">
<div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">Hi
Isaiah,<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">Thanks,
replies inline.<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div style="border:none;border-top:solid #CCCCCC
1.0pt;padding:0in 0in 0in
0in;margin-top:7.5pt;margin-bottom:7.5pt">
<p class="MsoNormal" style="mso-line-height-alt:0pt"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
<div id="Zm-_Id_-Sgn1">
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">----
On Tue, 21 Sep 2021 18:56:05 -0400 <b>Isaiah Olson
<a href="mailto:Isaiah@olson-network.com"
moz-do-not-send="true"><Isaiah@olson-network.com></a></b>
wrote ----<o:p></o:p></span></p>
</div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
<blockquote>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">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.<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">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.<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">Mike-You
are drifting. I never made the argument you are
saying I made regarding any benefit of leasing to
RIPE.<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">I
said in response to Noah, and you now agree, that
allowing leasing will not in fact lead to the
demise of an RIR.<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">I
take it you agree that Noah's objection in this
regard has been addressed.<o:p></o:p></span></p>
</div>
</blockquote>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<blockquote>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><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. <o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">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.<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><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. <o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">Mike-
I believe you have conceded that my assertion is
correct.<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><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.<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">Mike
- That is the current policy, to disallow
justification without a circuit, so your
objection to this proposal means you prefer no
leasing policy.<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><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.<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">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. <o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">Mike-
I agree with your first contention, that this
policy could in fact lead to price increases on
the transfer market.<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">But
the basic math you refer to is the linkage between
the transfer market and the lease market.<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">Transfer
prices have doubled this year, lease rates have
not doubled, they haven't risen anywhere nearly as
quickly.<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">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.<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">Thanks
for phrasing it as "if networks choose to lease",
as that is a clear understanding of the way things
work currently.<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">Lessors
and lessees are choosing to engage in leasing
because they both see an advantage.<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">So
let me admit my assertion that lease rates would
drop with this policy is just an assumption and
not an assertion.<o:p></o:p></span></p>
</div>
</blockquote>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<blockquote>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><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.<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">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.<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">Because
currently there is no "justification benefit" for
accurate registration, but this policy would
create one.<o:p></o:p></span></p>
</div>
</blockquote>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif">Regards,<br>
Mike<o:p></o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<blockquote>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
<div>
<p class="MsoNormal"><span
style="font-size:10.0pt;font-family:"Verdana",sans-serif"><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>
> <o:p></o:p></span></p>
</div>
</blockquote>
</div>
<div>
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style="font-size:10.0pt;font-family:"Verdana",sans-serif"><o:p> </o:p></span></p>
</div>
</div>
<p class="MsoNormal"><o:p> </o:p></p>
</blockquote>
</div>
</blockquote>
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