Please note that RFC2050 has be obsoleted by RFC7020 https://tools.ietf.org/html/rfc2050 https://tools.ietf.org/html/rfc7020
So you are arguing about a document that is no longer controlling. On Mon, Sep 30, 2019 at 4:23 PM Fernando Frediani <fhfredi...@gmail.com> wrote: > On 30/09/2019 18:06, Mike Burns wrote: > > Hi Fernando, > > Let me address the two items highlighted in your reply below. > > First is the reduction of ARIN to nothing more than a registration operation. > What is wrong with that? RFC2050 said the primary purpose of an RIR is > registration. We need to keep the numbers unique or everything fails. ARIN > should indeed reduce itself to registering transfers and doing what it can to > maintain accurate registration per our primary stewardship role. All else is > subservient, including conservation. But we have addressed conservation. > RIPE has been reduced to a registration operation, to use your term. What is > so wrong with RIPE? > > It also says: "*ISPs are required to utilize address space in an > efficient manner. To this end, ISPs should have documented justification > available for each assignment. The regional registry may, at any time, ask > for this information. If the information is not available, future > allocations may be impacted.In extreme cases, existing loans may be > impacted.*" > > What's wrong with that statement ? Sounds pretty reasonable to me. > Why do you wish to reduce substantially the roles of the RIRs and pass > them to private companies ? > > It also defines Conservation as: "*Fair distribution of globally unique > Internet address space according to the operational needs of the end-users > and Internet Service Providers operating networks using this address space. > Prevention of stockpiling in order to maximize the lifetime of the Internet > address space.*" > > What is wrong with that statement ? Sounds also pretty reasonable. > Or do you think that only assigning resources to those who can pay more > will be the best and more fair way to maximize the lifetime of the Internet > address space version 4 to those who really need them to get connected ? > RIRs have been the ones who check these operational needs impartially > (with no economic interests in mind) and according to the current policies. > Why remove it from them and pass to private companies to do ? > > Second is the point that one of the business cases for leasing is for > spamming. This is something to consider, but I would like for you to put > yourself into the position of a Lessor. The Lessor knows his blocks will > lose value if they are blacklisted, so they take steps to mitigate this. For > example, one notable lessor charges a $20 fee for every abuse complaint on a > leased block. The Lessee pays the $20 fee and most of it is paid to the > Lessor as compensation. This disincentivizes spamming on leased blocks. A > Lessor who gets tricked into leasing to a spammer will find his block > devalued significantly. He can get it delisted one, maybe twice if he can > spin a good story. After that, no more for that owner. So the owners have > penalties and usage terms built into the lease contract, or they get > prepayment for many months in advance, or they lease large blocks which are > not appealing to spammers. The point is this is a valid argument against > changing policy to support leasing, but the problems are long-known and the > market has applied corrections. On the other hand, spammers like to hijack > too, and having the ability to define a hijack as being non-compliant with a > lease policy will enable ARIN to pressure the address holder for a policy > violation if pressure from that side helps. > > This is more a point of view one how the things happen in practice or > should happen and I personally don't agree with that in full. > > Regards, > Mike > > > > -----Original Message----- > From: ARIN-PPML <arin-ppml-boun...@arin.net> <arin-ppml-boun...@arin.net> On > Behalf Of Fernando Frediani > Sent: Monday, September 30, 2019 4:36 PM > To: arin-ppml@arin.net > Subject: Re: [arin-ppml] Draft Policy ARIN-2019-18: LIR/ISP Re-Assignment to > Non-Connected Networks > > On 30/09/2019 15:36, hostmas...@uneedus.com wrote: > > > Currently, the ability to obtain IPv4 resources is constrained by the > requirement to prove to ARIN that you need the addresses for your > operational use in a network, which will be claimed to be no unneeded > once the "operational use" requirement is gone, leaving ARIN to be > nothing more than a registration operation. > > Excellent point raised. Couldn't agree more ! > > While this is claimed to reduce one problem with leasing IPv4 > addresses (lack of registration and associated abuse contacts) it > causes other issues. Often network abusers lease addresses for abuse, > dumping them and leasing others when they get blacklisted. > > And this too. Actually this is a well known issue. > > > On Mon, 30 Sep 2019, Mike Burns wrote: > > > Hi Fernando, > > > > 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.” > > > > 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. > > > > 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.https://blog.apnic.net/2017/01/09/studying-ipv4-transfer-market-repor > ted-transfers/ > > > > > 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.” > > > > 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. > > > > 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. > > > > 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. > > > > 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? > > > > 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. > > > > 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? > > > > Regards, > Mike Burns > > > > > > > > > > > > > > > > From: ARIN-PPML <arin-ppml-boun...@arin.net> <arin-ppml-boun...@arin.net> On > Behalf Of Fernando > Frediani > Sent: Saturday, September 28, 2019 7:20 PM > To: arin-ppml <arin-ppml@arin.net> <arin-ppml@arin.net> > Subject: Re: [arin-ppml] Draft Policy ARIN-2019-18: LIR/ISP > Re-Assignment to Non-Connected Networks > > > > I strongly oppose this proposal. > > > > 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. > > > > 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. > > > > 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. > > > > 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. > > 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. > > > > 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 ? > > > > > > By allowing leases it is just skipping the RIR's function to fairly > re-distribute them and passing it private companies with financial > interests. > > > > I think 8.5.2 is already properly written and doesn't require any > change. > > Also Non-Connected Networks is not properly defined. > > > > Regarding the point about Conservation to be done through market > pricing I will skip to comment such absurd thing. > > > > Regards > > Fernando > > > > On Tue, 24 Sep 2019, 17:41 ARIN, <i...@arin.net> <i...@arin.net> wrote: > > On 19 September 2019, the ARIN Advisory Council (AC) accepted > "ARIN-prop-277: LIR/ISP Re-Assignment to Non-Connected > Networks" as a > Draft Policy. > > Draft Policy ARIN-2019-18 is below and can be found at: > > https://www.arin.net/participate/policy/drafts/2019_18/ > > You are encouraged to discuss all Draft Policies on PPML. The > AC will > evaluate the discussion in order to assess the conformance of > this draft > policy with ARIN's Principles of Internet number resource > policy as > stated in the Policy Development Process (PDP). Specifically, > these > principles are: > > * Enabling Fair and Impartial Number Resource Administration > * Technically Sound > * Supported by the Community > > The PDP can be found at: > https://www.arin.net/participate/policy/pdp/ > > Draft Policies and Proposals under discussion can be found at: > https://www.arin.net/participate/policy/drafts/ > > Regards, > > Sean Hopkins > Policy Analyst > American Registry for Internet Numbers (ARIN) > > > > Draft Policy ARIN-2019-18: LIR/ISP Re-Assignment to > Non-Connected Networks > > Problem Statement: > > Businesses have a need to lease IPv4 space for limited periods > of time, > as evidenced by a robust (technically prohibited) subleasing > market. The > lack of legitimization of the subleasing market hinders > innovation, > research, reporting, and the development of rules/industry best > practices to ensure identifiability and contactability. > > Policy statement: > > ORIGINAL POLICY LANGUAGE > > 2.4. Local Internet Registry (LIR) > > A Local Internet Registry (LIR) is an IR that primarily assigns > address > space to the users of the network services that it provides. > LIRs are > generally Internet Service Providers (ISPs), whose customers > are > primarily end users and possibly other ISPs. > > PROPOSED POLICY LANGUAGE > > A Local Internet Registry (LIR) is an IR that primarily assigns > address > space to the users of the network services that it provides. > LIRs are > generally Internet Service Providers (ISPs), whose customers > are > primarily end users and possibly other ISPs. > > LIRs may also assign address space to other organizations or > customers > that request it for use in an operational network. > > ORIGINAL POLICY LANGUAGE > > 8.5.2 Operational Use > > ARIN allocates or assigns number resources to organizations via > transfer > solely for the purpose of use on an operational network. > > PROPOSED POLICY LANGUAGE > > Option 1 : Remove 8.5.2 entirely > > Option 2 : Edit as follows > > 8.5.2 Operational Use > > ARIN allocates or assigns number resources to organizations via > transfer > solely primarily for the purpose of use on an operational > network, but > may allocate or assign number resources to organizations for > other > purposes, including re-assignment to non-connected networks . > > Comments: > > Timetable for implementation: Immediate > > Anything Else: > > The legitimization of a subleasing market for IPv4 has numerous > business > and community benefits, including (but not limited to): > > - Allowing organizations to efficiently utilize IPv4 space > without > transferring space permanently; > - Allowing organizations to obtain IPv4 space for a limited > time in > order to facilitate transition to IPv6; > - Allowing organizations to develop enforceable acceptable use > policies > in a previously lawless illegitimate space; > - Allowing the community to develop reporting and recording > standards > and/or best practices to the benefit of preserving the > integrity of IPv4 > address space. > - We would like to engage further with the ARIN community to > discuss the > current state of the unauthorized subleasing market, and how > this > proposed policy change would both update ARIN policies to > reflect the > reality of the subleasing market, and positively address > business and > community concerns. > > _______________________________________________ > ARIN-PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). > Unsubscribe or manage your mailing list subscription at: > https://lists.arin.net/mailman/listinfo/arin-ppml > Please contact i...@arin.net if you experience any issues. > > > > > _______________________________________________ > ARIN-PPML > You are receiving this message because you are subscribed to the ARIN Public > Policy Mailing List (ARIN-PPML@arin.net). > Unsubscribe or manage your mailing list subscription > at:https://lists.arin.net/mailman/listinfo/arin-ppml > Please contact i...@arin.net if you experience any issues. > > > _______________________________________________ > ARIN-PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). > Unsubscribe or manage your mailing list subscription at: > https://lists.arin.net/mailman/listinfo/arin-ppml > Please contact i...@arin.net if you experience any issues. > -- =============================================== David Farmer Email:far...@umn.edu Networking & Telecommunication Services Office of Information Technology University of Minnesota 2218 University Ave SE Phone: 612-626-0815 Minneapolis, MN 55414-3029 Cell: 612-812-9952 ===============================================
_______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
