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-repo
r
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> On Behalf Of Fernando
Frediani
Sent: Saturday, September 28, 2019 7:20 PM
To: arin-ppml <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> 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
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