Why do you hold so much in this RIPE example even though it was already
mentioned differences that apply to different regions and mainly that
ARIN is not obliged to copy or follow everything that exists in another
region.
It is fine and legit to mention it exists over there, but you didn't
show the real lack of problems due to the policy being like that over
there, you just assumed it for the benefit of your argumentation with no
practical examples or anything to back you assumption. If you say Albert
is speculating but it seems you are too in this case.
He already mentioned very well the other several issues of allowing
leases to exist as for example increase on pricing for all (which is
only beneficial to IP transfer companies).
Furthermore as mentioned there are other concerns with regards ARIN
giving up some of its roles and passing it to the sole discretion of
those who are profiting from the transaction removing any impartiality
in analyzing the real justifications for those addresses.
Therefore I have the same view that leasing is not in the interest of
the overall community, but only to a few and specific organizations, and
there are already proper procedures for properly transfer addresses from
one organization to another.
Fernando Frediani
On 01/10/2019 12:27, Mike Burns wrote:
Hi Albert,
Your first issue is a requirement for operational use as being something
descended from heaven. It was simply the best method to fulfil our stewardship
duties in a free pool era. That duty was conservation, i.e. efficient use. So
naturally, since these were being given away for free, some limit was needed.
The limit was operational use. Now the limit is the cost of addresses, and it
is a more effective limit than the policy limit you cling to. I have
demonstrated this by linking to Geoff Huston's article showing how the market
drew addresses off the sidelines. I have pointed out that RIPE has no
requirement for operational needs and is functioning quite well. You keep
ignoring the RIPE experience, pointedly I think.
Your second issue is the lack of direct relationship between the block user and
ARIN. Sorry, that fails because this is the normal hierarchy for ISPs and LIRS
at every registry. As an ISP I can assign a block to a connected customer and
that customer has no RSA with ARIN. What's the problem? You have revealed a
distinction without a difference. The blocks are covered by RSA regardless.
You claim that anybody who doesn't use 50% of their block immediately is a
hoarder. There are a lot of hoarders in ARIN by that definition. Sorry, but I
took the time to define a speculator and your definition does not match, it's
far too broad. As far as the mechanics of it go, we are talking about the same
needs tests for leases as for connected customers, so a lessor or an owner has
the same incentives towards immediate and efficient use.
And once more, Albert, are you saying RIPE is subject to the many problems you
have speculated about, due to the complete absence of a requirement to
demonstrate use on operational network? You have gone on and on about how
wrong this is, but you can't point to the existence of a resulting problem from
dropping the needs test?
Finally, Albert, please do not start the ad hominem attacks on my positions as
resulting from selfishness. My arguments stand on their own and should be
properly evaluated as if they were anonymously offered. Surely you understand
this?
Regards,
Mike
The primary problem I have with the Draft Policy is that it eliminates the "operational
use" policy. Leasing is just a side issue. Right now, obtaining addresses in the marketplace
for the purposes of leasing them to others is not permitted because of that "operational
use" policy.
I also have an issue with another party being inserted into the transaction.
The operational use requirement is intended for the party receiving the
directed transfer and NOT another unrelated person who is NOT under contract
with ARIN. What you propose is that another party that is NOT using the
numbers sign the RSA and the lessee never does. In the case of abuse, the fact
that the party doing the abuse is not subject to a signed RSA complicates the
issues with ARIN enforcement action.
In my opinion, speculators ARE hoarders if they are not putting 50% of the
numbers to use at once as the policies generally require. If leasing is
permitted, someone willing to pay more for numbers, but is required to wait a
while to get someone to use them is tilting the market price higher as opposed
to those who want to use the numbers at once being the market price setters.
While I can see your point of view, as you represent those with numbers to
"sell", getting more money because of this change of policy. Leasing is not in
the interest of the overall community who has a current policy in place to restrict
buyers to those that intend to put the IPv4 resources to use at once.
In effect, you are proposing changing the policy, so those with numbers can get
more money for them by adding speculators to the market. This is wrong.
Albert Erdmann
Network Administrator
Paradise On Line Inc.
On Tue, 1 Oct 2019, Mike Burns wrote:
Albert wrote:
It was always understood you were supposed to turn back in unused numbers.
The market is one way to do that, by turning your unused addresses over to
someone who can use them. Leasing does not meet that standard in my mind.
Numbers are for operational networks, not for speculators.
Hi Albert and thanks for your thoughts. My I ask why the transfer market turns
unused addresses over to someone who can use them, but the leasing market does
not? Do you place such a premium on deal format? What if it's a lease-to-own
arrangement? What if it's a 10 year lease? What is different, except for
financial issues, between transfers and leases, in the context of bringing
unused addresses into use on an operational network?
Why do you think speculators would be antithetical to using numbers on
operational networks? I genuinely do not understand, unless you are
referring to that eternal bogeyman, the hoarder. You shouldn't oppose
policy in this regard until and unless somebody, somewhere has
evidence of IPv4 hoarding by speculators, ever. I define speculator
as somebody who invests money into IPv4 addresses seeking to profit
from that investment. Can somebody even offer a description of how
hoarding would work *in this market* to a speculator's benefit?
Regards,
Mike
On Mon, 30 Sep 2019, 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?
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 leasin!
g!
, 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.
Regards,
Mike
-----Original Message-----
From: ARIN-PPML <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-rep
o
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.
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