Wait so some company could come to ARIN and ask for a block of IP addresses using leasing as the justification and then turn around and lease them.
What value is the leasing company providing? It seems like a solid way to get a bunch of LLCs formed to acquire IP addresses from the waiting list and then make money for doing ~nothing. On Thu, Mar 17, 2022 at 4:18 PM Andrew Dul <andrew....@quark.net> wrote: > The draft policy as currently written does not provide any additional > limits against speculation. As drafted, it allows any organization > (including those who do not operate networks) to obtain IPv4 addresses for > the purpose of leasing. > > With that policy change what types of limits does the community think > would be needed? > > Thanks, > Andrew > > On 3/17/2022 3:00 PM, Scott Leibrand wrote: > > +1 to both Owen and David Farmer's comments. Leasing IPv4 space is likely > the best solution for some networks that need those addresses to operate > their network. If an organization wants to acquire and lease out IPv4 space > without providing bundled IPv4 transit, that should be allowed by policy. > It might be useful for ARIN policy to try to slightly dampen speculation by > requiring that organizations seeking to acquire large blocks of IPv4 space > demonstrate that their current holdings are being efficiently used by the > organization they're registered to in whois. I am not sure if this policy > proposal does that to my satisfaction, but once we ensure it does so, I > would likely support it. > > -Scott > > On Thu, Mar 17, 2022 at 1:33 PM Owen DeLong via ARIN-PPML < > arin-ppml@arin.net> wrote: > >> >> >> On Mar 16, 2022, at 15:22 , Fernando Frediani <fhfredi...@gmail.com> >> wrote: >> >> Hi David >> >> If I understand correctly you seem to have a view that there should be a >> ARIN policy to permit IPv4 leasing just because it is a reality and we kind >> of have to accept it in our days. No we don't, and that's for many >> different reasons. >> >> Well, of course, you are free to deny reality as much as you want. Many >> people do. It’s not particularly helpful in the discussion, however. >> >> I am used to see people saying the brokers are doing a good thing for the >> community by facilitating the things which in reality is the opposite. It >> may look like a good things, but the real beneficiaries are only them who >> profit from it without much concern of what is fair or not to most >> organizations involved. >> >> >> You are actually mistaken here. I used to think as you do, actually. I >> was very resistant to the first “specified transfer” policies because of >> some of the reasons you describe. However, what you are failing to >> recognize is that: >> + Brokers and specified transfers were going to happen with or without >> the RIRs. If they happened without the RIRs, >> there’d be no accurate record of who was using which address space and >> the provenance of addresses would be >> very difficult to support or defend. >> >> * Benefit to the community from brokers: (ethical) brokers are familiar >> with the rules in the RIRs in which >> they operate and can assist their customers in accurate and compliant >> registration updates and >> aid in keeping the allocation database(s) accurate. >> >> + With the economic realities of IPv4 addresses becoming progressively >> more and more expensive and the advent >> of ISPs with limited IPv4 resources available, it is inevitable that more >> and more IP service providers will be >> doing one or more of the following: >> >> + Separate surcharges for IPv4 addresses >> + Expecting customers to supply their own IPv4 addresses >> + Surcharges for IPv4 services >> + IPv4 “installation charges” large enough to cover the procurement of >> addresses >> >> * Brokers assist ISPs and customers in many of the above circumstances. >> >> + With a variety of organizations holding IPv4 addresses that may or may >> not even known they have them and whose >> IPv4 resources may vastly exceed their needs, it is (arguably) desirable >> to have those addresses be transferred to parties >> that have current need for IPv4 addresses. >> >> * Brokers provide a valuable service to the community identifying and >> marketing these resources >> * Paid transfers provide an incentive for entities to make more >> efficient use of the resources they have in order >> to monetize the resources they no longer need. Brokers are frequently >> able to assist in this process. >> >> + With the high cost of acquisition, IPv4 addresses have become a >> capital intensive part of any network-dependent >> business model that must support IPv4. Further, there is some risk that >> this capital outlay may be fore a resource >> which will abruptly and quickly lose its value and no longer be needed >> well before it can be amortized as a capital >> expenditure. As such, it may make sense for some entities to transfer >> that risk to another organization by using >> a lease structure instead of purchasing the addresses outright. >> >> * Brokers that provide IPv4 leasing in an ethical and policy compliant >> way provide a valuable service >> to these businesses. Yes, their price per address may eventually be more >> than it would have cost >> them to purchase the addresses, but the same is true of virtually any >> rental situation. On the other hand, >> that excess helps offset the risk that the lessor is taking by owning a >> resource that may or may not remain >> valuable and may or may not continue to produce revenue. >> >> IP Leasing is very different from IP Transfer which I see not problem >> they continue doing it. IP Transfer at least we have some guarantees that >> the directly receiving organization really justify for them and that is a >> quiet important (I would say fundamental) point to look at, because that is >> fairer to everyone involved. What guarantees we have when a IP Leasing is >> done in that sense, that fairness start to lack here. >> >> If we set the policies up correctly, we should have the same exact >> guarantees on a lease. >> >> If $ISP acquires a /10 through transfer and then issues various >> subordinate prefixes to their customer, the only guarantee >> you have that $ISP’s customers who receive the addresses really justify >> them is that $ISP says so. We generally trust $ISP >> to act in good faith. >> >> If $LESSOR acquires a /10 through transfer and then leases various >> subordinate prefixes to their customers, we have pretty >> much the same guarantee with the additional bit that $CUSTOMER is at >> least willing to pay enough for the addresses to $LESSOR >> to make the lease make sense. In general, I think it is somewhat safe to >> assume that $CUSTOMER is not going to make a >> monthly recurring payment to $LESSOR for something they don’t intend to >> use. If one’s intent is to deprive the market and >> inflate the price, then the risk profile for such a transaction is vastly >> more favorable if you purchase rather than lease. >> >> Sure, there could be lessors that don’t get reasonable justification for >> allocations from their customers, but there are most >> certainly ISPs in that category as well. Either way, you’ve got very >> little assurance. A lessor can provide just as much >> justification to an RIR for the addresses they will allocate to leases as >> an ISP can for addresses they will lease to their >> customers. The only difference is a lease with connectivity from the same >> company or a lease from a company other than >> the one(s) providing connectivity. >> >> People see the brokers are doing a favor to organizations in general by >> facilitating they get some chunks of IPv4, but that in reality makes the >> cost of IPv4 for both leasing and transfer more and more expensive as it >> makes organization even more dependent from these those crumbs that seem >> to be offered with good intention but in reality it is feeding a system >> that is contrary the interests to most organizations involved. >> >> Just as you are free to mount, balance, and rotate your own tires, or, >> you can go to a tire store and have them perform that service for a fee, >> brokers provide a service for a fee. If you want to obtain addresses in the >> transfer market without a broker, you’re still free to do that. Brokers are >> not driving the cost of IPv4… The scarcity and difficulty of operating with >> IPv4 is driving the cost of IPv4. Brokers are along for the ride providing >> a service and collecting a fee for that service. Whether that fee is >> reasonable or not is (and should be) entirely in the eye of the customer. >> Customers are always free to walk away and find a different supplier or >> look for their addresses independently. >> >> It may sound a cliche but IPv4 is over and organizations must learn how >> to survive with what they have, reinvent themselves and make better used of >> their IPv4 resources, deploy a proper CGNAT, deploy IPv6 either they like >> it or not, etc. If an organization have so little or none and need some >> minimal amount is fine they seek for a Transfer of a minimal amount with >> the help of brokers. >> >> I agree. However, the increasing cost of IPv4 is a natural and organic >> part of that process and sticking our heads in the sand and pretending that >> it is not the economic reality of how the current world works will not help >> anyone. Not the community, not organizations that are short on IPv4 >> resources, and not the RIRs who are only useful so long as their databases >> provide a reasonably accurate reflection of the actual utilization of the >> address space and who controls it. >> >> A broker is an LIR just like an ISP. Since ISPs are now charging for >> addresses independent of connectivity and bandwidth, it only makes sense >> that customers can shop for them separately from different suppliers. Just >> like you can buy tires for your car from the dealership or from some other >> store that sells and supports tires, IPv4 addresses are moving that way as >> well. The RIRs can either recognize this and adapt to it with policies that >> make sense and preserve some of the things you’ve outlined as concerns >> above, or, they can simply deny the reality of IPv4 leasing and lose track >> of how addresses are actually managed for some significant chunks of the >> internet. >> >> Encouraging IP Leasing as if it were something normal just "because it >> exists today" is a shot in the foot that in the long term only worsens the >> existing scenario, it feeds a market without much discretion increasing >> final prices for everyone and what is the worst of all, creates even more >> unfairness for everyone who has always submitted to the rules we have until >> today for distributing addresses to those who really have a real >> justification to keep control of that resource that does not belong to them. >> >> I don’t believe that a policy that merely allows IPv4 leasing can be said >> to encourage it. Rather, it permits it, recognizes that it exists and is >> not going to stop existing just because policy pretends it can’t exist. >> >> The market is not likely to be significantly swayed by policy in terms of >> pricing, with the exception that AFRINIC has been able to preserve a >> devalued price on addresses within their region due to their restrictive >> lack of a transfer policy for moving addresses to/from AFRINIC. However, >> while this has the effect of keeping AFRINIC IPv4 addresses less expensive >> on the open market, it also leads to a significant amount of utilization of >> those addresses outside of policy and quite a bit of hoarding of addresses >> by some of AFRINIC’s largest members. ARIN’s counsel has advised against >> naming names here, so I won’t, but if you want names, contact me off list. >> >> Owen >> >> >> Regards >> Fernando >> On 16/03/2022 13:09, David Farmer via ARIN-PPML wrote: >> >> Yes, bundling IPv4 addresses with bandwidth is permitted, and in the past >> was common practice, heck even the expected practice. However, the fact >> that IPv4 address demand isn't decreasing significantly, the costs to >> acquire new IPv4 addresses are increasing significantly, and with the >> increasing commoditization of bandwidth, it is no longer economically >> viable to bundle bandwidth, and its associated connectivity, with IPv4 >> addressing. This is driving a structural separation of bandwidth, >> connectivity, and IPv4 addressing, from each other, instead of bundling >> them together as in the past. >> >> Let me state that differently; ISPs are being driven, buy cost >> conscience consumers, to separate the costs of bandwidth and the costs of >> the IPv4 addresses needed to utilize the bandwidth from each other. >> Minimally this separation is achieved by accounting for the costs on >> separate line items of a common bill from a single provider. However, price >> competition for bandwidth and IPv4 addresses separately will inevitably >> drive a structural separation between the two. Consumers will want the best >> price they can get for bandwidth and the best price they can get for IPv4 >> addresses, regardless of whether they come from a single provider or not. >> >> Some may argue this is being driven by the existence of address brokers, >> and their desire to make money, I disagree. While address brokers making >> money is the grease that keeps this machine working, the need for the >> machine is driven by; IPv4 free pool exhaustion, the increasing cost of >> IPv4 addresses, and the lack of adoption of IPv6. >> In other words, address brokers wouldn't exist if there wasn't a demand >> for their services. >> >> In short, the economic conditions that allowed for and even encouraged >> the bundling of IPv4 addresses with bandwidth and connectivity no longer >> exist, that world is gone. While I have not personally yet determined if I >> support this particular policy text, nevertheless, the time has come to >> recognize the next step in this inextricable evolution of IPv4 address >> policy by the ARIN policy community and permit IPv4 leasing. >> >> Thanks. >> >> On Fri, Mar 11, 2022 at 5:05 PM John Santos <j...@egh.com> wrote: >> >>> I disagree. The addresses are useless unless they ALSO purchase access >>> and >>> routing from another network operator. How is this cheaper? >>> >>> It is and always has been allowed to lease bundled access of addresses >>> and >>> connectivity from a LIR, without any expense for purchasing those >>> addresses. >>> >>> >>> On 3/11/2022 12:13 PM, Tom Fantacone wrote: >>> > I support the proposal as written. >>> > >>> > It facilitates the provision of a valuable service to a large swath of >>> the ARIN >>> > community, namely the ability of network operators with an operational >>> need to >>> > lease IPv4 addresses from 3rd party lessors at a fraction of the cost >>> of >>> > purchasing those addresses. Too often we have seen network operators >>> justify >>> > their need for IPv4 space only to find that they can't afford to make >>> the >>> > purchase. They end up using CGNAT or some other sub-optimal solution. >>> > >>> > Bill, regarding your point "B", by providing IPv4 leasing, these 3rd >>> parties are >>> > certainly performing a function that ARIN does not. >>> > >>> > >>> > >>> > ---- On Thu, 10 Mar 2022 17:46:36 -0500 *William Herrin < >>> b...@herrin.us>* wrote ---- >>> > >>> > On Wed, Mar 9, 2022 at 8:24 PM ARIN <i...@arin.net <mailto: >>> i...@arin.net>> >>> > wrote: >>> > > * ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of >>> Determining >>> > Utilization for Future Allocations >>> > >>> > I continue to OPPOSE this proposal because: >>> > >>> > A) It asks ARIN to facilitate blatant and unapologetic rent-seeking >>> > behavior with changes to public policy. >>> > >>> > B) It proposes that third parties perform precisely and only the >>> > functions that ARIN itself performs without any credible compliance >>> > mechanism to assure the third party performs to ARIN's standards >>> or in >>> > accordance with the community's established number policy. >>> > >>> > Regards, >>> > Bill Herrin >>> > >>> > >>> > -- >>> > William Herrin >>> > b...@herrin.us <mailto:b...@herrin.us> >>> > https://bill.herrin.us/ <https://bill.herrin.us/> >>> > _______________________________________________ >>> > ARIN-PPML >>> > You are receiving this message because you are subscribed to >>> > the ARIN Public Policy Mailing List (ARIN-PPML@arin.net >>> > <mailto:ARIN-PPML@arin.net>). >>> > Unsubscribe or manage your mailing list subscription at: >>> > https://lists.arin.net/mailman/listinfo/arin-ppml >>> > <https://lists.arin.net/mailman/listinfo/arin-ppml> >>> > Please contact i...@arin.net <mailto: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. >>> >>> -- >>> John Santos >>> Evans Griffiths & Hart, Inc. >>> 781-861-0670 ext 539 >>> _______________________________________________ >>> 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. >> >> _______________________________________________ >> 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. > > > _______________________________________________ > 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. > -- Twitter: https://twitter.com/holdenkarau Books (Learning Spark, High Performance Spark, etc.): https://amzn.to/2MaRAG9 <https://amzn.to/2MaRAG9> YouTube Live Streams: https://www.youtube.com/user/holdenkarau
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