Leasing involves a contract for services, just like an ISP. It’s no more arms length than leasing addresses to someone you sell connectivity to, you have a nearly identical contractual relationship.
In fact, many ISPs charge for former customers to retain their addresses after they terminate their connectivity. How does that differ from a company which leases addresses without connectivity? I’m currently neither in favor of nor opposed to the proposed policy as written. I think it needs work before it’s ready to be a policy. However, I am in favor of formalizing the practice of leasing in policy since it is the economic reality of IPv4 for the foreseeable future, whether it is formalized in policy or not. Owen > On Mar 18, 2022, at 16:13, Michael Peddemors <mich...@linuxmagic.com> wrote: > > I oppose.. > > This removes ARIN's governance of IPv4 resources completely. And in a worst > case scenario a single party could buy up all of the IPv4 resources in > theory, and effectively control the internet. > > "Leasing" is for to wide of a definition, and needs to be better described > before even considering this. > > "leasing" is not a usage, IMHO in terms of the original mandate of ARIN, > without a fixed customer base for services (eg, it could be said every ISP > leases IPs to their customers) which is very different than saying we rent > the IP(s) to arm's length parties. > > On 2022-03-17 17:23, Owen DeLong via ARIN-PPML wrote: >> Actually, they’d be doing all of the same things any other LIR does with the >> exception of providing bandwidth and connectivity services. >> They’d still be responsible for getting a reasonable justification from the >> customer, validating that justification, registering the addresses properly >> in whois, etc. >> It might be a bit less overhead than being an ISP, but ISPs are increasingly >> short on IPv4 addresses and asking customers to get their own. >> Many customers are unable to make the capital outlay necessary to purchase >> the addresses they need, but do have the cash flow to support a lease. >> Many customers have a desire not to take the risk of a large capital outlay >> for a necessary component which may abruptly lose its value in the near to >> medium term. >> This situation will only get worse as the cost of IPv4 addresses continues >> to rise and as IPv6 deployment continues. >> Owen >>> On Mar 17, 2022, at 16:28 , Holden Karau <hol...@pigscanfly.ca >>> <mailto:hol...@pigscanfly.ca>> wrote: >>> >>> 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 >>> <mailto: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 <mailto:arin-ppml@arin.net>> wrote: >>>> >>>> >>>> >>>>> On Mar 16, 2022, at 15:22 , Fernando Frediani >>>>> <fhfredi...@gmail.com <mailto: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 >>>>>> <mailto: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 <mailto:b...@herrin.us>>* wrote ---- >>>>>> > >>>>>> > On Wed, Mar 9, 2022 at 8:24 PM ARIN >>>>>> <i...@arin.net >>>>>> <mailto:i...@arin.net> <mailto: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> <mailto:b...@herrin.us >>>>>> <mailto:b...@herrin.us>> >>>>>> > https://bill.herrin.us/ >>>>>> <https://bill.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> >>>>>> > <mailto: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> >>>>>> > >>>>>> <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> <mailto: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 <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. >>>>>> >>>>>> -- 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 >>>>>> <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. >>>>>> >>>>>> >>>>>> >>>>>> -- =============================================== >>>>>> David Farmer Email:far...@umn.edu >>>>>> <mailto:email%3afar...@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 >>>>>> 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