Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Ron Grant]

Have you looked at the waitlist lately? it's pretty long. Will take 
quite a while, and you might get a /24. Can't get anything higher than a 
/22, and that only if you lie through your teeth about your justification.


It just doesn't strike me as something that's going to materially affect 
anybody, not even the people on the waitlist.


But I still agree that amending the waitlist "Terms" to specifically 
exclude leasing would not be a bad thing - after all we also exclude 
transfers.


As for the general market, as David says, that horse has sailed. There 
is leasing, it's not going away, nobody has so far outlawed it, that's a 
separate subject.


I know one client who leases addresses to people ON THE WAITLIST so they 
can get their businesses working while WAITING for their "free" 
addresses. That sounds to me like a net positivemaybe by the time 
they get their 'freebie' they'll need BOTH blocks and that's a great thing.




On 2023-05-08 7:07 p.m., David Farmer via ARIN-PPML wrote:
It’s easy you you and me to say someone else would be better off 
buying a /24 at ~$10K on the transfer market, than leasing it from 
their transit provider or a third party. I tend to agree with that, 
but it’s not my money, so maybe my opinion doesn’t matter.


On Mon, May 8, 2023 at 20:36 Michael B. Williams 
 wrote:


I don’t believe third party leasing at a /24 or higher is in
anyone’s best interest expect IP brokers and those obtaining IP
resources with the intent to resell.

I’m not against portability but if a participant wants portability
they’d need a /24 or higher. Aquire their own IP resources…

On Mon, May 8, 2023 at 21:30 David Farmer via ARIN-PPML
 wrote:

At one time you couldn’t take your Telephone number with you
provider to provider, those rules were changed, because it was
in the telephone consumer’s interest.

Can you consider that maybe it is in the Internet consumer’s
to make some changes to the IPv4 address leasing rules at this
time. I’m not suggesting full Internet address portability,
but allowing 3rd party leasing especially at the /24 level
could be beneficial to the Internet consumer’s interest, at
least in my opinion.

There are bigger picture issues at play in this conversation,
should they win the day, maybe not, but dismissing them out of
had isn’t a good idea either.

Thanks.

On Mon, May 8, 2023 at 20:06 Fernando Frediani
 wrote:

On 08/05/2023 21:54, David Farmer wrote:



In my opinion, your very technical definition of leasing
is an anachronism. The reality is if you want/need more
than a /29 of addresses, and you don’t already have them,
you will need to pay for them one way or another on top
of your transit bandwidth, through the transfer market,
leasing them from your transit provider, or leasing them
from a 3rd party, this is today’s reality, like it or not.


Getting it from the transit provider who is building
Internet infrastructure and providing connectivity is
fine, has always been. Getting from a 3rd party who is
just speculating around IP space and not interested in
building any Internet stuff not. It does not matter what
reality may be happening in some places, if that is wrong
it does not make it look right because some are doing and
find that a normal thing because it fits to their
commercial needs. Is Congress willing to change law to
make crimes in the top of list not to be a crime anymore
because that is happening more often?
You are only authorized to trade with what you bought and own.

Fernando



Thanks

On Mon, May 8, 2023 at 18:23 Fernando Frediani
 wrote:

Hi Willian. A customer who holds an ASN and is a ARIN
member should not get IP space to announce with their
own ASN from the ISP provider but directly with ARIN
in all cases.
Legal risk will always exists and it is not because
it exists it should not be taken, just need to
evaluated and worked.

There has been a proposal presented not much a while
ago that intended to get that separation better
worded and which was still in the process of getting
feedback and improvements, but AC quickly dismissed
it in a questionable way despite there has been
people interested in discussing and improving it. A
pity. There has not even been a chance to get a
improved text in that sense.
And honestly there will always be some 

Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[David Farmer via ARIN-PPML]

It’s easy you you and me to say someone else would be better off buying a
/24 at ~$10K on the transfer market, than leasing it from their transit
provider or a third party. I tend to agree with that, but it’s not my
money, so maybe my opinion doesn’t matter.

On Mon, May 8, 2023 at 20:36 Michael B. Williams <
michael.willi...@glexia.com> wrote:

> I don’t believe third party leasing at a /24 or higher is in anyone’s best
> interest expect IP brokers and those obtaining IP resources with the intent
> to resell.
>
> I’m not against portability but if a participant wants portability they’d
> need a /24 or higher. Aquire their own IP resources…
>
> On Mon, May 8, 2023 at 21:30 David Farmer via ARIN-PPML <
> arin-ppml@arin.net> wrote:
>
>> At one time you couldn’t take your Telephone number with you provider to
>> provider, those rules were changed, because it was in the telephone
>> consumer’s interest.
>>
>> Can you consider that maybe it is in the Internet consumer’s to make some
>> changes to the IPv4 address leasing rules at this time. I’m not suggesting
>> full Internet address portability, but allowing 3rd party leasing
>> especially at the /24 level could be beneficial to the Internet consumer’s
>> interest, at least in my opinion.
>>
>> There are bigger picture issues at play in this conversation, should they
>> win the day, maybe not, but dismissing them out of had isn’t a good idea
>> either.
>>
>> Thanks.
>>
>> On Mon, May 8, 2023 at 20:06 Fernando Frediani 
>> wrote:
>>
>>> On 08/05/2023 21:54, David Farmer wrote:
>>>
>>> 
>>>
>>> In my opinion, your very technical definition of leasing is an
>>> anachronism. The reality is if you want/need more than a /29 of addresses,
>>> and you don’t already have them, you will need to pay for them one way or
>>> another on top of your transit bandwidth, through the transfer market,
>>> leasing them from your transit provider, or leasing them from a 3rd party,
>>> this is today’s reality, like it or not.
>>>
>>> Getting it from the transit provider who is building Internet
>>> infrastructure and providing connectivity is fine, has always been. Getting
>>> from a 3rd party who is just speculating around IP space and not interested
>>> in building any Internet stuff not. It does not matter what reality may be
>>> happening in some places, if that is wrong it does not make it look right
>>> because some are doing and find that a normal thing because it fits to
>>> their commercial needs. Is Congress willing to change law to make crimes in
>>> the top of list not to be a crime anymore because that is happening more
>>> often?
>>> You are only authorized to trade with what you bought and own.
>>>
>>> Fernando
>>>
>>>
>>> Thanks
>>>
>>> On Mon, May 8, 2023 at 18:23 Fernando Frediani 
>>> wrote:
>>>
 Hi Willian. A customer who holds an ASN and is a ARIN member should not
 get IP space to announce with their own ASN from the ISP provider but
 directly with ARIN in all cases.
 Legal risk will always exists and it is not because it exists it should
 not be taken, just need to evaluated and worked.

 There has been a proposal presented not much a while ago that intended
 to get that separation better worded and which was still in the process of
 getting feedback and improvements, but AC quickly dismissed it in a
 questionable way despite there has been people interested in discussing and
 improving it. A pity. There has not even been a chance to get a improved
 text in that sense.
 And honestly there will always be some way someone will find out to try
 to circumvent rules and I don't think there will be a perfect text, but a
 reasonable one that can cover most scenarios can play a important role in
 reducing scenarios where resources can be misused.
 On 08/05/2023 19:45, William Herrin wrote:

 On Mon, May 8, 2023 at 3:26 PM Fernando Frediani  
  wrote:

 Another thing which many here are targeting about IP leasing
 in the sense of renting, speculation made by those who don't
 build or offer any Internet infrastructure and services. In other
 words someone holding IP space and not using it to build any
 Internet infrastructure and services.

 Hi Fernando,

 You may be missing my point. How do you differentiate in policy between:

 Scenario 1: ISP A provides a T1 and a /24. ISP B provides a gigabit
 ethernet. Customer routes with BGP on both but depreferences ISP A so
 it never shows up in the Internet BGP tables.

 Scenario 2: Pretextual ISP C (the defacto address leaser) provides a
 /24 and a VPN (or virtual machine other nil-cost transit consuming
 mechanism). ISP D provides a gigabit ethernet. Customer routes with
 BGP on both but depreferences ISP C so it never shows up in the
 Internet BGP tables.

 Scenario 1 is considered reasonable and has been for the entire
 lifetime of the RIRs.

 

Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Michael B. Williams via ARIN-PPML]

I don’t believe third party leasing at a /24 or higher is in anyone’s best
interest expect IP brokers and those obtaining IP resources with the intent
to resell.

I’m not against portability but if a participant wants portability they’d
need a /24 or higher. Aquire their own IP resources…

On Mon, May 8, 2023 at 21:30 David Farmer via ARIN-PPML 
wrote:

> At one time you couldn’t take your Telephone number with you provider to
> provider, those rules were changed, because it was in the telephone
> consumer’s interest.
>
> Can you consider that maybe it is in the Internet consumer’s to make some
> changes to the IPv4 address leasing rules at this time. I’m not suggesting
> full Internet address portability, but allowing 3rd party leasing
> especially at the /24 level could be beneficial to the Internet consumer’s
> interest, at least in my opinion.
>
> There are bigger picture issues at play in this conversation, should they
> win the day, maybe not, but dismissing them out of had isn’t a good idea
> either.
>
> Thanks.
>
> On Mon, May 8, 2023 at 20:06 Fernando Frediani 
> wrote:
>
>> On 08/05/2023 21:54, David Farmer wrote:
>>
>> 
>>
>> In my opinion, your very technical definition of leasing is an
>> anachronism. The reality is if you want/need more than a /29 of addresses,
>> and you don’t already have them, you will need to pay for them one way or
>> another on top of your transit bandwidth, through the transfer market,
>> leasing them from your transit provider, or leasing them from a 3rd party,
>> this is today’s reality, like it or not.
>>
>> Getting it from the transit provider who is building Internet
>> infrastructure and providing connectivity is fine, has always been. Getting
>> from a 3rd party who is just speculating around IP space and not interested
>> in building any Internet stuff not. It does not matter what reality may be
>> happening in some places, if that is wrong it does not make it look right
>> because some are doing and find that a normal thing because it fits to
>> their commercial needs. Is Congress willing to change law to make crimes in
>> the top of list not to be a crime anymore because that is happening more
>> often?
>> You are only authorized to trade with what you bought and own.
>>
>> Fernando
>>
>>
>> Thanks
>>
>> On Mon, May 8, 2023 at 18:23 Fernando Frediani 
>> wrote:
>>
>>> Hi Willian. A customer who holds an ASN and is a ARIN member should not
>>> get IP space to announce with their own ASN from the ISP provider but
>>> directly with ARIN in all cases.
>>> Legal risk will always exists and it is not because it exists it should
>>> not be taken, just need to evaluated and worked.
>>>
>>> There has been a proposal presented not much a while ago that intended
>>> to get that separation better worded and which was still in the process of
>>> getting feedback and improvements, but AC quickly dismissed it in a
>>> questionable way despite there has been people interested in discussing and
>>> improving it. A pity. There has not even been a chance to get a improved
>>> text in that sense.
>>> And honestly there will always be some way someone will find out to try
>>> to circumvent rules and I don't think there will be a perfect text, but a
>>> reasonable one that can cover most scenarios can play a important role in
>>> reducing scenarios where resources can be misused.
>>> On 08/05/2023 19:45, William Herrin wrote:
>>>
>>> On Mon, May 8, 2023 at 3:26 PM Fernando Frediani  
>>>  wrote:
>>>
>>> Another thing which many here are targeting about IP leasing
>>> in the sense of renting, speculation made by those who don't
>>> build or offer any Internet infrastructure and services. In other
>>> words someone holding IP space and not using it to build any
>>> Internet infrastructure and services.
>>>
>>> Hi Fernando,
>>>
>>> You may be missing my point. How do you differentiate in policy between:
>>>
>>> Scenario 1: ISP A provides a T1 and a /24. ISP B provides a gigabit
>>> ethernet. Customer routes with BGP on both but depreferences ISP A so
>>> it never shows up in the Internet BGP tables.
>>>
>>> Scenario 2: Pretextual ISP C (the defacto address leaser) provides a
>>> /24 and a VPN (or virtual machine other nil-cost transit consuming
>>> mechanism). ISP D provides a gigabit ethernet. Customer routes with
>>> BGP on both but depreferences ISP C so it never shows up in the
>>> Internet BGP tables.
>>>
>>> Scenario 1 is considered reasonable and has been for the entire
>>> lifetime of the RIRs.
>>>
>>> Scenario 2 is the objectionable address leasing arrangement with a
>>> tiny bit of fluff to bring it into technical compliance with ARIN
>>> policy.
>>>
>>>
>>> You can't tell ARIN to just exercise their judgement whether something
>>> is defacto leasing. That creates legal risk to the organization where
>>> they can't effectively act against the people they "know" to be
>>> leasers.
>>>
>>> You have to write a policy that outright breaks scenario #2 without
>>> harming 

Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[David Farmer via ARIN-PPML]

At one time you couldn’t take your Telephone number with you provider to
provider, those rules were changed, because it was in the telephone
consumer’s interest.

Can you consider that maybe it is in the Internet consumer’s to make some
changes to the IPv4 address leasing rules at this time. I’m not suggesting
full Internet address portability, but allowing 3rd party leasing
especially at the /24 level could be beneficial to the Internet consumer’s
interest, at least in my opinion.

There are bigger picture issues at play in this conversation, should they
win the day, maybe not, but dismissing them out of had isn’t a good idea
either.

Thanks.

On Mon, May 8, 2023 at 20:06 Fernando Frediani  wrote:

> On 08/05/2023 21:54, David Farmer wrote:
>
> 
>
> In my opinion, your very technical definition of leasing is an
> anachronism. The reality is if you want/need more than a /29 of addresses,
> and you don’t already have them, you will need to pay for them one way or
> another on top of your transit bandwidth, through the transfer market,
> leasing them from your transit provider, or leasing them from a 3rd party,
> this is today’s reality, like it or not.
>
> Getting it from the transit provider who is building Internet
> infrastructure and providing connectivity is fine, has always been. Getting
> from a 3rd party who is just speculating around IP space and not interested
> in building any Internet stuff not. It does not matter what reality may be
> happening in some places, if that is wrong it does not make it look right
> because some are doing and find that a normal thing because it fits to
> their commercial needs. Is Congress willing to change law to make crimes in
> the top of list not to be a crime anymore because that is happening more
> often?
> You are only authorized to trade with what you bought and own.
>
> Fernando
>
>
> Thanks
>
> On Mon, May 8, 2023 at 18:23 Fernando Frediani 
> wrote:
>
>> Hi Willian. A customer who holds an ASN and is a ARIN member should not
>> get IP space to announce with their own ASN from the ISP provider but
>> directly with ARIN in all cases.
>> Legal risk will always exists and it is not because it exists it should
>> not be taken, just need to evaluated and worked.
>>
>> There has been a proposal presented not much a while ago that intended to
>> get that separation better worded and which was still in the process of
>> getting feedback and improvements, but AC quickly dismissed it in a
>> questionable way despite there has been people interested in discussing and
>> improving it. A pity. There has not even been a chance to get a improved
>> text in that sense.
>> And honestly there will always be some way someone will find out to try
>> to circumvent rules and I don't think there will be a perfect text, but a
>> reasonable one that can cover most scenarios can play a important role in
>> reducing scenarios where resources can be misused.
>> On 08/05/2023 19:45, William Herrin wrote:
>>
>> On Mon, May 8, 2023 at 3:26 PM Fernando Frediani  
>>  wrote:
>>
>> Another thing which many here are targeting about IP leasing
>> in the sense of renting, speculation made by those who don't
>> build or offer any Internet infrastructure and services. In other
>> words someone holding IP space and not using it to build any
>> Internet infrastructure and services.
>>
>> Hi Fernando,
>>
>> You may be missing my point. How do you differentiate in policy between:
>>
>> Scenario 1: ISP A provides a T1 and a /24. ISP B provides a gigabit
>> ethernet. Customer routes with BGP on both but depreferences ISP A so
>> it never shows up in the Internet BGP tables.
>>
>> Scenario 2: Pretextual ISP C (the defacto address leaser) provides a
>> /24 and a VPN (or virtual machine other nil-cost transit consuming
>> mechanism). ISP D provides a gigabit ethernet. Customer routes with
>> BGP on both but depreferences ISP C so it never shows up in the
>> Internet BGP tables.
>>
>> Scenario 1 is considered reasonable and has been for the entire
>> lifetime of the RIRs.
>>
>> Scenario 2 is the objectionable address leasing arrangement with a
>> tiny bit of fluff to bring it into technical compliance with ARIN
>> policy.
>>
>>
>> You can't tell ARIN to just exercise their judgement whether something
>> is defacto leasing. That creates legal risk to the organization where
>> they can't effectively act against the people they "know" to be
>> leasers.
>>
>> You have to write a policy that outright breaks scenario #2 without
>> harming scenario #1.That's the utilization count approach. ISP A in
>> scenario #1 is not particularly bothered if ARIN gets a bee in their
>> bonnet about counting that /24 utilized. So they have to be at 81%
>> instead of 80%. Same difference.
>>
>> ISP C in scenario #2, that's their entire business. If ARIN counts it
>> unutilized, they're out of business.
>>
>> Get it?
>>
>> Regards,
>> Bill Herrin
>>
>>
>> ___
>> ARIN-PPML
>> You are 

Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Fernando Frediani]

On 08/05/2023 21:54, David Farmer wrote:



In my opinion, your very technical definition of leasing is an 
anachronism. The reality is if you want/need more than a /29 of 
addresses, and you don’t already have them, you will need to pay for 
them one way or another on top of your transit bandwidth, through the 
transfer market, leasing them from your transit provider, or leasing 
them from a 3rd party, this is today’s reality, like it or not.


Getting it from the transit provider who is building Internet 
infrastructure and providing connectivity is fine, has always been. 
Getting from a 3rd party who is just speculating around IP space and not 
interested in building any Internet stuff not. It does not matter what 
reality may be happening in some places, if that is wrong it does not 
make it look right because some are doing and find that a normal thing 
because it fits to their commercial needs. Is Congress willing to change 
law to make crimes in the top of list not to be a crime anymore because 
that is happening more often?

You are only authorized to trade with what you bought and own.

Fernando



Thanks

On Mon, May 8, 2023 at 18:23 Fernando Frediani  
wrote:


Hi Willian. A customer who holds an ASN and is a ARIN member
should not get IP space to announce with their own ASN from the
ISP provider but directly with ARIN in all cases.
Legal risk will always exists and it is not because it exists it
should not be taken, just need to evaluated and worked.

There has been a proposal presented not much a while ago that
intended to get that separation better worded and which was still
in the process of getting feedback and improvements, but AC
quickly dismissed it in a questionable way despite there has been
people interested in discussing and improving it. A pity. There
has not even been a chance to get a improved text in that sense.
And honestly there will always be some way someone will find out
to try to circumvent rules and I don't think there will be a
perfect text, but a reasonable one that can cover most scenarios
can play a important role in reducing scenarios where resources
can be misused.

On 08/05/2023 19:45, William Herrin wrote:

On Mon, May 8, 2023 at 3:26 PM Fernando Frediani  
  wrote:

Another thing which many here are targeting about IP leasing
in the sense of renting, speculation made by those who don't
build or offer any Internet infrastructure and services. In other
words someone holding IP space and not using it to build any
Internet infrastructure and services.

Hi Fernando,

You may be missing my point. How do you differentiate in policy between:

Scenario 1: ISP A provides a T1 and a /24. ISP B provides a gigabit
ethernet. Customer routes with BGP on both but depreferences ISP A so
it never shows up in the Internet BGP tables.

Scenario 2: Pretextual ISP C (the defacto address leaser) provides a
/24 and a VPN (or virtual machine other nil-cost transit consuming
mechanism). ISP D provides a gigabit ethernet. Customer routes with
BGP on both but depreferences ISP C so it never shows up in the
Internet BGP tables.

Scenario 1 is considered reasonable and has been for the entire
lifetime of the RIRs.

Scenario 2 is the objectionable address leasing arrangement with a
tiny bit of fluff to bring it into technical compliance with ARIN
policy.


You can't tell ARIN to just exercise their judgement whether something
is defacto leasing. That creates legal risk to the organization where
they can't effectively act against the people they "know" to be
leasers.

You have to write a policy that outright breaks scenario #2 without
harming scenario #1.That's the utilization count approach. ISP A in
scenario #1 is not particularly bothered if ARIN gets a bee in their
bonnet about counting that /24 utilized. So they have to be at 81%
instead of 80%. Same difference.

ISP C in scenario #2, that's their entire business. If ARIN counts it
unutilized, they're out of business.

Get it?

Regards,
Bill Herrin


___
ARIN-PPML
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===
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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

Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[David Farmer via ARIN-PPML]

Fernando,

You are using a very technical definition of leasing, and at least
historically you are correct.

However, with IPv4 runout the market place has changed significantly.
For example, I recently worked on a national scale RFP for the research and
education community, as part of it we asked the respondents about pricing
for IPv4 blocks provided with their DIA Internet services, consistent with
your view of how IP addresses should be provided. The responses ranged from
$1 - $5 per IPv4 address per month for midsized blocks (/28 - /26) and $.30
- $5 per IPv4 address per month for larger blocks (/25 - /21).

That a range of $600 to $10k a month for a /21, just for addresses and on
top of the transit bandwidth charges, and only half of the respondents
would even provide a block that big, the other half wouldn’t provide any
blocks bigger than a /24.

So, when I say all ISP are leasing addresses, this is the market reality
I’m referring too. The very technical definition of leasing you are talking
about has been overtaken by the facts of the IPv4 address market place.

In my opinion, your very technical definition of leasing is an anachronism.
The reality is if you want/need more than a /29 of addresses, and you don’t
already have them, you will need to pay for them one way or another on top
of your transit bandwidth, through the transfer market, leasing them from
your transit provider, or leasing them from a 3rd party, this is today’s
reality, like it or not.

Thanks

On Mon, May 8, 2023 at 18:23 Fernando Frediani  wrote:

> Hi Willian. A customer who holds an ASN and is a ARIN member should not
> get IP space to announce with their own ASN from the ISP provider but
> directly with ARIN in all cases.
> Legal risk will always exists and it is not because it exists it should
> not be taken, just need to evaluated and worked.
>
> There has been a proposal presented not much a while ago that intended to
> get that separation better worded and which was still in the process of
> getting feedback and improvements, but AC quickly dismissed it in a
> questionable way despite there has been people interested in discussing and
> improving it. A pity. There has not even been a chance to get a improved
> text in that sense.
> And honestly there will always be some way someone will find out to try to
> circumvent rules and I don't think there will be a perfect text, but a
> reasonable one that can cover most scenarios can play a important role in
> reducing scenarios where resources can be misused.
> On 08/05/2023 19:45, William Herrin wrote:
>
> On Mon, May 8, 2023 at 3:26 PM Fernando Frediani  
>  wrote:
>
> Another thing which many here are targeting about IP leasing
> in the sense of renting, speculation made by those who don't
> build or offer any Internet infrastructure and services. In other
> words someone holding IP space and not using it to build any
> Internet infrastructure and services.
>
> Hi Fernando,
>
> You may be missing my point. How do you differentiate in policy between:
>
> Scenario 1: ISP A provides a T1 and a /24. ISP B provides a gigabit
> ethernet. Customer routes with BGP on both but depreferences ISP A so
> it never shows up in the Internet BGP tables.
>
> Scenario 2: Pretextual ISP C (the defacto address leaser) provides a
> /24 and a VPN (or virtual machine other nil-cost transit consuming
> mechanism). ISP D provides a gigabit ethernet. Customer routes with
> BGP on both but depreferences ISP C so it never shows up in the
> Internet BGP tables.
>
> Scenario 1 is considered reasonable and has been for the entire
> lifetime of the RIRs.
>
> Scenario 2 is the objectionable address leasing arrangement with a
> tiny bit of fluff to bring it into technical compliance with ARIN
> policy.
>
>
> You can't tell ARIN to just exercise their judgement whether something
> is defacto leasing. That creates legal risk to the organization where
> they can't effectively act against the people they "know" to be
> leasers.
>
> You have to write a policy that outright breaks scenario #2 without
> harming scenario #1.That's the utilization count approach. ISP A in
> scenario #1 is not particularly bothered if ARIN gets a bee in their
> bonnet about counting that /24 utilized. So they have to be at 81%
> instead of 80%. Same difference.
>
> ISP C in scenario #2, that's their entire business. If ARIN counts it
> unutilized, they're out of business.
>
> Get it?
>
> Regards,
> Bill Herrin
>
>
> ___
> 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 

Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Paul E McNary via ARIN-PPML]

For one ARIN is technically out of IPv4. 
2 - Every Upstream provider I have gotten bandwidth from requires us to use 
"their" provided IP Block in front of our block. Albeit 1 or 2 usable IP's. 
They also never let us pass through BGP announcing. They take our ASN BGP and 
convert to their ASN BGP. 


From: "Fernando Frediani"  
To: "William Herrin"  
Cc: "arin-ppml"  
Sent: Monday, May 8, 2023 6:23:01 PM 
Subject: Re: [arin-ppml] Policy Experience Report Working Group Leasing 
Question 



Hi Willian. A customer who holds an ASN and is a ARIN member should not get IP 
space to announce with their own ASN from the ISP provider but directly with 
ARIN in all cases. 
Legal risk will always exists and it is not because it exists it should not be 
taken, just need to evaluated and worked. 


There has been a proposal presented not much a while ago that intended to get 
that separation better worded and which was still in the process of getting 
feedback and improvements, but AC quickly dismissed it in a questionable way 
despite there has been people interested in discussing and improving it. A 
pity. There has not even been a chance to get a improved text in that sense. 
And honestly there will always be some way someone will find out to try to 
circumvent rules and I don't think there will be a perfect text, but a 
reasonable one that can cover most scenarios can play a important role in 
reducing scenarios where resources can be misused. 
On 08/05/2023 19:45, William Herrin wrote: 



On Mon, May 8, 2023 at 3:26 PM Fernando Frediani [ mailto:fhfredi...@gmail.com 
|  ] wrote: 

BQ_BEGIN

Another thing which many here are targeting about IP leasing
in the sense of renting, speculation made by those who don't
build or offer any Internet infrastructure and services. In other
words someone holding IP space and not using it to build any
Internet infrastructure and services. 



Hi Fernando,

You may be missing my point. How do you differentiate in policy between:

Scenario 1: ISP A provides a T1 and a /24. ISP B provides a gigabit
ethernet. Customer routes with BGP on both but depreferences ISP A so
it never shows up in the Internet BGP tables.

Scenario 2: Pretextual ISP C (the defacto address leaser) provides a
/24 and a VPN (or virtual machine other nil-cost transit consuming
mechanism). ISP D provides a gigabit ethernet. Customer routes with
BGP on both but depreferences ISP C so it never shows up in the
Internet BGP tables.

Scenario 1 is considered reasonable and has been for the entire
lifetime of the RIRs.

Scenario 2 is the objectionable address leasing arrangement with a
tiny bit of fluff to bring it into technical compliance with ARIN
policy.


You can't tell ARIN to just exercise their judgement whether something
is defacto leasing. That creates legal risk to the organization where
they can't effectively act against the people they "know" to be
leasers.

You have to write a policy that outright breaks scenario #2 without
harming scenario #1.That's the utilization count approach. ISP A in
scenario #1 is not particularly bothered if ARIN gets a bee in their
bonnet about counting that /24 utilized. So they have to be at 81%
instead of 80%. Same difference.

ISP C in scenario #2, that's their entire business. If ARIN counts it
unutilized, they're out of business.

Get it?

Regards,
Bill Herrin 

BQ_END

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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[William Herrin]

On Mon, May 8, 2023 at 4:22 PM Fernando Frediani  wrote:
> A customer who holds an ASN and is a ARIN member should not
> get IP space to announce with their own ASN from the ISP provider
> but directly with ARIN in all cases.

You are 100% guaranteed to lose that fight. Don't tie address leasing
policy to it unless you want to lose that fight too.

Also, bear in mind that the customer doesn't need their own ASN to
announce an address block. I was at a NANOG some years ago where one
of the sessions was a tutorial on how to announce to your upstreams
with a private AS and have them strip the private AS so that to the
Internet you're announcing from multiple origin ASes. While unusual,
it is a completely valid way to operate.

Regards,
Bill Herrin

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b...@herrin.us
https://bill.herrin.us/
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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Fernando Frediani]

Hi Willian. A customer who holds an ASN and is a ARIN member should not 
get IP space to announce with their own ASN from the ISP provider but 
directly with ARIN in all cases.
Legal risk will always exists and it is not because it exists it should 
not be taken, just need to evaluated and worked.


There has been a proposal presented not much a while ago that intended 
to get that separation better worded and which was still in the process 
of getting feedback and improvements, but AC quickly dismissed it in a 
questionable way despite there has been people interested in discussing 
and improving it. A pity. There has not even been a chance to get a 
improved text in that sense.
And honestly there will always be some way someone will find out to try 
to circumvent rules and I don't think there will be a perfect text, but 
a reasonable one that can cover most scenarios can play a important role 
in reducing scenarios where resources can be misused.


On 08/05/2023 19:45, William Herrin wrote:

On Mon, May 8, 2023 at 3:26 PM Fernando Frediani  wrote:

Another thing which many here are targeting about IP leasing
in the sense of renting, speculation made by those who don't
build or offer any Internet infrastructure and services. In other
words someone holding IP space and not using it to build any
Internet infrastructure and services.

Hi Fernando,

You may be missing my point. How do you differentiate in policy between:

Scenario 1: ISP A provides a T1 and a /24. ISP B provides a gigabit
ethernet. Customer routes with BGP on both but depreferences ISP A so
it never shows up in the Internet BGP tables.

Scenario 2: Pretextual ISP C (the defacto address leaser) provides a
/24 and a VPN (or virtual machine other nil-cost transit consuming
mechanism). ISP D provides a gigabit ethernet. Customer routes with
BGP on both but depreferences ISP C so it never shows up in the
Internet BGP tables.

Scenario 1 is considered reasonable and has been for the entire
lifetime of the RIRs.

Scenario 2 is the objectionable address leasing arrangement with a
tiny bit of fluff to bring it into technical compliance with ARIN
policy.


You can't tell ARIN to just exercise their judgement whether something
is defacto leasing. That creates legal risk to the organization where
they can't effectively act against the people they "know" to be
leasers.

You have to write a policy that outright breaks scenario #2 without
harming scenario #1.That's the utilization count approach. ISP A in
scenario #1 is not particularly bothered if ARIN gets a bee in their
bonnet about counting that /24 utilized. So they have to be at 81%
instead of 80%. Same difference.

ISP C in scenario #2, that's their entire business. If ARIN counts it
unutilized, they're out of business.

Get it?

Regards,
Bill Herrin
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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[William Herrin]

On Mon, May 8, 2023 at 3:26 PM Fernando Frediani  wrote:
> Another thing which many here are targeting about IP leasing
> in the sense of renting, speculation made by those who don't
> build or offer any Internet infrastructure and services. In other
> words someone holding IP space and not using it to build any
> Internet infrastructure and services.

Hi Fernando,

You may be missing my point. How do you differentiate in policy between:

Scenario 1: ISP A provides a T1 and a /24. ISP B provides a gigabit
ethernet. Customer routes with BGP on both but depreferences ISP A so
it never shows up in the Internet BGP tables.

Scenario 2: Pretextual ISP C (the defacto address leaser) provides a
/24 and a VPN (or virtual machine other nil-cost transit consuming
mechanism). ISP D provides a gigabit ethernet. Customer routes with
BGP on both but depreferences ISP C so it never shows up in the
Internet BGP tables.

Scenario 1 is considered reasonable and has been for the entire
lifetime of the RIRs.

Scenario 2 is the objectionable address leasing arrangement with a
tiny bit of fluff to bring it into technical compliance with ARIN
policy.


You can't tell ARIN to just exercise their judgement whether something
is defacto leasing. That creates legal risk to the organization where
they can't effectively act against the people they "know" to be
leasers.

You have to write a policy that outright breaks scenario #2 without
harming scenario #1.That's the utilization count approach. ISP A in
scenario #1 is not particularly bothered if ARIN gets a bee in their
bonnet about counting that /24 utilized. So they have to be at 81%
instead of 80%. Same difference.

ISP C in scenario #2, that's their entire business. If ARIN counts it
unutilized, they're out of business.

Get it?

Regards,
Bill Herrin

-- 
William Herrin
b...@herrin.us
https://bill.herrin.us/
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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Fernando Frediani]

Hello Willian

It is that very difficult to differentiate a scenario where a final 
customer receives a block allocation in order to have their Internet 
service working with that connectivity provider. That has never been a 
problem.
Another thing which many here are targeting about IP leasing in the 
sense of renting, speculation made by those who don't build or offer any 
Internet infrastructure and services. In other words someone holding IP 
space and not using it to build any Internet infrastructure and services.


Fernando

On 08/05/2023 19:16, William Herrin wrote:

On Mon, May 8, 2023 at 3:05 PM Noah  wrote:

On Mon, 8 May 2023, 22:19 William Herrin,  wrote:
We are all aware that ISPs are generally LIRs and as such,
their downstream endusers/customers often time get assigned
small blocks like /24 based on need ontop of the connectivity
services they are provided by the ISP.

Some also end up being the source of the IP addresses but only a small
source of the transit. Think: T1 and /24 from ISP A, gigabit ethernet
from ISP B. I haven't counted but there are at least hundreds of
these. I don't know how we write policy that disqualifies pretextual
leasing (like Owen was talking about) without also disqualifying these
longstanding and reasonable uses.



Historically, a few ISPs even allowed some customers to keep their IP
addresses when they left.

Very few __and those IPs were transferred to those customers__ who then became 
resource members through the RIR process.

That is not accurate.



Unused address ought to be returned back to the RIR inventory for further 
redistribution.

A quarter of a century of RIR experience suggests that mostly doesn't
happen. Hence the existence of a transfer market. Which does seem to
work.

Regards,
Bill Herrin

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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[William Herrin]

On Mon, May 8, 2023 at 3:05 PM Noah  wrote:
> On Mon, 8 May 2023, 22:19 William Herrin,  wrote:
> We are all aware that ISPs are generally LIRs and as such,
> their downstream endusers/customers often time get assigned
> small blocks like /24 based on need ontop of the connectivity
> services they are provided by the ISP.

Some also end up being the source of the IP addresses but only a small
source of the transit. Think: T1 and /24 from ISP A, gigabit ethernet
from ISP B. I haven't counted but there are at least hundreds of
these. I don't know how we write policy that disqualifies pretextual
leasing (like Owen was talking about) without also disqualifying these
longstanding and reasonable uses.


>> Historically, a few ISPs even allowed some customers to keep their IP
>> addresses when they left.
>
> Very few __and those IPs were transferred to those customers__ who then 
> became resource members through the RIR process.

That is not accurate.


> Unused address ought to be returned back to the RIR inventory for further 
> redistribution.

A quarter of a century of RIR experience suggests that mostly doesn't
happen. Hence the existence of a transfer market. Which does seem to
work.

Regards,
Bill Herrin


-- 
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b...@herrin.us
https://bill.herrin.us/
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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Fernando Frediani]

On 08/05/2023 19:05, Noah wrote:



Good.. and the RIR system and only the RIR must handle the 
management and distribution based on need of IP resources and not a 
3rd party entity that the community does not even recognize.

Totally ! That´s a fundamental point !


IP Leasing undermines the foundation of the system that has served the 
Internet community so well.


Any endorsement of such a practise will be setting a very dangerous 
presidence if we attempt to ignore order in favour of an unregulated 
practise and greed. There has to be a limit, a demarcation, as to how 
internet number resources are managed and distributed.

Well said too.



Cheers,
Noah

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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Noah]

On Mon, 8 May 2023, 22:19 William Herrin,  wrote:

> On Mon, May 8, 2023 at 9:46 AM Noah  wrote:
> > Firstly, leasing should never be an option. Its an idea that the
> community has rejected the leasing IPv4 for a very long time and often led
> to mix reactions.
>
> Hi Noah,
>
> Never say never.


I say never because the RIR system has not failed. Its model has been
successful albeit with hicups yet it has stood the taste of time and the
last thing we want as a community is to attempt on inacting chaos as the
new normal.

The community has long permitted ISPs to authorize a
> customer to use their /24 with service from another vendors' network.
>

We are all aware that ISPs are generally LIRs and as such, their downstream
endusers/customers often time get assigned small blocks like /24 based on
need ontop of the connectivity services they are provided by the ISP.

When ISP customers churn, most ISP recover the assigned block back into the
LIR inventory for re-assigning to new customers and this is a known
practise.

Some ISP customers would endup becoming resource members of an RIR and
based on need get some IP space to number their infra...


Historically, a few ISPs even allowed some customers to keep their IP
> addresses when they left.


Very few and those IPs were transferred to those customers who then became
resource members through the RIR process.

Policy targeting IP-leasers should take care
> not to stomp on these longstanding and reasonable uses.
>
> This is why I suggested a policy which simply declares such addresses
> unused for justification purposes: a small amount of such activity by
> otherwise legitimate ISPs won't cause them a problem


Unused address ought to be returned back to the RIR inventory for further
redistribution.

but it'd block
> anybody from making a business model out of it.
>

Good.. and the RIR system and only the RIR must handle the management
and distribution based on need of IP resources and not a 3rd party entity
that the community does not even recognize.

IP Leasing undermines the foundation of the system that has served the
Internet community so well.

Any endorsement of such a practise will be setting a very dangerous
presidence if we attempt to ignore order in favour of an unregulated
practise and greed. There has to be a limit, a demarcation, as to how
internet number resources are managed and distributed.


Cheers,
Noah
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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[William Herrin]

On Mon, May 8, 2023 at 9:46 AM Noah  wrote:
> Firstly, leasing should never be an option. Its an idea that the community 
> has rejected the leasing IPv4 for a very long time and often led to mix 
> reactions.

Hi Noah,

Never say never. The community has long permitted ISPs to authorize a
customer to use their /24 with service from another vendors' network.
Historically, a few ISPs even allowed some customers to keep their IP
addresses when they left. Policy targeting IP-leasers should take care
not to stomp on these longstanding and reasonable uses.

This is why I suggested a policy which simply declares such addresses
unused for justification purposes: a small amount of such activity by
otherwise legitimate ISPs won't cause them a problem but it'd block
anybody from making a business model out of it.

Regards,
Bill Herrin

-- 
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b...@herrin.us
https://bill.herrin.us/
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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[William Herrin]

On Mon, May 8, 2023 at 4:32 AM Fernando Frediani  wrote:
> You can only lease what you own.

You've never heard of subletting?


> IP leasing is an attestation that the resource holder doesn't justify for 
> those resources anymore, therefore they should be revoked and assigned to 
> someone else

In principle, I agree.

Regards,
Bill Herrin


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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Noah]

On Fri, 5 May 2023, 18:54 WOOD Alison * DAS, 
wrote:

> Good morning PPML!
>
>
>
> I would like community feedback on the leasing of ip space that is
> obtained from the waitlist.
>
Firstly, leasing should never be an option. Its an idea that the community
has rejected the leasing IPv4 for a very long time and often led to mix
reactions.

The normal process for RIR has always been to allocate IP space to resource
members who qualify to get additional allocation or assignment based on
need.

If there are resource members who were allocated IPv4 space based on their
needd at the time and they no longer need the space... the community has
consensus that the said resource member transfers the IPv4 space to another
resource member who has need.

The RIR role is to ensure that process is smooth.

If RIR has obtained IPv4 address space from resource members who nolonger
need them, then the RIR allocates the space to those resource members with
need.

Please let me know what you think and if a policy proposal would be
> warranted.
>

I will vehemently oppose such a proposal if it were ever be drafted.

Noah
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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Michael B. Williams via ARIN-PPML]

Noah very well said, and I completely agree!
Capitalism decided otherwise... The business model changed the day IP
brokers realised they could earn a living by sitting in their couches,
running no useful IP-based network and thereby undermining the
community-based RIR system role and long-standing objectives.


On Mon, May 8, 2023 at 8:14 AM Noah  wrote:

>
> On Mon, May 8, 2023 at 2:33 PM Fernando Frediani 
> wrote:
>
>> You can only lease what you own.
>>
>
> Is there any such thing as ownership?... My understanding has always been
> that resource members agreed to sign agreements with an RIR to become a
> member so that they can be afforded INR based on need to use the number IP
> based networks
>
>
>> What people are trying to do here is pretend they own the resources and
>> earn money with an asset they don't own despite everything that what IP
>> addresses have always meant for.
>>
> Its total chaos.
>
> IP leasing is an attestation that the resource holder doesn't justify for
>> those resources anymore, therefore they should be revoked and assigned to
>> someone else who really justifies for it.
>>
>
> Capitalism decided otherwise the business model changed the day IP
> brokers realised they could earn a living by seating in their couches,
> running no useful IP based network and thereby undermining the community
> based RIR system role and long standing objectives.
>
> ARIN should use any financial and legal resources it has to invest in a
>> efficient reclamation process in order to keep its missing to assign shared
>> resources to those who really need them to build internet infrastructure,
>> not do those who wish to speculate around IP space.
>>
>
> Well various IP based business models cropped from the community and
> succeeded through the need based system.
>
> The system ought to find itself and renew its bandwith and capacity if it
> will be able to continue serving the community as it always did.
>
> Noah
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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Noah]

On Mon, May 8, 2023 at 2:33 PM Fernando Frediani 
wrote:

> You can only lease what you own.
>

Is there any such thing as ownership?... My understanding has always been
that resource members agreed to sign agreements with an RIR to become a
member so that they can be afforded INR based on need to use the number IP
based networks


> What people are trying to do here is pretend they own the resources and
> earn money with an asset they don't own despite everything that what IP
> addresses have always meant for.
>
Its total chaos.

IP leasing is an attestation that the resource holder doesn't justify for
> those resources anymore, therefore they should be revoked and assigned to
> someone else who really justifies for it.
>

Capitalism decided otherwise the business model changed the day IP
brokers realised they could earn a living by seating in their couches,
running no useful IP based network and thereby undermining the community
based RIR system role and long standing objectives.

ARIN should use any financial and legal resources it has to invest in a
> efficient reclamation process in order to keep its missing to assign shared
> resources to those who really need them to build internet infrastructure,
> not do those who wish to speculate around IP space.
>

Well various IP based business models cropped from the community and
succeeded through the need based system.

The system ought to find itself and renew its bandwith and capacity if it
will be able to continue serving the community as it always did.

Noah
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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Michael B. Williams via ARIN-PPML]

+1

Completely agree with this.

Michael

On Mon, May 8, 2023 at 07:33 Fernando Frediani  wrote:

> You can only lease what you own. What people are trying to do here is
> pretend they own the resources and earn money with an asset they don't own
> despite everything that what IP addresses have always meant for.
>
> IP leasing is an attestation that the resource holder doesn't justify for
> those resources anymore, therefore they should be revoked and assigned to
> someone else who really justifies for it. ARIN should use any financial and
> legal resources it has to invest in a efficient reclamation process in
> order to keep its missing to assign shared resources to those who really
> need them to build internet infrastructure, not do those who wish to
> speculate around IP space.
>
> Fernando
> On 08/05/2023 01:40, Ron Grant wrote:
>
> Pitch perfect points herein:
> - Transfer market already successful
> - Avoids a "highly litigious reclamation process"
> - Leasing is a natural evolution of the Transfer process
> - Section 12 allows both for a reclamation due to misuse, and for a green
> light after 5 years.
>
> I withdraw my initial "can o' worms" objection - when likening them to
> transfers, it looks like we already have controls in place.
>
>
> On 2023-05-07 3:08 p.m., David Farmer via ARIN-PPML wrote:
>
> In my opinion, the 60-month probation on transfers in section 4.1.8 is
> intended to prevent immediate monetization through the transfer market of
> IPv4 resources obtained from the waiting list. Allowing the lease of IPv4
> resources obtained from the waiting list prior to the end of the 60-month
> probation would seem to flaunt the intent of the probation. However, once
> past the 60-month probation, allowing the transfer or lease of IPv4
> resources seems consistent with the policies intent.
>
> I would like to point out that the transfer market has been remarkably
> successful in making IPv4 resources voluntarily available that otherwise
> would not have been available or would have required a highly
> litigious reclamation process to be made available. In addition, leasing
> seems to be a natural evolution of the transfer market for those that do
> not have the capital funding to obtain IPv4 resources on the transfer
> market. Finally, despite a few issues, the waiting list has also been
> remarkably successful at ensuring any IPv4 resources returned to ARIN, for
> whatever reason, are redistributed to the ARIN community.
>
> Suggestions that ARIN should instead auction the waiting list resources,
> while seemingly logical, given the success of the transfer market,
> nevertheless seem incompatible with ARIN's not-for-profit status.
>
> In summary, leasing IPv4 resources obtained from the waiting list after
> the 60-month probation should be allowed. Prior to that, leasing should not
> be allowed. How we effectively enforce that is another question entirely,
> and I personally don't have any good answers to that question.
>
> Thanks
>
> On Fri, May 5, 2023 at 10:54 AM WOOD Alison * DAS <
> alison.w...@das.oregon.gov> wrote:
>
>> Good morning PPML!
>>
>>
>>
>> I would like community feedback on the leasing of ip space that is
>> obtained from the waitlist.  Please let me know what you think and if a
>> policy proposal would be warranted.
>>
>>
>>
>> Thank you!
>>
>>
>>
>> -Alison
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> --
> ===
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> Office of Information Technology
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> 2218 University Ave SE
> 
>   Phone: 612-626-0815
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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Fernando Frediani]

You can only lease what you own. What people are trying to do here is 
pretend they own the resources and earn money with an asset they don't 
own despite everything that what IP addresses have always meant for.


IP leasing is an attestation that the resource holder doesn't justify 
for those resources anymore, therefore they should be revoked and 
assigned to someone else who really justifies for it. ARIN should use 
any financial and legal resources it has to invest in a efficient 
reclamation process in order to keep its missing to assign shared 
resources to those who really need them to build internet 
infrastructure, not do those who wish to speculate around IP space.


Fernando

On 08/05/2023 01:40, Ron Grant wrote:

Pitch perfect points herein:
- Transfer market already successful
- Avoids a "highly litigious reclamation process"
- Leasing is a natural evolution of the Transfer process
- Section 12 allows both for a reclamation due to misuse, and for a 
green light after 5 years.


I withdraw my initial "can o' worms" objection - when likening them to 
transfers, it looks like we already have controls in place.



On 2023-05-07 3:08 p.m., David Farmer via ARIN-PPML wrote:
In my opinion, the 60-month probation on transfers in section 4.1.8 
is intended to prevent immediate monetization through the transfer 
market of IPv4 resources obtained from the waiting list. Allowing the 
lease of IPv4 resources obtained from the waiting list prior to the 
end of the 60-month probation would seem to flaunt the intent of the 
probation. However, once past the 60-month probation, allowing the 
transfer or lease of IPv4 resources seems consistent with 
the policies intent.


I would like to point out that the transfer market has been 
remarkably successful in making IPv4 resources voluntarily available 
that otherwise would not have been available or would have required a 
highly litigious reclamation process to be made available. In 
addition, leasing seems to be a natural evolution of the transfer 
market for those that do not have the capital funding to obtain IPv4 
resources on the transfer market. Finally, despite a few issues, the 
waiting list has also been remarkably successful at ensuring any IPv4 
resources returned to ARIN, for whatever reason, are redistributed to 
the ARIN community.


Suggestions that ARIN should instead auction the waiting list 
resources, while seemingly logical, given the success of the transfer 
market, nevertheless seem incompatible with ARIN's not-for-profit status.


In summary, leasing IPv4 resources obtained from the waiting list 
after the 60-month probation should be allowed. Prior to that, 
leasing should not be allowed. How we effectively enforce that is 
another question entirely, and I personally don't have any good 
answers to that question.


Thanks

On Fri, May 5, 2023 at 10:54 AM WOOD Alison * DAS 
 wrote:


Good morning PPML!

I would like community feedback on the leasing of ip space that
is obtained from the waitlist.  Please let me know what you think
and if a policy proposal would be warranted.

Thank you!

-Alison

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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Ron Grant]

Pitch perfect points herein:
- Transfer market already successful
- Avoids a "highly litigious reclamation process"
- Leasing is a natural evolution of the Transfer process
- Section 12 allows both for a reclamation due to misuse, and for a 
green light after 5 years.


I withdraw my initial "can o' worms" objection - when likening them to 
transfers, it looks like we already have controls in place.



On 2023-05-07 3:08 p.m., David Farmer via ARIN-PPML wrote:
In my opinion, the 60-month probation on transfers in section 4.1.8 is 
intended to prevent immediate monetization through the transfer market 
of IPv4 resources obtained from the waiting list. Allowing the lease 
of IPv4 resources obtained from the waiting list prior to the end of 
the 60-month probation would seem to flaunt the intent of the 
probation. However, once past the 60-month probation, allowing the 
transfer or lease of IPv4 resources seems consistent with the policies 
intent.


I would like to point out that the transfer market has been remarkably 
successful in making IPv4 resources voluntarily available that 
otherwise would not have been available or would have required a 
highly litigious reclamation process to be made available. In 
addition, leasing seems to be a natural evolution of the transfer 
market for those that do not have the capital funding to obtain IPv4 
resources on the transfer market. Finally, despite a few issues, the 
waiting list has also been remarkably successful at ensuring any IPv4 
resources returned to ARIN, for whatever reason, are redistributed to 
the ARIN community.


Suggestions that ARIN should instead auction the waiting list 
resources, while seemingly logical, given the success of the transfer 
market, nevertheless seem incompatible with ARIN's not-for-profit status.


In summary, leasing IPv4 resources obtained from the waiting list 
after the 60-month probation should be allowed. Prior to that, leasing 
should not be allowed. How we effectively enforce that is another 
question entirely, and I personally don't have any good answers to 
that question.


Thanks

On Fri, May 5, 2023 at 10:54 AM WOOD Alison * DAS 
 wrote:


Good morning PPML!

I would like community feedback on the leasing of ip space that is
obtained from the waitlist.  Please let me know what you think and
if a policy proposal would be warranted.

Thank you!

-Alison

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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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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Martin Hannigan]

This is sensible and realistic.  In agreement.

Thanks Dave,

-M<

Get Outlook for iOS<https://aka.ms/o0ukef>

From: ARIN-PPML  on behalf of David Farmer via 
ARIN-PPML 
Sent: Sunday, May 7, 2023 6:08:45 PM
To: WOOD Alison * DAS 
Cc: arin-ppml@arin.net 
Subject: Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

In my opinion, the 60-month probation on transfers in section 4.1.8 is intended 
to prevent immediate monetization through the transfer market of IPv4 resources 
obtained from the waiting list. Allowing the lease of IPv4 resources obtained 
from the waiting list prior to the end of the 60-month probation would seem to 
flaunt the intent of the probation. However, once past the 60-month probation, 
allowing the transfer or lease of IPv4 resources seems consistent with the 
policies intent.

I would like to point out that the transfer market has been remarkably 
successful in making IPv4 resources voluntarily available that otherwise would 
not have been available or would have required a highly litigious reclamation 
process to be made available. In addition, leasing seems to be a natural 
evolution of the transfer market for those that do not have the capital funding 
to obtain IPv4 resources on the transfer market. Finally, despite a few issues, 
the waiting list has also been remarkably successful at ensuring any IPv4 
resources returned to ARIN, for whatever reason, are redistributed to the ARIN 
community.

Suggestions that ARIN should instead auction the waiting list resources, while 
seemingly logical, given the success of the transfer market, nevertheless seem 
incompatible with ARIN's not-for-profit status.

In summary, leasing IPv4 resources obtained from the waiting list after the 
60-month probation should be allowed. Prior to that, leasing should not be 
allowed. How we effectively enforce that is another question entirely, and I 
personally don't have any good answers to that question.

Thanks

On Fri, May 5, 2023 at 10:54 AM WOOD Alison * DAS 
mailto:alison.w...@das.oregon.gov>> wrote:

Good morning PPML!



I would like community feedback on the leasing of ip space that is obtained 
from the waitlist.  Please let me know what you think and if a policy proposal 
would be warranted.



Thank you!



-Alison

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University of Minnesota
2218 University Ave SEPhone: 612-626-0815
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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[David Farmer via ARIN-PPML]

I’m no lawyer, but 501c14s, state chartered credit unions, and 501c6s,
business leagues and how ARIN is organized, have significantly different
purposes and rules. Could ARIN auction the waiting list resources, maybe,
but it’s likely to be the cause for a significant review by the IRS. With
such a review, there is a risk, significant in my opinion, the auction
could be ruled a non-exempt business activity, and risk ARIN’s tax exempt
status. In any case, this is really a matter for the ARIN board and not
really a policy discussion.

Thanks.

On Sun, May 7, 2023 at 18:55 Michel Py 
wrote:

> Hi David,
>
> > David Farmer wrote :
> > Suggestions that ARIN should instead auction the waiting list resources,
> while seemingly logical, given
> > the success of the transfer market, nevertheless seem incompatible with
> ARIN's not-for-profit status.
>
> I have to disagree with that. I work for a Credit Union, that some people
> call a not-for-profit bank.
> We do not have publicly traded shares, and obviously we do not pay
> dividends to shareholders. _That_ would be profit.
> However, we do make money. Revenue, which is not the same thing as profit.
> If you were to have a loan to buy a car or a mortgage to acquire a house,
> not only you would have to pay it back, but you'd also have to pay us
> interest. We are a non-profit, not a charity, we do not give free money
> away and we even make money on financial markets. That is how we pay our
> bills and our employees. It's not greed, but we do have to make a buck like
> everyone else including ARIN.
>
> There is nothing wrong for a non-profit to make money. ARIN does make
> money : we pay fees. How that money is used could (and should) indeed be
> questioned, if it was used to lower member fees or pay for expenses, I
> don't see any fundamental problem with ARIN charging $38 (or whatever the
> market is) per IP as a fee to transfer space that would become available or
> reclaimed.
>
> Now, let's hypothesize that 240/4 becomes available for public routing
> unicast allocation and that ARIN gets a /6 out of it, 67 million IP at $38
> a pop would be 2 billion and change, then that would be a different issue.
> If the waiting list was to disappear, it would be wise to have some
> language that Class E suddenly becoming available would not be auctioned
> out.
> But given what I would call a trickle that the waiting list currently is,
> I don't see a problem.
>
> Michel
>
-- 
===
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Networking & Telecommunication Services
Office of Information Technology
University of Minnesota
2218 University Ave SEPhone: 612-626-0815
Minneapolis, MN 55414-3029   Cell: 612-812-9952
===
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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Michel Py via ARIN-PPML]

Hi David,

> David Farmer wrote :
> Suggestions that ARIN should instead auction the waiting list resources, 
> while seemingly logical, given
> the success of the transfer market, nevertheless seem incompatible with 
> ARIN's not-for-profit status.

I have to disagree with that. I work for a Credit Union, that some people call 
a not-for-profit bank.
We do not have publicly traded shares, and obviously we do not pay dividends to 
shareholders. _That_ would be profit.
However, we do make money. Revenue, which is not the same thing as profit. If 
you were to have a loan to buy a car or a mortgage to acquire a house, not only 
you would have to pay it back, but you'd also have to pay us interest. We are a 
non-profit, not a charity, we do not give free money away and we even make 
money on financial markets. That is how we pay our bills and our employees. 
It's not greed, but we do have to make a buck like everyone else including ARIN.

There is nothing wrong for a non-profit to make money. ARIN does make money : 
we pay fees. How that money is used could (and should) indeed be questioned, if 
it was used to lower member fees or pay for expenses, I don't see any 
fundamental problem with ARIN charging $38 (or whatever the market is) per IP 
as a fee to transfer space that would become available or reclaimed.

Now, let's hypothesize that 240/4 becomes available for public routing unicast 
allocation and that ARIN gets a /6 out of it, 67 million IP at $38 a pop would 
be 2 billion and change, then that would be a different issue. If the waiting 
list was to disappear, it would be wise to have some language that Class E 
suddenly becoming available would not be auctioned out.
But given what I would call a trickle that the waiting list currently is, I 
don't see a problem.

Michel
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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Fernando Frediani]

How on earth people are still considering such an absurd ? From time to 
time it seems that some people take turns in trying make IP leasing 
looks a normal thing, an acceptable using the same excuse that "the 
market already accepted" and throwing in the bin that IP addresses are 
for those who have a need justify for it. Rules have always been and are 
still based on that and companies always have received IP space based on 
their justified needs, not in the basis that they can pay more.


ARIN is no an IP factory that sells it as other companies manufacturer 
and sell servers or routers and as such should never even consider 
anything related to allocate IP space to those who can pay more instead 
of those who subjected themselves to the rules, to the same line and 
justify the need.


As times passes into IP exhaustion seems people keep trying to play 
smart to get an extra tiny portion of IP addresses as if that would make 
any difference to their business. Any left over IP space should be given 
only to newcomers in order to give them a chance to exist in the 
Internet and those who have already some get over with the reality of 
IPv4 exhaustion and find other ways to keep going with their business.


Fernando

On 05/05/2023 14:21, John Santos wrote:
Totally against.  This violates the principle of "justified need".  It 
is rent-seeking.


On 5/5/2023 11:54 AM, WOOD Alison * DAS wrote:

Good morning PPML!

I would like community feedback on the leasing of ip space that is 
obtained from the waitlist.  Please let me know what you think and if 
a policy proposal would be warranted.


Thank you!

-Alison


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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[David Farmer via ARIN-PPML]

In my opinion, the 60-month probation on transfers in section 4.1.8 is
intended to prevent immediate monetization through the transfer market of
IPv4 resources obtained from the waiting list. Allowing the lease of IPv4
resources obtained from the waiting list prior to the end of the 60-month
probation would seem to flaunt the intent of the probation. However, once
past the 60-month probation, allowing the transfer or lease of IPv4
resources seems consistent with the policies intent.

I would like to point out that the transfer market has been remarkably
successful in making IPv4 resources voluntarily available that otherwise
would not have been available or would have required a highly
litigious reclamation process to be made available. In addition, leasing
seems to be a natural evolution of the transfer market for those that do
not have the capital funding to obtain IPv4 resources on the transfer
market. Finally, despite a few issues, the waiting list has also been
remarkably successful at ensuring any IPv4 resources returned to ARIN, for
whatever reason, are redistributed to the ARIN community.

Suggestions that ARIN should instead auction the waiting list resources,
while seemingly logical, given the success of the transfer market,
nevertheless seem incompatible with ARIN's not-for-profit status.

In summary, leasing IPv4 resources obtained from the waiting list after
the 60-month probation should be allowed. Prior to that, leasing should not
be allowed. How we effectively enforce that is another question entirely,
and I personally don't have any good answers to that question.

Thanks

On Fri, May 5, 2023 at 10:54 AM WOOD Alison * DAS <
alison.w...@das.oregon.gov> wrote:

> Good morning PPML!
>
>
>
> I would like community feedback on the leasing of ip space that is
> obtained from the waitlist.  Please let me know what you think and if a
> policy proposal would be warranted.
>
>
>
> Thank you!
>
>
>
> -Alison
> ___
> ARIN-PPML
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> 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.
>


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===
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University of Minnesota
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Minneapolis, MN 55414-3029   Cell: 612-812-9952
===
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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Michel Py via ARIN-PPML]

> Michael B. Williams wrote :
> Quite frankly, if this model were adopted with no waitlist, it would not be 
> surprising if a venture
> capital fund came in and just started buying IP space to reduce supply and 
> control the price.

They don’t need the suppression of the waiting list for that. Some people say 
that the spikes at $60 in 2021 were due to speculation, not to market dynamics. 
Hopefully someone speculating got hurt and the market has decreased for the 
last year. Eventually, the market will reach a more mature and stable state 
than it is now.

The way I see the waiting list is a lottery. Apply regardless you are 
innovating or not, if you have or not a legitimate need, and hope you win. The 
problem I have with it is that the crooks who want to make a quick buck are 
generally better at B.S. in terms of justification than the genuine innovator 
who would benefit from a cheap allocation from the waitlist. The other problem 
I have with it is that innovation is time sensitive; waiting only ensures that 
someone else will come up with the same idea, get serious with it, and secure 
the funding.

Michel

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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Ron Grant]

Does ARIN actually have policies that allow them to reclaim space for 
any reason other than non-payment of fees?


Hmmm, apparently they do, in section 12 of the NRPM. It looks pretty 
straightforward, that is to say it would be extremely difficult to 
wiggle around it.


That being the case, I would vote +1 for an amendment of the Waitlist 
agreement to incude a restriction on leasing during the same 60 months 
that the transfer restriction is in place. After all, a lease is just a 
"temporary transfer".





On 2023-05-07 12:55 p.m., Michael B. Williams via ARIN-PPML wrote:
The problem is that some genuine market participants may be unable to 
afford the market rate, thus stifling potential market entry or 
innovation.


I am not necessarily against this idea as long as there are 
appropriate ways to preserve market entry for new entrants without. I 
am not necessarily saying this needs to be free; however, promoting 
competitiveness in space should be a factor. What I'd suggest we'd see 
is continued consolidation of IP resources. Quite frankly, if this 
model were adopted with no waitlist, it would not be surprising if a 
venture capital fund came in and just started buying IP space to 
reduce supply and control the price.


If that's what we want as a community, then so be it. *My 
recommendation is to eliminate IP leasing or transfer entirely for any 
space obtained from the waitlist.* If customers want a /24 or larger, 
they go to ARIN, get their own space, and go through the appropriate 
justification process. The ISP can then announce that IP space on 
their behalf.


If a member is not using their IP space for public routing for a 
period of time that ARIN should reclaim space in accordance with 
standard policies.





On Sun, May 7, 2023 at 3:38 PM Michel Py via ARIN-PPML 
 wrote:


> William Herrin wrote :
> We could also just eliminate the waitlist. That's my preferred
solution. When addresses become available for allocation and
assignment,
> have ARIN contract one of the IP brokers to sell it per the
in-region specified transfer rules. No free addresses, no
incentive to cheat.

+1
And have it all publicly done, and reduce our fees with the money
obtained.

Michel

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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[scott]

+1

On Sun, 7 May 2023, Michael B. Williams via ARIN-PPML wrote:


I disagree. While the waitlist may help companies offer competitive services
for their product lines, it should not be the "product" itself. I.e. the
offering of IP services should be coupled with the actual offering of
services.

To point, if companies offer connectivity-related services, such as, but not
limited to, hosting, transit, data transit, and ISP, I don't have an issue
as these are in the spirit of what IP resources should be obtained for.

Obtaining IP resources for the purposes of immediately reselling or leasing
them to companies is not in the spirit of ARIN's policies.

The waitlist should not be designed for companies simply to make money by
"waiting" in line as a spot holder than reselling the IP addresses.

On Sun, May 7, 2023 at 2:16 PM Ron Grant  wrote:
  To be honest, the whole purpose of the waitlist is for companies
  to make money from obtaining IP space.  True, we usually assume
  they'll be doing it the old-fashioned way, by (gasp) offering
  services - however I think that somehow "tainting" the
  waitlist-obtained addresses is going to cause more trouble than
  it would prevent.



  On 2023-05-05 8:58 a.m., Michael B. Williams via ARIN-PPML
  wrote:
  Are you asking if an entity were to obtain IP space from
  the waitlist, should they be permitted to lease it to
  someone else? My answer is a resounding no. That defeats
  the whole purpose of the waitlist. Entities should not be
  encouraged to hoard IP space because ARIN will subsidise
  the cost, allowing a for-profit entity to make money from
  obtaining IP space.

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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Michael B. Williams via ARIN-PPML]

The problem is that some genuine market participants may be unable to
afford the market rate, thus stifling potential market entry or innovation.

I am not necessarily against this idea as long as there are appropriate
ways to preserve market entry for new entrants without. I am not
necessarily saying this needs to be free; however, promoting
competitiveness in space should be a factor. What I'd suggest we'd see is
continued consolidation of IP resources. Quite frankly, if this model were
adopted with no waitlist, it would not be surprising if a venture capital
fund came in and just started buying IP space to reduce supply and control
the price.

If that's what we want as a community, then so be it. *My recommendation is
to eliminate IP leasing or transfer entirely for any space obtained from
the waitlist.* If customers want a /24 or larger, they go to ARIN, get
their own space, and go through the appropriate justification process. The
ISP can then announce that IP space on their behalf.

If a member is not using their IP space for public routing for a period of
time that ARIN should reclaim space in accordance with standard policies.




On Sun, May 7, 2023 at 3:38 PM Michel Py via ARIN-PPML 
wrote:

> > William Herrin wrote :
> > We could also just eliminate the waitlist. That's my preferred solution.
> When addresses become available for allocation and assignment,
> > have ARIN contract one of the IP brokers to sell it per the in-region
> specified transfer rules. No free addresses, no incentive to cheat.
>
> +1
> And have it all publicly done, and reduce our fees with the money obtained.
>
> Michel
>
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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Michel Py via ARIN-PPML]

> William Herrin wrote :
> We could also just eliminate the waitlist. That's my preferred solution. When 
> addresses become available for allocation and assignment,
> have ARIN contract one of the IP brokers to sell it per the in-region 
> specified transfer rules. No free addresses, no incentive to cheat.

+1
And have it all publicly done, and reduce our fees with the money obtained.

Michel

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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[William Herrin]

On Sun, May 7, 2023 at 11:22 AM Michael B. Williams via ARIN-PPML
 wrote:
> The waitlist should not be designed for companies simply to make money by 
> "waiting" in line as a spot holder than reselling the IP addresses.

We could also just eliminate the waitlist. That's my preferred
solution. When addresses become available for allocation and
assignment, have ARIN contract one of the IP brokers to sell it per
the in-region specified transfer rules. No free addresses, no
incentive to cheat.

Regards,
Bill Herrin


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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Dominik Dobrowolski]

Dear ARIN Friends,

Could we expect the adoption of 240/4 for unicast use? There were
proposals, yet do you know this is treated seriously?

It would be a step back regarding the adoption of ipv6, yet the use of such
a block for NAT64 use would be beneficial for all.

There is an issue of hardware compatibility, but I can imagine that most of
the hardware platforms could support it in a span of 10 years. Anyway I say
it is better to have a block partially useful than not useful at all.


Kind Regards,
Dominik Dobrowolski,
dominet LLC

pt., 5 maj 2023, 19:21 użytkownik John Santos  napisał:

> Totally against.  This violates the principle of "justified need".  It is
> rent-seeking.
>
> On 5/5/2023 11:54 AM, WOOD Alison * DAS wrote:
> > Good morning PPML!
> >
> > I would like community feedback on the leasing of ip space that is
> obtained from
> > the waitlist.  Please let me know what you think and if a policy
> proposal would
> > be warranted.
> >
> > Thank you!
> >
> > -Alison
> >
> >
> > ___
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> --
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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Ron Grant]

And while I ALSO agree with this sentiment, I think that the ship has 
sailed on the whole question of "what can people do with their IP 
address space". You say it yourself - if you start to insist on people 
not leasing their waitlist-obtained resources, why not just ban leasing 
altogether? But how to retroactively do that? And what about all that 
legacy space that you have no legal control over?


Until the IRRs get firmly into the "we control the routing tables" 
business (shudder), they have very little say in what people actually 
do. What about the guy who gets addresses from the waitlist but then 
decides not to expand his business, and doesn't route the addresses AT 
ALL? Isn't that arguably WORSE than letting someone else use them (100% 
waste of resource)? And yet, because he's not "making money", it's 
somehow better?





On 2023-05-05 9:04 a.m., Michael B. Williams via ARIN-PPML wrote:
I'd go a step further even to say there should be an explicit policy 
statement *against* the leasing of IP space from entities who obtain 
IP space from the waitlist. Even further, if an entity obtains IP 
space from the waitlist, it should have to attest that they are not 
leasing its IP space to another entity. I believe in the community's 
efficient use of IP space, so perhaps if an entity is not using its 
entire IP space, it should hand the corresponding blocks back to ARIN 
or alternatively let ARIN govern a fair and acceptable method to lease 
IP space. Still, it should *not* be for profit.


On Fri, May 5, 2023 at 11:58 AM Michael B. Williams 
 wrote:


Are you asking if an entity were to obtain IP space from the
waitlist, should they be permitted to lease it to someone else? My
answer is a resounding no. That defeats the whole purpose of the
waitlist. Entities should not be encouraged to hoard IP space
because ARIN will subsidise the cost, allowing a for-profit entity
to make money from obtaining IP space.


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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Ron Grant]

Oh, I totally agree with you!

I just think it'd be hard to enforce.



On 2023-05-07 11:22 a.m., Michael B. Williams via ARIN-PPML wrote:
I disagree. While the waitlist may help companies offer 
competitive services for their product lines, it should not be the 
"product" itself. I.e. the offering of IP services should be coupled 
with the actual offering of services.


To point, if companies offer connectivity-related services, such as, 
but not limited to, hosting, transit, data transit, and ISP, I don't 
have an issue as these are in the spirit of what IP resources 
should be obtained for.


Obtaining IP resources for the purposes of immediately reselling or 
leasing them to companies is not in the spirit of ARIN's policies.


The waitlist should not be designed for companies simply to make money 
by "waiting" in line as a spot holder than reselling the IP addresses.


On Sun, May 7, 2023 at 2:16 PM Ron Grant  wrote:

To be honest, the whole purpose of the waitlist is for companies
to make money from obtaining IP space.  True, we usually assume
they'll be doing it the old-fashioned way, by (gasp) offering
services - however I think that somehow "tainting" the
waitlist-obtained addresses is going to cause more trouble than it
would prevent.



On 2023-05-05 8:58 a.m., Michael B. Williams via ARIN-PPML wrote:

Are you asking if an entity were to obtain IP space from the
waitlist, should they be permitted to lease it to someone else?
My answer is a resounding no. That defeats the whole purpose of
the waitlist. Entities should not be encouraged to hoard IP space
because ARIN will subsidise the cost, allowing a for-profit
entity to make money from obtaining IP space.

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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Michael B. Williams via ARIN-PPML]

I disagree. While the waitlist may help companies offer
competitive services for their product lines, it should not be the
"product" itself. I.e. the offering of IP services should be coupled with
the actual offering of services.

To point, if companies offer connectivity-related services, such as, but
not limited to, hosting, transit, data transit, and ISP, I don't have an
issue as these are in the spirit of what IP resources should be
obtained for.

Obtaining IP resources for the purposes of immediately reselling or leasing
them to companies is not in the spirit of ARIN's policies.

The waitlist should not be designed for companies simply to make money by
"waiting" in line as a spot holder than reselling the IP addresses.

On Sun, May 7, 2023 at 2:16 PM Ron Grant  wrote:

> To be honest, the whole purpose of the waitlist is for companies to make
> money from obtaining IP space.  True, we usually assume they'll be doing it
> the old-fashioned way, by (gasp) offering services - however I think that
> somehow "tainting" the waitlist-obtained addresses is going to cause more
> trouble than it would prevent.
>
>
>
> On 2023-05-05 8:58 a.m., Michael B. Williams via ARIN-PPML wrote:
>
> Are you asking if an entity were to obtain IP space from the waitlist,
> should they be permitted to lease it to someone else? My answer is a
> resounding no. That defeats the whole purpose of the waitlist. Entities
> should not be encouraged to hoard IP space because ARIN will subsidise the
> cost, allowing a for-profit entity to make money from obtaining IP space.
>
> ___
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>
>
> --
> Ron Grant
> Balan Software/Networks
> Network Architecture & Programming
> 604-737-2113 
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>


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Re: [arin-ppml] Policy Experience Report Working Group

[William Herrin]

On Sun, May 7, 2023 at 7:37 AM Owen DeLong  wrote:
> There are plenty of factual ways to write up a justification that would pass 
> muster in policy for leasing as leasing with connectivity and without are 
> essentially indistinguishable absent voluntary disclosure.

Hi Owen,

As there are factual ways to document writing IP addresses in pen on a
computer case as private internetworking. Off-Internet use can justify
an allocation, for example when building an multi-organization private
network. If you tell the -whole- truth about what you're doing with
either penmanship or leasing, neither one passes muster as a
"technical need." And when ARIN catches you telling less than the
whole truth, they prefer to call it fraud.

The character of "technical" justification has never been made
explicit in policy, save that it must be some sort of network
infrastructure. It's up to the judgement or ARIN staff. Which is why I
call it "convention." But whether you label it policy or convention,
either way when your primary intent is to lease addresses to third
parties for use on a fourth party's network infrastructure, you're
going against what the NRPM calls legitimate.


Policy-wise, I'd try something along these lines:

Where IP addresses are leased to third parties who make little or no
use of your network infrastructure with those addresses, the addresses
are deemed -unused- for the purpose of calculating or projecting the
utilization rate.

Regards,
Bill Herrin





-- 
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Re: [arin-ppml] Policy Experience Report Working Group

[Owen DeLong via ARIN-PPML]

> On May 7, 2023, at 07:08, William Herrin  wrote:
> 
> On Fri, May 5, 2023 at 5:32 PM Owen DeLong  wrote:
>> That isn’t a technical need for the addresses.
> 
> Neither is registering addresses so you can lease them. A financial
> need maybe, but not a technical one.
> 
>> So as a matter of fact, it is prohibited by policy, not just convention.
> 
> Your words.

Arguably, yes. I didn’t say otherwise.  What I said was that staff is allowed 
to deny on policy and not on convention. 

There are plenty of factual ways to write up a justification that would pass 
muster in policy for leasing as leasing with connectivity and without are 
essentially indistinguishable absent voluntary disclosure. 

There are also plenty of ways to write one that would get rejected. 

Owen

> 
> Regards,
> Bill Herrin
> 
> -- 
> William Herrin
> b...@herrin.us
> https://bill.herrin.us/

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Re: [arin-ppml] Policy Experience Report Working Group

[William Herrin]

On Fri, May 5, 2023 at 5:32 PM Owen DeLong  wrote:
> That isn’t a technical need for the addresses.

Neither is registering addresses so you can lease them. A financial
need maybe, but not a technical one.

> So as a matter of fact, it is prohibited by policy, not just convention.

Your words.

Regards,
Bill Herrin

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Re: [arin-ppml] Policy Experience Report Working Group

[Owen DeLong via ARIN-PPML]

That isn’t a technical need for the addresses. So as a matter of fact, it is 
prohibited by policy, not just convention. 

Owen


> On May 5, 2023, at 15:37, William Herrin  wrote:
> 
> On Fri, May 5, 2023 at 2:30 PM Owen DeLong  wrote:
>> Nobody should have been denied addresses based on convention. Address denial 
>> should have been rooted in policy.
> 
> Owen,
> 
> I defy you to show me the policy which says I can't have a /22 based
> on the use justification that I'm going to write those thousand
> addresses, in pen, on my computer case. 100% utilization within hours
> of the assignment!  -Conventionally- that is not a sufficient
> technical justification. You won't find it in the -policy- but I'm
> pretty sure ARIN staff will deny the request based on -convention-.
> 
> Regards,
> Bill Herrin
> 
> 
> -- 
> William Herrin
> b...@herrin.us
> https://bill.herrin.us/

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Re: [arin-ppml] Policy Experience Report Working Group

[William Herrin]

On Fri, May 5, 2023 at 2:30 PM Owen DeLong  wrote:
> Nobody should have been denied addresses based on convention. Address denial 
> should have been rooted in policy.

Owen,

I defy you to show me the policy which says I can't have a /22 based
on the use justification that I'm going to write those thousand
addresses, in pen, on my computer case. 100% utilization within hours
of the assignment!  -Conventionally- that is not a sufficient
technical justification. You won't find it in the -policy- but I'm
pretty sure ARIN staff will deny the request based on -convention-.

Regards,
Bill Herrin


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Re: [arin-ppml] Policy Experience Report Working Group

[Owen DeLong via ARIN-PPML]

> On May 5, 2023, at 13:45, William Herrin  wrote:
> 
> On Fri, May 5, 2023 at 12:54 PM Dustin Moses  wrote:
>> Also, I don’t see anywhere in the existing NRPM where an leasing is defined. 
>> If there was new policy added to address this related to waitlist Ips in 
>> section 4.1.8, leasing would also need to be defined additionally in the 
>> NRPM, likely in section 2.
> 
> Hi Dustin,
> 
> The longstanding convention is that the ONLY reason someone is allowed
> to register addresses to be used by someone else is because they're
> also the ones implementing the network the other party uses. This goes
> back to the '90s when we were all trying to keep the BGP routers from
> exploding by preventing folks from getting provider-independent
> address blocks. It's the origin of the whole allocation / assignment,
> ISP / end user dichotomy in the public policy structure.

It might be longstanding convention in some people’s minds, but in reality, it 
hasn’t been fact for many many years.
Convention and policy are very different things. Convention says you try not to 
belch at the table (at least in US
polite society). However, nobody’s going to arrest you for it or claim you 
violated the terms of some contract.

> Address leasing defies that convention.

OK, you consider it unconventional. I’m not sure what that has to do with ARIN 
policy.

> The problem with changing the convention -now- is that it'd be grossly
> unfair to all the folks who for two and a half decades were denied
> IPv4 assignments from ARIN until, oh look at that, the IP addresses
> are all gone.

Nobody should have been denied addresses based on convention. Address denial 
should have been rooted in policy.

Owen

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Re: [arin-ppml] Policy Experience Report Working Group

[William Herrin]

On Fri, May 5, 2023 at 12:54 PM Dustin Moses  wrote:
> Also, I don’t see anywhere in the existing NRPM where an leasing is defined. 
> If there was new policy added to address this related to waitlist Ips in 
> section 4.1.8, leasing would also need to be defined additionally in the 
> NRPM, likely in section 2.

Hi Dustin,

The longstanding convention is that the ONLY reason someone is allowed
to register addresses to be used by someone else is because they're
also the ones implementing the network the other party uses. This goes
back to the '90s when we were all trying to keep the BGP routers from
exploding by preventing folks from getting provider-independent
address blocks. It's the origin of the whole allocation / assignment,
ISP / end user dichotomy in the public policy structure.

Address leasing defies that convention.

The problem with changing the convention -now- is that it'd be grossly
unfair to all the folks who for two and a half decades were denied
IPv4 assignments from ARIN until, oh look at that, the IP addresses
are all gone.

Regards,
Bill Herrin


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Re: [arin-ppml] Policy Experience Report Working Group

[Mike Burns]

“I do not see a reason to add policy around leasing those IP addresses at this 
time.”

+1 to what Dustin wrote.

How would the leasing of waitlist space be detected? How would the prohibition 
be enforced? How much staff time would be involved?

It’s quite simple to deliver leased addresses through a tunnel. 

Dustin has pointed out how this prohibition would result in some addresses left 
unused as the recipient waits out the 60 months before they can sell the 
addresses they no longer need. Isn’t it our goal to have addresses in use?

Why do we allow virtually all other addresses to be leased out for direct 
rent-seeking profit, but not waiting-list addresses? Remember they were all 
distributed according to need. Needs change.

The monetary interest that would motivate a run on waiting list addresses also 
ensures a very limited supply of these addresses will be distributed. Companies 
normally don’t return valuable resources to ARIN when they can sell them 
instead, and they usually pay their ARIN bills in order to maintain their claim 
on this value. Sometimes they lease them out to pay the ARIN bills while they 
bide their time. The horror!

I believe the staff has reported that the waiting list is expected to shrink 
and waiting times increase, and this makes sense to me. In any case the profit 
motive for getting free 4.1.8 address space mainly comes from the resale of it 
in five years.  A leasing prohibition won’t change that incentive.

And those seeking to profit have to demonstrate a justified need to receive the 
addresses in the first place, unless you limit your profits to what comes from 
receiving the minimum sized /24.

This is a miniscule if not imaginary problem that doesn’t require more NRPM 
verbiage, nor turning ARIN into a monitor of post-allocation usage for the 
first time.

 

 

 

From: ARIN-PPML  On Behalf Of Dustin Moses
Sent: Friday, May 5, 2023 12:28 PM
To: arin-ppml@arin.net
Subject: Re: [arin-ppml] Policy Experience Report Working Group

 

According to ARIN policy, the maximum allocation size an organization can get 
is a /22 from the waitlist. Considering also that an organization can only have 
1 waitlist request at a time and how long it takes to get an allocation on that 
waitlist, I don't see a lot of incentive for a for-profit entity to do this, 
especially over and over.

I believe the waitlist parameters inhibit organizations do this for a money 
making scheme.

Also, since the IP market already exists, what if an organization who gets an 
allocation from the waitlist, changes its priorities after a few months and 
decides to lease that space to another org? They cannot by policy 4.1.8 
transfer that space to another organization for 60 months, unless they went 
through 8.2 rules which are about re-organizing/merging. Enacting a policy 
explicitly denying leasing after a waitlist fulfillment would be tying the 
hands of that organization and thus no-one benefits here.

I do not see a reason to add policy around leasing those IP addresses at this 
time.





 <https://intermaxnetworks.com/> 





Dustin Moses​



Network Engineer II








o:   208-762-8065


  


d: (208) 758‑0489



w:  <http://intermaxnetworks.com/> intermaxnetworks.com




a: 


7400 N Mineral Drive Suite 300


, 


Coeur d'Alene


, 


ID


 


83815





 <https://twitter.com/imaxnetworks> 


 <https://www.facebook.com/ImaxNetworks/> 


 <https://linkedin.com/company/intermaxnetworks> 

-Original Message-
From: ARIN-PPML mailto:arin-ppml-boun...@arin.net> 
> On Behalf Of arin-ppml-requ...@arin.net <mailto:arin-ppml-requ...@arin.net> 
Sent: Friday, May 5, 2023 9:00 AM
To: arin-ppml@arin.net <mailto:arin-ppml@arin.net> 
Subject: ARIN-PPML Digest, Vol 215, Issue 2

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When replying, please edit your Subject line so it is more specific than "Re: 
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Today's Topics:

1. Policy Experience Report Working Group Leasing Question
(WOOD Alison * DAS)
2. Re: Policy Experience Report Working Group Leasing Question
(Michael B. Williams)


--

Message: 1
Date: Fri, 5 May 2023 15:54:17 +
From: WOOD Alison * DAS mailto:alison.w...@das.oregon.gov> >
To: "arin-ppml@arin.net <mailto:arin-ppml@arin.net> " mailto:arin-ppml@arin.net> >
Subject: [arin-ppml] Policy Experience Report Working Group Leasing
Question
Message-ID:
mailto:sa1pr09mb8318e80f3232e2e60616c26cc7...@sa1pr09m

Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[William Herrin]

On Fri, May 5, 2023 at 8:54 AM WOOD Alison * DAS
 wrote:
> I would like community feedback on the leasing of ip space that is obtained 
> from the waitlist.

Kill it and burn it with fire.

Regards,
Bill Herrin

-- 
William Herrin
b...@herrin.us
https://bill.herrin.us/
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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Matt Erculiani]

Per NRPM 4.1.8:  "...Address space distributed from the waitlist will not
be eligible for transfer, with the exception of Section 8.2 transfers, for
a period of 60 months..."

Despite this policy not explicitly covering leasing the space, I think the
same sentiment applies: One joins the waiting list to procure IPv4
Addresses to facilitate the generation of revenue (or advance a non-profit
mission) not to generate revenue off of the number resources themselves.

I have to agree that a policy to modify the verbiage of 4.1.8 to prohibit
leasing out the space for at least that same cooldown period would be
beneficial. I think it should also be clear that subleasing smaller blocks
to one's own transit customers is an exception.

-Matt

On Fri, May 5, 2023 at 11:23 AM Michael B. Williams via ARIN-PPML <
arin-ppml@arin.net> wrote:

> I completely agree!
>
>
> On Fri, May 5, 2023 at 1:21 PM John Santos  wrote:
>
>> Totally against.  This violates the principle of "justified need".  It is
>> rent-seeking.
>>
>> On 5/5/2023 11:54 AM, WOOD Alison * DAS wrote:
>> > Good morning PPML!
>> >
>> > I would like community feedback on the leasing of ip space that is
>> obtained from
>> > the waitlist.  Please let me know what you think and if a policy
>> proposal would
>> > be warranted.
>> >
>> > Thank you!
>> >
>> > -Alison
>> >
>> >
>> > ___
>> > 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.
>>
> ___
> ARIN-PPML
> You are receiving this message because you are subscribed to
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> Unsubscribe or manage your mailing list subscription at:
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> Please contact i...@arin.net if you experience any issues.
>


-- 
Matt Erculiani
ERCUL-ARIN
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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Michael B. Williams via ARIN-PPML]

I completely agree!


On Fri, May 5, 2023 at 1:21 PM John Santos  wrote:

> Totally against.  This violates the principle of "justified need".  It is
> rent-seeking.
>
> On 5/5/2023 11:54 AM, WOOD Alison * DAS wrote:
> > Good morning PPML!
> >
> > I would like community feedback on the leasing of ip space that is
> obtained from
> > the waitlist.  Please let me know what you think and if a policy
> proposal would
> > be warranted.
> >
> > Thank you!
> >
> > -Alison
> >
> >
> > ___
> > 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.
>


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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[John Santos]

Totally against.  This violates the principle of "justified need".  It is 
rent-seeking.


On 5/5/2023 11:54 AM, WOOD Alison * DAS wrote:

Good morning PPML!

I would like community feedback on the leasing of ip space that is obtained from 
the waitlist.  Please let me know what you think and if a policy proposal would 
be warranted.


Thank you!

-Alison


___
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--
John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539
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Re: [arin-ppml] Policy Experience Report Working Group

[Dustin Moses]

According to ARIN policy, the maximum allocation size an organization can get 
is a /22 from the waitlist. Considering also that an organization can only have 
1 waitlist request at a time and how long it takes to get an allocation on that 
waitlist, I don't see a lot of incentive for a for-profit entity to do this, 
especially over and over.

I believe the waitlist parameters inhibit organizations do this for a money 
making scheme.

Also, since the IP market already exists, what if an organization who gets an 
allocation from the waitlist, changes its priorities after a few months and 
decides to lease that space to another org? They cannot by policy 4.1.8 
transfer that space to another organization for 60 months, unless they went 
through 8.2 rules which are about re-organizing/merging. Enacting a policy 
explicitly denying leasing after a waitlist fulfillment would be tying the 
hands of that organization and thus no-one benefits here.

I do not see a reason to add policy around leasing those IP addresses at this 
time.


Dustin Moses
Network Engineer II
o: 208-762-8065  d: (208) 758-0489
w: intermaxnetworks.com
a: 7400 N Mineral Drive Suite 300, Coeur d'Alene, ID
83815
-Original Message-
From: ARIN-PPML  On Behalf Of 
arin-ppml-requ...@arin.net
Sent: Friday, May 5, 2023 9:00 AM
To: arin-ppml@arin.net
Subject: ARIN-PPML Digest, Vol 215, Issue 2

Send ARIN-PPML mailing list submissions to
arin-ppml@arin.net

To subscribe or unsubscribe via the World Wide Web, visit
https://lists.arin.net/mailman/listinfo/arin-ppml
or, via email, send a message with subject or body 'help' to
arin-ppml-requ...@arin.net

You can reach the person managing the list at
arin-ppml-ow...@arin.net

When replying, please edit your Subject line so it is more specific than "Re: 
Contents of ARIN-PPML digest..."


Today's Topics:

   1. Policy Experience Report Working Group Leasing Question
  (WOOD Alison * DAS)
   2. Re: Policy Experience Report Working Group Leasing Question
  (Michael B. Williams)


--

Message: 1
Date: Fri, 5 May 2023 15:54:17 +
From: WOOD Alison * DAS 
To: "arin-ppml@arin.net" 
Subject: [arin-ppml] Policy Experience Report Working Group Leasing
Question
Message-ID:



Content-Type: text/plain; charset="us-ascii"

Good morning PPML!

I would like community feedback on the leasing of ip space that is obtained 
from the waitlist.  Please let me know what you think and if a policy proposal 
would be warranted.

Thank you!

-Alison
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--

Message: 2
Date: Fri, 5 May 2023 11:58:03 -0400
From: "Michael B. Williams" 
To: "WOOD Alison * DAS" 
Cc: "arin-ppml@arin.net" 
Subject: Re: [arin-ppml] Policy Experience Report Working Group
Leasing Question
Message-ID:

Content-Type: text/plain; charset="utf-8"

Are you asking if an entity were to obtain IP space from the waitlist, should 
they be permitted to lease it to someone else? My answer is a resounding no. 
That defeats the whole purpose of the waitlist. Entities should not be 
encouraged to hoard IP space because ARIN will subsidise the cost, allowing a 
for-profit entity to make money from obtaining IP space.
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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Michael B. Williams via ARIN-PPML]

I'd go a step further even to say there should be an explicit policy
statement *against* the leasing of IP space from entities who obtain IP
space from the waitlist. Even further, if an entity obtains IP space from
the waitlist, it should have to attest that they are not leasing its IP
space to another entity. I believe in the community's efficient use of IP
space, so perhaps if an entity is not using its entire IP space, it should
hand the corresponding blocks back to ARIN or alternatively let ARIN govern
a fair and acceptable method to lease IP space. Still, it should *not* be
for profit.

On Fri, May 5, 2023 at 11:58 AM Michael B. Williams <
michael.willi...@glexia.com> wrote:

> Are you asking if an entity were to obtain IP space from the waitlist,
> should they be permitted to lease it to someone else? My answer is a
> resounding no. That defeats the whole purpose of the waitlist. Entities
> should not be encouraged to hoard IP space because ARIN will subsidise the
> cost, allowing a for-profit entity to make money from obtaining IP space.
>


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Re: [arin-ppml] Policy Experience Report Working Group Leasing Question

[Michael B. Williams via ARIN-PPML]

Are you asking if an entity were to obtain IP space from the waitlist,
should they be permitted to lease it to someone else? My answer is a
resounding no. That defeats the whole purpose of the waitlist. Entities
should not be encouraged to hoard IP space because ARIN will subsidise the
cost, allowing a for-profit entity to make money from obtaining IP space.


smime.p7s
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[arin-ppml] Policy Experience Report Working Group Leasing Question

[WOOD Alison * DAS]

Good morning PPML!

I would like community feedback on the leasing of ip space that is obtained 
from the waitlist.  Please let me know what you think and if a policy proposal 
would be warranted.

Thank you!

-Alison
___
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