Hi Albert,
You can't just wave away RIPE's experience like that.
I raised it to dispel the idea that a "free for all" leads to bad results.
All the rest of your post is hand-waving of supposed bad results.
If bad results will ensue, where are they at RIPE?
Can you answer that simple question?
Regards,
Mike
-----Original Message-----
From: [email protected] <[email protected]>
Sent: Monday, September 30, 2019 2:37 PM
To: Mike Burns <[email protected]>
Cc: 'Fernando Frediani' <[email protected]>; 'arin-ppml' <[email protected]>
Subject: Re: [arin-ppml] Draft Policy ARIN-2019-18: LIR/ISP Re-Assignment to
Non-Connected Networks
Like Fernando I am also strongly opposed to the leasing of IPv4 addresses and oppose
getting rid of the "operational use" requirement in 8.5.2.
I really DO NOT CARE what RIPE policy is, since we are discussing ARIN policy
on this list. I do not agree with RIPE policy on this subject, and have no
desire whatsoever to move ARIN's policy in the direction of RIPE.
It is wrong to get rid of the "operational use" requirement in 8.5.2. If one
wants to have addresses that are not connected to the Internet, they can use RFC1918
addresses, the CGNAT block of addresses, or camp out on certain class A government space
that is not currently being routed.
With 7 billion people on the earth, and only 4.3 billion possible IPv4
addresses, addresses should be only assigned, allocated and registered by ARIN
for active use.
All of the proceedures for determining the network size that an organization
qualifies for goes out the window if leasing is actively permitted by ARIN
policy, as this wording change is attempting to allow.
I strongly suspect that should the operational use requirement be struck, the
next policy proposal will be to remove all the qualification requirements in
section 4, which will have the effect of turning the IPv4 market into a free
for all.
Currently, the ability to obtain IPv4 resources is constrained by the requirement to
prove to ARIN that you need the addresses for your operational use in a network, which
will be claimed to be no unneeded once the "operational use" requirement is
gone, leaving ARIN to be nothing more than a registration operation.
While this is claimed to reduce one problem with leasing IPv4 addresses (lack
of registration and associated abuse contacts) it causes other issues. Often
network abusers lease addresses for abuse, dumping them and leasing others when
they get blacklisted.
I realize that some of the larger North American Cellular Carriers also have
been known to lease IPv4 space, these carriers would be forced to go the normal
route (and have no problems doing so) if leasing is prohibited.
Fernando spelled out in his statement a lot of other reasons why leasing should not be
allowed, and why the "operational use" requirement should not be permitted to
go away to allow leasing.
Albert Erdmann
Network Administrator
Paradise On Line Inc.
On Mon, 30 Sep 2019, Mike Burns wrote:
Hi Fernando,
You said “RIR is and has always been the one who drives the resources
to be efficientlly assigned by analysing justifications not private
transfer companies. If an organization is not using resouces efficiently it
either may change its resource assignment strategy otherwise it doesn't justify
for those addresses anymore and should return them back to the RIR.”
There is no policy in ARIN to return un-needed space. IPv4 resource
holders own something of value, which is what economists call an
“alienable asset”. It is possible for such resource holders to return such
space to ARIN, but you don’t have to be an economist to understand why they
don’t and haven’t for the most part.
Your method has been tried, and it was really a good try. The effort was
decades-long, yet recognized a failure by the clear evidence of the routing
table.
So much space allocated, yet not routed. Not enough to be explained
away by internal use; this is unconvincing. No, the space sat on the
sidelines, it was not returned to ARIN. Until the market provided the
missing incentive to action, and that action is also quite visible in the
routing table and transfer logs. The profit incentive, the draw of lucre, the
absurd effect of price have led to an increase in the efficient use of the IPv4
address universe. Geoff Huston did a good analysis of the source of
transferred addresses and showed the market brought many never-routed addresses
into efficient use.
https://blog.apnic.net/2017/01/09/studying-ipv4-transfer-market-report
ed-transfers/
You also said “It is pretty reasonable to think that in no RIRs you
are able justify more IP space by saying ‘I need these addresses in order to
lease them to someone else’. If that is never a possible justification that can
be used therefore leases don't make any sense.”
Anybody can indeed purchase RIPE addresses via transfer solely for the
purpose of leasing them out. That is because RIPE does not have a
needs justification for transfers (nor policy forbidding leasing). And
that is because, in my opinion, the RIPE community realized that their
intrinsic role of conservation would now be undertaken by market forces. These
can be relied upon to bring un- and under-utilized addresses to their “highest
and best use”, again as economists say.
But you do bring up the relevant question in the context of this ARIN
policy proposal, which is whether leasing to a “connected” customer is
all that different from leasing to a “non-connected” customer when it
comes to justifications. In the first case, the ISP normally registers the
assignment of this block to his customer in Whois and can use it as
justification. In the second there is no such registration requirement and the
lease can’t be used as a justification. To me this is a problem, and I think
there is a solution.
Conservation and Registration are our lodestars. In this case pricing
will handle conservation, but what about registration? What about when
pricing drives Conservation at the expense of Registration? I am on record as
supporting the RIPE model, which allows for lessors to purchase lease
inventory, with registered transfers, and also allows them to record leases as
assignments that include access to important contact information.
The simple and straightforward answer here is to end the needs-test for
transfers. RIPE has shown us the way, taken the “risk” and now we can look at
years’
and thousands of transfers’ worth of data. Anybody see any problems resulting
from the dropping of the needs test in RIPE?
Absent dropping the needs test for transfers, the logical step in the
context of this policy allowing leasing, is to allow certain leases to
be used for justifications while at the same time providing policy
requiring registration (SWIP) and documentation (Letter Of Agency).
It’s my opinion that this carrot and stick approach will induce Lessors to
properly register their leases while also providing a clear demarcation of
leasing versus hijacking that will empower our community and potentially law
enforcement. You want to purchase addresses because you think you can make
money in their rental? Fine, show us that you are efficiently using your prior
allocations and properly registering assignments.
There should be no difference in the way we treat those who assign to
“non-connected” or “connected” networks. ARIN calls a VPN a
connection. Times have moved on, and any two networks can be easily “connected”
for the purposes of policy-compliance only. So why trade the lack of insight
into IPv4 block contact information for the maintenance of this fig-leaf?
Regards,
Mike Burns
From: ARIN-PPML <[email protected]> On Behalf Of Fernando
Frediani
Sent: Saturday, September 28, 2019 7:20 PM
To: arin-ppml <[email protected]>
Subject: Re: [arin-ppml] Draft Policy ARIN-2019-18: LIR/ISP
Re-Assignment to Non-Connected Networks
I strongly oppose this proposal.
Leasing of IP addresses in such way should never be permmited and is a
distortion of the way IP addresses must be used by organizations.
The main reason is simple: if an organization is "leasing" IP address
it is a clear sign that the organization does not have usage for that
IP space and as it doesn't justify anymore it should therefore return them back
to the RIR in order to be re-assigned to those who really have a need for it,
via waiting list or other methods covered by the policies.
It is pretty reasonable to think that in no RIRs you are able justify
more IP space by saying "I need these addresses in order to lease them to someone
else".
If that is never a possible justification that can be used therefore leases
don't make any sense.
If an organization needs further IP space for a temporary project it
may just get from the LIR or ISP but if that is not possible and the
organization is an Autonomous System it can just go to market and get it
transfered permanentlly.
Either from the RIR or transfered via market addresses must be justified and
leases are nothing but unused address by who is willing to lease.
The justification given to allow organizations to facilitate
transition to IPv6 does not apply at all as organizations can go directlly to
the RIR for that (4.10). Why would it get via a lease bypassing the RIR ?
By allowing leases it is just skipping the RIR's function to fairly
re-distribute them and passing it private companies with financial interests.
I think 8.5.2 is already properly written and doesn't require any change.
Also Non-Connected Networks is not properly defined.
Regarding the point about Conservation to be done through market pricing I will
skip to comment such absurd thing.
Regards
Fernando
On Tue, 24 Sep 2019, 17:41 ARIN, <[email protected]> wrote:
On 19 September 2019, the ARIN Advisory Council (AC) accepted
"ARIN-prop-277: LIR/ISP Re-Assignment to Non-Connected Networks" as a
Draft Policy.
Draft Policy ARIN-2019-18 is below and can be found at:
https://www.arin.net/participate/policy/drafts/2019_18/
You are encouraged to discuss all Draft Policies on PPML. The AC will
evaluate the discussion in order to assess the conformance of this draft
policy with ARIN's Principles of Internet number resource policy as
stated in the Policy Development Process (PDP). Specifically, these
principles are:
* Enabling Fair and Impartial Number Resource Administration
* Technically Sound
* Supported by the Community
The PDP can be found at:
https://www.arin.net/participate/policy/pdp/
Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/participate/policy/drafts/
Regards,
Sean Hopkins
Policy Analyst
American Registry for Internet Numbers (ARIN)
Draft Policy ARIN-2019-18: LIR/ISP Re-Assignment to
Non-Connected Networks
Problem Statement:
Businesses have a need to lease IPv4 space for limited periods of time,
as evidenced by a robust (technically prohibited) subleasing market. The
lack of legitimization of the subleasing market hinders innovation,
research, reporting, and the development of rules/industry best
practices to ensure identifiability and contactability.
Policy statement:
ORIGINAL POLICY LANGUAGE
2.4. Local Internet Registry (LIR)
A Local Internet Registry (LIR) is an IR that primarily assigns address
space to the users of the network services that it provides. LIRs are
generally Internet Service Providers (ISPs), whose customers are
primarily end users and possibly other ISPs.
PROPOSED POLICY LANGUAGE
A Local Internet Registry (LIR) is an IR that primarily assigns address
space to the users of the network services that it provides. LIRs are
generally Internet Service Providers (ISPs), whose customers are
primarily end users and possibly other ISPs.
LIRs may also assign address space to other organizations or customers
that request it for use in an operational network.
ORIGINAL POLICY LANGUAGE
8.5.2 Operational Use
ARIN allocates or assigns number resources to organizations via transfer
solely for the purpose of use on an operational network.
PROPOSED POLICY LANGUAGE
Option 1 : Remove 8.5.2 entirely
Option 2 : Edit as follows
8.5.2 Operational Use
ARIN allocates or assigns number resources to organizations via transfer
solely primarily for the purpose of use on an operational network, but
may allocate or assign number resources to organizations for other
purposes, including re-assignment to non-connected networks .
Comments:
Timetable for implementation: Immediate
Anything Else:
The legitimization of a subleasing market for IPv4 has numerous business
and community benefits, including (but not limited to):
- Allowing organizations to efficiently utilize IPv4 space without
transferring space permanently;
- Allowing organizations to obtain IPv4 space for a limited time in
order to facilitate transition to IPv6;
- Allowing organizations to develop enforceable acceptable use policies
in a previously lawless illegitimate space;
- Allowing the community to develop reporting and recording standards
and/or best practices to the benefit of preserving the integrity of IPv4
address space.
- We would like to engage further with the ARIN community to discuss the
current state of the unauthorized subleasing market, and how this
proposed policy change would both update ARIN policies to reflect the
reality of the subleasing market, and positively address business and
community concerns.
_______________________________________________
ARIN-PPML
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