Hello
Why do you use the term "purchase 'RIR' addresses" ? They don't sold
them and never did it. Most here know well that what we pay are
administrative fees and we are resource holders. Therefore there is no
selling of addresses by RIRs as they don't manufacture them.
With regards address return this can be done by the will of Autonomous
System or by the RIR when policies and contract are applied. Although I
agree now a days will be rare to see it is possible and would be the
right thing to do for any organization holding a lot of addresses where
they don't have justification for it anymore. We are talking about a
concept.
Still RIRs or NIRs can ask an organization to justify **at any time**
they need to keep those addresses should they have indications all
assignments are not justified anymore. This is actually done in other
RIRs and not something uncommon to happen. Since BCP-12 written by Jon
Postel himself and others it is there very clear that RIRs "may, at any
time, ask for this information" and what are the implications. This
keeps been the way RIRs deal with it in order to assign addresses to
organizations and is a pretty obvious thing: an organization which
doesn't justify anymore cannot receive or keep the addresses previously
assigned (not sold) to them and these address must be re-assigned to
other organizations.
You mentioned someone is able to transfer address in RIPE without having
to justify the need of them and because of that he is able to lease
them. Let's assume this as true. Still if the RIR finds (after the
transfer is concluded) an organization is not using a fair amount of the
assignments then the right is to ask them to justify and if they fail
those addresses should be recovered.
As leases is not a proper use of address by the organization who
received them from the RIR or by their directly connected customers they
have no propose to be kept with that organization anymore just for
speculation. Addresses are not meant to be leased, but to get people
connected to the internet. As mentioned by Albert whatever the RIPE
policy differs form ARIN it is not mandatory for ARIN to copy or adopt
it. And as mentioned in other messages there are differences from both
scenarios and regions.
With regards pricing and conservation the point is quiet simple: IP
addresses are never meant to be leased but to get people connected to
the internet. They must be assigned to those who really need them not to
those who can pay more. We are not talking a manufactured product that
you may produce as much as you wish and sell and re-sell in the market
freely.
And the RIR is the only possible neutral organization able to apply the
rules equally to anyone following this principles. Why would we as a
community want to give it over to private companies only interested to
profit from these transactions and not concerned about if addresses will
be properly used to get people connected or to be speculated ?
Allowing leases basically skips the ability from the RIR to apply rules
equally to everyone and ask for justifications whenever needed passing
it out to private profit driven organizations. Why do we want that to
happen ?
If someone has usage for IP addresses and cannot get them directly from
the RIR it can do via permanent transfers. Any other ways don't serve to
the interests of organizations in the region, but only to a few private
and specific interests.
Fernando
On 30/09/2019 15:02, 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-reported-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]
<mailto:[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.
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