I favor the kind of limitations Scott has expressed. I was commenting on the arguments made by Fernando and have not yet had the bandwidth to review the actual policy text in detail.
Owen > On Mar 17, 2022, at 16:17 , Andrew Dul <[email protected]> wrote: > > The draft policy as currently written does not provide any additional limits > against speculation. As drafted, it allows any organization (including those > who do not operate networks) to obtain IPv4 addresses for the purpose of > leasing. > > With that policy change what types of limits does the community think would > be needed? > > Thanks, > Andrew > > On 3/17/2022 3:00 PM, Scott Leibrand wrote: >> +1 to both Owen and David Farmer's comments. Leasing IPv4 space is likely >> the best solution for some networks that need those addresses to operate >> their network. If an organization wants to acquire and lease out IPv4 space >> without providing bundled IPv4 transit, that should be allowed by policy. It >> might be useful for ARIN policy to try to slightly dampen speculation by >> requiring that organizations seeking to acquire large blocks of IPv4 space >> demonstrate that their current holdings are being efficiently used by the >> organization they're registered to in whois. I am not sure if this policy >> proposal does that to my satisfaction, but once we ensure it does so, I >> would likely support it. >> >> -Scott >> >> On Thu, Mar 17, 2022 at 1:33 PM Owen DeLong via ARIN-PPML >> <[email protected] <mailto:[email protected]>> wrote: >> >> >>> On Mar 16, 2022, at 15:22 , Fernando Frediani <[email protected] >>> <mailto:[email protected]>> wrote: >>> >>> Hi David >>> >>> If I understand correctly you seem to have a view that there should be a >>> ARIN policy to permit IPv4 leasing just because it is a reality and we kind >>> of have to accept it in our days. No we don't, and that's for many >>> different reasons. >>> >> Well, of course, you are free to deny reality as much as you want. Many >> people do. It’s not particularly helpful in the discussion, however. >> >>> I am used to see people saying the brokers are doing a good thing for the >>> community by facilitating the things which in reality is the opposite. It >>> may look like a good things, but the real beneficiaries are only them who >>> profit from it without much concern of what is fair or not to most >>> organizations involved. >>> >> >> You are actually mistaken here. I used to think as you do, actually. I was >> very resistant to the first “specified transfer” policies because of some of >> the reasons you describe. However, what you are failing to recognize is that: >> + Brokers and specified transfers were going to happen with or >> without the RIRs. If they happened without the RIRs, >> there’d be no accurate record of who was using which address >> space and the provenance of addresses would be >> very difficult to support or defend. >> >> * Benefit to the community from brokers: (ethical) >> brokers are familiar with the rules in the RIRs in which >> they operate and can assist their customers in >> accurate and compliant registration updates and >> aid in keeping the allocation database(s) >> accurate. >> >> + With the economic realities of IPv4 addresses becoming >> progressively more and more expensive and the advent >> of ISPs with limited IPv4 resources available, it is inevitable >> that more and more IP service providers will be >> doing one or more of the following: >> >> + Separate surcharges for IPv4 addresses >> + Expecting customers to supply their own IPv4 addresses >> + Surcharges for IPv4 services >> + IPv4 “installation charges” large enough to cover the >> procurement of addresses >> >> * Brokers assist ISPs and customers in many of the above >> circumstances. >> >> + With a variety of organizations holding IPv4 addresses that may >> or may not even known they have them and whose >> IPv4 resources may vastly exceed their needs, it is (arguably) >> desirable to have those addresses be transferred to parties >> that have current need for IPv4 addresses. >> >> * Brokers provide a valuable service to the community >> identifying and marketing these resources >> * Paid transfers provide an incentive for entities to >> make more efficient use of the resources they have in order >> to monetize the resources they no longer need. Brokers >> are frequently able to assist in this process. >> >> + With the high cost of acquisition, IPv4 addresses have become a >> capital intensive part of any network-dependent >> business model that must support IPv4. Further, there is some >> risk that this capital outlay may be fore a resource >> which will abruptly and quickly lose its value and no longer be >> needed well before it can be amortized as a capital >> expenditure. As such, it may make sense for some entities to >> transfer that risk to another organization by using >> a lease structure instead of purchasing the addresses outright. >> >> * Brokers that provide IPv4 leasing in an ethical and >> policy compliant way provide a valuable service >> to these businesses. Yes, their price per address may >> eventually be more than it would have cost >> them to purchase the addresses, but the same is true of >> virtually any rental situation. On the other hand, >> that excess helps offset the risk that the lessor is >> taking by owning a resource that may or may not remain >> valuable and may or may not continue to produce revenue. >>> IP Leasing is very different from IP Transfer which I see not problem they >>> continue doing it. IP Transfer at least we have some guarantees that the >>> directly receiving organization really justify for them and that is a quiet >>> important (I would say fundamental) point to look at, because that is >>> fairer to everyone involved. What guarantees we have when a IP Leasing is >>> done in that sense, that fairness start to lack here. >>> >> If we set the policies up correctly, we should have the same exact >> guarantees on a lease. >> >> If $ISP acquires a /10 through transfer and then issues various >> subordinate prefixes to their customer, the only guarantee >> you have that $ISP’s customers who receive the addresses really justify >> them is that $ISP says so. We generally trust $ISP >> to act in good faith. >> >> If $LESSOR acquires a /10 through transfer and then leases various >> subordinate prefixes to their customers, we have pretty >> much the same guarantee with the additional bit that $CUSTOMER is at >> least willing to pay enough for the addresses to $LESSOR >> to make the lease make sense. In general, I think it is somewhat safe >> to assume that $CUSTOMER is not going to make a >> monthly recurring payment to $LESSOR for something they don’t intend to >> use. If one’s intent is to deprive the market and >> inflate the price, then the risk profile for such a transaction is >> vastly more favorable if you purchase rather than lease. >> >> Sure, there could be lessors that don’t get reasonable justification >> for allocations from their customers, but there are most >> certainly ISPs in that category as well. Either way, you’ve got very >> little assurance. A lessor can provide just as much >> justification to an RIR for the addresses they will allocate to leases >> as an ISP can for addresses they will lease to their >> customers. The only difference is a lease with connectivity from the >> same company or a lease from a company other than >> the one(s) providing connectivity. >>> People see the brokers are doing a favor to organizations in general by >>> facilitating they get some chunks of IPv4, but that in reality makes the >>> cost of IPv4 for both leasing and transfer more and more expensive as it >>> makes organization even more dependent from these those crumbs that seem to >>> be offered with good intention but in reality it is feeding a system that >>> is contrary the interests to most organizations involved. >>> >> Just as you are free to mount, balance, and rotate your own tires, or, you >> can go to a tire store and have them perform that service for a fee, brokers >> provide a service for a fee. If you want to obtain addresses in the transfer >> market without a broker, you’re still free to do that. Brokers are not >> driving the cost of IPv4… The scarcity and difficulty of operating with IPv4 >> is driving the cost of IPv4. Brokers are along for the ride providing a >> service and collecting a fee for that service. Whether that fee is >> reasonable or not is (and should be) entirely in the eye of the customer. >> Customers are always free to walk away and find a different supplier or look >> for their addresses independently. >>> It may sound a cliche but IPv4 is over and organizations must learn how to >>> survive with what they have, reinvent themselves and make better used of >>> their IPv4 resources, deploy a proper CGNAT, deploy IPv6 either they like >>> it or not, etc. If an organization have so little or none and need some >>> minimal amount is fine they seek for a Transfer of a minimal amount with >>> the help of brokers. >>> >> I agree. However, the increasing cost of IPv4 is a natural and organic part >> of that process and sticking our heads in the sand and pretending that it is >> not the economic reality of how the current world works will not help >> anyone. Not the community, not organizations that are short on IPv4 >> resources, and not the RIRs who are only useful so long as their databases >> provide a reasonably accurate reflection of the actual utilization of the >> address space and who controls it. >> >> A broker is an LIR just like an ISP. Since ISPs are now charging for >> addresses independent of connectivity and bandwidth, it only makes sense >> that customers can shop for them separately from different suppliers. Just >> like you can buy tires for your car from the dealership or from some other >> store that sells and supports tires, IPv4 addresses are moving that way as >> well. The RIRs can either recognize this and adapt to it with policies that >> make sense and preserve some of the things you’ve outlined as concerns >> above, or, they can simply deny the reality of IPv4 leasing and lose track >> of how addresses are actually managed for some significant chunks of the >> internet. >>> Encouraging IP Leasing as if it were something normal just "because it >>> exists today" is a shot in the foot that in the long term only worsens the >>> existing scenario, it feeds a market without much discretion increasing >>> final prices for everyone and what is the worst of all, creates even more >>> unfairness for everyone who has always submitted to the rules we have until >>> today for distributing addresses to those who really have a real >>> justification to keep control of that resource that does not belong to them. >>> >> I don’t believe that a policy that merely allows IPv4 leasing can be said to >> encourage it. Rather, it permits it, recognizes that it exists and is not >> going to stop existing just because policy pretends it can’t exist. >> >> The market is not likely to be significantly swayed by policy in terms of >> pricing, with the exception that AFRINIC has been able to preserve a >> devalued price on addresses within their region due to their restrictive >> lack of a transfer policy for moving addresses to/from AFRINIC. However, >> while this has the effect of keeping AFRINIC IPv4 addresses less expensive >> on the open market, it also leads to a significant amount of utilization of >> those addresses outside of policy and quite a bit of hoarding of addresses >> by some of AFRINIC’s largest members. ARIN’s counsel has advised against >> naming names here, so I won’t, but if you want names, contact me off list. >> >> Owen >> >>> Regards >>> Fernando >>> >>> On 16/03/2022 13:09, David Farmer via ARIN-PPML wrote: >>>> Yes, bundling IPv4 addresses with bandwidth is permitted, and in the past >>>> was common practice, heck even the expected practice. However, the fact >>>> that IPv4 address demand isn't decreasing significantly, the costs to >>>> acquire new IPv4 addresses are increasing significantly, and with the >>>> increasing commoditization of bandwidth, it is no longer economically >>>> viable to bundle bandwidth, and its associated connectivity, with IPv4 >>>> addressing. This is driving a structural separation of bandwidth, >>>> connectivity, and IPv4 addressing, from each other, instead of bundling >>>> them together as in the past. >>>> >>>> Let me state that differently; ISPs are being driven, buy cost conscience >>>> consumers, to separate the costs of bandwidth and the costs of the IPv4 >>>> addresses needed to utilize the bandwidth from each other. Minimally this >>>> separation is achieved by accounting for the costs on separate line items >>>> of a common bill from a single provider. However, price competition for >>>> bandwidth and IPv4 addresses separately will inevitably drive a structural >>>> separation between the two. Consumers will want the best price they can >>>> get for bandwidth and the best price they can get for IPv4 addresses, >>>> regardless of whether they come from a single provider or not. >>>> >>>> Some may argue this is being driven by the existence of address brokers, >>>> and their desire to make money, I disagree. While address brokers making >>>> money is the grease that keeps this machine working, the need for the >>>> machine is driven by; IPv4 free pool exhaustion, the increasing cost of >>>> IPv4 addresses, and the lack of adoption of IPv6. >>>> In other words, address brokers wouldn't exist if there wasn't a demand >>>> for their services. >>>> >>>> In short, the economic conditions that allowed for and even encouraged the >>>> bundling of IPv4 addresses with bandwidth and connectivity no longer >>>> exist, that world is gone. While I have not personally yet determined if I >>>> support this particular policy text, nevertheless, the time has come to >>>> recognize the next step in this inextricable evolution of IPv4 address >>>> policy by the ARIN policy community and permit IPv4 leasing. >>>> >>>> Thanks. >>>> >>>> On Fri, Mar 11, 2022 at 5:05 PM John Santos <[email protected] >>>> <mailto:[email protected]>> wrote: >>>> I disagree. The addresses are useless unless they ALSO purchase access >>>> and >>>> routing from another network operator. How is this cheaper? >>>> >>>> It is and always has been allowed to lease bundled access of addresses and >>>> connectivity from a LIR, without any expense for purchasing those >>>> addresses. >>>> >>>> >>>> On 3/11/2022 12:13 PM, Tom Fantacone wrote: >>>> > I support the proposal as written. >>>> > >>>> > It facilitates the provision of a valuable service to a large swath of >>>> > the ARIN >>>> > community, namely the ability of network operators with an operational >>>> > need to >>>> > lease IPv4 addresses from 3rd party lessors at a fraction of the cost of >>>> > purchasing those addresses. Too often we have seen network operators >>>> > justify >>>> > their need for IPv4 space only to find that they can't afford to make >>>> > the >>>> > purchase. They end up using CGNAT or some other sub-optimal solution. >>>> > >>>> > Bill, regarding your point "B", by providing IPv4 leasing, these 3rd >>>> > parties are >>>> > certainly performing a function that ARIN does not. >>>> > >>>> > >>>> > >>>> > ---- On Thu, 10 Mar 2022 17:46:36 -0500 *William Herrin <[email protected] >>>> > <mailto:[email protected]>>* wrote ---- >>>> > >>>> > On Wed, Mar 9, 2022 at 8:24 PM ARIN <[email protected] >>>> > <mailto:[email protected]> <mailto:[email protected] <mailto:[email protected]>>> >>>> > wrote: >>>> > > * ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of >>>> > Determining >>>> > Utilization for Future Allocations >>>> > >>>> > I continue to OPPOSE this proposal because: >>>> > >>>> > A) It asks ARIN to facilitate blatant and unapologetic rent-seeking >>>> > behavior with changes to public policy. >>>> > >>>> > B) It proposes that third parties perform precisely and only the >>>> > functions that ARIN itself performs without any credible compliance >>>> > mechanism to assure the third party performs to ARIN's standards or >>>> > in >>>> > accordance with the community's established number policy. >>>> > >>>> > Regards, >>>> > Bill Herrin >>>> > >>>> > >>>> > -- >>>> > William Herrin >>>> > [email protected] <mailto:[email protected]> <mailto:[email protected] >>>> > <mailto:[email protected]>> >>>> > https://bill.herrin.us/ <https://bill.herrin.us/> >>>> > <https://bill.herrin.us/ <https://bill.herrin.us/>> >>>> > _______________________________________________ >>>> > ARIN-PPML >>>> > You are receiving this message because you are subscribed to >>>> > the ARIN Public Policy Mailing List ([email protected] >>>> > <mailto:[email protected]> >>>> > <mailto:[email protected] <mailto:[email protected]>>). >>>> > Unsubscribe or manage your mailing list subscription at: >>>> > https://lists.arin.net/mailman/listinfo/arin-ppml >>>> > <https://lists.arin.net/mailman/listinfo/arin-ppml> >>>> > <https://lists.arin.net/mailman/listinfo/arin-ppml >>>> > <https://lists.arin.net/mailman/listinfo/arin-ppml>> >>>> > Please contact [email protected] <mailto:[email protected]> >>>> > <mailto:[email protected] <mailto:[email protected]>> if you experience any >>>> > issues. >>>> > >>>> > >>>> > >>>> > >>>> > _______________________________________________ >>>> > ARIN-PPML >>>> > You are receiving this message because you are subscribed to >>>> > the ARIN Public Policy Mailing List ([email protected] >>>> > <mailto:[email protected]>). >>>> > Unsubscribe or manage your mailing list subscription at: >>>> > https://lists.arin.net/mailman/listinfo/arin-ppml >>>> > <https://lists.arin.net/mailman/listinfo/arin-ppml> >>>> > Please contact [email protected] <mailto:[email protected]> 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 ([email protected] >>>> <mailto:[email protected]>). >>>> Unsubscribe or manage your mailing list subscription at: >>>> https://lists.arin.net/mailman/listinfo/arin-ppml >>>> <https://lists.arin.net/mailman/listinfo/arin-ppml> >>>> Please contact [email protected] <mailto:[email protected]> if you experience any >>>> issues. >>>> >>>> >>>> -- >>>> =============================================== >>>> David Farmer Email:[email protected] >>>> <mailto:email%[email protected]> >>>> Networking & Telecommunication Services >>>> Office of Information Technology >>>> University of Minnesota >>>> 2218 University Ave SE Phone: 612-626-0815 >>>> Minneapolis, MN 55414-3029 Cell: 612-812-9952 >>>> =============================================== >>>> >>>> >>>> _______________________________________________ >>>> ARIN-PPML >>>> You are receiving this message because you are subscribed to >>>> the ARIN Public Policy Mailing List ([email protected] >>>> <mailto:[email protected]>). >>>> Unsubscribe or manage your mailing list subscription at: >>>> https://lists.arin.net/mailman/listinfo/arin-ppml >>>> <https://lists.arin.net/mailman/listinfo/arin-ppml> >>>> Please contact [email protected] <mailto:[email protected]> if you experience any >>>> issues. >>> _______________________________________________ >>> ARIN-PPML >>> You are receiving this message because you are subscribed to >>> the ARIN Public Policy Mailing List ([email protected] >>> <mailto:[email protected]>). >>> Unsubscribe or manage your mailing list subscription at: >>> https://lists.arin.net/mailman/listinfo/arin-ppml >>> <https://lists.arin.net/mailman/listinfo/arin-ppml> >>> Please contact [email protected] <mailto:[email protected]> if you experience any >>> issues. >> >> _______________________________________________ >> ARIN-PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List ([email protected] >> <mailto:[email protected]>). >> Unsubscribe or manage your mailing list subscription at: >> https://lists.arin.net/mailman/listinfo/arin-ppml >> <https://lists.arin.net/mailman/listinfo/arin-ppml> >> Please contact [email protected] <mailto:[email protected]> if you experience any >> issues. >> >> >> _______________________________________________ >> ARIN-PPML >> You are receiving this message because you are subscribed to >> the ARIN Public Policy Mailing List ([email protected] >> <mailto:[email protected]>). >> Unsubscribe or manage your mailing list subscription at: >> https://lists.arin.net/mailman/listinfo/arin-ppml >> <https://lists.arin.net/mailman/listinfo/arin-ppml> >> Please contact [email protected] <mailto:[email protected]> if you experience any >> issues. > > _______________________________________________ > ARIN-PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List ([email protected]). > Unsubscribe or manage your mailing list subscription at: > https://lists.arin.net/mailman/listinfo/arin-ppml > Please contact [email protected] if you experience any issues.
_______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected] if you experience any issues.
