Hi Scott, Sorry, I misinterpreted your statement and missed your point. Which I guess was that the little guy should be concentrating on transitioning to IPv6 and can thus acquire "free" addresses from the 4.10 pool.
Fair enough. Regards, Mike -----Original Message----- From: [email protected] <[email protected]> Sent: Friday, March 18, 2022 11:23 AM To: Mike Burns <[email protected]> Cc: [email protected] Subject: Re: [arin-ppml] FW: Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations Mike, > > The primary value of the leasing company is that they are allowing the > effective financing of Ipv4 address space through the taking-on of > risk in the initial investment. Currently there is no vehicle for > this, and the result is that smaller, newer, less-capitalized > companies are required to pay in full, up-front, for address blocks. > Seems as though the little guy can meet these needs with 4.10, for only the cost of annual membership. I certainly was able to, realizing a cost savings over upstream LIR provided addresses. Scott > Regards, > > Mike > > > > From: ARIN-PPML <[email protected]> On Behalf Of Holden Karau > Sent: Thursday, March 17, 2022 7:29 PM > To: [email protected] > Cc: arin-ppml <[email protected]> > Subject: Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: > Permit IPv4 Leased Addresses for Purposes of Determining Utilization > for Future Allocations > > > > Wait so some company could come to ARIN and ask for a block of IP > addresses using leasing as the justification and then turn around and lease > them. > > > > What value is the leasing company providing? It seems like a solid way > to get a bunch of LLCs formed to acquire IP addresses from the waiting > list and then make money for doing ~nothing. > > > > On Thu, Mar 17, 2022 at 4:18 PM Andrew Dul <[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]> wrote: > > > > > > On Mar 16, 2022, at 15:22 , Fernando > Frediani <[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]> 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]>* wrote ---- > > > > On Wed, Mar 9, 2022 at 8:24 > PM ARIN > <[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]> > > > 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]>). > > 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. > > -- > 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]). > 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. > > > > > -- > > =============================================== > David Farmer > 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]). > > 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. > > > > _______________________________________________ > 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 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