Unless they lease them from the only allowed lessors (per current
policy), that is the IPv4-rich incumbent owners.
So if you want to support the little guy, I think you should support
this policy, but if you want to protect those who received address in
the past that they no longer need, then you should oppose this policy.
There are many other values the leasing company provides, values
stemming from skills related to reputation, location, hijacking,
recovery, and the pre-identification of scammers/spammers, and values
related to the provision of addresses for temporary or seasonal use,
or to enter markets aggressively which may or may not pay off. As the
market matures, more value will no doubt be driven by competition.
Things like lease-to-own options, highly efficient web or app-based
access to lessors and lessees, these are some things that spring to my
mind as capabilities to distinguish leasing companies from RIRs so as
to provide the value that the market requires. If there were no value
provided, why would anybody utilize their services?
Regards,
Mike
*From:* ARIN-PPML <arin-ppml-boun...@arin.net> *On Behalf Of *Holden Karau
*Sent:* Thursday, March 17, 2022 7:29 PM
*To:* andrew....@quark.net
*Cc:* arin-ppml <arin-ppml@arin.net>
*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 <andrew....@quark.net> 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
<arin-ppml@arin.net> wrote:
On Mar 16, 2022, at 15:22 , Fernando Frediani
<fhfredi...@gmail.com> 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
<j...@egh.com> 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 <b...@herrin.us>* wrote ----
>
> On Wed, Mar 9, 2022 at 8:24 PM ARIN
<i...@arin.net <mailto:i...@arin.net>>
> 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
> b...@herrin.us <mailto:b...@herrin.us>
>
https://bill.herrin.us/ <https://bill.herrin.us/>
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