Owen
You efforts to defend brokers interests and less of community interests
are curious. And that hasn't been just in ARIN which is even more
curious this increased efforts.
Interesting as well the conflict of "they will happen without the RIRs"
and "ethical and policy compliant".
Oh and funny joke that a broker is like a LIR.
On 17/03/2022 17:32, Owen DeLong 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/>
> _______________________________________________
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>
>
>
>
> _______________________________________________
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--
John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539
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===============================================
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Networking & Telecommunication Services
Office of Information Technology
University of Minnesota
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