Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[John Curran]

On 21 Mar 2022, at 7:29 PM, John Curran 
mailto:jcur...@arin.net>> wrote:

On 21 Mar 2022, at 7:13 PM, Jay Hennigan 
mailto:j...@impulse.net>> wrote:

On 3/21/22 16:03, Mike Burns wrote:
Hi Martin,
We once saw an ipv4 block included among hardware as part of a third party 
lease.
That happened years ago and really was a one-off. Generally nobody will 
recognize IPv4 blocks as assets.
That leaves leasing-out addresses by incumbent address holders as the only 
effective financing mechanism.

I'm curious if ARIN has put any thought into how encouraging leasing will 
affect the practice of spammers and other bad actors leasing IPv4 space, 
turning it into a DNSBL wasteland, lather, rinse, repeat.

Jay -

There’s often quite a bit of work involved in getting a prefix off most 
blocklists, so the burden will be fall to the lessor to explain why a given 
recently-polluted prefix should be removed and won’t just be let out to the 
same (or materially similar) party – i.e. some folks may get away with that 
once, but it’s very likely to work a second time.

My bad - that should have read:  "it’s very _unlikely_ to work a second time."

Apologies,
/John

John Curran
President and CEO
American Registry for Internet Numbers


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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[John Curran]

On 21 Mar 2022, at 7:13 PM, Jay Hennigan 
mailto:j...@impulse.net>> wrote:

On 3/21/22 16:03, Mike Burns wrote:
Hi Martin,
We once saw an ipv4 block included among hardware as part of a third party 
lease.
That happened years ago and really was a one-off. Generally nobody will 
recognize IPv4 blocks as assets.
That leaves leasing-out addresses by incumbent address holders as the only 
effective financing mechanism.

I'm curious if ARIN has put any thought into how encouraging leasing will 
affect the practice of spammers and other bad actors leasing IPv4 space, 
turning it into a DNSBL wasteland, lather, rinse, repeat.

Jay -

There’s often quite a bit of work involved in getting a prefix off most 
blocklists, so the burden will be fall to the lessor to explain why a given 
recently-polluted prefix should be removed and won’t just be let out to the 
same (or materially similar) party – i.e. some folks may get away with that 
once, but it’s very likely to work a second time.

Thanks,
/John

John Curran
President and CEO
American Registry for Internet Numbers



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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Mike Burns]

Hi Jay,

The Spamhauses of the world don't allow infinite lather rinse repeat cycles.

Regards,
Mike  On Mon, 21 Mar 2022 19:13:49 -0400  j...@impulse.net  wrote On 
3/21/22 16:03, Mike Burns wrote:
> Hi Martin,
> 
> We once saw an ipv4 block included among hardware as part of a third 
> party lease.
> 
> That happened years ago and really was a one-off. Generally nobody will 
> recognize IPv4 blocks as assets.
> 
> That leaves leasing-out addresses by incumbent address holders as the 
> only effective financing mechanism.

I'm curious if ARIN has put any thought into how encouraging leasing 
will affect the practice of spammers and other bad actors leasing IPv4 
space, turning it into a DNSBL wasteland, lather, rinse, repeat.

-- 
Jay Hennigan  |  j...@impulse.net  |  CCIE #7880  |  WB6RDV
Chief Network Architect  |  Impulse Advanced Communications
direct 805.884.6323  |  fax 805.880.1523  |  www.impulse.net
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Jay Hennigan]

On 3/21/22 16:03, Mike Burns wrote:

Hi Martin,

We once saw an ipv4 block included among hardware as part of a third 
party lease.


That happened years ago and really was a one-off. Generally nobody will 
recognize IPv4 blocks as assets.


That leaves leasing-out addresses by incumbent address holders as the 
only effective financing mechanism.


I'm curious if ARIN has put any thought into how encouraging leasing 
will affect the practice of spammers and other bad actors leasing IPv4 
space, turning it into a DNSBL wasteland, lather, rinse, repeat.


--
Jay Hennigan  |  j...@impulse.net  |  CCIE #7880  |  WB6RDV
Chief Network Architect  |  Impulse Advanced Communications
direct 805.884.6323  |  fax 805.880.1523  |  www.impulse.net
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Mike Burns]

Hi Martin,

We once saw an ipv4 block included among hardware as part of a third party 
lease.

That happened years ago and really was a one-off. Generally nobody will 
recognize IPv4 blocks as assets.

That leaves leasing-out addresses by incumbent address holders as the only 
effective financing mechanism.

We have been asked about lease-to-own arrangements but policy makes those sorts 
of transactions very difficult.Regards,Mike  On Mon, 21 Mar 2022 18:15:26 
-0400  hanni...@gmail.com  wrote On Sun, Mar 20, 2022 at 10:42 Martin 
Hannigan  wrote:On Fri, Mar 18, 2022 at 5:47 PM Scott 
Leibrand  wrote:On Fri, Mar 18, 2022 at 12:39 PM Mike 
Burns  wrote:Hi Scott, I am sorry, I actually penned a long 
reply to  your initial post but never sent it.The limit on initial block size 
is the same as if you came to ARIN seeking a block not for lease, but for your 
circuit-connected customers. To wit, ARIN will require more than just your 
statement.What’s to stop a company from claiming they will be delivering 
service to connected clients over the next two years, so they should get a 
pre-approval?They have to buy equipment and sign contracts for transit to 
deliver such service. That equipment is worth far less if re-sold, and those 
contracts cost money to terminate.Equipment can be repurposed. Contracts can 
provide portability of capital or resources. Contracts can have termination for 
convenience options. Might be more useful to think about cost of capital, risk 
and other factors that go into IPv4 "speculating".And heres another data point. 
No reputable private equity firm or source of capital (that Im aware of) has 
funded IP speculation. I wonder why. Doubt you can even finance them non 
recourse and with a big balance sheet. Mike/Tom, see anything different? 
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Martin Hannigan]

On Sun, Mar 20, 2022 at 10:42 Martin Hannigan  wrote:

>
>
> On Fri, Mar 18, 2022 at 5:47 PM Scott Leibrand 
> wrote:
>
>>
>>
>> On Fri, Mar 18, 2022 at 12:39 PM Mike Burns  wrote:
>>
>>> Hi Scott,
>>>
>>>
>>>
>>> I am sorry, I actually penned a long reply to  your initial post but
>>> never sent it.
>>>
>>> The limit on initial block size is the same as if you came to ARIN
>>> seeking a block not for lease, but for your circuit-connected customers. To
>>> wit, ARIN will require more than just your statement.
>>>
>>> What’s to stop a company from claiming they will be delivering service
>>> to connected clients over the next two years, so they should get a
>>> pre-approval?
>>>
>>
>> They have to buy equipment and sign contracts for transit to deliver such
>> service. That equipment is worth far less if re-sold, and those contracts
>> cost money to terminate.
>>
>
> Equipment can be repurposed. Contracts can provide portability of capital
> or resources. Contracts can have termination for convenience options. Might
> be more useful to think about cost of capital, risk and other factors that
> go into IPv4 "speculating".
>


And heres another data point. No reputable private equity firm or source of
capital (that Im aware of) has funded IP speculation. I wonder why.

Doubt you can even finance them non recourse and with a big balance sheet.

Mike/Tom, see anything different?
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[John Curran]

Owen - 

Leasing being part of the "economic reality of IPv4 for the foreseeable 
future” is orthogonal to the ARIN registry – i.e. such an occurrence does not 
necessarily mean that ARIN should do either of:

a)  Issue additional IPv4 resources via the wait-list policy to 
parties for the purpose of leasing to others absent connectivity services

b)  Take into consideration a purported need based on IPv4 
leasing to others (absent connectivity services) when assessing the validity of 
an 8.3/8.4 transfer request 

It would be good to hear clear arguments on why each of the above 
changes is warranted; i.e. what is the specific benefit to the ARIN community 
would be achieved as result.

(I have no view either way on the merits of the proposed policy, but 
believe the community should have as much clarity as possible on desired policy 
outcomes.)

Thanks!
/John

John Curran
President and CEO
American Registry for Internet Numbers

> On 20 Mar 2022, at 7:25 PM, Owen DeLong via ARIN-PPML  
> wrote:
> 
> Leasing involves a contract for services, just like an ISP.
> 
> It’s no more arms length than leasing addresses to someone you sell 
> connectivity to, you have a nearly identical contractual relationship.
> 
> In fact, many ISPs charge for former customers to retain their addresses 
> after they terminate their connectivity. How does that differ from a company 
> which leases addresses without connectivity?
> 
> I’m currently neither in favor of nor opposed to the proposed policy as 
> written. I think it needs work before it’s ready to be a policy.
> 
> However, I am in favor of formalizing the practice of leasing in policy since 
> it is the economic reality of IPv4 for the foreseeable future, whether it is 
> formalized in policy or not.
> 
> Owen
> 
> 
>> On Mar 18, 2022, at 16:13, Michael Peddemors  wrote:
>> 
>> I oppose..
>> 
>> This removes ARIN's governance of IPv4 resources completely.  And in a worst 
>> case scenario a single party could buy up all of the IPv4 resources in 
>> theory, and effectively control the internet.
>> 
>> "Leasing" is for to wide of a definition, and needs to be better described 
>> before even considering this.
>> 
>> "leasing" is not a usage, IMHO in terms of the original mandate of ARIN, 
>> without a fixed customer base for services (eg, it could be said every ISP 
>> leases IPs to their customers) which is very different than saying we rent 
>> the IP(s) to arm's length parties.
>> 
>> On 2022-03-17 17:23, Owen DeLong via ARIN-PPML wrote:
>>> Actually, they’d be doing all of the same things any other LIR does with 
>>> the exception of providing bandwidth and connectivity services.
>>> They’d still be responsible for getting a reasonable justification from the 
>>> customer, validating that justification, registering the addresses properly 
>>> in whois, etc.
>>> It might be a bit less overhead than being an ISP, but ISPs are 
>>> increasingly short on IPv4 addresses and asking customers to get their own.
>>> Many customers are unable to make the capital outlay necessary to purchase 
>>> the addresses they need, but do have the cash flow to support a lease.
>>> Many customers have a desire not to take the risk of a large capital outlay 
>>> for a necessary component which may abruptly lose its value in the near to 
>>> medium term.
>>> This situation will only get worse as the cost of IPv4 addresses continues 
>>> to rise and as IPv6 deployment continues.
>>> Owen
 On Mar 17, 2022, at 16:28 , Holden Karau >>> > wrote:
 
 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 >>> > 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
...
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Fernando Frediani]

You may repeat 1000 times and still it will not become a true that when 
someone sell connectivity they lease IP addresses. When someone buys 
connectivity having an IP address is a condition for them to receive the 
connectivity services they are buying and the real propose of keeping IP 
addresses justified to the RIR.
There is a big and clear difference in one case and in the other which 
the build of Internet infrastructure and the service provision which is 
the main reason to justify the addresses.


Fernando

Em 20/03/2022 20:25, Owen DeLong via ARIN-PPML escreveu:

Leasing involves a contract for services, just like an ISP.

It’s no more arms length than leasing addresses to someone you sell 
connectivity to, you have a nearly identical contractual relationship.

In fact, many ISPs charge for former customers to retain their addresses after 
they terminate their connectivity. How does that differ from a company which 
leases addresses without connectivity?

I’m currently neither in favor of nor opposed to the proposed policy as 
written. I think it needs work before it’s ready to be a policy.

However, I am in favor of formalizing the practice of leasing in policy since 
it is the economic reality of IPv4 for the foreseeable future, whether it is 
formalized in policy or not.

Owen



On Mar 18, 2022, at 16:13, Michael Peddemors  wrote:

I oppose..

This removes ARIN's governance of IPv4 resources completely.  And in a worst 
case scenario a single party could buy up all of the IPv4 resources in theory, 
and effectively control the internet.

"Leasing" is for to wide of a definition, and needs to be better described 
before even considering this.

"leasing" is not a usage, IMHO in terms of the original mandate of ARIN, 
without a fixed customer base for services (eg, it could be said every ISP leases IPs to 
their customers) which is very different than saying we rent the IP(s) to arm's length 
parties.

On 2022-03-17 17:23, Owen DeLong via ARIN-PPML wrote:

Actually, they’d be doing all of the same things any other LIR does with the 
exception of providing bandwidth and connectivity services.
They’d still be responsible for getting a reasonable justification from the 
customer, validating that justification, registering the addresses properly in 
whois, etc.
It might be a bit less overhead than being an ISP, but ISPs are increasingly 
short on IPv4 addresses and asking customers to get their own.
Many customers are unable to make the capital outlay necessary to purchase the 
addresses they need, but do have the cash flow to support a lease.
Many customers have a desire not to take the risk of a large capital outlay for 
a necessary component which may abruptly lose its value in the near to medium 
term.
This situation will only get worse as the cost of IPv4 addresses continues to 
rise and as IPv6 deployment continues.
Owen

On Mar 17, 2022, at 16:28 , Holden Karau mailto:hol...@pigscanfly.ca>> wrote:

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 mailto: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
mailto:arin-ppml@arin.net>> wrote:




On Mar 16, 2022, at 15:22 , Fernando Frediani
mailto: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. 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Owen DeLong via ARIN-PPML]

Leasing involves a contract for services, just like an ISP.

It’s no more arms length than leasing addresses to someone you sell 
connectivity to, you have a nearly identical contractual relationship.

In fact, many ISPs charge for former customers to retain their addresses after 
they terminate their connectivity. How does that differ from a company which 
leases addresses without connectivity?

I’m currently neither in favor of nor opposed to the proposed policy as 
written. I think it needs work before it’s ready to be a policy.

However, I am in favor of formalizing the practice of leasing in policy since 
it is the economic reality of IPv4 for the foreseeable future, whether it is 
formalized in policy or not.

Owen


> On Mar 18, 2022, at 16:13, Michael Peddemors  wrote:
> 
> I oppose..
> 
> This removes ARIN's governance of IPv4 resources completely.  And in a worst 
> case scenario a single party could buy up all of the IPv4 resources in 
> theory, and effectively control the internet.
> 
> "Leasing" is for to wide of a definition, and needs to be better described 
> before even considering this.
> 
> "leasing" is not a usage, IMHO in terms of the original mandate of ARIN, 
> without a fixed customer base for services (eg, it could be said every ISP 
> leases IPs to their customers) which is very different than saying we rent 
> the IP(s) to arm's length parties.
> 
> On 2022-03-17 17:23, Owen DeLong via ARIN-PPML wrote:
>> Actually, they’d be doing all of the same things any other LIR does with the 
>> exception of providing bandwidth and connectivity services.
>> They’d still be responsible for getting a reasonable justification from the 
>> customer, validating that justification, registering the addresses properly 
>> in whois, etc.
>> It might be a bit less overhead than being an ISP, but ISPs are increasingly 
>> short on IPv4 addresses and asking customers to get their own.
>> Many customers are unable to make the capital outlay necessary to purchase 
>> the addresses they need, but do have the cash flow to support a lease.
>> Many customers have a desire not to take the risk of a large capital outlay 
>> for a necessary component which may abruptly lose its value in the near to 
>> medium term.
>> This situation will only get worse as the cost of IPv4 addresses continues 
>> to rise and as IPv6 deployment continues.
>> Owen
>>> On Mar 17, 2022, at 16:28 , Holden Karau >> > wrote:
>>> 
>>> 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 >> > 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
mailto:arin-ppml@arin.net>> wrote:
 
 
 
>On Mar 16, 2022, at 15:22 , Fernando Frediani
>mailto: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 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Martin Hannigan]

On Fri, Mar 18, 2022 at 5:47 PM Scott Leibrand 
wrote:

>
>
> On Fri, Mar 18, 2022 at 12:39 PM Mike Burns  wrote:
>
>> Hi Scott,
>>
>>
>>
>> I am sorry, I actually penned a long reply to  your initial post but
>> never sent it.
>>
>> The limit on initial block size is the same as if you came to ARIN
>> seeking a block not for lease, but for your circuit-connected customers. To
>> wit, ARIN will require more than just your statement.
>>
>> What’s to stop a company from claiming they will be delivering service to
>> connected clients over the next two years, so they should get a
>> pre-approval?
>>
>
> They have to buy equipment and sign contracts for transit to deliver such
> service. That equipment is worth far less if re-sold, and those contracts
> cost money to terminate.
>

Equipment can be repurposed. Contracts can provide portability of capital
or resources. Contracts can have termination for convenience options. Might
be more useful to think about cost of capital, risk and other factors that
go into IPv4 "speculating".

/not an attorney nor using Attorney Google

Warm regards,

-M<
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Michael Peddemors]

I oppose..

This removes ARIN's governance of IPv4 resources completely.  And in a 
worst case scenario a single party could buy up all of the IPv4 
resources in theory, and effectively control the internet.


"Leasing" is for to wide of a definition, and needs to be better 
described before even considering this.


"leasing" is not a usage, IMHO in terms of the original mandate of ARIN, 
without a fixed customer base for services (eg, it could be said every 
ISP leases IPs to their customers) which is very different than saying 
we rent the IP(s) to arm's length parties.


On 2022-03-17 17:23, Owen DeLong via ARIN-PPML wrote:
Actually, they’d be doing all of the same things any other LIR does with 
the exception of providing bandwidth and connectivity services.


They’d still be responsible for getting a reasonable justification from 
the customer, validating that justification, registering the addresses 
properly in whois, etc.


It might be a bit less overhead than being an ISP, but ISPs are 
increasingly short on IPv4 addresses and asking customers to get their own.


Many customers are unable to make the capital outlay necessary to 
purchase the addresses they need, but do have the cash flow to support a 
lease.


Many customers have a desire not to take the risk of a large capital 
outlay for a necessary component which may abruptly lose its value in 
the near to medium term.


This situation will only get worse as the cost of IPv4 addresses 
continues to rise and as IPv6 deployment continues.


Owen


On Mar 17, 2022, at 16:28 , Holden Karau > wrote:


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 > 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
mailto:arin-ppml@arin.net>> wrote:




On Mar 16, 2022, at 15:22 , Fernando Frediani
mailto: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
   

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Owen DeLong via ARIN-PPML]

> On Mar 11, 2022, at 11:37, Fernando Frediani  wrote:
> 
> Scott, the point is that we should not be spending much time and should 
> dismiss such proposal because although it may not look like it is willing to 
> change a fundamental thing about IP address usage based on justification, 
> something that doesn't require to much debate such obvious it is. 
> Fundamentally we are not dealing with an irrevocable asset that someone 
> purchased and may dispose or sell it at he/she wishes, but about a right to 
> use which may be revoked if used against the rules.
> Therefore it should not need too much debate to find out that anyone using 
> this scarce resources, that doesn't belong to anyone individually MUST always 
> justify for that need.
> 
Fortunately for the community, you are not the arbiter of what we do or do not 
consider in terms of policy proposals and you don’t get to decide what we do or 
don’t spend time on. Fortunately, you aren’t granted the authority to dismiss a 
proposal based on your faulty tautological reasoning.

This is a legitimate proposal. It is being considered by the community, and it 
is unlikely that the AC will abandon it out of hand simply because you have 
decreed that it should be so.

Like it or not, there is value in current IPv4 registrations issued by RIRs 
today. This value fluctuates as a function of demand for IPv4 addresses and 
availability of addresses from various sources. Currently, those sources are 
limited to:
RIR free pools (when such exist, mostly not these days)
Transfers (essentially party A purchasing all or part of party B’s 
registration and effecting the
transfer of that registration through complex interaction with 
the applicable RIR(s)).
Leasing from a party that has addresses and/or engages in wholesale 
leasing of addresses from
fourth parties.

The first is allowed universally and fits your model of the world. 
Unfortunately, it is not effective or timely for most businesses these days.

The second is allowed everywhere except AFRINIC and even in AFRINIC with some 
bizarre limitations.

The third is allowed in the RIPE region and common in the APNIC region even 
though technically prohibited by policy. In the ARIN region, it’s tacitly 
allowed, but a lessor cannot use their lease customers as justification for 
acquiring additional space by transfer or from the free pool. The proposal we 
are discussing would change this.
> There is already a neutral and well established entity tasked to evaluate 
> those justifications, the RIR, and we all assume they do this in the most 
> impartial way. And better they do this directlly with those who are really 
> using the resources, not via a 3rd party who have financial interest in it.
> 
Well, yes and no… Mostly, RIRs don’t evaluate most of those justifications. 
That task is delegated to LIRs for the most part. LIRs are traditionally 
providers of connectivity and addresses. Traditionally, connectivity cost and 
addresses were included for free, much the way gas stations with car washes 
used to include a free car wash when you filled up your tank (though they 
usually charged slightly more per gallon than gas stations without car washes).

Now that the gas stations (LIRs) are starting to charge for the car wash 
(addresses) separately from the gas (connectivity), people want the option of 
driving down the street to get a cheaper car wash (lessors).
> For those that for a moment believe a lessor may be able to justify to the 
> RIR that "their clients are really using it" (just look how absurd this is!), 
> it is a lot simple and removes any points of doubt to just have any 
> unjustified space to be returned to the RIR and they, according to the 
> current agreed rules will re-distribute those addresses to those who are 
> really building operational networks in a most neutral and fair way, not to 
> those who are able to pay more for it.
> 
So you’re saying that LIRs can’t tell if their customers are really using the 
addresses they issue to them? A lessor is just an LIR that isn’t providing 
network services to the same client. It’s not an entirely new model for 
distribution of addresses, it’s just an unbundling of previously bundled 
services.

Your pretense that this is somehow novel or absurd rings hollow.
> If for some reason a resource holder realizes doesn't need any addresses 
> anymore there are always the Transfer policies in place. As long the receiver 
> can justify the need and building networks ARIN will proceed with the 
> transfer.
> 
You’re ignoring the existence of an entire class of resource holder who are 
getting their addresses from LIRs. These resource holders actually hold the 
majority of the resources issued by RIRs. When they no longer need, the 
resources revert to the LIR in question, not to an RIR. This is how it 
currently works with LIRs that also sell network services. This is also how it 
would work with 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Scott Leibrand]

On Fri, Mar 18, 2022 at 12:39 PM Mike Burns  wrote:

> Hi Scott,
>
>
>
> I am sorry, I actually penned a long reply to  your initial post but never
> sent it.
>
> The limit on initial block size is the same as if you came to ARIN seeking
> a block not for lease, but for your circuit-connected customers. To wit,
> ARIN will require more than just your statement.
>
> What’s to stop a company from claiming they will be delivering service to
> connected clients over the next two years, so they should get a
> pre-approval?
>

They have to buy equipment and sign contracts for transit to deliver such
service. That equipment is worth far less if re-sold, and those contracts
cost money to terminate.

If literally the only thing I have to purchase to start an IP leasing
company is the addresses themselves, and I expect the addresses to continue
appreciating in value, then I am incentivized to buy the largest block I
can and provide ARIN with extremely optimistic (but not fraudulent) sales
projections showing how I plan to lease it all out. If I fail to lease the
space out as fast as my optimistic plans, I still make a healthy profit on
any price appreciation.

One way to address this might be to require that the documentation to be
provided to ARIN which details the use of at least 50% of the requested
IPv4 block be in the form of binding contracts if the IPv4 space is
intended for reassignment to customers. That way, a speculative lessor can
only start with a /24 or 2x as much IP space as they've already signed up
customers for, and then can come back to ARIN to transfer more as soon as
their customers have efficiently utilized at least 50% of their cumulative
IPv4 space.

If that's the approach we want to take, I think we'd need to modify the
policy to stipulate that.


>
> The initial size for a section 8 transfer per 8.5.5 is a /24. To get a
> larger initial block, evidence is required that should be equivalent in
> scope and detail regardless of whether the anticipated clients are
> connected with a circuit or not. Are we seeing such fraud by ISPs to
> increase their purchase size?
>
>
>
> Finally, if you attest to fraudulent information, you are taking liability
> risks that also dampen speculation.
>
>
>
> Regards,
>
> Mike
>
> PS You ignored my request for evidence of speculation at RIPE where
> absolutely no needs demonstration has been required for many years. 
>

It won't discuss in public whether I have observed speculation first-hand,
but I will say that all transactions I'm aware of were above-board and
policy-compliant. I do agree, though, that pure financial speculation is
not driving the overall market price for addresses beyond the difference
between prices for RIPE vs. ARIN space (which is minimal). If the choice
were between RIPE's (lack of) policy and ARIN's current no-leasing-allowed
policy, I'd likely choose RIPE's. But I think a leasing-allowed policy that
limits initial block size and then allows additional transfers based on 50%
utilization would be better than both of those.

-Scott


>
>
>
>
>
>
>
>
>
>
> *From:* Scott Leibrand 
> *Sent:* Friday, March 18, 2022 3:25 PM
> *To:* Mike Burns 
> *Cc:* Owen DeLong ; Andrew Dul ;
> 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
>
>
>
>
>
> On Mar 18, 2022, at 7:37 AM, Mike Burns  wrote:
>
> 
>
> Hi Owen, Andrew, and Scott,
>
>
>
> Transfer approval of a larger-than-minimum block size requires detailed
> documentation of the use of at least 50% of the block in 24 months, and
> that detailed documentation must be officer-attested.  I’m sure we all
> agree that nobody can approach ARIN for a large initial block without
> providing believable documentation to ARIN, and the attestation provides
> actionability against fraud.
>
>
>
> I don’t doubt that believable documentation is required. But my concern,
> as I stated in the very first reply to this thread that everyone ignored,
> is:
>
>
>
> If you’re going to remove that, what is to stop me from opening a new LIR
> and stating that I want pre-qualification for a transfer of a /8 to lease
> out, because I have sales projections that I can lease out a /9 within 24
> months, a /10 within 12 months, and a /11 within 6 months? And if I fail to
> meet my sales projections, I can sell some or all of the /8 after 12 months
> (presumably at a profit, as prices just keep going up).
>
>
>
> It seems that there should be some limit on initial block size if we’re
> going to rely exclusively on recipients’ leasing projections instead of
> requiring use on an operational network.
>
>
>
> I take your point about a /8 being infeasible to acquire on the market,
> but the same point applies at whatever the maximum available size currently
> is.
>
>
>
> -Scott
>
>
>
> Further transfers require proof of utilization of the original transfers.
>
>
>
> This persistent fear of 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Owen DeLong via ARIN-PPML]

While it has always been allowed, it’s becoming less common that LIRs are 
willing to do so. Many ISPs are starting to add surcharges for IPv4 addresses 
and in some cases, even for IPv4 service (whether expressed as a discount for 
IPv6 only or a surcharge for IPv4, it amounts to the same thing).

Since network providers are starting to add line-item billing for addressing 
and/or encourage their customers to BYO addressing, you now have customers that 
are seeking to reduce the price they pay per address to go with their 
connectivity.

If lessors are competitive with service providers, then obviously it is in fact 
cheaper. If they are not competitive, then likely they will eventually go out 
of business for lack of customers and whatever addresses they were holding are 
returned to the RIR free pool when they fail to pay their annual bill.

That doesn’t provide a path whereby lessors can inflate the price of IPv4 
addresses.

Now you _COULD_ try to make the argument that lessors acquiring IPv4 addresses 
are reducing the number of addresses available for transfer and therefore 
increasing the price of transfers, but the reality is that even with this 
policy, they are likely noise in that equation compared to the cloud providers 
that are vacuuming up available IPv4 addresses like they are going out of 
style. (Which, ideally, they are and then this will no longer be an issue at 
all).

Owen


> On Mar 11, 2022, at 15:04, John Santos  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 * 
>> wrote 
>>On Wed, Mar 9, 2022 at 8:24 PM ARIN 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 
>>https://bill.herrin.us/ 
>>___
>>ARIN-PPML
>>You are receiving this message because you are subscribed to
>>the ARIN Public Policy Mailing List (ARIN-PPML@arin.net
>>).
>>Unsubscribe or manage your mailing list subscription at:
>>https://lists.arin.net/mailman/listinfo/arin-ppml
>>
>>Please contact i...@arin.net  if you experience any
>>issues.
>> ___
>> ARIN-PPML
>> You are receiving this message because you are subscribed to
>> the ARIN Public Policy Mailing List (ARIN-PPML@arin.net).
>> Unsubscribe or manage your mailing list subscription at:
>> https://lists.arin.net/mailman/listinfo/arin-ppml
>> Please contact i...@arin.net 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 (ARIN-PPML@arin.net).
> Unsubscribe or manage your mailing list subscription at:
> https://lists.arin.net/mailman/listinfo/arin-ppml
> Please contact i...@arin.net if you experience any issues.

___
ARIN-PPML
You are receiving this message because you are subscribed to
the ARIN Public Policy Mailing List (ARIN-PPML@arin.net).
Unsubscribe or manage your mailing list subscription at:
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Please contact 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Fernando Frediani]

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  
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 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Mike Burns]

Hi Scott,

 

I am sorry, I actually penned a long reply to  your initial post but never sent 
it.

The limit on initial block size is the same as if you came to ARIN seeking a 
block not for lease, but for your circuit-connected customers. To wit, ARIN 
will require more than just your statement.

What’s to stop a company from claiming they will be delivering service to 
connected clients over the next two years, so they should get a pre-approval?

 

The initial size for a section 8 transfer per 8.5.5 is a /24. To get a larger 
initial block, evidence is required that should be equivalent in scope and 
detail regardless of whether the anticipated clients are connected with a 
circuit or not. Are we seeing such fraud by ISPs to increase their purchase 
size? 

 

Finally, if you attest to fraudulent information, you are taking liability 
risks that also dampen speculation.

 

Regards,

Mike

PS You ignored my request for evidence of speculation at RIPE where absolutely 
no needs demonstration has been required for many years. 

 

 

 

 

 

From: Scott Leibrand  
Sent: Friday, March 18, 2022 3:25 PM
To: Mike Burns 
Cc: Owen DeLong ; Andrew Dul ; 
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

 

 

On Mar 18, 2022, at 7:37 AM, Mike Burns mailto:m...@iptrading.com> > wrote:



Hi Owen, Andrew, and Scott,

 

Transfer approval of a larger-than-minimum block size requires detailed 
documentation of the use of at least 50% of the block in 24 months, and that 
detailed documentation must be officer-attested.  I’m sure we all agree that 
nobody can approach ARIN for a large initial block without providing believable 
documentation to ARIN, and the attestation provides actionability against 
fraud. 

 

I don’t doubt that believable documentation is required. But my concern, as I 
stated in the very first reply to this thread that everyone ignored, is:

 

If you’re going to remove that, what is to stop me from opening a new LIR and 
stating that I want pre-qualification for a transfer of a /8 to lease out, 
because I have sales projections that I can lease out a /9 within 24 months, a 
/10 within 12 months, and a /11 within 6 months? And if I fail to meet my sales 
projections, I can sell some or all of the /8 after 12 months (presumably at a 
profit, as prices just keep going up).  

 

It seems that there should be some limit on initial block size if we’re going 
to rely exclusively on recipients’ leasing projections instead of requiring use 
on an operational network.

 

I take your point about a /8 being infeasible to acquire on the market, but the 
same point applies at whatever the maximum available size currently is. 

 

-Scott

 

Further transfers require proof of utilization of the original transfers. 

 

This persistent fear of “speculation”, whatever that word means in this 
context, is belied by the RIPE experience. Will somebody please answer the RIPE 
experience before bringing up the “speculation” argument?

It’s over 10 years now. The experiment has been performed. We have the data. 
It’s time to point to evidence instead of holding policy in thrall to 
assertions of the dangers of speculation.

 

Remember the biggest damper on speculation is the reality of the market. You 
can’t just whip up a /8 to be transferred, and if you could, you are looking at 
spending almost a billion dollars! Do you really think a billion dollar 
investment in an asset that all the smart people say will be valueless at some 
point isn’t a damper on speculation? Do you think ARIN would approve an initial 
transfer of a /8 on the mere promise it will be leased out in two years?

 

I trust the market and I trust ARIN staff enough to dampen “speculation”. As 
always, should something damaging appear, we retain the ability to change 
policy.

 

Regards,
Mike

 

 

From: ARIN-PPML mailto:arin-ppml-boun...@arin.net> 
> On Behalf Of Owen DeLong via ARIN-PPML
Sent: Thursday, March 17, 2022 8:20 PM
To: Andrew Dul mailto:andrew@quark.net> >
Cc: 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

 

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 mailto: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?

 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Scott Leibrand]

> On Mar 18, 2022, at 7:37 AM, Mike Burns  wrote:
> 
> 
> Hi Owen, Andrew, and Scott,
>  
> Transfer approval of a larger-than-minimum block size requires detailed 
> documentation of the use of at least 50% of the block in 24 months, and that 
> detailed documentation must be officer-attested.  I’m sure we all agree that 
> nobody can approach ARIN for a large initial block without providing 
> believable documentation to ARIN, and the attestation provides actionability 
> against fraud. 

I don’t doubt that believable documentation is required. But my concern, as I 
stated in the very first reply to this thread that everyone ignored, is:

> If you’re going to remove that, what is to stop me from opening a new LIR and 
> stating that I want pre-qualification for a transfer of a /8 to lease out, 
> because I have sales projections that I can lease out a /9 within 24 months, 
> a /10 within 12 months, and a /11 within 6 months? And if I fail to meet my 
> sales projections, I can sell some or all of the /8 after 12 months 
> (presumably at a profit, as prices just keep going up).  
> 
> It seems that there should be some limit on initial block size if we’re going 
> to rely exclusively on recipients’ leasing projections instead of requiring 
> use on an operational network.


I take your point about a /8 being infeasible to acquire on the market, but the 
same point applies at whatever the maximum available size currently is. 

-Scott

> Further transfers require proof of utilization of the original transfers.
>  
> This persistent fear of “speculation”, whatever that word means in this 
> context, is belied by the RIPE experience. Will somebody please answer the 
> RIPE experience before bringing up the “speculation” argument?
> It’s over 10 years now. The experiment has been performed. We have the data. 
> It’s time to point to evidence instead of holding policy in thrall to 
> assertions of the dangers of speculation.
>  
> Remember the biggest damper on speculation is the reality of the market. You 
> can’t just whip up a /8 to be transferred, and if you could, you are looking 
> at spending almost a billion dollars! Do you really think a billion dollar 
> investment in an asset that all the smart people say will be valueless at 
> some point isn’t a damper on speculation? Do you think ARIN would approve an 
> initial transfer of a /8 on the mere promise it will be leased out in two 
> years?
>  
> I trust the market and I trust ARIN staff enough to dampen “speculation”. As 
> always, should something damaging appear, we retain the ability to change 
> policy.
>  
> Regards,
> Mike
>  
>  
> From: ARIN-PPML  On Behalf Of Owen DeLong via 
> ARIN-PPML
> Sent: Thursday, March 17, 2022 8:20 PM
> To: Andrew Dul 
> Cc: 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
>  
> 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  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 
>  wrote:
>  
> 
> 
> On Mar 16, 2022, at 15:22 , Fernando Frediani  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 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Mike Burns]

Hi Owen, Andrew, and Scott,

 

Transfer approval of a larger-than-minimum block size requires detailed 
documentation of the use of at least 50% of the block in 24 months, and that 
detailed documentation must be officer-attested.  I’m sure we all agree that 
nobody can approach ARIN for a large initial block without providing believable 
documentation to ARIN, and the attestation provides actionability against 
fraud.  Further transfers require proof of utilization of the original 
transfers. 

 

This persistent fear of “speculation”, whatever that word means in this 
context, is belied by the RIPE experience. Will somebody please answer the RIPE 
experience before bringing up the “speculation” argument?

It’s over 10 years now. The experiment has been performed. We have the data. 
It’s time to point to evidence instead of holding policy in thrall to 
assertions of the dangers of speculation.

 

Remember the biggest damper on speculation is the reality of the market. You 
can’t just whip up a /8 to be transferred, and if you could, you are looking at 
spending almost a billion dollars! Do you really think a billion dollar 
investment in an asset that all the smart people say will be valueless at some 
point isn’t a damper on speculation? Do you think ARIN would approve an initial 
transfer of a /8 on the mere promise it will be leased out in two years?

 

I trust the market and I trust ARIN staff enough to dampen “speculation”. As 
always, should something damaging appear, we retain the ability to change 
policy.

 

Regards,
Mike

 

 

From: ARIN-PPML  On Behalf Of Owen DeLong via 
ARIN-PPML
Sent: Thursday, March 17, 2022 8:20 PM
To: Andrew Dul 
Cc: 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

 

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 mailto: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 mailto:arin-ppml@arin.net> > wrote:

 





On Mar 16, 2022, at 15:22 , Fernando Frediani mailto: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 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Owen DeLong via ARIN-PPML]

Actually, they’d be doing all of the same things any other LIR does with the 
exception of providing bandwidth and connectivity services.

They’d still be responsible for getting a reasonable justification from the 
customer, validating that justification, registering the addresses properly in 
whois, etc.

It might be a bit less overhead than being an ISP, but ISPs are increasingly 
short on IPv4 addresses and asking customers to get their own.

Many customers are unable to make the capital outlay necessary to purchase the 
addresses they need, but do have the cash flow to support a lease.

Many customers have a desire not to take the risk of a large capital outlay for 
a necessary component which may abruptly lose its value in the near to medium 
term.

This situation will only get worse as the cost of IPv4 addresses continues to 
rise and as IPv6 deployment continues.

Owen


> On Mar 17, 2022, at 16:28 , Holden Karau  wrote:
> 
> 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  > 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 
>> mailto:arin-ppml@arin.net>> wrote:
>> 
>> 
>>> On Mar 16, 2022, at 15:22 , Fernando Frediani >> > 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 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Owen DeLong via ARIN-PPML]

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  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 
>> mailto:arin-ppml@arin.net>> wrote:
>> 
>> 
>>> On Mar 16, 2022, at 15:22 , Fernando Frediani >> > 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 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Steven Ryerse]

One of the goals of ARIN when it was founded was to further the Internet. If 
leasing does that then it should be allowed. Seems like all these rules that 
have the effect of restricting the Internet should be removed and rules that 
further the Internet should be allowed. As I think leasing does further the 
usage of the internet it should be allowed. My 2 Cents.

Sent from my iPhone

On Mar 17, 2022, at 7:50 PM, Fernando Frediani  wrote:



Exactly, that's the main point about how absurd the idea of leasing it, in any 
form.

I fell that some people sometimes are able to only look at a particular 
scenario that he/she being involved once or few times and believe that is the 
scenario for everybody else in order to justify leasing, so basically to 
resolve their own particular problem as if that was everybody else's problem 
and tentatively force a fundamental change in this system.  Does anyone really 
believe that most arguments  people involved in the leasing business are 
intended to do any good for the whole of the community or simply to promote 
changes to the rules that benefits fewer and specifics actors ?

Allowing leasing as some defend is detrimental to the whole RIR system and 
therefore to the whole of the community. IP Leasing resolves some minor cases 
but worse situations that at long term make things more difficult, expensive 
and less accountable, therefore less fair to everybody in a well established 
system. This is why justifications such as "need to change because there are 
already people doing it" or "it is the new reality and we have to accept" are 
just beautiful word to try to justify something that is not intended to build 
Internet using these shared resources. We can never call it another name - 
shared resources.

Fernando

On 17/03/2022 20:28, Holden Karau wrote:
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 
mailto: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 
mailto:arin-ppml@arin.net>> wrote:


On Mar 16, 2022, at 15:22 , Fernando Frediani 
mailto: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.

+ 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Fernando Frediani]

Exactly, that's the main point about how absurd the idea of leasing it, 
in any form.


I fell that some people sometimes are able to only look at a particular 
scenario that he/she being involved once or few times and believe that 
is the scenario for everybody else in order to justify leasing, so 
basically to resolve their own particular problem as if that was 
everybody else's problem and tentatively force a fundamental change in 
this system.  Does anyone really believe that most arguments  people 
involved in the leasing business are intended to do any good for the 
whole of the community or simply to promote changes to the rules that 
benefits fewer and specifics actors ?


Allowing leasing as some defend is detrimental to the whole RIR system 
and therefore to the whole of the community. IP Leasing resolves some 
minor cases but worse situations that at long term make things more 
difficult, expensive and less accountable, therefore less fair to 
everybody in a well established system. This is why justifications such 
as "need to change because there are already people doing it" or "it is 
the new reality and we have to accept" are just beautiful word to try to 
justify something that is not intended to build Internet using these 
shared resources. We can never call it another name - shared resources.


Fernando

On 17/03/2022 20:28, Holden Karau wrote:
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  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
 wrote:




On Mar 16, 2022, at 15:22 , Fernando Frediani
 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 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Holden Karau]

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  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 
>> 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.
>>
>> * 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Andrew Dul]

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 
 wrote:





On Mar 16, 2022, at 15:22 , Fernando Frediani
 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 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Scott Leibrand]

+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 
> 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 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Owen DeLong via ARIN-PPML]

> On Mar 16, 2022, at 15:22 , Fernando Frediani  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 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Fernando Frediani]

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.


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.
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.


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.


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.


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.


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  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 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[David Farmer via ARIN-PPML]

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  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 *
> wrote 
> >
> > On Wed, Mar 9, 2022 at 8:24 PM ARIN  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 
> > https://bill.herrin.us/ 
> > ___
> > ARIN-PPML
> > You are receiving this message because you are subscribed to
> > the ARIN Public Policy Mailing List (ARIN-PPML@arin.net
> > ).
> > Unsubscribe or manage your mailing list subscription at:
> > https://lists.arin.net/mailman/listinfo/arin-ppml
> > 
> > Please contact i...@arin.net  if you
> experience any
> > issues.
> >
> >
> >
> >
> > ___
> > ARIN-PPML
> > You are receiving this message because you are subscribed to
> > the ARIN Public Policy Mailing List (ARIN-PPML@arin.net).
> > Unsubscribe or manage your mailing list subscription at:
> > 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Tom Fantacone]

Hi John,



These days it's pretty hard to find an LIR who will bundle a substantial number 
of addresses at no additional charge with a circuit, and that's assuming they 
have the addresses available to bundle.  With IPv4 scarcity, we more often see 
an LIR client request, say, an /18, and perhaps be able to justify it, but 
their ISP can only allocate a /22 or /21 given their own shortage of addresses. 
 Those LIRs that do have the space are charging for it, either directly or by 
bundling it into the circuit price.  Nevertheless, there are still certainly 
cases where what you are saying is true, and the client can get what they need 
from their upstream LIR.



What I was comparing is the cost of an end user purchasing a block on the 
transfer market vs. leasing one from a 3rd party lessor.  These might be the 
only 2 options for the client for the reasons I mentioned above, or because 
they want to multi-home, or because they want the flexibility of moving 
providers without having to renumber, or for whatever reason network operators 
currently purchase IPv4 space on the transfer market vs. trying to get them 
from their upstream.



Regards,



Tom Fantacone







 On Fri, 11 Mar 2022 18:04:52 -0500 John Santos  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 
> * wrote 
> 
> On Wed, Mar 9, 2022 at 8:24 PM ARIN  >
> 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
> mailto:b...@herrin.us 
> https://bill.herrin.us/ 
> ___
> ARIN-PPML
> You are receiving this message because you are subscribed to
> the ARIN Public Policy Mailing List (mailto:ARIN-PPML@arin.net
> ).
> Unsubscribe or manage your mailing list subscription at:
> https://lists.arin.net/mailman/listinfo/arin-ppml
> 
> Please contact mailto:i...@arin.net  if you 
> experience any
> issues.
> 
> 
> 
> 
> ___
> ARIN-PPML
> You are receiving this message because you are subscribed to
> the ARIN Public Policy Mailing List (mailto:ARIN-PPML@arin.net).
> Unsubscribe or manage your mailing list subscription at:
> https://lists.arin.net/mailman/listinfo/arin-ppml
> Please contact mailto:i...@arin.net 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 (mailto:ARIN-PPML@arin.net).
Unsubscribe or manage your mailing list subscription at:
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ARIN-PPML
You are receiving this message because you are subscribed to
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[John Santos]

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 * wrote 


On Wed, Mar 9, 2022 at 8:24 PM ARIN 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 
https://bill.herrin.us/ 
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[William Herrin]

On Fri, Mar 11, 2022 at 10:38 AM Mike Burns  wrote:
> I understand there are ways to effectively circumvent ARIN policy through 
> legal relationships.

Hi Mike,

You misunderstand me. The legal relationship I described does not
circumvent ARIN policy. Rather the opposite - it brings your desired
use into compliance, both in letter and spirit. In the partnership
example, the actual user of the addresses must demonstrate their
qualification to ARIN before they can receive them. No different than
if they'd purchased them. As the address purchasing part of the
partnership, you don't contribute to qualification for the addresses
at all. And indeed, were you to reclaim and reassign the addresses
without forming a new partnership and going through ARIN again, the
addresses would no longer count as utilized under ARIN policy.


> But it's just simpler to create a thin VPN or to operate out of the RIPE RIR.

There's always something simpler that skirts the rules. At least until
you get caught.

RIPE's policy is RIPE's lookout. If you have what you want with RIPE,
why are you pestering ARIN?

While you can get away with a thin VPN here and there I think you'd be
risking ARIN finding your behavior pretextual, in bad-faith and
therefore fraudulent if you based a business on it.

For those who don't follow the reference - a thin VPN means that the
lessor provides the lessee with a VPN tunnel over which they're
permitted to advertise BGP. If the lessor advertises BGP via the
tunnel, that advertisement is propagated to the Internet and the
lessee is billed for the data usage in addition to the address lease.
The customer then goes and gets their *real* IP connectivity elsewhere
and ignores the VPN. It's not just thin, it's anorexic.

Regards,
Bill Herrin


-- 
William Herrin
b...@herrin.us
https://bill.herrin.us/
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Steven Ryerse]

+1 I support this as well


Steven Ryerse
President

srye...@eclipse-networks.com | C: 
770.656.1460
100 Ashford Center North | Suite 110 | Atlanta, Georgia 30338

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From: ARIN-PPML  On Behalf Of Tom Fantacone
Sent: Friday, March 11, 2022 12:14 PM
To: William Herrin ; PPML 
Subject: Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: 
Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future 
Allocations

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 
mailto:b...@herrin.us>> wrote 

On Wed, Mar 9, 2022 at 8:24 PM ARIN 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


--
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b...@herrin.us
https://bill.herrin.us/
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Fernando Frediani]

Scott, the point is that we should not be spending much time and should 
dismiss such proposal because although it may not look like it is 
willing to change a fundamental thing about IP address usage based on 
justification, something that doesn't require to much debate such 
obvious it is. Fundamentally we are not dealing with an irrevocable 
asset that someone purchased and may dispose or sell it at he/she 
wishes, but about a right to use which may be revoked if used against 
the rules.
Therefore it should not need too much debate to find out that anyone 
using this scarce resources, that doesn't belong to anyone individually 
MUST always justify for that need.


There is already a neutral and well established entity tasked to 
evaluate those justifications, the RIR, and we all assume they do this 
in the most impartial way. And better they do this directlly with those 
who are really using the resources, not via a 3rd party who have 
financial interest in it.


For those that for a moment believe a lessor may be able to justify to 
the RIR that "their clients are really using it" (just look how absurd 
this is!), it is a lot simple and removes any points of doubt to just 
have any unjustified space to be returned to the RIR and they, according 
to the current agreed rules will re-distribute those addresses to those 
who are really building operational networks in a most neutral and fair 
way, not to those who are able to pay more for it.


If for some reason a resource holder realizes doesn't need any addresses 
anymore there are always the Transfer policies in place. As long the 
receiver can justify the need and building networks ARIN will proceed 
with the transfer.
We do not need 3rd parties making it even more complex something that 
can remain simple in the hands of the RIR - and avoids pretending 
leasing is a normal and legitimate thing. At the end that only 
beneficiaries are the companies who intermediate these type of business 
and have financial interest in it, not the organizations who need IP 
addresses.


I don't care that leasing "makes it cheaper" in short time for those 
without IP addresses to get some, but only that those who really justify 
for those resources do that directly with the RIR which is the fairer 
thing to all involved - all the community - which is the most important. 
We if let these 3rd parties turn something unnecessary in something 
normal we all know where it is going to end basically because their 
interest is not a better and fair distribution of IP addresses to those 
who really need or who are building networks, but simple to those who 
are willing to pay more.


Regards
Fernando

Em 11/03/2022 15:43, Scott Leibrand escreveu:
It seems that lots of people oppose this policy based on 
their assumptions about what it will do to the economics of the IP 
address transfer market, but no one is making those assumptions 
explicit or describing what exactly they think would happen if it were 
passed.


Right now https://auctions.ipv4.global/prior-sales is showing recent 
prices of about $55 per IP (to buy them on the transfer market), up 
from about $30/IP a year ago.


Right now https://www.heficed.com/lease-ipv4/ is quoting $0.50/mo per 
IP ($546 for 1024 addresses). The data at 
https://www.ipxo.com/blog/leasing-vs-buying-ip-addresses/ is a bit 
older, but indicates that in late 2020, prices were in a similar range 
of $0.34 - $0.67 per IP.


If someone buys addresses at $55 each and leases them out at $0.50/mo, 
it would take 110 months (9 years) to cover the cost. That would be a 
lousy business, so clearly, entities leasing space are expecting IPv4 
purchase prices to continue rising more quickly than their cost of 
financing, and expect to be able to sell any addresses they buy at a 
profit.


Leasing is clearly already happening. Right now it has to be done 
using RIPE space or by an entity that has (at least nominal) network 
connectivity.


If you oppose or support this policy on grounds that it will affect 
the supply and demand of addresses, can you be more specific as to 
what effects you expect relaxing the justification requirements for 
those offering IP leasing who want to buy more space to lease 
out would have? How would this policy affect the demand and price of 
IPv4 addresses bought and sold on the transfer market? How would that 
affect the supply, demand, and price of IPv4 addresses available for 
lease? How would that affect network operators? Would more of them 
switch from purchasing addresses to leasing them? With leasing 
(currently) being cheaper than purchasing (because a purchase is also 
an investment in a currently-appreciating asset), would it help or 
hurt network operators for leasing to be considered a more legitimate 
option?


-Scott

On Fri, Mar 11, 2022 at 10:02 AM Fernando Frediani 
 wrote:


On 11/03/2022 14:56, Tom Fantacone wrote:

Bill,

We can quibble about semantics, but let's go with your verbiage:

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Mike Burns]

Hi Scott,

 

Thank you, I wrote a response to your initial post that centered on the market 
and the current leasing returns, which I would put at roughly a 12% rental 
return on  investment, or 100 months of payments equals one address purchase.

 

I would like to point out that prices in the transfer market plateaued last 
November and have traded in increasingly narrow ranges subsequent to that. This 
is the longest duration price plateau that I can remember.

 

Stable prices and 12% returns on investments that don’t wear out, have no 
moving parts, and which generally appreciate in value. Not tremendous, not bad. 
A good place to inaugurate an ARIN-based leasing business, in my opinion.

 

And frankly one of the reasons leasing is attractive is because there is no 
other financing vehicle for IPv4 purchases, and that is an indictment of stodgy 
bankers. Still you can’t blame them, as they have absolutely no knowledge of 
this market, even though it’s really a $200 billion commodity market. Once they 
hear that the IPv6 transition is both inevitable and will result in a zero 
value at some unpredictable future time, they’re out.

 

That leaves sophisticated and risk-tolerant investors, and for them 12% is a 
hard sell. Nonetheless some of these have begun sniffing around the market and 
some are actively buying, but only in RIPE.

 

This policy seeks to recognize that a need for leasing exists, and seeks to 
remove the restriction that participants must already be incumbent owners, 
while retaining the essential element of needs testing which is deployment on 
an operating network.

 

Regards,
Mike

 

 

From: ARIN-PPML  On Behalf Of Scott Leibrand
Sent: Friday, March 11, 2022 1:43 PM
To: ARIN-PPML List 
Subject: Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: 
Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future 
Allocations

 

It seems that lots of people oppose this policy based on their assumptions 
about what it will do to the economics of the IP address transfer market, but 
no one is making those assumptions explicit or describing what exactly they 
think would happen if it were passed.

 

Right now https://auctions.ipv4.global/prior-sales is showing recent prices of 
about $55 per IP (to buy them on the transfer market), up from about $30/IP a 
year ago.

 

Right now https://www.heficed.com/lease-ipv4/ is quoting $0.50/mo per IP ($546 
for 1024 addresses). The data at 
https://www.ipxo.com/blog/leasing-vs-buying-ip-addresses/ is a bit older, but 
indicates that in late 2020, prices were in a similar range of $0.34 - $0.67 
per IP.

 

If someone buys addresses at $55 each and leases them out at $0.50/mo, it would 
take 110 months (9 years) to cover the cost. That would be a lousy business, so 
clearly, entities leasing space are expecting IPv4 purchase prices to continue 
rising more quickly than their cost of financing, and expect to be able to sell 
any addresses they buy at a profit.

 

Leasing is clearly already happening. Right now it has to be done using RIPE 
space or by an entity that has (at least nominal) network connectivity.

 

If you oppose or support this policy on grounds that it will affect the supply 
and demand of addresses, can you be more specific as to what effects you expect 
relaxing the justification requirements for those offering IP leasing who want 
to buy more space to lease out would have? How would this policy affect the 
demand and price of IPv4 addresses bought and sold on the transfer market? How 
would that affect the supply, demand, and price of IPv4 addresses available for 
lease? How would that affect network operators? Would more of them switch from 
purchasing addresses to leasing them? With leasing (currently) being cheaper 
than purchasing (because a purchase is also an investment in a 
currently-appreciating asset), would it help or hurt network operators for 
leasing to be considered a more legitimate option?

 

-Scott

 

On Fri, Mar 11, 2022 at 10:02 AM Fernando Frediani mailto:fhfredi...@gmail.com> > wrote:

On 11/03/2022 14:56, Tom Fantacone wrote:

Bill,

 

We can quibble about semantics, but let's go with your verbiage:

 

If I run a network and qualify for an /18 right now, can I go to ARIN and lease 
one?   I must either pay someone to release their addresses to ARIN to lease to 
me or lease one from a (non-ARIN) 3rd party.

And that should always be the expected, release them to ARIN which should be 
the only actor taking care of it.
I really fail to understand how can one consider legit that a 3rd party could 
be doing this job otherwise.

If everybody sticks that what is expected, things work better, is much better 
to trust ARIN to do this plus in the end doing in such way doesn't least space 
for speculation, price rises and community have the assurance that the one who 
is intermediating it is someone really neutral and with no other interests to 
the business other than make 

Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Mike Burns]

Hi Brian,

 

But the addresses will be used to build and operate networks, or they could not 
be used as justification.

Where are the cost and fairness issues?

Even if a lessee could justify a purchase, that doesn’t mean they can afford a 
purchase.

Which is fairer, to deny them addresses or effectively finance them through 
leasing?

 

Regards,
Mike

 

 

From: Brian Jones  
Sent: Friday, March 11, 2022 1:35 PM
To: Mike Burns 
Cc: ARIN-PPML 
Subject: Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: 
Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future 
Allocations

 

 





On Mar 11, 2022, at 1:25 PM, Mike Burns mailto:m...@iptrading.com> > wrote:

 

Are you saying that because investors could buy more addresses (through 
demonstrating to ARIN utilization on operating networks) that would raise IPv4 
purchase prices? Because they would add demand to the transfer market?

 

 

I’m saying that IMO getting addresses from ARIN for the sole purpose of leasing 
them to an entity that would qualify on their own for Addresses from ARIN, Does 
not  meet requirements of building and operating networks.

 

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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Scott Leibrand]

It seems that lots of people oppose this policy based on their assumptions
about what it will do to the economics of the IP address transfer market,
but no one is making those assumptions explicit or describing what exactly
they think would happen if it were passed.

Right now https://auctions.ipv4.global/prior-sales is showing recent prices
of about $55 per IP (to buy them on the transfer market), up from about
$30/IP a year ago.

Right now https://www.heficed.com/lease-ipv4/ is quoting $0.50/mo per IP
($546 for 1024 addresses). The data at
https://www.ipxo.com/blog/leasing-vs-buying-ip-addresses/ is a bit older,
but indicates that in late 2020, prices were in a similar range of $0.34 -
$0.67 per IP.

If someone buys addresses at $55 each and leases them out at $0.50/mo, it
would take 110 months (9 years) to cover the cost. That would be a lousy
business, so clearly, entities leasing space are expecting IPv4 purchase
prices to continue rising more quickly than their cost of financing, and
expect to be able to sell any addresses they buy at a profit.

Leasing is clearly already happening. Right now it has to be done using
RIPE space or by an entity that has (at least nominal) network connectivity.

If you oppose or support this policy on grounds that it will affect the
supply and demand of addresses, can you be more specific as to what effects
you expect relaxing the justification requirements for those offering IP
leasing who want to buy more space to lease out would have? How would this
policy affect the demand and price of IPv4 addresses bought and sold on the
transfer market? How would that affect the supply, demand, and price of
IPv4 addresses available for lease? How would that affect network
operators? Would more of them switch from purchasing addresses to leasing
them? With leasing (currently) being cheaper than purchasing (because a
purchase is also an investment in a currently-appreciating asset), would it
help or hurt network operators for leasing to be considered a more
legitimate option?

-Scott

On Fri, Mar 11, 2022 at 10:02 AM Fernando Frediani 
wrote:

> On 11/03/2022 14:56, Tom Fantacone wrote:
>
> Bill,
>
> We can quibble about semantics, but let's go with your verbiage:
>
> If I run a network and qualify for an /18 right now, can I go to ARIN and
> lease one?   I must either *pay someone to release their addresses to
> ARIN to lease to me* or lease one from a (non-ARIN) 3rd party.
>
> And that should always be the expected, release them to ARIN which should
> be the only actor taking care of it.
> I really fail to understand how can one consider legit that a 3rd party
> could be doing this job otherwise.
>
> If everybody sticks that what is expected, things work better, is much
> better to trust ARIN to do this plus in the end doing in such way doesn't
> least space for speculation, price rises and community have the assurance
> that the one who is intermediating it is someone really neutral and with no
> other interests to the business other than make sure the policies are being
> followed.
>
> Fernando
>
>
> And the amount I must pay (commonly referred to as the Purchase Price in
> most IPv4 transfer contracts, whether I'm technically "buying" it or not),
> is significantly more than either typical lease rates or ARIN's annual
> fees.  My point is that 3rd party lessors do provide a service that ARIN
> does not.
>
> Regards,
>
> Tom Fantacone
>
>
>
>  On Fri, 11 Mar 2022 12:42:52 -0500 *William Herrin 
> * wrote 
>
> On Fri, Mar 11, 2022 at 9:40 AM Tom Fantacone  wrote:
> > If I run a network and qualify for an /18 right now, can I got to ARIN
> and lease one? I must either buy one on the transfer market
>
> Tom,
>
> I think you misunderstand the transfer market. You don't buy addresses
> on the transfer market. You lease addresses from ARIN and then pay
> someone on the transfer market to release their addresses to ARIN for
> lease to you.
>
> Regards,
> Bill Herrin
>
>
> --
> William Herrin
> b...@herrin.us
> https://bill.herrin.us/
>
>
>
>
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Mike Burns]

Hi Bill,

I understand there are ways to effectively circumvent ARIN policy through legal 
relationships.
But it's just simpler to create a thin VPN or to operate out of the RIPE RIR.
My point is that ARIN policy doesn't prevent leasing, it only restricts lessors 
to incumbent holders and thwarts newcomers. And current policy doesn't seem to 
have broken anything.

You can't go to ARIN and simply predict you will have X customers within two 
years and receive transfer pre-approval. The same rules would apply here, the 
same initial block size and protections, everything in justification remaining 
the same as it is for those who used to be called ISPs. Except historically 
ISPs could use their SWIPed addresses to show utilization only if they were 
connected to their clients by a circuit. They still have to be real clients, 
they still have to deployed on an operating network, they will still be 
required to submit evidence of that to ARIN.

Regards,
Mike


-Original Message-
From: William Herrin  
Sent: Friday, March 11, 2022 12:28 PM
To: Mike Burns 
Cc: PPML 
Subject: Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: 
Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future 
Allocations

On Fri, Mar 11, 2022 at 6:25 AM Mike Burns  wrote:
> Are you against all renting of IPv4 addresses, and if so, why?
> Or are you against only non-incumbent owners renting space?

Hi Mike,

I would suggest that if you really want to lease addresses without 
infrastructure there are lawful and compliant ways to do so without change to 
ARIN policy. For example:

The broker and user of the addresses might form a legal partnership.
The address user would have the right to terminate its participation in the 
partnership comparable to a lessor's terms for ending a lease.
The broker would have the right, upon termination of the partnership, to resell 
the numbers compliant with ARIN rules and would retain the proceeds of such 
sale.
Finally the partnership, including both the practicing user and the purchasing 
broker, would request addresses through ARIN and, upon approval, purchase them 
on the open market. Because the partnership is, in fact, deploying a network 
which uses the addresses, such a use is compliant with ARIN policy.

While more complicated than a simple lease agreement, such a process would 
assure compliance with the community's then-extant number policies. In 
particular, the actual user of the addresses would be evaluated by ARIN and 
would have to qualify.

Even were I to find such "leasing" objectionable, I would have no cause for 
objection under current ARIN policy.

I note that once the initial template development is complete, instancing such 
legal partnerships is of trivial cost.

Regards,
Bill Herrin


--
William Herrin
b...@herrin.us
https://bill.herrin.us/

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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Brian Jones]

> On Mar 11, 2022, at 1:25 PM, Mike Burns  wrote:
> 
> Are you saying that because investors could buy more addresses (through 
> demonstrating to ARIN utilization on operating networks) that would raise 
> IPv4 purchase prices? Because they would add demand to the transfer market?
> 

I’m saying that IMO getting addresses from ARIN for the sole purpose of leasing 
them to an entity that would qualify on their own for Addresses from ARIN, Does 
not  meet requirements of building and operating networks.



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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Mike Burns]

Hi Brian,

 

I am not understanding. 

Can  you be more clear on whose costs are increased by this policy exactly?

 

Are you saying that because investors could buy more addresses (through 
demonstrating to ARIN utilization on operating networks) that would raise IPv4 
purchase prices? Because they would add demand to the transfer market?

 

I don’t want to put words in your mouth, but that is something worthy of 
discussion I guess.

 

Regards,

Mike

 

 

 

 

From: Brian Jones  
Sent: Friday, March 11, 2022 11:58 AM
To: Mike Burns ; ARIN-PPML 
Subject: Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: 
Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future 
Allocations

 

Mike,

IMHO Allowing for rent-seeking behavior increases the cost to those who are 
actually building and operating networks, therefore further limiting the 
availability of Internet number resources available for those with less funds 
to purchase them.

 

—

Brian

 





On Mar 11, 2022, at 10:09 AM, Mike Burns mailto:m...@iptrading.com> > wrote:

 

 

This policy removes the circuit requirement but retains the requirement that 
blocks be used on operating networks.

This policy only affects transferred (read “purchased”) addresses and I don’t 
see  how it affects fair and impartial distribution, can you elucidate the 
manner in which fair and impartial distributions are affected by removing the 
circuit requirement?

 

I don’t think the proposal would have been approved for discussion if it 
opposed fair and impartial distribution.

 

The original proposal had wording to include the stipulation that Internet 
numbers were to be used by those building and operating networks.





 

 

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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Fernando Frediani]

On 11/03/2022 14:56, Tom Fantacone wrote:

Bill,

We can quibble about semantics, but let's go with your verbiage:

If I run a network and qualify for an /18 right now, can I go to ARIN 
and lease one?   I must either /pay someone to release their addresses 
to ARIN to lease to me/ or lease one from a (non-ARIN) 3rd party.
And that should always be the expected, release them to ARIN which 
should be the only actor taking care of it.
I really fail to understand how can one consider legit that a 3rd party 
could be doing this job otherwise.


If everybody sticks that what is expected, things work better, is much 
better to trust ARIN to do this plus in the end doing in such way 
doesn't least space for speculation, price rises and community have the 
assurance that the one who is intermediating it is someone really 
neutral and with no other interests to the business other than make sure 
the policies are being followed.


Fernando



And the amount I must pay (commonly referred to as the Purchase Price 
in most IPv4 transfer contracts, whether I'm technically "buying" it 
or not), is significantly more than either typical lease rates or 
ARIN's annual fees.  My point is that 3rd party lessors do provide a 
service that ARIN does not.


Regards,

Tom Fantacone



 On Fri, 11 Mar 2022 12:42:52 -0500 *William Herrin 
* wrote 


On Fri, Mar 11, 2022 at 9:40 AM Tom Fantacone 
wrote:
> If I run a network and qualify for an /18 right now, can I got
to ARIN and lease one? I must either buy one on the transfer market

Tom,

I think you misunderstand the transfer market. You don't buy
addresses
on the transfer market. You lease addresses from ARIN and then pay
someone on the transfer market to release their addresses to ARIN for
lease to you.

Regards,
Bill Herrin


-- 
William Herrin

b...@herrin.us
https://bill.herrin.us/




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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Tom Fantacone]

Bill,



We can quibble about semantics, but let's go with your verbiage:



If I run a network and qualify 
for an /18 right now, can I go to ARIN and lease one?   I must either pay 
someone to release their addresses to ARIN to lease to me or lease one from a 
(non-ARIN) 3rd party.



And the amount I must pay (commonly referred to as the Purchase Price in most 
IPv4 transfer contracts, whether I'm technically "buying" it or not), is 
significantly more than either typical lease rates or ARIN's annual fees.  My 
point is that 3rd party lessors do provide a service that ARIN does not.



Regards,



Tom Fantacone







 On Fri, 11 Mar 2022 12:42:52 -0500 William Herrin  wrote 




On Fri, Mar 11, 2022 at 9:40 AM Tom Fantacone  
wrote: 
> If I run a network and qualify for an /18 right now, can I got to ARIN and 
> lease one?   I must either buy one on the transfer market 
 
Tom, 
 
I think you misunderstand the transfer market. You don't buy addresses 
on the transfer market. You lease addresses from ARIN and then pay 
someone on the transfer market to release their addresses to ARIN for 
lease to you. 
 
Regards, 
Bill Herrin 
 
 
-- 
William Herrin 
mailto:b...@herrin.us 
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Fernando Frediani]

Wrong.
You don't lease addresses from ARIN.

You receive them for used based on the justified needs and you pay an 
administrative fee to support the services to keep all the 
infrastructure necessary for the ecosystem that keeps track of those 
resources remain operational. This has nothing to do with leasing them 
from ARIN.


Fernando

On 11/03/2022 14:42, William Herrin wrote:

On Fri, Mar 11, 2022 at 9:40 AM Tom Fantacone  wrote:

If I run a network and qualify for an /18 right now, can I got to ARIN and 
lease one?   I must either buy one on the transfer market

Tom,

I think you misunderstand the transfer market. You don't buy addresses
on the transfer market. You lease addresses from ARIN and then pay
someone on the transfer market to release their addresses to ARIN for
lease to you.

Regards,
Bill Herrin



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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Fernando Frediani]

The justification that one cannot pay for something (make a proper 
Transfer as expected under the current policy) doesn't seem to be a 
valid justification to remove a essential requirement for justifying 
need to usage of those resources that don't belong to them.
The principle of usage justification to become a resource holder doesn't 
take in account if something is expensive or cheap to someone.


Fernando

On 11/03/2022 14:13, 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 
* wrote 


On Wed, Mar 9, 2022 at 8:24 PM ARIN  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
https://bill.herrin.us/
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[William Herrin]

On Fri, Mar 11, 2022 at 9:40 AM Tom Fantacone  wrote:
> If I run a network and qualify for an /18 right now, can I got to ARIN and 
> lease one?   I must either buy one on the transfer market

Tom,

I think you misunderstand the transfer market. You don't buy addresses
on the transfer market. You lease addresses from ARIN and then pay
someone on the transfer market to release their addresses to ARIN for
lease to you.

Regards,
Bill Herrin


-- 
William Herrin
b...@herrin.us
https://bill.herrin.us/
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Tom Fantacone]

Bill,



If I run a network and qualify for an /18 right now, can I got to ARIN and 
lease one?   I must either buy one on the transfer market or lease one from a 
(non-ARIN) 3rd party.



Your analogy makes some sense regarding previously allocated IPv4 space, but we 
are in exhaust.  This policy would not have made sense when there was a free 
pool, but it excludes waiting list addresses and so covers that base.


Regards,


Tom Fantacone







 On Fri, 11 Mar 2022 12:31:47 -0500 William Herrin  wrote 




On Fri, Mar 11, 2022 at 9:14 AM Tom Fantacone  
wrote: 
> Bill, regarding your point "B", by providing IPv4 leasing, these 3rd parties 
> are certainly performing a function that ARIN does not. 
 
Oh really? ARIN doesn't charge an annual fee to retain the IP address 
assignment they've made? And they don't reclaim the addresses for use 
by someone else should you fail to pay? Your "leasing" differs from 
ARIN's only in that you charge much more money and perform 
questionable diligence with respect to enforcing number policy. 
 
Regards, 
Bill Herrin 
 
 
-- 
William Herrin 
mailto:b...@herrin.us 
https://bill.herrin.us/___
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[William Herrin]

On Fri, Mar 11, 2022 at 9:14 AM Tom Fantacone  wrote:
> Bill, regarding your point "B", by providing IPv4 leasing, these 3rd parties 
> are certainly performing a function that ARIN does not.

Oh really? ARIN doesn't charge an annual fee to retain the IP address
assignment they've made? And they don't reclaim the addresses for use
by someone else should you fail to pay? Your "leasing" differs from
ARIN's only in that you charge much more money and perform
questionable diligence with respect to enforcing number policy.

Regards,
Bill Herrin


-- 
William Herrin
b...@herrin.us
https://bill.herrin.us/
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[William Herrin]

On Fri, Mar 11, 2022 at 6:25 AM Mike Burns  wrote:
> Are you against all renting of IPv4 addresses, and if so, why?
> Or are you against only non-incumbent owners renting space?

Hi Mike,

I would suggest that if you really want to lease addresses without
infrastructure there are lawful and compliant ways to do so without
change to ARIN policy. For example:

The broker and user of the addresses might form a legal partnership.
The address user would have the right to terminate its participation
in the partnership comparable to a lessor's terms for ending a lease.
The broker would have the right, upon termination of the partnership,
to resell the numbers compliant with ARIN rules and would retain the
proceeds of such sale.
Finally the partnership, including both the practicing user and the
purchasing broker, would request addresses through ARIN and, upon
approval, purchase them on the open market. Because the partnership
is, in fact, deploying a network which uses the addresses, such a use
is compliant with ARIN policy.

While more complicated than a simple lease agreement, such a process
would assure compliance with the community's then-extant number
policies. In particular, the actual user of the addresses would be
evaluated by ARIN and would have to qualify.

Even were I to find such "leasing" objectionable, I would have no
cause for objection under current ARIN policy.

I note that once the initial template development is complete,
instancing such legal partnerships is of trivial cost.

Regards,
Bill Herrin


-- 
William Herrin
b...@herrin.us
https://bill.herrin.us/
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Tom Fantacone]

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  wrote 




On Wed, Mar 9, 2022 at 8:24 PM ARIN  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 
mailto:b...@herrin.us 
https://bill.herrin.us/ 
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Brian Jones]

Mike,
IMHO Allowing for rent-seeking behavior increases the cost to those who are 
actually building and operating networks, therefore further limiting the 
availability of Internet number resources available for those with less funds 
to purchase them.

—
Brian


> On Mar 11, 2022, at 10:09 AM, Mike Burns  wrote:
> 
> 
> This policy removes the circuit requirement but retains the requirement that 
> blocks be used on operating networks.
> This policy only affects transferred (read “purchased”) addresses and I don’t 
> see  how it affects fair and impartial distribution, can you elucidate the 
> manner in which fair and impartial distributions are affected by removing the 
> circuit requirement?
> 
> I don’t think the proposal would have been approved for discussion if it 
> opposed fair and impartial distribution.

The original proposal had wording to include the stipulation that Internet 
numbers were to be used by those building and operating networks.

> 



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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Fernando Frediani]

I am opposed to this proposal.
In fact it sound like a debauchery to try to permit leased addresses to 
be a valid reasons for justifying any type of allocation.


It is not in ARIN interest to facilitate something that not only is 
essentially against the fundamental of IP usage and justification but 
only would favor a tiny niche of business from what a tiny fraction of 
ARIN community benefits - the brokers.
I totally agree that in practice what is proposed removes functions from 
ARIN without any credible compliance mechanism to assure resources are 
being used as they have always intended to be.


Another thing from this proposal is that it started with subject "Remove 
Circuit Requirement" which is a too simplistic description of what it 
intends to do which was later adjusted to show all community what really is.


If there is no circuit in place there is no Internet access being 
provided and as such there is not justification to keep addresses if 
they are not used for providing Internet access. Addresses are not and 
can never be justified to be used to simply be leased to a third parties 
that are perfectly able to be RIR members and justify the need directly 
without any intermediaries.


Regards
Fernando

Em 10/03/2022 19:46, William Herrin escreveu:

On Wed, Mar 9, 2022 at 8:24 PM ARIN  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

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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Mike Burns]

Hi Joe,

Setting up a thin VPN in not heavy lifting.
This policy continues to only allow usage on operational networks to
function as justification for purchase.

Regards,
Mike


-Original Message-
From: Joe Provo  
Sent: Thursday, March 10, 2022 7:12 PM
To: Mike Burns 
Cc: William Herrin ; PPML 
Subject: Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6:
Permit IPv4 Leased Addresses for Purposes of Determining Utilization for
Future Allocations




On Thu, Mar 10, 2022 at 06:23:27PM -0500, Mike Burns wrote:
[snip]
> For point B, this policy provides the same opportunities that ARIN has 
> always provided its ISP customers, to temporarily sub-assign networks 
> to its clients.
> The only difference is these clients would not be part of the 
> registrant's own operational network. And if all the lessors do is
[snip]

"The only difference" is doing a LOT of heavy lifting here. 
Number resources are precisely for operating networks. These integers have
no reason to otherwise be tallied.

Registration rights are not investment vehicles.




--
Posted from my personal account - see X-Disclaimer header.
Joe Provo / Gweep / Earthling 

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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Mike Burns]

Hi Bill,

I am aware of the phrase and its freighted use.
But you are using it here as an argument against a policy that would facilitate 
the renting of IPv4 addresses by entities other than incumbent address owners 
or RIPE members. 
So I ask for more clarity regarding the application of the phrase to this  
policy proposal.
Are you against all renting of IPv4 addresses, and if so, why?
Or are you against only non-incumbent owners renting space?

Regards,
Mike




-Original Message-
From: William Herrin  
Sent: Thursday, March 10, 2022 6:44 PM
To: Mike Burns 
Cc: PPML 
Subject: Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: 
Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future 
Allocations

On Thu, Mar 10, 2022 at 3:42 PM William Herrin  wrote:
>
> On Thu, Mar 10, 2022 at 3:23 PM Mike Burns  wrote:
> > Is rent always and everywhere a bad thing?

> Just a clarification: "rent-seeking behavior" is a socio-economic term 
> that is at best loosely related to leasing things. For anyone not 
> familiar with the term, I ask you to google it. The resources you find 
> will explain it much better than I can.

And yes, "rent-seeking behavior" is always and everywhere a bad thing.

Regards,
Bill Herrin


--
William Herrin
b...@herrin.us
https://bill.herrin.us/

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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Brian Jones]

Speaking for myself, I oppose this policy if this is removed: “...entities 
building and operating networks…”.

If you are not building and operating networks, what are the resources needed 
for? This policy seems to oppose the fair and impartial dissemination of 
Internet number resources for their intended purposes.

-
Brian



> On Mar 9, 2022, at 11:23 PM, ARIN  wrote:
> 
> Section 1.4 Stewardship
> 
> Replace
> 
> “The fundamental purpose of Internet number stewardship is to distribute 
> unique number resources to entities building and operating networks thereby 
> facilitating the growth and sustainability of the Internet for the benefit of 
> all.”
> 
> with
> 
> “The fundamental purpose of Internet number stewardship is to distribute 
> unique number resources to facilitate the growth and sustainability of the 
> Internet for the benefit of all.”
> 



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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Joe Provo]

On Thu, Mar 10, 2022 at 06:23:27PM -0500, Mike Burns wrote:
[snip]
> For point B, this policy provides the same opportunities that
> ARIN has always provided its ISP customers, to temporarily sub-assign
> networks to its clients.
> The only difference is these clients would not be part of the
> registrant's own operational network. And if all the lessors do is
[snip]

"The only difference" is doing a LOT of heavy lifting here. 
Number resources are precisely for operating networks. These
integers have no reason to otherwise be tallied.

Registration rights are not investment vehicles.




-- 
Posted from my personal account - see X-Disclaimer header.
Joe Provo / Gweep / Earthling 
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[William Herrin]

On Thu, Mar 10, 2022 at 3:42 PM William Herrin  wrote:
>
> On Thu, Mar 10, 2022 at 3:23 PM Mike Burns  wrote:
> > Is rent always and everywhere a bad thing?

> Just a clarification: "rent-seeking behavior" is a socio-economic term
> that is at best loosely related to leasing things. For anyone not
> familiar with the term, I ask you to google it. The resources you find
> will explain it much better than I can.

And yes, "rent-seeking behavior" is always and everywhere a bad thing.

Regards,
Bill Herrin


-- 
William Herrin
b...@herrin.us
https://bill.herrin.us/
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[William Herrin]

On Thu, Mar 10, 2022 at 3:23 PM Mike Burns  wrote:
> Is rent always and everywhere a bad thing?

Hi Mike,

Just a clarification: "rent-seeking behavior" is a socio-economic term
that is at best loosely related to leasing things. For anyone not
familiar with the term, I ask you to google it. The resources you find
will explain it much better than I can.

Regards,
Bill Herrin


-- 
William Herrin
b...@herrin.us
https://bill.herrin.us/
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Mike Burns]

Hi Bill,



Thanks for your reasoning. 



For point A I would say the cart has left the barn and these once public 
resources are now effectively private resources, with different rules logically 
applying.

Is rent always and everywhere a bad thing? We can't ignore the fact that these 
resources are valuable and that drives behaviors like leasing and efficient use.



For point B, this policy provides the same opportunities that ARIN has always 
provided its ISP customers, to temporarily sub-assign networks to its clients.

The only difference is these clients would not be part of the registrant's own 
operational network. And if all the lessors do is precisely and only what ARIN 
does, I fail to see the market opportunity for those who would wish to purchase 
addresses in order to lease them out.



Remember this is pretty much policy today, except for the circuit requirement, 
which:



A) Can be easily worked-around through a traffic-free virtual connection



B) Is more restrictive than RIPE policy has been for many years. Can you point 
to the problems that have ensued that should worry us?



Regards,



Mike













 On Thu, 10 Mar 2022 17:46:36 -0500 William Herrin  wrote 




On Wed, Mar 9, 2022 at 8:24 PM ARIN  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 
mailto:b...@herrin.us 
https://bill.herrin.us/ 
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[William Herrin]

On Wed, Mar 9, 2022 at 8:24 PM ARIN  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
https://bill.herrin.us/
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[John Santos]

It sounds to me like another attempt to get around recipients needing an 
operational requirement to obtain resources.  In other words, yet another 
attempt to privatize public resources and charge people for access without 
providing any sort of services to justify those charges.


If the proposers of this policy change have such a service in mind that they 
feel or have been told by ARIN is not a permitted justification under current 
policy, they should explicitly spell it out in the reasons for the policy 
proposal so it can be debated and the community can decide if it is a worthwhile 
service and what changes to the rules would be needed to permit it without 
allowing anyone to claim the entire Internet as their private property.


On 3/10/2022 9:11 AM, John Curran wrote:

John -

Can you provide a brief explanation of why you believe this potential 
change to policy is not desirable?

(I have no particular view either way, but having some explanation of 
support / opposition viewpoints aids others in their consideration of the 
merits/concerns with potential policy changes…)

Thanks!
/John

John Curran
President and CEO
American Registry for Internet Numbers



On 10 Mar 2022, at 12:57 AM, John Santos  wrote:

Oppose.


On 3/9/2022 11:23 PM, ARIN wrote:

The following Draft Policy has been revised and retitled:
* ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining 
Utilization for Future Allocations
Revised text is below and can be found at:
https://www.arin.net/participate/policy/drafts/2021_6/ 

You are encouraged to discuss all Draft Policies on PPML. The AC will evaluate 
the discussion 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
Senior Policy Analyst
American Registry for Internet Numbers (ARIN)
Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of 
Determining Utilization for Future Allocations
Problem Statement: Current ARIN policy prevents the use of leased-out addresses 
as evidence of utilization.
Policy statement:
Section 1.2 Conservation
Replace
“Due to the requirement for uniqueness, Internet number resources of each type 
are drawn from a common number space. Conservation of these common number 
spaces requires that Internet number resources be efficiently distributed to 
those organizations who have a technical need for them in support of 
operational networks.”
with
“Due to the requirement for uniqueness, Internet number resources of each type are 
drawn from a common number space. Conservation of these common number spaces 
requires that free-pool (ASN & IPv6) and IPv4 wait-list Internet number 
resources be efficiently distributed to those organizations who have a technical 
need for them in support of operational networks.”
Section 1.4 Stewardship
Replace
“The fundamental purpose of Internet number stewardship is to distribute unique 
number resources to entities building and operating networks thereby 
facilitating the growth and sustainability of the Internet for the benefit of 
all.”
with
“The fundamental purpose of Internet number stewardship is to distribute unique 
number resources to facilitate the growth and sustainability of the Internet 
for the benefit of all.”
Section 2.4
Replace
“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.”
with
“2.4. Local Internet Registry (LIR) A Local Internet Registry (LIR) is an IR 
that primarily assigns address space to users of the network. LIRs are 
generally Internet Service Providers (ISPs), whose customers are primarily end 
users and possibly other ISPs.”
Section 4.18
Replace
“ARIN will only issue future IPv4 assignments/allocations (excluding 4.4 and 
4.10 space) from the ARIN Waitlist.”
with
“ARIN will only issue future IPv4 assignments/allocations (excluding 4.4 and 
4.10 space) from the ARIN Waitlist to those with operational need.”
Delete Section 8.5.2 Operational Use
Timetable for implementation: Immediate.
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[John Curran]

John - 

Can you provide a brief explanation of why you believe this potential 
change to policy is not desirable?

(I have no particular view either way, but having some explanation of 
support / opposition viewpoints aids others in their consideration of the 
merits/concerns with potential policy changes…)

Thanks!
/John

John Curran
President and CEO
American Registry for Internet Numbers


> On 10 Mar 2022, at 12:57 AM, John Santos  wrote:
> 
> Oppose.
> 
> 
> On 3/9/2022 11:23 PM, ARIN wrote:
>> The following Draft Policy has been revised and retitled:
>> * ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining 
>> Utilization for Future Allocations
>> Revised text is below and can be found at:
>> https://www.arin.net/participate/policy/drafts/2021_6/ 
>> 
>> You are encouraged to discuss all Draft Policies on PPML. The AC will 
>> evaluate the discussion 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
>> Senior Policy Analyst
>> American Registry for Internet Numbers (ARIN)
>> Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of 
>> Determining Utilization for Future Allocations
>> Problem Statement: Current ARIN policy prevents the use of leased-out 
>> addresses as evidence of utilization.
>> Policy statement:
>> Section 1.2 Conservation
>> Replace
>> “Due to the requirement for uniqueness, Internet number resources of each 
>> type are drawn from a common number space. Conservation of these common 
>> number spaces requires that Internet number resources be efficiently 
>> distributed to those organizations who have a technical need for them in 
>> support of operational networks.”
>> with
>> “Due to the requirement for uniqueness, Internet number resources of each 
>> type are drawn from a common number space. Conservation of these common 
>> number spaces requires that free-pool (ASN & IPv6) and IPv4 wait-list 
>> Internet number resources be efficiently distributed to those organizations 
>> who have a technical need for them in support of operational networks.”
>> Section 1.4 Stewardship
>> Replace
>> “The fundamental purpose of Internet number stewardship is to distribute 
>> unique number resources to entities building and operating networks thereby 
>> facilitating the growth and sustainability of the Internet for the benefit 
>> of all.”
>> with
>> “The fundamental purpose of Internet number stewardship is to distribute 
>> unique number resources to facilitate the growth and sustainability of the 
>> Internet for the benefit of all.”
>> Section 2.4
>> Replace
>> “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.”
>> with
>> “2.4. Local Internet Registry (LIR) A Local Internet Registry (LIR) is an IR 
>> that primarily assigns address space to users of the network. LIRs are 
>> generally Internet Service Providers (ISPs), whose customers are primarily 
>> end users and possibly other ISPs.”
>> Section 4.18
>> Replace
>> “ARIN will only issue future IPv4 assignments/allocations (excluding 4.4 and 
>> 4.10 space) from the ARIN Waitlist.”
>> with
>> “ARIN will only issue future IPv4 assignments/allocations (excluding 4.4 and 
>> 4.10 space) from the ARIN Waitlist to those with operational need.”
>> Delete Section 8.5.2 Operational Use
>> Timetable for implementation: Immediate.
>> ___
>> ARIN-PPML
>> You are receiving this message because you are subscribed to
>> the ARIN Public Policy Mailing List (ARIN-PPML@arin.net).
>> Unsubscribe or manage your mailing list subscription at:
>> https://lists.arin.net/mailman/listinfo/arin-ppml
>> Please contact i...@arin.net if you experience any issues.
> 
> -- 
> John Santos
> Evans Griffiths & Hart, Inc.
> 781-861-0670 ext 539
> ___
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[John Santos]

Oppose.


On 3/9/2022 11:23 PM, ARIN wrote:

The following Draft Policy has been revised and retitled:

* ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining 
Utilization for Future Allocations


Revised text is below and can be found at:

https://www.arin.net/participate/policy/drafts/2021_6/ 



You are encouraged to discuss all Draft Policies on PPML. The AC will evaluate 
the discussion 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

Senior Policy Analyst

American Registry for Internet Numbers (ARIN)

Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of 
Determining Utilization for Future Allocations


Problem Statement: Current ARIN policy prevents the use of leased-out addresses 
as evidence of utilization.


Policy statement:

Section 1.2 Conservation

Replace

“Due to the requirement for uniqueness, Internet number resources of each type 
are drawn from a common number space. Conservation of these common number spaces 
requires that Internet number resources be efficiently distributed to those 
organizations who have a technical need for them in support of operational 
networks.”


with

“Due to the requirement for uniqueness, Internet number resources of each type 
are drawn from a common number space. Conservation of these common number spaces 
requires that free-pool (ASN & IPv6) and IPv4 wait-list Internet number 
resources be efficiently distributed to those organizations who have a technical 
need for them in support of operational networks.”


Section 1.4 Stewardship

Replace

“The fundamental purpose of Internet number stewardship is to distribute unique 
number resources to entities building and operating networks thereby 
facilitating the growth and sustainability of the Internet for the benefit of all.”


with

“The fundamental purpose of Internet number stewardship is to distribute unique 
number resources to facilitate the growth and sustainability of the Internet for 
the benefit of all.”


Section 2.4

Replace

“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.”


with

“2.4. Local Internet Registry (LIR) A Local Internet Registry (LIR) is an IR 
that primarily assigns address space to users of the network. LIRs are generally 
Internet Service Providers (ISPs), whose customers are primarily end users and 
possibly other ISPs.”


Section 4.18

Replace

“ARIN will only issue future IPv4 assignments/allocations (excluding 4.4 and 
4.10 space) from the ARIN Waitlist.”


with

“ARIN will only issue future IPv4 assignments/allocations (excluding 4.4 and 
4.10 space) from the ARIN Waitlist to those with operational need.”


Delete Section 8.5.2 Operational Use

Timetable for implementation: Immediate.


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--
John Santos
Evans Griffiths & Hart, Inc.
781-861-0670 ext 539
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Re: [arin-ppml] Revised and Retitled - Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining Utilization for Future Allocations

[Scott Leibrand]

8.5.2 Operational Use reads:

> ARIN allocates or assigns number resources to organizations via transfer 
> solely for the purpose of use on an operational network.


If you’re going to remove that, what is to stop me from opening a new LIR and 
stating that I want pre-qualification for a transfer of a /8 to lease out, 
because I have sales projections that I can lease out a /9 within 24 months, a 
/10 within 12 months, and a /11 within 6 months? And if I fail to meet my sales 
projections, I can sell some or all of the /8 after 12 months (presumably at a 
profit, as prices just keep going up).  

It seems that there should be some limit on initial block size if we’re going 
to rely exclusively on recipients’ leasing projections instead of requiring use 
on an operational network. Once they have leased out 50% of their initial block 
to tenants who are using the space on their own networks, they could then come 
back for approval to receive a larger block via transfer, sized to an 
extrapolation of their 24 month need based on how quickly they leased out their 
existing space. 

Scott

> On Mar 9, 2022, at 8:24 PM, ARIN  wrote:
> 
> 
> The following Draft Policy has been revised and retitled:
>  
> * ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of Determining 
> Utilization for Future Allocations
>  
> Revised text is below and can be found at:
>  
> https://www.arin.net/participate/policy/drafts/2021_6/
>  
> You are encouraged to discuss all Draft Policies on PPML. The AC will 
> evaluate the discussion 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
> Senior Policy Analyst
> American Registry for Internet Numbers (ARIN)
>  
>  
>  
>  
> Draft Policy ARIN-2021-6: Permit IPv4 Leased Addresses for Purposes of 
> Determining Utilization for Future Allocations
>  
> Problem Statement: Current ARIN policy prevents the use of leased-out 
> addresses as evidence of utilization.
>  
> Policy statement:
>  
> Section 1.2 Conservation
>  
> Replace
>  
> “Due to the requirement for uniqueness, Internet number resources of each 
> type are drawn from a common number space. Conservation of these common 
> number spaces requires that Internet number resources be efficiently 
> distributed to those organizations who have a technical need for them in 
> support of operational networks.”
>  
> with
>  
> “Due to the requirement for uniqueness, Internet number resources of each 
> type are drawn from a common number space. Conservation of these common 
> number spaces requires that free-pool (ASN & IPv6) and IPv4 wait-list 
> Internet number resources be efficiently distributed to those organizations 
> who have a technical need for them in support of operational networks.”
>  
> Section 1.4 Stewardship
>  
> Replace
>  
> “The fundamental purpose of Internet number stewardship is to distribute 
> unique number resources to entities building and operating networks thereby 
> facilitating the growth and sustainability of the Internet for the benefit of 
> all.”
>  
> with
>  
> “The fundamental purpose of Internet number stewardship is to distribute 
> unique number resources to facilitate the growth and sustainability of the 
> Internet for the benefit of all.”
>  
> Section 2.4
>  
> Replace
>  
> “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.”
>  
> with
>  
> “2.4. Local Internet Registry (LIR) A Local Internet Registry (LIR) is an IR 
> that primarily assigns address space to users of the network. LIRs are 
> generally Internet Service Providers (ISPs), whose customers are primarily 
> end users and possibly other ISPs.”
>  
> Section 4.18
>  
> Replace
>  
> “ARIN will only issue future IPv4 assignments/allocations (excluding 4.4 and 
> 4.10 space) from the ARIN Waitlist.”
>  
> with
>  
> “ARIN will only issue future IPv4 assignments/allocations (excluding 4.4 and 
> 4.10 space) from the ARIN Waitlist to those with operational need.”
>  
> Delete Section 8.5.2 Operational Use
>  
> Timetable for implementation: Immediate.
> ___
> ARIN-PPML
> You are receiving this message because you are subscribed to
> the ARIN Public Policy Mailing List (ARIN-PPML@arin.net).
> Unsubscribe or manage your mailing list subscription at:
>