Because currently there is no "justification benefit" for accurate
registration, but this policy would create one.
I don't understand what you are asserting here. There is currently a
requirement to accurately report re-allocations. The only benefit I
see is to networks that are currently non-compliant with that policy.
If networks are failing to meet those obligations, I would argue a
better policy proposal would be one to strengthen the penalties
related to non-compliance with that policy, rather than rewarding
non-complaint networks.
- Isaiah
Good morning Isaiah,
This policy will create a financial benefit for accurate registration
of leased addresses that currently does not exist. I lease addresses
out, but there is no financial incentive for me to register those
leases in any way at ARIN. However if I wanted to purchase more
addresses to meet the needs of more lessees, then I would have a
financial incentive for accurate registration. I am not arguing that
this should be required, I think we all should strive for accurate
registration. But I see financial incentives as meaningful, they are
driving the IPv4 distribution system today.
It’s the carrot approach, but you can try the stick to see if that
would encourage more accurate assignments.
Regards,
Mike
*From:* Isaiah Olson <[email protected]>
*Sent:* Tuesday, September 21, 2021 8:00 PM
*To:* Mike Burns <[email protected]>
*Cc:* 'ARIN-PPML List' <[email protected]>
*Subject:* Re: Draft Policy ARIN-2021-6: Remove Circuit Requirement
Nonetheless your objection was that this proposal somehow would
not distribute resources in accordance with policy, I think your
objection was addressed completely.
You are certainly correct that my initial objection was unclear.
Specifically, I do not believe that this policy is compatible with
section 4.2 of the PDP process, nor 4.3 as of this moment. Compliance
with the NRPM would seem to be irrelevant since the policy proposal
would change the NRPM.
You are drifting. I never made the argument you are saying I made
regarding any benefit of leasing to RIPE.
I said in response to Noah, and you now agree, that allowing
leasing will not in fact lead to the demise of an RIR.
I take it you agree that Noah's objection in this regard has been
addressed.
You are the one who opened the door to the RIPE situation, although I
would have certainly cited the research from my first email
regardless. Although you may have addressed the extreme example
brought up by Noah, you have failed to address any of the concerns I
have raised about the results of the RIPE policy. If I've put words in
your mouth, I apologize. However, I am asking you directly to address
whether you consider the policy implementation in RIPE to have been
beneficial to the Internet community, both in the region and as a
whole, because I would argue the data says otherwise.
OK the waiting list is rock solid, but my wisp needs a /21, what
now? My point remains, the waiting list is not appropriate for all
those in need, and if there were alternatives then there would be
no market for leases to begin with. I can spend all day giving
examples of legitimate lessees. I think you should concede that
there are legitimate business cases where leases make more sense
for the recipient.
The waiting list may not be appropriate for all needs, but it
certainly fills in many of the gaps you are arguing necessitate
leasing. The edge cases you note may make for a compelling argument
for expanding wait list eligibility, but I don't find them compelling
enough to justify a RIR-wide policy change to allow leased addresses
to be considered as justification, a policy which has the potential
for considerable negative side effects to the community. The existence
of a market for leasing does not equate to a necessity for the ARIN
community to enable and subsidize the practice by changing policy in
this way. I would certainly concede that legitimate business cases for
leasing IPv4 do exist. Unfortunately, there is a dearth of reputable
research into the leasing market, so I will refrain from making any
assertions about the proportion of legitimate to non-legitimate use
cases. Regardless, the existence of legitimate use cases doesn't
strike me as a compelling reason to support this policy.
I believe you have conceded that my assertion is correct.
With regards to your assertions about the composition of the pool of
lessors, I would agree that you are correct. I do not concede or agree
in any way that your assertion supports implementation of this
particular policy. I do not support the concept of LIRs acquiring new
space solely to lease off-network, and I would prefer that the pool
available for leasing off-network dwindles over time until as much
space as possible can be brought under terms that explicitly disallow
the practice. For networks smaller than /20, the waiting list provides
an acceptable alternative and it appears that the current rate of
revocations is approximately matched to the demand on the waiting
list, for networks larger than /20, I assert that what you propose
would only exacerbate the difficulty of obtaining a block at a
reasonable price.
That is the current policy, to disallow justification without a
circuit, so your objection to this proposal means you prefer no
leasing policy.
You are correct here, I certainly prefer a no leasing policy,
specifically one that is stronger than the current policy, but I still
prefer the current policy to what you propose. I do not believe it is
legally or economically feasible for ARIN to retroactively reclaim
resources that are currently being leased off-network, but I don't
consider anything you've presented here as a compelling argument to
officially sanction the practice regardless of the historical
inequalities.
I consider this also a concession that what I said is true about
"providing an incentive" which is as far as I went.
You're going to need to go further if you want to garner any
significant community support for this proposal.
I agree with your first contention, that this policy could in fact
lead to price increases on the transfer market.
But the basic math you refer to is the linkage between the
transfer market and the lease market.
Transfer prices have doubled this year, lease rates have not
doubled, they haven't risen anywhere nearly as quickly.
I think the lack of ability to purchase blocks to feed the lease
market in ARIN serves to loosen that coupling between the lease
and transfer market.
Thanks for phrasing it as "if networks choose to lease", as that
is a clear understanding of the way things work currently.
Lessors and lessees are choosing to engage in leasing because they
both see an advantage.
So let me admit my assertion that lease rates would drop with this
policy is just an assumption and not an assertion.
I would agree with your assertion that the linkage between the
transfer market and the leasing market is loose. I expect that there
will be a corresponding increase in lease prices over time. If you
have any historical data to contradict that expectation, I'd certainly
be open to hearing it. If networks choose to lease when there are
alternatives available, I am unconcerned if they must pay more, even
significantly more in the far flung future when the leasing pool has
dwindled, because that is the price they are choosing to pay for the
flexibility associated with a lease.
Thanks, I think we understand that you do not support the policy
but I don't think that you overcame my assertion this time.
Because currently there is no "justification benefit" for accurate
registration, but this policy would create one.
I don't understand what you are asserting here. There is currently a
requirement to accurately report re-allocations. The only benefit I
see is to networks that are currently non-compliant with that policy.
If networks are failing to meet those obligations, I would argue a
better policy proposal would be one to strengthen the penalties
related to non-compliance with that policy, rather than rewarding
non-complaint networks.
- Isaiah
On 9/21/2021 6:17 PM, Mike Burns wrote:
Hi Isaiah,
Thanks, replies inline.
---- On Tue, 21 Sep 2021 18:56:05 -0400 *Isaiah Olson
<[email protected]> <mailto:[email protected]>*
wrote ----
Hi Mike,
Thanks for your reply. I would be happy to address each of
your assertions.
> That RIPE situation is an unfortunate artifact of their
reserve pool
> for new entrants.
>
> Can you share the percent of those /24s that begin with 185?
Roughly 17% of the RIPE IP space that I have on my list comes
from that
block. I would hardly agree that the statistically significant
disparity
in transfer market abuse activity across all RIPE IP ranges is
solely an
artifact of this single block.
> First you wrote “The onus is not on ARIN to sanctify
practices that
> some are already engaging in, but rather to distribute number
> resources in accordance with community developed policy.”
>
> My answer is that this policy proposal continues to
distribute number
> resources in accordance with community developed policy.
It will be community policy if and when it is adopted through
this PDP,
which seems unlikely at this point since you are the only
person arguing
in favor and I don't find your arguments particularly
convincing since
they are not backed up by any hard data. Whether the policy
comports
with the goals of the PDP itself is a different question.
Mike-Nonetheless your objection was that this proposal somehow
would not distribute resources in accordance with policy, I
think your objection was addressed completely.
> I would agree with you, but that doesn’t mean we should ignore
> relevant data from our sister registry, and I brought up
RIPE to deal
> with Noah’s objection about what will happen should this
policy pass
What relevant data have you provided from RIPE which justifies
your
initial assertion? Certainly you may have rejected Noah's
concern that
the RIR would collapse, given the fact that RIPE still exists,
but I
haven't seen any compelling data cited here that shows any
benefit to
the RIPE community due to their policy and I have provided
data which
shows quite the opposite. A lack of immediate negative effects
is hardly
sufficient data to declare that RIPE policy hasn't caused
negative long
term effects, of which we may not have yet seen the full impact.
Mike-You are drifting. I never made the argument you are
saying I made regarding any benefit of leasing to RIPE.
I said in response to Noah, and you now agree, that allowing
leasing will not in fact lead to the demise of an RIR.
I take it you agree that Noah's objection in this regard has
been addressed.
> Then you won’t have to worry about leasing, because you
claim there is
> no market for it. The waiting list is not a guaranty, and
has an
> unpredictable schedule for address delivery. I gave an
example of a
> WISP seeking to try out a new area, and why leasing
addresses might be
> quite attractive to that WISP for entirely legitimate reasons.
I would not consider the current waiting list distributions
unpredictable, in fact I would argue it's quite the opposite in
practice. Speaking from personal experience on the waiting
list before
ARIN moved to quarterly distributions, I waited only four
months to
receive a block. Under the last several quarterly
distributions, nearly
every request on the list has been fulfilled in each
distribution,
resulting in a consistent distribution schedule of 3-6 months
for the
last several distributions. The oldest request currently on
the list is
from 07/01/2021. I would ask ARIN to please provide some hard
data about
this process for the community to consider when evaluating
this policy,
because I do not believe the current reality of the waiting
list agrees
with your assertions. If and when that changes, I would
possibly be open
to re-considering my position on the matter.
With regards to leasing, I did not assert that there is no
market for
leasing, but rather that alternatives to leasing do exist and
you are
casting them in an a light that I do not believe reflects the
reality of
the situation. Under current policy, your WISP example is free
to apply
to the waiting list for the block it needs to try out the new
area, and
either return or re-purpose it if services in that new area
don't work
out. I don't find a compelling argument here for the necessity of
leasing addresses.
Mike- OK the waiting list is rock solid, but my wisp needs a
/21, what now? My point remains, the waiting list is not
appropriate for all those in need, and if there were
alternatives then there would be no market for leases to begin
with. I can spend all day giving examples of legitimate
lessees. I think you should concede that there are legitimate
business cases where leases make more sense for the recipient.
> Opposing this policy means the only lessors are the lucky
incumbents.
If the lucky incumbents choose to retain their IPv4 space and
lease it,
that is certainly their choice to make. However, under the
current
policy you propose to change, they may not consider leased
addresses as
justification for additional space. I feel the current policy
strikes a
perfectly appropriate balance. If a network has leased space
available
to reclaim when leases expire, it is inappropriate for them to
seek
additional allocations from the RIR. If they have over-leased
their
space such that they cannot operate their network until
someone's lease
expires, then they should not expect the ARIN community to
subsidize
their lack of foresight with additional addresses. Transfers
in such a
situation are a different matter and I would certainly
consider this
policy in a different light if leasing space were to be
exempted as
justification for waiting list request.
Mike- I believe you have conceded that my assertion is correct.
> Opposing this policy means a lack of policy is preferred,
despite the
> open practice of leasing.
As I originally stated in my first e-mail, I do not prefer the
lack of
policy or the insufficiency of the current policy. I would
instead
prefer to see the policy explicitly strengthened to disallow
off-network
leasing as justification for additional requests, despite the
fact that
ARIN has made it clear that they consider the current policy
to prohibit
using such addresses as justification.
Mike - That is the current policy, to disallow justification
without a circuit, so your objection to this proposal means
you prefer no leasing policy.
> Opposing this policy provides incentive for
registry-shopping and
> address outflow.
I agree that RIR-shopping is a concern and there is a real
chance that
strict policy against leasing in the ARIN region may encourage
the
practice. However, I don't believe this should be the concern
of the
ARIN community in deciding how to allocate resources in our
corner of
the world. If other RIR communities want to make other
decisions, they
are endowed with that freedom under the current system. I
don't think
"everyone is jumping off the bridge so we should too" makes
for a good
argument. What would convince me is hard data that shows how
the RIPE
community has benefited from the elimination of the needs-test
in the
transfer process, or data that demonstrates what tangible
issue your
policy proposal would solve in the ARIN region. "Current ARIN
policy
prevents the use of leased-out addresses as evidence of
utilization"
doesn't strike me as a complete problem statement.
Mike-I consider this also a concession that what I said is
true about "providing an incentive" which is as far as I went.
> Opposing this policy reduces the lessor pool and drives up
lease rates.
This argument cuts both ways. I would argue that supporting
the policy
drives up transfer market prices by increasing speculation by
entities
that have no stake in the shared Internet resource aside from
the rights
to use IPv4 addresses. Basic math tells us that higher prices
in the
transfer markets will result in higher prices in the leasing
market, as
well as resulting in fewer blocks available to networks who
wish to
obtain space directly from the RIR via transfers. I do not see
this as a
benefit to the community. As I have stated before, I am
unmotivated by
the impacts on lessees/lessors of keeping the current policy or
strengthening the requirement to provision actual services on an
operational network. If networks choose to lease, they may pay
more,
which is a similar situation for any capital-intensive
resource that is
subject to leasing. Developing policy to keep lease rates low
is not the
concern of the ARIN community or this PDP, but rather
developing policy
that supports efficient and technically competent
administration of the
region's resources.
Mike- I agree with your first contention, that this policy
could in fact lead to price increases on the transfer market.
But the basic math you refer to is the linkage between the
transfer market and the lease market.
Transfer prices have doubled this year, lease rates have not
doubled, they haven't risen anywhere nearly as quickly.
I think the lack of ability to purchase blocks to feed the
lease market in ARIN serves to loosen that coupling between
the lease and transfer market.
Thanks for phrasing it as "if networks choose to lease", as
that is a clear understanding of the way things work currently.
Lessors and lessees are choosing to engage in leasing because
they both see an advantage.
So let me admit my assertion that lease rates would drop with
this policy is just an assumption and not an assertion.
> Opposing this policy dis-incentivizes accurate registration
If networks choose to report inaccurate or fraudulent SWIP
data in order
to evade the requirements of the current policy, then they are
not
allocating addresses in accordance with ARIN policy and could
be subject
to enforcement actions from ARIN. Although I wish ARIN was more
aggressive in maintaining an accurate WHOIS database and abuse
contacts,
I would argue that the current situation in the ARIN region is
quite
good compared to other RIRs in this respect, since there has
been a
regular review process to ensure database accuracy for many
years.
Either way, this policy proposal doesn't fundamentally change
reporting
requirements, but simply blesses networks who currently have
"something
to hide" to report their usage accurately. Certainly, I can
see how the
policy benefits the community in this limited sense. Still, I am
unconvinced that the net effects would be positive and I do
not support
the policy.
Mike - Thanks, I think we understand that you do not support
the policy but I don't think that you overcame my assertion
this time.
Because currently there is no "justification benefit" for
accurate registration, but this policy would create one.
Regards,
Mike
- Isaiah
On 9/21/2021 4:29 PM, Mike Burns wrote:
>
> Hi Isaiah,
>
> That RIPE situation is an unfortunate artifact of their
reserve pool
> for new entrants.
>
> Can you share the percent of those /24s that begin with 185?
>
> You didn’t support Noah’s theory that this policy proposal
would lead
> to the demise of RIRs, so let’s address your particular
objections.
>
> First you wrote “The onus is not on ARIN to sanctify
practices that
> some are already engaging in, but rather to distribute number
> resources in accordance with community developed policy.”
>
> My answer is that this policy proposal continues to
distribute number
> resources in accordance with community developed policy.
>
> Second you wrote:” If other RIR communities choose to make
other
> decisions, that doesn't make it the correct decision for the
ARIN region.”
>
> I would agree with you, but that doesn’t mean we should ignore
> relevant data from our sister registry, and I brought up
RIPE to deal
> with Noah’s objection about what will happen should this
policy pass”
>
> Third you wrote “There is a waiting list available for
legitimate new
> entrants, and I don't buy the argument that networks with
greater than
> a /20 cannot afford the capital outlay to purchase a block.”
>
> Then you won’t have to worry about leasing, because you
claim there is
> no market for it. The waiting list is not a guaranty, and
has an
> unpredictable schedule for address delivery. I gave an
example of a
> WISP seeking to try out a new area, and why leasing
addresses might be
> quite attractive to that WISP for entirely legitimate reasons.
>
> I feel I have addressed what I see as the objections you
have noted.
>
> Now, why not try to actually address even one of my
assertions and
> tell me where it fails?
>
> “Opposing this policy means the only lessors are the lucky
incumbents.
>
> Opposing this policy means a lack of policy is preferred,
despite the
> open practice of leasing.
>
> Opposing this policy provides incentive for
registry-shopping and
> address outflow.
>
> Opposing this policy reduces the lessor pool and drives up
lease rates.
>
> Opposing this policy dis-incentivizes accurate registration”
>
> Regards,
> Mike
>
> *From:* Isaiah Olson <[email protected]
<mailto:[email protected]>>
> *Sent:* Tuesday, September 21, 2021 5:07 PM
> *To:* Mike Burns <[email protected]
<mailto:[email protected]>>; 'Noah' <[email protected]
<mailto:[email protected]>>
> *Cc:* 'ARIN-PPML List' <[email protected]
<mailto:[email protected]>>
> *Subject:* Draft Policy ARIN-2021-6: Remove Circuit Requirement
>
> Mike,
>
> I would hardly say it's time for a funeral in RIPE, but I
would ask,
> do you think it's a coincidence that roughly 75% of the /24
blocks
> that I have blackholed on my network for spamming my email
server are
> registered to anonymous hosting companies in the RIPE
region? I don't
> agree that the results of the RIPE policy speak for
themselves, and I
> would love to see more data aggregated by some of the more
talented
> internet sleuths on here regarding the proportion of abuse
activity
> split up by RIR. I also disagree with all five of your
assumptions
> about opposing this policy. The onus is not on ARIN to sanctify
> practices that some are already engaging in, but rather to
distribute
> number resources in accordance with community developed
policy. If
> other RIR communities choose to make other decisions, that
doesn't
> make it the correct decision for the ARIN region. I don't
support any
> policy that amplifies the practice of leasing because I
reject your
> arguments about the necessity of the practice. There is a
waiting list
> available for legitimate new entrants, and I don't buy the
argument
> that networks with greater than a /20 cannot afford the
capital outlay
> to purchase a block. Please feel free to provide any data
you can to
> back up your five assertions. For my assertion, please
consider the
> following:
>
> Prefixes exchanged within the RIPE region as sales originate
have
> the highest fraction of blacklisted IPs, which is statistically
> significant.
>
> Source:
>
https://eprints.lancs.ac.uk/id/eprint/139789/1/VGiotsas_PAM2020_IPv4_Transfers_abuse.pdf
<https://eprints.lancs.ac.uk/id/eprint/139789/1/VGiotsas_PAM2020_IPv4_Transfers_abuse.pdf>
>
<https://eprints.lancs.ac.uk/id/eprint/139789/1/VGiotsas_PAM2020_IPv4_Transfers_abuse.pdf
<https://eprints.lancs.ac.uk/id/eprint/139789/1/VGiotsas_PAM2020_IPv4_Transfers_abuse.pdf>>
>
> - Isaiah
>
> On 9/21/2021 3:24 PM, Mike Burns wrote:
>
> I am in total agreement with your sentiment and the requirement
> for a circuit should continue to stand.
>
> Any policy that removes such a requirement would render the
> management of Internet Number Resources by the registry useless
> and thereby essentially lead to no need for the registry
after all.
>
> Noah
>
> Hi Noah,
>
> Are you aware that there has been no needs-test for RIPE
transfers
> for many years and the RIR system hasn’t collapsed?
>
> To make it clear, in RIPE you can purchase address space
with the
> sole purpose of leasing it out. And you have been able to do
that
> for many years now. Plainly, openly, within all policy. So
please
> let us know where to send the flowers for RIPE’s funeral. That
> goes for others who predict that bad things will follow from
> adopting this policy, please keep RIPE’s example in mind to
> provide a reality check. The experiment has already been
performed.
>
> Owen has already pointed out the futility of the circuit
> requirement in practice, yet you think that’s what keeps
the RIR
> system functional?
>
> Opposing this policy means the only lessors are the lucky
incumbents.
>
> Opposing this policy means a lack of policy is preferred,
despite
> the open practice of leasing.
>
> Opposing this policy provides incentive for
registry-shopping and
> address outflow.
>
> Opposing this policy reduces the lessor pool and drives up
lease
> rates.
>
> Opposing this policy dis-incentivizes accurate registration.
>
> Let me know if any of these assertions require amplification, I
> guess some may not be clear but this is already too long.
>
> Regards,
> Mike
>
