2015-01 New Policy Proposal (Alignment of Transfer Requirements for IPv4 Allocations)
Dear colleagues, A proposed change to RIPE Document "IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region" is now available for discussion. You can find the full proposal at: https://www.ripe.net/ripe/policies/proposals/2015-01 We encourage you to review this proposal and send your comments to <address-policy-wg@ripe.net> before 12 March 2015. Regards Marco Schmidt Policy Development Officer RIPE NCC
On 11 February 2015 at 13:46, Marco Schmidt <mschmidt@ripe.net> wrote:
How would this affect organisations that are acquired post their acquisition of a /22 but within 24 months. I assume its under a different policy but I'm just checking... J -- James Blessing 07989 039 476
Hi James, On 11/02/15 15:31, James Blessing wrote:
On 11 February 2015 at 13:46, Marco Schmidt <mschmidt@ripe.net> wrote:
How would this affect organisations that are acquired post their acquisition of a /22 but within 24 months. I assume its under a different policy but I'm just checking...
currently, this policy proposal only touches on the /22s (from the last /8) received from the RIPE NCC and which will (if the policy proposal is accepted) have the same 2 years restriction when transferred thru the transfer policy. A second discussion that will spin-off from this proposal will be to see what can be done when a company receiving the last /22 within the 2 years restriction will be acquired by or will merge with an existing LIR using M&A. The M&A (part of ripe-628) is a RIPE NCC procedure and will need to be discussed on the members-discuss mailing list, with the Board and at the GM before the RIPE NCC can do something about that. I'm waiting to get the feeling of the community on this proposal before starting a discussion on the members-discuss mailing list about the M&A procedure.
J -- James Blessing 07989 039 476
regards, elvis -- <http://v4escrow.net> Elvis Daniel Velea Chief Executive Officer Email: elvis@V4Escrow.net <mailto:elvis@v4escrow.net> US Phone: +1 (702) 475 5914 EU Phone: +31 (0) 61458 1914 Recognised IPv4 Broker/Facilitator in: This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received this email in error, please notify the sender immediately and delete the original.Any other use of this email is strictly prohibited.
On Wed, 11 Feb 2015, Elvis Daniel Velea wrote:
I'm waiting to get the feeling of the community on this proposal before starting a discussion on the members-discuss mailing list about the M&A procedure.
My gut feeling is that I do not want new LIRs created to acquire a /22, immediately transfer it out, and close the LIR. Considering the market price on IPv4 addresses I have seen and the cost of creating a LIR, this would be below market price. Thus I support any measure that brings the /22 last /8 policy more in line with market prices for IPv4 addresses, for instance by requiring that the LIR exists and fees are paid total over the life of the LIR that'll bring the cost-per-address closer to reality. If the current proposal means the minimmum cost of creating a new LIR, getting /22 and closing it down is 2000EUR signup fee and 2*yearly fee minimum (currently 1600EUR yearly fee according to https://www.ripe.net/ripe/docs/ripe-620) for a total of 5200 EUR, I am fine with that. I would also be fine with a one-time fee for the last /22 if that would make things easier. -- Mikael Abrahamsson email: swmike@swm.pp.se
* Mikael Abrahamsson
My gut feeling is that I do not want new LIRs created to acquire a /22, immediately transfer it out, and close the LIR. Considering the market price on IPv4 addresses I have seen and the cost of creating a LIR, this would be below market price.
Thus I support any measure that brings the /22 last /8 policy more in line with market prices for IPv4 addresses, for instance by requiring that the LIR exists and fees are paid total over the life of the LIR that'll bring the cost-per-address closer to reality.
If the current proposal means the minimmum cost of creating a new LIR, getting /22 and closing it down is 2000EUR signup fee and 2*yearly fee minimum (currently 1600EUR yearly fee according to https://www.ripe.net/ripe/docs/ripe-620) for a total of 5200 EUR, I am fine with that.
Agreed. That said, €5200 is still half off compared to the supposed market price so I doubt that this policy proposal will stop sufficiently desperate people who actually need the addresses for themselves or their customers from going down the multiple LIRs route. It won̈́'t fully close the "register temporary LIR, get /22, instantly sell /22 to third party" loophole either, as the temporary LIR might simply sub-allocate or assign the space to his customer for the first two years, and afterwards transfer it and close the LIR. But the extra unavoidable yearly fees would cut into the possible profits, of course. Tore
Hi Mikael, On 19/02/15 18:57, Mikael Abrahamsson wrote:
On Wed, 11 Feb 2015, Elvis Daniel Velea wrote:
I'm waiting to get the feeling of the community on this proposal before starting a discussion on the members-discuss mailing list about the M&A procedure.
My gut feeling is that I do not want new LIRs created to acquire a /22, immediately transfer it out, and close the LIR. Considering the market price on IPv4 addresses I have seen and the cost of creating a LIR, this would be below market price. and this is the loophole this policy proposal wants to close. I have seen at least one example where an LIR was created, received a /22 and within a week sold it (and I suppose it also got closed just after that).
regards, Elvis -- <http://v4escrow.net> Elvis Daniel Velea Chief Executive Officer Email: elvis@V4Escrow.net <mailto:elvis@v4escrow.net> US Phone: +1 (702) 475 5914 EU Phone: +31 (0) 61458 1914 Recognised IPv4 Broker/Facilitator in: This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received this email in error, please notify the sender immediately and delete the original.Any other use of this email is strictly prohibited.
On 11 Feb 2015, at 13:46, Marco Schmidt <mschmidt@ripe.net> wrote:
A proposed change to RIPE Document "IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region" is now available for discussion.
Thanks for your sharing policy proposal idea but I think the deckchairs would look better on the other side of this mighty unsinkable ship. I therefore can’t support this proposal. Andy
On Thu, 2015-02-19 at 17:53 +0000, Andy Davidson wrote:
On 11 Feb 2015, at 13:46, Marco Schmidt <mschmidt@ripe.net> wrote:
A proposed change to RIPE Document "IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region" is now available for discussion.
Thanks for your sharing policy proposal idea but I think the deckchairs would look better on the other side of this mighty unsinkable ship. I therefore can’t support this proposal.
Andy
I also oppose this proposal. I believe the best thing that can happen is for IPv4 to run out completely, as fast as possible. Increasing the RIPE NCC IPv4 price is counter-productive to that goal. Real market prices will arrive when this happens. I'm generally in favour of any proposal that hastens the run-out of the final /8. /M
Hello Martin,
I'm generally in favour of any proposal that hastens the run-out of the final /8.
The main design goal for the final /8 policy was to make sure that newcomers still had the possibility of participating on the IPv4 internet. It is unfortunately still not possible to run an ISP, hoster etc. with only IPv6. Without the final /8 policy every new company would have to get (borrow, buy, rent, ...) IPv4 addresses from existing companies that already got IPv4 addresses before we ran out of addresses to distribute using our needs-based allocation policies. With the final /8 policy they don't get much but at least they are able to participate on the internet. There is still an imbalance because of the low amount of addresses they get but at least they have *something* to work with. I do feel that as a community we should take this into account. Although I am sure there are many governments who want to take control over the internet we still are in a position that we can (are allowed to?) self-regulate the distribution of number resources. If we only think about ourselves (the existing participants on the internet) and block new entrants from getting even that tiny fraction of the addresses that most of us got for free in the past then I am afraid that this won't last very long. Comments from the working group on this are highly appreciated :) Cheers, Sander PS: I don't have a strong opinion on the policy proposal under discussion, sorry for drifting a bit from this thread's subject
Hi Sander! On Fri, 2015-02-20 at 01:15 +0100, Sander Steffann wrote:
Hello Martin,
I'm generally in favour of any proposal that hastens the run-out of the final /8.
The main design goal for the final /8 policy was to make sure that newcomers still had the possibility of participating on the IPv4 internet.
Indeed. Participate with a major handicap however. One could even argue that it is in fact anti-competitive compared with the rules pre final-/8 policy. The major architectural reason for and result of it was and is to buy RIPE NCC time to adjust to the post-depletion Internet world order.
It is unfortunately still not possible to run an ISP, hoster etc. with only IPv6.
Indeed it is not. It is likewise pretty futile to launch a new business as an ISP or hoster on a total of 1024 addresses. Any 'relevant' business plan for either will necessarily have to contain plans for acquiring much more than 1024 IPv4 addresses, since the availability of addresses, especially for hosters, is basically proportional to the growth possibility of the business.
Without the final /8 policy every new company would have to get (borrow, buy, rent, ...) IPv4 addresses from existing companies that already got IPv4 addresses before we ran out of addresses to distribute using our needs-based allocation policies.
Yes. Why is this worse than getting addresses from RIPE NCC's free pool, other than the fact that RIPE NCC sells pretty cheap addresses?
With the final /8 policy they don't get much but at least they are able to participate on the internet. There is still an imbalance because of the low amount of addresses they get but at least they have *something* to work with.
I've found size /22 sufficiently large to connect your average random SMB to the DFZ.
I do feel that as a community we should take this into account. Although I am sure there are many governments who want to take control over the internet we still are in a position that we can (are allowed to?) self-regulate the distribution of number resources.
I'll respond to this paragraph with four points: 1) Controlling Internet is much less about deciding who can have what address space uniquely, from a pool of unallocated space, than it is about deciding who gets to keep the address space. Secondary to this is the right of actually using the routing policy without interference. Many so-called democratic countries already implement filtering by hijacking via more-specifics, often based on actual laws, laws that won't change regardless of what this community self-regulates. 2) Since the final /8 will run out sooner (but IMO not soon enough) rather than later, this community's ability to self-regulate the distribution of IPv4 addresses is completely dead-end. 3) Once v4 address space is depleted and there is no more free pool to distribute from, the requirement for a needs based distribution model vanishes. If there is no more scarce resource, there is no more need to regulate it. Therefore it could be hypothesized that depleting the final /8 would *reduce* the need for governments to absorb regulatory work from the RIPE NCC. Address space becomes increasingly indistinguishable from radio frequencies - a right to transmit - however with typically global reach. 4) Also, once RIPE NCC's pools are depleted, some non-trivial amount of bureaucracy will basically go into the shredder, to my and Douglas Adams delight, saving on the environment. The green choice is therefore to accelerate the run-out.
If we only think about ourselves (the existing participants on the internet) and block new entrants from getting even that tiny fraction of the addresses that most of us got for free in the past then I am afraid that this won't last very long.
You bring up blocking of new entrants. To paraphrase Bill Gates, "1024 addresses are enough for everybody". If you were truly honest about welcoming new entrants to compete on equal terms, a /22 is not enough. Your fear for post-depletion is irrational in my opinion. You need to start entertaining the idea of the fact that it will happen. Post-depletion, what do you think governments will need to regulate and why do you fear it? Are you afraid some country with more military than address space compared to its neighbour will use the former to get more of the latter, from one that "got lucky"? Or are you afraid that governments will apply needs-based logic on already allocated address space? --> "No ISPs with blue in the logo may exist any more, now return the space to our national regulatory body, thanks" The best way of mitigating those examples is to empower people to themselves value their need of address space vs the need of the goods that it can be traded for. I am convinced that world order will be very healthy. If there's any worry about job security, the stock markets of today do employ people, and keep track of who has what. It's not very different from what's required from a regional registrar in the future. And you seldom see governments walking around redistributing stock between owners by force.
Comments from the working group on this are highly appreciated :)
Cheers, Sander
PS: I don't have a strong opinion on the policy proposal under discussion, sorry for drifting a bit from this thread's subject
I think this discussion is more relevant to APWG than the policy proposal at hand. :-) /M - Pondering the merits of a "reverse the final /8 policy" proposal.
Hi Martin, I'm sorry but your message contains so many lines of reasoning that I cannot follow that I have no way of giving you a meaningful response... Sincerely, Sander
Op 20 feb. 2015 om 02:30 heeft Martin Millnert <millnert@gmail.com> het volgende geschreven:
Hi Sander!
On Fri, 2015-02-20 at 01:15 +0100, Sander Steffann wrote: Hello Martin,
I'm generally in favour of any proposal that hastens the run-out of the final /8.
The main design goal for the final /8 policy was to make sure that newcomers still had the possibility of participating on the IPv4 internet.
Indeed. Participate with a major handicap however. One could even argue that it is in fact anti-competitive compared with the rules pre final-/8 policy.
The major architectural reason for and result of it was and is to buy RIPE NCC time to adjust to the post-depletion Internet world order.
It is unfortunately still not possible to run an ISP, hoster etc. with only IPv6.
Indeed it is not. It is likewise pretty futile to launch a new business as an ISP or hoster on a total of 1024 addresses. Any 'relevant' business plan for either will necessarily have to contain plans for acquiring much more than 1024 IPv4 addresses, since the availability of addresses, especially for hosters, is basically proportional to the growth possibility of the business.
Without the final /8 policy every new company would have to get (borrow, buy, rent, ...) IPv4 addresses from existing companies that already got IPv4 addresses before we ran out of addresses to distribute using our needs-based allocation policies.
Yes. Why is this worse than getting addresses from RIPE NCC's free pool, other than the fact that RIPE NCC sells pretty cheap addresses?
With the final /8 policy they don't get much but at least they are able to participate on the internet. There is still an imbalance because of the low amount of addresses they get but at least they have *something* to work with.
I've found size /22 sufficiently large to connect your average random SMB to the DFZ.
I do feel that as a community we should take this into account. Although I am sure there are many governments who want to take control over the internet we still are in a position that we can (are allowed to?) self-regulate the distribution of number resources.
I'll respond to this paragraph with four points:
1) Controlling Internet is much less about deciding who can have what address space uniquely, from a pool of unallocated space, than it is about deciding who gets to keep the address space. Secondary to this is the right of actually using the routing policy without interference. Many so-called democratic countries already implement filtering by hijacking via more-specifics, often based on actual laws, laws that won't change regardless of what this community self-regulates.
2) Since the final /8 will run out sooner (but IMO not soon enough) rather than later, this community's ability to self-regulate the distribution of IPv4 addresses is completely dead-end.
3) Once v4 address space is depleted and there is no more free pool to distribute from, the requirement for a needs based distribution model vanishes. If there is no more scarce resource, there is no more need to regulate it. Therefore it could be hypothesized that depleting the final /8 would *reduce* the need for governments to absorb regulatory work from the RIPE NCC. Address space becomes increasingly indistinguishable from radio frequencies - a right to transmit - however with typically global reach.
4) Also, once RIPE NCC's pools are depleted, some non-trivial amount of bureaucracy will basically go into the shredder, to my and Douglas Adams delight, saving on the environment. The green choice is therefore to accelerate the run-out.
If we only think about ourselves (the existing participants on the internet) and block new entrants from getting even that tiny fraction of the addresses that most of us got for free in the past then I am afraid that this won't last very long.
You bring up blocking of new entrants. To paraphrase Bill Gates, "1024 addresses are enough for everybody". If you were truly honest about welcoming new entrants to compete on equal terms, a /22 is not enough.
Your fear for post-depletion is irrational in my opinion. You need to start entertaining the idea of the fact that it will happen.
Post-depletion, what do you think governments will need to regulate and why do you fear it?
Are you afraid some country with more military than address space compared to its neighbour will use the former to get more of the latter, from one that "got lucky"?
Or are you afraid that governments will apply needs-based logic on already allocated address space? --> "No ISPs with blue in the logo may exist any more, now return the space to our national regulatory body, thanks"
The best way of mitigating those examples is to empower people to themselves value their need of address space vs the need of the goods that it can be traded for. I am convinced that world order will be very healthy. If there's any worry about job security, the stock markets of today do employ people, and keep track of who has what. It's not very different from what's required from a regional registrar in the future. And you seldom see governments walking around redistributing stock between owners by force.
Comments from the working group on this are highly appreciated :)
Cheers, Sander
PS: I don't have a strong opinion on the policy proposal under discussion, sorry for drifting a bit from this thread's subject
I think this discussion is more relevant to APWG than the policy proposal at hand. :-)
/M - Pondering the merits of a "reverse the final /8 policy" proposal.
The main design goal for the final /8 policy was to make sure that newcomers still had the possibility of participating on the IPv4 internet. It is unfortunately still not possible to run an ISP, hoster etc. with only IPv6. Without the final /8 policy every new company would have to get (borrow, buy, rent, ...) IPv4 addresses from existing companies that already got IPv4 addresses before we ran out of addresses to distribute using our needs-based allocation policies. With the final /8 policy they don't get much but at least they are able to participate on the internet. There is still an imbalance because of the low amount of addresses they get but at least they have *something* to work with.
try to minimize barrier to entry. i am sure there are nice terms in law for intentionally doing the opposite. randy
Hi Randy,
try to minimize barrier to entry.
Thanks, those were the words I was looking for. Cheers, Sander
Sander, On Fri, 2015-02-20 at 03:36 +0100, Sander Steffann wrote:
Hi Randy,
try to minimize barrier to entry.
Thanks, those were the words I was looking for.
Limiting entry to 1024 addresses is anti-competitive. Short enough for you? /M
Hi,
try to minimize barrier to entry.
Thanks, those were the words I was looking for.
Limiting entry to 1024 addresses is anti-competitive.
Short enough for you?
And intentionally running out and limiting entry to 0 addresses is ... ? Cheers, Sander
On Fri, Feb 20, 2015 at 11:05:53AM +0100, Sander Steffann wrote:
Limiting entry to 1024 addresses is anti-competitive.
And intentionally running out and limiting entry to 0 addresses is ... ?
Well, you can't sue a shop for having run out of milk to sell... I do see the point of running out quickly - stretching the ipv4 supply out as long as possible does damn us to this speculation nonsense for decades to come. The question is whether running out quickly will force ipv6 to happen and thus make ipv4 essentially useless as a speculation object. The way I see it, there are conflicting goals here - protect the investment of the big ipv4 players or cause enough pain to force the switch to ipv6 in my lifetime. If it should be the job of the RIRs to promote either goal (and I'm not sure it is) the latter one would be the better outcome for the Internet in the long term. As for the proposal, I'm "neutral tending towards opposition" pending further argument. rgds, Sascha Luck
On Fri, 2015-02-20 at 10:37 +0000, Sascha Luck [ml] wrote:
The way I see it, there are conflicting goals here - protect the investment of the big ipv4 players or cause enough pain to force the switch to ipv6 in my lifetime.
This proposal serves the purpose of shutting off access to 'cheap' IPv4 for new businesses, definitely forcing them to turn to the IPv4 resellers who in turn can protect their prices. It also obviously extends the life of the /8 for the very limited and specific Internet business use cases approved by the community. For all other use cases, assistance to entry by the RIPE NCC is banned. The proposal *increases* the relevance of the IPv4 resellers. The proposal *diminishes* the relevance of the RIPE NCC as a partner for entry to the Internet for any Internet service business. "Shooting yourself in the foot", I believe is the term, for what many in the community actually would like to see (inevitable eventual outcome is inevitable, though). /M
On Fri, Feb 20, 2015 at 12:21:12PM +0100, Martin Millnert wrote:
This proposal serves the purpose of shutting off access to 'cheap' IPv4 for new businesses, definitely forcing them to turn to the IPv4 resellers who in turn can protect their prices.
I can't actually see that. The proposal doesn't move the goalposts for a new LIR at all, assuming that a new business would want to hang on to their ipv4 space for at least two years. It doesn't even prevent them from creating >1 LIR if they need more than 1024 addresses - as long as each "LIR" hangs on to theirs for 2 years. The only difficulty is in creating multiple LIRS and then immediately merging them (and that issue has been raised) rgds, Sascha Luck
Sascha, On Fri, 2015-02-20 at 11:29 +0000, Sascha Luck [ml] wrote:
On Fri, Feb 20, 2015 at 12:21:12PM +0100, Martin Millnert wrote:
This proposal serves the purpose of shutting off access to 'cheap' IPv4 for new businesses, definitely forcing them to turn to the IPv4 resellers who in turn can protect their prices.
I can't actually see that. The proposal doesn't move the goalposts for a new LIR at all, assuming that a new business would want to hang on to their ipv4 space for at least two years. It doesn't even prevent them from creating >1 LIR if they need more than 1024 addresses - as long as each "LIR" hangs on to theirs for 2 years.
Right. I re-compiled the proposal text and read it in full.
The only difficulty is in creating multiple LIRS and then immediately merging them (and that issue has been raised)
Which sometimes would be convenient. Holding on to multiple LIRs rather than one does have an effect in higher TCO of IPv4 from RIPE NCC. But seeing as the proposal doesn't actually affect multiple-LIR solutions, my opposition is a bit decreased -- however I still believe we're all best served by just getting this s**t over with. It's akin to removing a patch from the skin, just rip it off and deal with it. /M
Hi Sacha, On 20/02/15 12:29, Sascha Luck [ml] wrote:
On Fri, Feb 20, 2015 at 12:21:12PM +0100, Martin Millnert wrote:
This proposal serves the purpose of shutting off access to 'cheap' IPv4 for new businesses, definitely forcing them to turn to the IPv4 resellers who in turn can protect their prices.
I can't actually see that. The proposal doesn't move the goalposts for a new LIR at all, assuming that a new business would want to hang on to their ipv4 space for at least two years. It doesn't even prevent them from creating >1 LIR if they need more than 1024 addresses - as long as each "LIR" hangs on to theirs for 2 years. The only difficulty is in creating multiple LIRS and then immediately merging them (and that issue has been raised)
Well, if a business wants to hang on to their addresses (for two or more years), then that is a 'legitimate' use of the /22 :) This policy proposal tries to close the loophole where companies only request the /22 in order to transfer it immediately using the transfer policy. I know this policy proposal is not perfect, as the LIR that receives the /22 can sub-allocate/assign the IP block for two years before transferring it (*). There is also the loophole where, if their only intention is to make a profit from (ab)using the policy, they can try to merge the newly created LIR into an existing one using the M&A process/procedure. This last point is where I want to receive some further comments/suggestions before deciding how to move forward.
rgds, Sascha Luck
(*) I would argue that the assignment or sub-allocation of the address space to an other company is a legitimate usage of the allocation. regards, elvis -- <http://v4escrow.net> Elvis Daniel Velea Chief Executive Officer Email: elvis@V4Escrow.net <mailto:elvis@v4escrow.net> US Phone: +1 (702) 475 5914 EU Phone: +31 (0) 61458 1914 Recognised IPv4 Broker/Facilitator in: This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received this email in error, please notify the sender immediately and delete the original.Any other use of this email is strictly prohibited.
On Fri, Feb 20, 2015 at 03:32:48PM +0100, Elvis Daniel Velea wrote:
I know this policy proposal is not perfect, as the LIR that receives the /22 can sub-allocate/assign the IP block for two years before transferring it (*). There is also the loophole where, if their only intention is to make a profit from (ab)using the policy, they can try to merge the newly created LIR into an existing one using the M&A process/procedure. This last point is where I want to receive some further comments/suggestions before deciding how to move forward.
That wouldn't be speculation though, just gaming the policy in order to get more than a /22. A startup company getting bought out within 2 years of receiving an allocation is also not unthinkable and I think provision should be made for that - provision that doesn't mean "return the space", of course... rgds, Sascha Luck
On Fri, Feb 20, 2015, at 15:32, Elvis Daniel Velea wrote:
This policy proposal tries to close the loophole where companies only request the /22 in order to transfer it immediately using the transfer policy.
If this is random/occasional behavior, this policy may be able to stop or reduce it. If this is regular (or even common) behavior, the policy may not help very much (just push prices up a little).
intention is to make a profit from (ab)using the policy, they can try to merge the newly created LIR into an existing one using the M&A process/procedure. This last point is where I want to receive some further comments/suggestions before deciding how to move forward.
Just pay attention not to have a very bad impact on real M&A. Some of them may not fit the "classic" view of a merger/acquisition.
On 20 Feb 2015, at 11:21, Martin Millnert <millnert@gmail.com> wrote:
This proposal serves the purpose of shutting off access to 'cheap' IPv4 for new businesses, definitely forcing them to turn to the IPv4 resellers who in turn can protect their prices.
It does not. Nobody's "definitely forced" to do anything. A new entrant who wants lots of IPv4 is going to have problems. [Not least of which will be acquiring enough clue to understand how to design and operate a network in the 21st century or later.] Maybe they'll buy that space from a reseller. Maybe they don't. Maybe they find reseller prices or T&Cs to be unacceptable and walk away, maybe they won't. Maybe they adopt IPv6. Maybe they don't. Maybe they do Stupid Things (tm) with NAT or ALG. Maybe they don't. Maybe they acquire an LIR or legacy holder who has a spare /8 stuffed down the back of the sofa, maybe they don't. They'll have lots of options to choose from and they are free to pick from whatever combination of these best meets their needs or business case at that point. Prevailing RIR policy would be just one probably small aspect of those deliberations.
It also obviously extends the life of the /8 for the very limited and specific Internet business use cases approved by the community.
That's what consensus based bottom-up policy making is all about. Get over it. You seem to be generating a lot of unhelpful noise. Could you please try to focus on providing counterproposals which are technically sound and deal with clearly identifiable problems or gaps in the current proposal? Thanks.
For all other use cases, assistance to entry by the RIPE NCC is banned.
Nope. Nobody is banning anything. The NCC is implementing policies which have consensus from the community and are broadly fair and reasonable. For some definition of those terms. Anyone who does not like those policies has access to an open and transparent mechanism for changing them. If their ideas have merit or the community can be persuaded that the new proposals are better (for some definition of "better"), they will get support. Over to you..
Jim, On Fri, 2015-02-20 at 11:58 +0000, Jim Reid wrote:
Could you please try to focus on providing counterproposals which are technically sound and deal with clearly identifiable problems or gaps in the current proposal? Thanks.
Yes, although a counterproposal should probably go in its own thread / actual PDP submission.
A new entrant who wants lots of IPv4 is going to have problems. [Not least of which will be acquiring enough clue to understand how to design and operate a network in the 21st century or later.] Maybe they'll buy that space from a reseller. Maybe they don't. Maybe they find reseller prices or T&Cs to be unacceptable and walk away, maybe they won't. Maybe they adopt IPv6. Maybe they don't. Maybe they do Stupid Things (tm) with NAT or ALG. Maybe they don't. Maybe they acquire an LIR or legacy holder who has a spare /8 stuffed down the back of the sofa, maybe they don't.
Completely agree with this. It's messy. Messy is bad. This is a clearly identified problem. Agreed? When it comes to what to do, I believe the markets need clear and very transparent rules to reduce friction, but restrain abuse. This is the mainly important policy aspect of future IPv4 management. I'll go study the policies from this aspect - I have nothing to add currently.
They'll have lots of options to choose from and they are free to pick from whatever combination of these best meets their needs or business case at that point. Prevailing RIR policy would be just one probably small aspect of those deliberations.
Indeed that is the full reality today, that RIR's role as a IPv4 supplier has vastly diminished.
For all other use cases, assistance to entry by the RIPE NCC is banned.
Nope. Nobody is banning anything.
The NCC is implementing policies which have consensus from the community and are broadly fair and reasonable. For some definition of those terms. Anyone who does not like those policies has access to an open and transparent mechanism for changing them. If their ideas have merit or the community can be persuaded that the new proposals are better (for some definition of "better"), they will get support.
Semantics, and also not completely true. The NCC has lately increasingly been implementing policies without any deliberation at all in the community. But that's another topic. I will agree with you that it was the way things originally worked in the RIPE region, before, when there was v4 space available. :] The relevant point here is that the policies implemented have consequences, and the community is responsible for these consequences. Legally, I guess it's the NCC. /M
Hi Sascha, On 20/02/15 11:37, Sascha Luck [ml] wrote:
On Fri, Feb 20, 2015 at 11:05:53AM +0100, Sander Steffann wrote:
Limiting entry to 1024 addresses is anti-competitive.
And intentionally running out and limiting entry to 0 addresses is ... ?
Well, you can't sue a shop for having run out of milk to sell...
I do see the point of running out quickly - stretching the ipv4 supply out as long as possible does damn us to this speculation nonsense for decades to come. The question is whether running out quickly will force ipv6 to happen and thus make ipv4 essentially useless as a speculation object. The way I see it, there are conflicting goals here - protect the investment of the big ipv4 players or cause enough pain to force the switch to ipv6 in my lifetime. If it should be the job of the RIRs to promote either goal (and I'm not sure it is) the latter one would be the better outcome for the Internet in the long term. The limitation to only one /22 (from the last /8) per LIR has been approved by this community years ago. Reverting this policy proposal is a discussion that I would like to see in a separate thread and not part of the discussion of this policy proposal.
As for the proposal, I'm "neutral tending towards opposition" pending further argument.
Can you explain why you tend to oppose so I could try to address your concerns?
rgds, Sascha Luck
thanks, elvis -- <http://v4escrow.net> Elvis Daniel Velea Chief Executive Officer Email: elvis@V4Escrow.net <mailto:elvis@v4escrow.net> US Phone: +1 (702) 475 5914 EU Phone: +31 (0) 61458 1914 Recognised IPv4 Broker/Facilitator in: This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received this email in error, please notify the sender immediately and delete the original.Any other use of this email is strictly prohibited.
On Fri, Feb 20, 2015 at 03:19:04PM +0100, Elvis Daniel Velea wrote:
The limitation to only one /22 (from the last /8) per LIR has been approved by this community years ago. Reverting this policy proposal is a discussion that I would like to see in a separate thread and not part of the discussion of this policy proposal.
I didn't argue for a reversal of "last /8", merely against fixing every "loop-hole" in order to make the ipv4 misery run even longer. Although, if it is true that NCC has more free space now than it had when "last /8" came in, this loop-hole seems more of an academic concern anyway.
Can you explain why you tend to oppose so I could try to address your concerns?
I'd like to see ipv6 deployment get some (more) traction while I'm still alive tbh. And I think that leaving the speculators to it might accelerate that a lot more than giving out golden stars for ipv6 deployment or requiring ipv6 allocations (but not their use) for "last /8" ipv4 allocations. rgds, Sascha Luck
On Fri, Feb 20, 2015, at 21:10, Sascha Luck [ml] wrote:
On Fri, Feb 20, 2015 at 03:19:04PM +0100, Elvis Daniel Velea wrote:
The limitation to only one /22 (from the last /8) per LIR has been approved by this community years ago. Reverting this policy proposal is a discussion that I would like to see in a separate thread and not part of the discussion of this policy proposal.
I didn't argue for a reversal of "last /8", merely against fixing every "loop-hole" in order to make the ipv4 misery run even longer.
If we are to "terminate the misery sooner rather than later", while ensuring the fairness, how about allowing for a second /22 under conditions such as: - 2/3/5 years after the first allocation from 185/8 - only for LIRs started after a certain date (??? 09/2012 ???) Does anyone think this makes any sense ? Just as a reminder, no matter how much we push IPv6, as of today (22/02/2015) you need IPv4 if: - you want MPLS in your network (in real-life, MPLS signalling is still v4-only) - want to sell to business customers (which barely give a s*** on v6).
I'd like to see ipv6 deployment get some (more) traction while I'm still alive tbh. And I think that leaving the speculators to it might accelerate that a lot more than giving out golden stars
Nope. You (we) need to be more inventive than that.
Having read the emails in this discussion I think that we are moving away from the policy at hand ... This policy is not about reverting the final /8 policy ... The discussion is amusing to read and I like ( mind I say .. Love ? ! ) to read what the different opinions are in the community about moving faster or reverting at all.. The policy is about closing a gap in the current procedure .. which we all see is being abused against the original intent of the stated policy ... The reasoning for reservation of the /22's in the final /8 is for new LIR's and current LIR's, to be able to get into the market and do v4 to v6 CGNAT or something alike .. or at least get some kind of startup going on some IP space ... That was the original intent .. Currently what I see ( And with that, I'm sure that Elvis agrees with me.. ) as a broker you see people offering that /22 to the market in order to make a quick buck. I don't mind .. An IPv4 resource is an IPv4 resource .. a transaction is a transaction .... however this is against the original intent of the policy ... We have a 24 month waiting period for IPv4 space after being transferred, to avoid 'stock piling' or to speculation .. What was not foreseen at that time, is that new allocations should also fall under that same 24 month waiting period ... This policy is to close the flipping of the /22´s to the market .. Even setting up new LIR's and flipping the /22's and closing the LIR's again ... By having the /22's fall under the same 24 month waiting period, it will make it more expensive for $parties to flip those resources ... Yes you will still make money, but they have to hold the investment for 24 months at least .. The profit they can/will make is gone for 2 years .. Now that might not stop all speculation, but it will stop the majority of the people with the idea of how to get rich quick, or at least make a quick buck .. I think that we should get this policy change in place and not because it will drive more people to the actual broker market ... Because the real IP brokers with actual inventory, can really do without these small prefixes in the sales sheets for inventory .. The idea to close this, is because that flipping of the /22's of the final /8 goes against the intent of the initial policy. Having said that, it is a Support +1 from me on this. Regards, Erik Bais
Hello all, I also support the proposal. Although it won't stop speculation, it will at least discourage it. I'd also support an even longer waiting period. I don't believe anyone who seriously starts a business will have a problem with such "limitation". Of course we'll have to consider the issue that Elvis mentioned earlier, about M&A Regards George On Fri, Feb 20, 2015 at 12:45 PM, Erik Bais <ebais@a2b-internet.com> wrote:
Having read the emails in this discussion I think that we are moving away from the policy at hand ...
This policy is not about reverting the final /8 policy ...
The discussion is amusing to read and I like ( mind I say .. Love ? ! ) to read what the different opinions are in the community about moving faster or reverting at all.. The policy is about closing a gap in the current procedure .. which we all see is being abused against the original intent of the stated policy ...
The reasoning for reservation of the /22's in the final /8 is for new LIR's and current LIR's, to be able to get into the market and do v4 to v6 CGNAT or something alike .. or at least get some kind of startup going on some IP space ... That was the original intent ..
Currently what I see ( And with that, I'm sure that Elvis agrees with me.. ) as a broker you see people offering that /22 to the market in order to make a quick buck. I don't mind .. An IPv4 resource is an IPv4 resource .. a transaction is a transaction .... however this is against the original intent of the policy ...
We have a 24 month waiting period for IPv4 space after being transferred, to avoid 'stock piling' or to speculation .. What was not foreseen at that time, is that new allocations should also fall under that same 24 month waiting period ...
This policy is to close the flipping of the /22´s to the market .. Even setting up new LIR's and flipping the /22's and closing the LIR's again ... By having the /22's fall under the same 24 month waiting period, it will make it more expensive for $parties to flip those resources ... Yes you will still make money, but they have to hold the investment for 24 months at least .. The profit they can/will make is gone for 2 years .. Now that might not stop all speculation, but it will stop the majority of the people with the idea of how to get rich quick, or at least make a quick buck ..
I think that we should get this policy change in place and not because it will drive more people to the actual broker market ... Because the real IP brokers with actual inventory, can really do without these small prefixes in the sales sheets for inventory ..
The idea to close this, is because that flipping of the /22's of the final /8 goes against the intent of the initial policy.
Having said that, it is a Support +1 from me on this.
Regards, Erik Bais
+1 support. I would even agree with a 5-year restriction instead of 2. Regards, Carlos On Fri, 20 Feb 2015, Erik Bais wrote:
Having read the emails in this discussion I think that we are moving away from the policy at hand ...
This policy is not about reverting the final /8 policy ...
The discussion is amusing to read and I like ( mind I say .. Love ? ! ) to read what the different opinions are in the community about moving faster or reverting at all.. The policy is about closing a gap in the current procedure .. which we all see is being abused against the original intent of the stated policy ...
The reasoning for reservation of the /22's in the final /8 is for new LIR's and current LIR's, to be able to get into the market and do v4 to v6 CGNAT or something alike .. or at least get some kind of startup going on some IP space ... That was the original intent ..
Currently what I see ( And with that, I'm sure that Elvis agrees with me.. ) as a broker you see people offering that /22 to the market in order to make a quick buck. I don't mind .. An IPv4 resource is an IPv4 resource .. a transaction is a transaction .... however this is against the original intent of the policy ...
We have a 24 month waiting period for IPv4 space after being transferred, to avoid 'stock piling' or to speculation .. What was not foreseen at that time, is that new allocations should also fall under that same 24 month waiting period ...
This policy is to close the flipping of the /22´s to the market .. Even setting up new LIR's and flipping the /22's and closing the LIR's again ... By having the /22's fall under the same 24 month waiting period, it will make it more expensive for $parties to flip those resources ... Yes you will still make money, but they have to hold the investment for 24 months at least .. The profit they can/will make is gone for 2 years .. Now that might not stop all speculation, but it will stop the majority of the people with the idea of how to get rich quick, or at least make a quick buck ..
I think that we should get this policy change in place and not because it will drive more people to the actual broker market ... Because the real IP brokers with actual inventory, can really do without these small prefixes in the sales sheets for inventory ..
The idea to close this, is because that flipping of the /22's of the final /8 goes against the intent of the initial policy.
Having said that, it is a Support +1 from me on this.
Regards, Erik Bais
On Fri, 2015-02-20 at 11:45 +0100, Erik Bais wrote:
The reasoning for reservation of the /22's in the final /8 is for new LIR's and current LIR's, to be able to get into the market and do v4 to v6 CGNAT or something alike .. or at least get some kind of startup going on some IP space ... That was the original intent ..
So the RIPE community still agree to allowing these use cases? - CGNAT to v4: Limited to 335 555 customers. Math: /28 for infrastructure (good luck...), then using http://www.ietf.org/proceedings/87/slides/slides-87-behave-6.pdf slide 7: S * a * N f(P,S,a,N,R)::= P == ------------ (65536-R) Translated to our case: f(1008,S,25%,400,32767) => S == 335 555. So apart from only being able to compete with other ISPs on CGNAT services, they'll be strictly limited in scope to basically serve one smaller city. Thus, the current policy basically excludes new entrants on the market, employing full CGNAT, to grow to 335 555 customers. - Cloud service provider: Limited to a maximum of 1008 customers. Assuming same minimalistic infrastructure of 1x /28 for infrastructure, a CSP is limited to a maximum of 1008 customers. And that is in the best case that each customer only has one service instance, where each service instance uses 1x IPv4. Thus, the current policy basically excludes new entrants from competition with established cloud service providers. <snip>
The idea to close this, is because that flipping of the /22's of the final /8 goes against the intent of the initial policy.
Is the intent of the original policy is to exclude new entrants from competing with established service providers? Or is this exclusion from entering the market just a side-effect of making the pool last longer by rationing address space out per legal entity? /M
On 20.02.2015 12:49, Martin Millnert wrote:
Is the intent of the original policy is to exclude new entrants from competing with established service providers?
I would formulate it like "it is a not so bad side-effect that the current big players don't need to fear new players" ... otherwise it is not understandable, why some big players are sitting on their not (and sometimes never before) used IPv4-Space instead of returning it. As already mentioned in GM in Warsaw, a pretty easy way to relax the IPv4-Situation in RIPE-Region would be to change the charging-scheme to pay per IP ... but that's out of scope of apwg ... so let's stay with "It is only an unintended side-effect." BR -- Jens Ott Opteamax GmbH Simrockstr. 4b 53619 Rheinbreitbach Tel.: +49 2224 969500 Fax: +49 2224 97691059 Email: jo@opteamax.de HRB: 23144, Amtsgericht Montabaur Umsatzsteuer-ID.: DE264133989
On 20 Feb 2015, at 09:45, Martin Millnert <millnert@gmail.com> wrote:
Limiting entry to 1024 addresses is anti-competitive. Short enough for you?
Evidence please. Anecdote is not evidence. Is that short enough for you? :-)
On Fri, 2015-02-20 at 10:06 +0000, Jim Reid wrote:
On 20 Feb 2015, at 09:45, Martin Millnert <millnert@gmail.com> wrote:
Limiting entry to 1024 addresses is anti-competitive. Short enough for you?
Evidence please. Anecdote is not evidence.
Evidence? It is completely a no-brainer to reproduce: Try starting a cloud service provider. I am, so example from reality. Current policy gives you three choices: 1) Follow the intent of the current policy and don't enter the market to compete with existing providers. The reason is that funding won't happen if the ceiling of the service is ~1000 customer service instances. 2) Turn away from RIPE NCC to the reseller market to satisfy IPv4 address needs. 3) Use policy loopholes and get 'cheap' address space from the final /8 pool. See math of https://www.ripe.net/ripe/mail/archives/address-policy-wg/2015-February/0095... if you don't think my reality is evidence enough. I'd like the community reconcile with the reality of the policies, and see that the current policy, and certainly this proposal, is anti-competitive. The only way out is option 2. This proposal increases the importance and reliance of option 2. Is this what the community really wants? /M
hi Martin, I will try to answer some of the points you have raised in the e-mails sent to this list in the past couple of days. On 19/02/15 19:26, Martin Millnert wrote:
I also oppose this proposal.
I believe the best thing that can happen is for IPv4 to run out completely, as fast as possible. [...] I'm generally in favour of any proposal that hastens the run-out of the final /8. This community has decided to allow any new member to request and receive a /22. It is quite clear that the RIPE community has chosen a different approach than the one you are in favor of (and which is, if I am not mistaken) the chosen path of the ARIN community.
Increasing the RIPE NCC IPv4 price is counter-productive to that goal. This policy proposal does not intend to increase the IPv4 price. It only wants to close a loophole where someone could just open an LIR only for
When the last /8 policy kicked in, the RIPE NCC had a /8 in its free pool. Since September 2012 the RIPE NCC has made more than 5500 /22 allocations and the free pool is now even bigger (1.09 /8) than when the policy got in effect. [1] shows that there are still 18.36 million IP addresses in the free pool. This means that new entrants will have a method to at least receive a /22 from the RIPE NCC for the foreseeable future. When the last /22 policy was discussed and approved, the members of this community knew that even if all the existing members would get the last /22, there would still be enough addresses to support 6-8k new entrants (considering that at that time there were 9-10k members). Looking at the free pool now, I see there is enough space for even more than 10k new entrants. the reason to request and sell the /22 allocation immediately. I will not try to comment on your conspiracy theories about the 'Internet world order' and how the community is trying to buy RIPE NCC time to adjust to this 'world order'. I will also not comment on your idea of 'anti-competitive' limitations. I think you should have had this discussion when the 'last /22 from the last /8' policy proposal was discussed. I will also not comment on your ideas that the RIPE NCC implements 'policies without any deliberation at all in the community'. Firstly, because I know it's not true as all policy changes have been going through this PDP process. Secondly, because I think it's the RIPE NCC and the WG chairs who should respond to this 'accusation'. Thirdly, because this has nothing to do with this policy proposal. Finally, If you think that the last /8 policy is bad and that the RIPE NCC should implement a policy where all the free pool is depleted as soon as possible, feel free to come up with a new policy proposal. [1] https://www.ripe.net/internet-coordination/ipv4-exhaustion/ipv4-available-po... regards, elvis -- <http://v4escrow.net> Elvis Daniel Velea Chief Executive Officer Email: elvis@V4Escrow.net <mailto:elvis@v4escrow.net> US Phone: +1 (702) 475 5914 EU Phone: +31 (0) 61458 1914 Recognised IPv4 Broker/Facilitator in: This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received this email in error, please notify the sender immediately and delete the original.Any other use of this email is strictly prohibited.
Hi Elvis! On Fri, 2015-02-20 at 15:10 +0100, Elvis Daniel Velea wrote:
hi Martin,
I will try to answer some of the points you have raised in the e-mails sent to this list in the past couple of days.
Thank you. <snip>
This means that new entrants will have a method to at least receive a /22 from the RIPE NCC for the foreseeable future.
At the current burn-rate, 8 years.
When the last /22 policy was discussed and approved, the members of this community [...] I see there is enough space for even more than 10k new entrants.
I have no argument against that this is what the community has decided.
Increasing the RIPE NCC IPv4 price is counter-productive to that goal. This policy proposal does not intend to increase the IPv4 price. It only wants to close a loophole where someone could just open an LIR only for the reason to request and sell the /22 allocation immediately.
Nod. On your website, http://v4escrow.net/policy-development/ , I learned that your organisation was asked by some in the room to produce this (and other?) policy proposals, referring to slide 10 of https://ripe69.ripe.net/presentations/72-APWG_RS_Feedback_Final.pdf . I wasn't there, but on your website you're talking about that there is "speculation" going on with this address space and that it is the speculation that you want to stop with this policy proposal. Could you elaborate or provide evidence for that? The slide referenced doesn't support the claim. Buying and selling address space isn't at all necessarily "speculation". It's just reselling, right? Just like your business. (I also learned on your website that your organisation is involved with making policies -- transfer policies I assume -- better. I approve of that work!)
I will not try to comment on your conspiracy theories about the 'Internet world order' and how the community is trying to buy RIPE NCC time to adjust to this 'world order'.
It is not a conspiracy - it is a fact that you are even living proof of, by the business that you now have, that it is insufficient for the Registry to be handing out IP space from its available free pools, now after the point of depletion.
I will also not comment on your idea of 'anti-competitive' limitations. I think you should have had this discussion when the 'last /22 from the last /8' policy proposal was discussed.
I will also not comment on your ideas that the RIPE NCC implements 'policies without any deliberation at all in the community'. Firstly, because I know it's not true as all policy changes have been going through this PDP process. Secondly, because I think it's the RIPE NCC and the WG chairs who should respond to this 'accusation'.
It's an observation of the fact that there are a couple of quite significant internet architecture pieces put into production by RIPE NCC, that are not to be found at https://www.ripe.net/ripe/policies/proposals whatsoever. (And there's been no consensus elsewhere.) It is no accusation of any sort. I fully accept that this is how the internet is governed today.
Thirdly, because this has nothing to do with this policy proposal.
A good reason to leave it out of the discussion indeed.
Finally, If you think that the last /8 policy is bad and that the RIPE NCC should implement a policy where all the free pool is depleted as soon as possible, feel free to come up with a new policy proposal.
I'll retreat and think a bit about it. :) /M
Hi Elvis!
On Fri, 2015-02-20 at 15:10 +0100, Elvis Daniel Velea wrote:
hi Martin,
I will try to answer some of the points you have raised in the e-mails sent to this list in the past couple of days. Thank you.
<snip>
This means that new entrants will have a method to at least receive a /22 from the RIPE NCC for the foreseeable future. At the current burn-rate, 8 years. Want to bet it's going to be more than 10? I would even dare to say 15 at a normal pace. But only if this policy proposal does not get approved and the type of speculation this policy proposal tries to prevent doesn't speed up even more than it has in the few months since RIPE69.
When the last /22 policy was discussed and approved, the members of this community [...] I see there is enough space for even more than 10k new entrants. I have no argument against that this is what the community has decided. But you would like to change it... Please do start a separate topic if you feel like you would maybe want to come up with a proposal in that
hi Martin, maybe I should have started my first e-mail to this proposal with the links of the recordings at RIPE69 in London where we have discussed the creation of this policy proposal: https://ripe69.ripe.net/archives/video/200/ https://ripe69.ripe.net/archives/video/10147/ On 20/02/15 18:26, Martin Millnert wrote: direction.
Increasing the RIPE NCC IPv4 price is counter-productive to that goal. This policy proposal does not intend to increase the IPv4 price. It only wants to close a loophole where someone could just open an LIR only for the reason to request and sell the /22 allocation immediately. Nod. On your website, http://v4escrow.net/policy-development/ , I learned that your organisation was asked by some in the room to produce this (and other?) policy proposals, referring to slide 10 of https://ripe69.ripe.net/presentations/72-APWG_RS_Feedback_Final.pdf .
Well, as mentioned above, the video is also available, you could have found it easily if you wanted to (it is in the presentation archives of the RIPE Meeting). https://ripe69.ripe.net/archives/video/200/ You can see Andrea's presentation there, the interesting part starts at 7:50, the discussion of this topic starts at: 18:00 and lasts until the end. Further discussion where I have been asked to 'volunteer and 'be the target for the tomatoes': https://ripe69.ripe.net/archives/video/10147/ (30 more minutes :)
I wasn't there, but on your website you're talking about that there is "speculation" going on with this address space and that it is the speculation that you want to stop with this policy proposal. That is actually what I also mentioned in the policy proposal. Could you elaborate or provide evidence for that? The slide referenced doesn't support the claim. If you want to ask for the evidence for the 70 cases the RIPE NCC has observed, well you could ask Andrea.
Buying and selling address space isn't at all necessarily "speculation". It's just reselling, right? Just like your business. I would not compare them, but I'll take this bullet for the sake of the
some things that I have noticed, and this is public data: 1. see the example of registries ru.ibulavkin* on one side. I think they have opened about 27 registries in a few months. They have 6 opened at this moment and I believe #23 and #25 will be closed to make room for more harvesting. ftp://ftp.ripe.net/ripe/stats/membership/alloclist.txt I think all of their /22s are merged into ru.srv2013 (as they have 24 of those /22s) which is on the same name. I could also bet that the 4 /22s they have in registries #22, #24, #26 and #27 will be merged into the big one and I am not sure that we could ever prevent that. I kinda see it as a legitimate way to getting addresses if they really use them and not stockpile. However... 2.have a look at the transfer list and filter for QuickSoft LLC. https://www.ripe.net/lir-services/resource-management/ipv4-transfers/table-o... How can _one_ company transfer (up until now) 12 /22s from the last /8 and 3 of them only in February 2015. 3. If you further verify the list of transfers and the delegated-extended files, filter for /22s from 185/8 you will even find allocations that have been made by the RIPE NCC and transferred within a week from the allocation date. proposal... (Gert, you said tomatoes, not bullets directed to my business :)... heh, should have expected it.
(I also learned on your website that your organisation is involved with making policies -- transfer policies I assume -- better. I approve of that work!)
Well, not only. I/we also volunteered (along with a few other co-authors) to unify the IPv6 policies into one simple document (as also requested by the community at a few RIPE Meetings). However, that policy proposal was withdrawn after RIPE67 because the changes it proposed were too complex. https://ripe67.ripe.net/archives/video/36/ [...]
Finally, If you think that the last /8 policy is bad and that the RIPE NCC should implement a policy where all the free pool is depleted as soon as possible, feel free to come up with a new policy proposal. I'll retreat and think a bit about it. :)
I would also welcome a constructive approach to this proposal :)
/M
regards, elvis -- <http://v4escrow.net> Elvis Daniel Velea Chief Executive Officer Email: elvis@V4Escrow.net <mailto:elvis@v4escrow.net> US Phone: +1 (702) 475 5914 EU Phone: +31 (0) 61458 1914 Recognised IPv4 Broker/Facilitator in: This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received this email in error, please notify the sender immediately and delete the original.Any other use of this email is strictly prohibited.
On 20/02/15 20:43, Elvis Daniel Velea wrote:
hi Martin,
[...]
At the current burn-rate, 8 years. Want to bet it's going to be more than 10? I would even dare to say 15 at a normal pace. But only if this policy proposal does not get approved and the type of speculation this policy proposal tries to prevent doesn't speed up even more than it has in the few months since RIPE69. here I meant "only if this policy proposal does get approved"
/elvis
On Fri, Feb 20, 2015 at 08:43:33PM +0100, Elvis Daniel Velea wrote:
At the current burn-rate, 8 years. Want to bet it's going to be more than 10? I would even dare to say 15 at a normal pace. But only if this policy proposal does not get approved and the type of speculation this policy proposal tries to prevent doesn't speed up even more than it has in the few months since RIPE69.
Another 15 years of this would be a pretty damn bleak prospect if you ask me. For the good of the Internet, let ipv4 run (really) out as quickly as possible. rgds, Sascha Luck
Hi, The reason there is such a market for legacy IP space, and the reason new market entrants[1] stockpile space like the good old big players do, is that somehow legacy IP space is considered worthy. Why? Because it is running short. The less we have to give away, the higher the price will be. There will be much more and much higher valued transfers in the future, up to the point where the price is so ridiculously high that shiny not-so-new IPv6 becomes a real business case. I want that point to be as soon as possible and get the sh*t done and over with. Until then, in my opinion, we as a community are making things worse! As Martin said, you can not get serious funding without having a serious growth plan. This includes legacy IP space. A startup is *forced* to play tricks on the policies or to make use of an escrow service or just call the trusted dealer at the east end of the RIPE region. The current loophole is the way we as a community, but also startups in deep need of legacy IP space, can save faces If we start adding a “more realistic” price tag to legacy IP space, we can redo this every few months, and even in shorter intervals as the market heats up. Let the market figure it out and please, please let us not make a resource that is already short even shorter! Get the stuff out, it may even decrease legacy IP space price tags for a while?[2] I am always in favor of policies and policy loopholes that lead to a sooner depletion of legacy IP space, so I would very much like this loophole not to be closed. I oppose this proposal. I would also argue for larger allocations if that becomes a new proposal. Martin? CHeers Dan PS: Sorry for the tomatoes in this thread, Elvis, I don’t think you deserved them. [1] There is so much allocated, unused space stockpiled by the big players. And we want to help market entrants by giving them time instead of space? This is not how the business works. It is all about speed and innovation, not about the ability to enter the market in 5 years from now and find the same market rules as today. [2] I have no evidence for that, this is just speculation. Maybe Elvis can share some data as he probably has a better view on that market?
Hello everybody, Dan has pointed something that is bothering me for sometimes now. BIG-Players who stockpile IPs. If we take a look at advertisements for selling address spaces, time to time we can see /8 or bigger spaces are there, announced to find customers. Now my problem is that, all of previous allocated address spaces ( in RIPE NCC region ) should have been justified, at least by their network-plan in their requests. Now if some organizations are selling their IP address spaces, it means they don't need them. Even worse, they may have been lying in the first place. Now, isn't it possible, that RIPE NCC develops a policy ( maybe there one ) to take back these advertised address spaces ? because their initial criteria is not valid any more ? ( obviously those organization, do not need these address spaces. ) I can understand LEASING some IPs for some period of time, but I can't understand selling them. Kind Regards, Saeed. -----Original Message----- From: Dan Lüdtke Sent: Saturday, February 21, 2015 3:25 PM To: address-policy-wg@ripe.net Subject: Re: [address-policy-wg] 2015-01 New Policy Proposal (Alignment ofTransfer Requirements for IPv4 Allocations) Hi, The reason there is such a market for legacy IP space, and the reason new market entrants[1] stockpile space like the good old big players do, is that somehow legacy IP space is considered worthy. Why? Because it is running short. The less we have to give away, the higher the price will be. There will be much more and much higher valued transfers in the future, up to the point where the price is so ridiculously high that shiny not-so-new IPv6 becomes a real business case. I want that point to be as soon as possible and get the sh*t done and over with. Until then, in my opinion, we as a community are making things worse! As Martin said, you can not get serious funding without having a serious growth plan. This includes legacy IP space. A startup is *forced* to play tricks on the policies or to make use of an escrow service or just call the trusted dealer at the east end of the RIPE region. The current loophole is the way we as a community, but also startups in deep need of legacy IP space, can save faces If we start adding a “more realistic” price tag to legacy IP space, we can redo this every few months, and even in shorter intervals as the market heats up. Let the market figure it out and please, please let us not make a resource that is already short even shorter! Get the stuff out, it may even decrease legacy IP space price tags for a while?[2] I am always in favor of policies and policy loopholes that lead to a sooner depletion of legacy IP space, so I would very much like this loophole not to be closed. I oppose this proposal. I would also argue for larger allocations if that becomes a new proposal. Martin? CHeers Dan PS: Sorry for the tomatoes in this thread, Elvis, I don’t think you deserved them. [1] There is so much allocated, unused space stockpiled by the big players. And we want to help market entrants by giving them time instead of space? This is not how the business works. It is all about speed and innovation, not about the ability to enter the market in 5 years from now and find the same market rules as today. [2] I have no evidence for that, this is just speculation. Maybe Elvis can share some data as he probably has a better view on that market?
Hello Saeed,
Now, isn't it possible, that RIPE NCC develops a policy ( maybe there one ) to take back these advertised address spaces ? because their initial criteria is not valid any more ? ( obviously those organization, do not need these address spaces. )
I can understand LEASING some IPs for some period of time, but I can't understand selling them.
We (this working group) had that discussion in 2007 when policy proposal 2007-08 was introduced. At the time it was decided that reallocation (transfers) were a better / more viable solution than trying to reclaim unused addresses. Please take a look at the mailing list archives to see how the discussion went. It was a quite long discussion. Proposal 2007-08: https://www.ripe.net/ripe/policies/proposals/2007-08 Mailing list archive: https://www.ripe.net/search?SearchableText=2007-08&portal_type%3Alist=Message Cheers, Sander
Hello, Thank you Sander for the info. I looked into it. Indeed it was a long discussion. Only one point: As you can see, at the time of suggestion of that proposal, there were NO opposing arguments ( according to available data at that time. ) Now there are new data, specially some experiments with re-allocation of address spaces through selling/buying them. Is it possible to re-activate, or re-consider previously approved policies? Because of this policy for re-allocating address spaces through selling/buying, now we see a very HOT bazar and many are making money with it, while none of us ( I mean LIRs ) have paid for any particular address spaces to RIPE NCC. This is easily driving people to lie ( make a new LIR, get some IPs, sell it .... and again and again ) Kind Regards, Saeed. -----Original Message----- From: Sander Steffann Sent: Saturday, February 21, 2015 4:35 PM To: Saeed Khademi Cc: address-policy-wg@ripe.net Working Group Subject: *FIREWALL-SPAM ALERT* Re: [address-policy-wg] 2015-01 New Policy Proposal (Alignment ofTransfer Requirements for IPv4 Allocations) Hello Saeed,
Now, isn't it possible, that RIPE NCC develops a policy ( maybe there one ) to take back these advertised address spaces ? because their initial criteria is not valid any more ? ( obviously those organization, do not need these address spaces. )
I can understand LEASING some IPs for some period of time, but I can't understand selling them.
We (this working group) had that discussion in 2007 when policy proposal 2007-08 was introduced. At the time it was decided that reallocation (transfers) were a better / more viable solution than trying to reclaim unused addresses. Please take a look at the mailing list archives to see how the discussion went. It was a quite long discussion. Proposal 2007-08: https://www.ripe.net/ripe/policies/proposals/2007-08 Mailing list archive: https://www.ripe.net/search?SearchableText=2007-08&portal_type%3Alist=Message Cheers, Sander
Hi Saeed,
Thank you Sander for the info. I looked into it. Indeed it was a long discussion.
Only one point: As you can see, at the time of suggestion of that proposal, there were NO opposing arguments ( according to available data at that time. )
There were. There were people who reasoned that if someone could transfer addresses they could also just give them back. On the other hand freeing up a contiguous block of addresses will probably take effort (renumbering) so allowing people to sell them would create an incentive to do that and make those addresses usable by someone else. At the time reclaiming addresses want seen as a viable solution. If that isn't possible then allowing transfers was seen as the next option so that at least unused addresses would be freed up and transferred/sold to someone who would actually use them.
Now there are new data, specially some experiments with re-allocation of address spaces through selling/buying them.
That was foreseen and intended :)
Is it possible to re-activate, or re-consider previously approved policies?
Of course. Policies are never static. The whole purpose of this working group is to improve policies and align them with today's requirements.
Because of this policy for re-allocating address spaces through selling/buying, now we see a very HOT bazar and many are making money with it, while none of us ( I mean LIRs ) have paid for any particular address spaces to RIPE NCC. This is easily driving people to lie ( make a new LIR, get some IPs, sell it .... and again and again )
A new LIR can only get a /22 from RIPE NCC so while this is indeed possible the impact of that is limited. Whether this opening up new LIRs just to sell the /22 is something that needs to be prevented/discouraged (the policy proposal under discussion) or whether this is a good thing (see Martin Millnert's messages) is for this working group to discuss. Cheers, Sander
"Sander Steffann mentioned you in an e-mail": On Sun, 2015-02-22 at 12:10 +0100, Sander Steffann wrote:
A new LIR can only get a /22 from RIPE NCC so while this is indeed possible the impact of that is limited. Whether this opening up new LIRs just to sell the /22 is something that needs to be prevented/discouraged (the policy proposal under discussion) or whether this is a good thing (see Martin Millnert's messages) is for this working group to discuss.
Yeah, it's not as much "starting lots of LIRs" that I think in itself is valuable (for the community). It's a pretty bad means to an end. The real issue I have is rather - "how much space per LIR", and whether the internet community is best served by the RIPE NCC having an available pool for low-utilization projects/business for some time forward (subject to abuse), or if its best served by depleting fully the free pool sooner rather than later to accelerate the development into the future IP addressing functions. I'm not sure what I think is correct myself - I think we're right now doing the equivalent of slowly tearing a patch off the skin. My presupposition is that we should just let the market fix it because it is much wiser than us. But the infrastructure for that needs to be functionally in place (policies etc), on the other hand, some of the issues may not reveal themselves until the new situation arrives. I do think this merits further discussion. (Hence change of topic). There are many concepts that I think needs to go out the window today. One of them, I believe strongly, is all the bureaucracy of the RIPE NCC to judge "need" for allocations/assignment. The ripe-623 ch 3.0 #3 "Fairness" is also deprecated once RIPE NCC has no more addresses to distribute, which is the case already today! It is not fair that some end users have /8 and others have /22 or /24. The market resolves need. The registry registers. The unnecessary bureaucracy is nothing but a waste of natural resources (energy, time, resources). /M
On Sat, 21 Feb 2015, Saeed Khademi wrote:
Now if some organizations are selling their IP address spaces, it means they don't need them. Even worse, they may have been lying in the first place.
Or they just decide that putting their existing customers behind CGN and selling their IPv4 addresses is a better business decision than keeping their customers on globally unique IPv4 address per customer. The only reason they would be doing this work (and possible customer experience degradation) is that the IPv4 address has value. So if IPv4 address has no value (as per your implication above), then this work will never get done. So your proposal will never work in real life unless you start to change the definion of "justification", for instance to say that we no longer consider giving IPv4 GUA to residential consumers or mobile handsets justifiable, and that all that space must be handed back. I don't see how you will ever get consensus for that policy change though. -- Mikael Abrahamsson email: swmike@swm.pp.se
Or they just decide that putting their existing customers behind CGN and selling their IPv4 addresses is a better business decision than keeping their customers on globally unique IPv4 address per customer.
Every company / organization decide for their own business and there is no question there. Problem is in the way we look at IP address spaces, allocated to different organizations. There are 2 ways to look at it: 1- IP allocations are property of an organization ( so naturally, they can decide what to do with it ) 2- IP allocations are indeed property of IANA. They distributed it through RIRs & LIRs to end-users, free of charge. And end-users are entitle to use these allocations, as long as their initial criteria are valid. And if initial criteria are not valid anymore, RIRs may take back the address space according to their policies. I think you are looking at it according to 1, while I am looking at it according to 2. I am looking at the whole IPV4 address space, as property of whole globe. So organizations holding allocations are not OWNER of IPs. Allocations have been given to them to use for their networks, not to start selling them in stuck markets. If a company decides to put their customers behind CGN and free some part of their allocations / assignments, they should return free address space to RIRs, so they can fulfill other requests. Anyway, as Sander explained, for now selling IP addresses is alright according to existing policy. And there were lots of talks there. I am not suggesting a new proposal, I just had problem understanding the concept of selling IPs, so I asked. ( I'm still against selling IPs ) Kind Regards, Saeed. -----Original Message----- From: Mikael Abrahamsson Sent: Monday, February 23, 2015 12:44 PM To: Saeed Khademi Cc: address-policy-wg@ripe.net Subject: Re: [address-policy-wg] 2015-01 New Policy Proposal (Alignment ofTransfer Requirements for IPv4 Allocations) On Sat, 21 Feb 2015, Saeed Khademi wrote:
Now if some organizations are selling their IP address spaces, it means they don't need them. Even worse, they may have been lying in the first place.
Or they just decide that putting their existing customers behind CGN and selling their IPv4 addresses is a better business decision than keeping their customers on globally unique IPv4 address per customer. The only reason they would be doing this work (and possible customer experience degradation) is that the IPv4 address has value. So if IPv4 address has no value (as per your implication above), then this work will never get done. So your proposal will never work in real life unless you start to change the definion of "justification", for instance to say that we no longer consider giving IPv4 GUA to residential consumers or mobile handsets justifiable, and that all that space must be handed back. I don't see how you will ever get consensus for that policy change though. -- Mikael Abrahamsson email: swmike@swm.pp.se
Hi, On Mon, Feb 23, 2015 at 01:43:41PM +0330, Saeed Khademi wrote:
2- IP allocations are indeed property of IANA. They distributed it through RIRs & LIRs to end-users, free of charge. And end-users are entitle to use these allocations, as long as their initial criteria are valid. And if initial criteria are not valid anymore, RIRs may take back the address space according to their policies.
This is indeed the crucial point here. The RIPE policies do not have provisions for taking back *allocations* if the allocation criteria are no longer valid. So, voluntarily giving them back is always fine, but if a LIR clings to the space (and pays their bills and does not do anything fraudulent), the NCC can not forcibly take back the space. The reasons for this is easy to see - historically, ISPs did not shrink, they just grew, and needed more and more space. Unless they went bankrupt, in which case the space went to whoever bought them, or back to the RIPE NCC. Nowadays, "LIR" is not necessarily "ISP" anymore, and the business has changed as well - like, no longer giving out /24s to customers but single addresses behind CGNs... [..]
Anyway, as Sander explained, for now selling IP addresses is alright according to existing policy. And there were lots of talks there. I am not suggesting a new proposal, I just had problem understanding the concept of selling IPs, so I asked. ( I'm still against selling IPs )
The thing is that we can't really regulate or prevent the "selling" bit as such - not without preventing completely "ok!" business transactions (like, I want to buy another ISP with all their assets, it should be fine to also take over their address space). What we *can* do is to enforce proper *documentation* of transfers, so it is always clear who is the current holder of an address block, who is permitted to announce it into BGP, etc. - and that, I think, is one of the most important roles of a RIR in the post-depletion era. Gert Doering -- APWG chair -- have you enabled IPv6 on something today...? SpaceNet AG Vorstand: Sebastian v. Bomhard Joseph-Dollinger-Bogen 14 Aufsichtsratsvors.: A. Grundner-Culemann D-80807 Muenchen HRB: 136055 (AG Muenchen) Tel: +49 (0)89/32356-444 USt-IdNr.: DE813185279
On Mon, 23 Feb 2015, Saeed Khademi wrote:
If a company decides to put their customers behind CGN and free some part of their allocations / assignments, they should return free address space to RIRs, so they can fulfill other requests.
If this is the case, then the customers will not be put behind CGN because the business case of putting them behind CGN isn't there anymore. The customers are only put behind CGN because iPv4 addresses have value. You're saying they have no value, thus there is no driver to sell them, thus no reason to put customers behind CGN (prematurely). -- Mikael Abrahamsson email: swmike@swm.pp.se
Hello, It is not the value, motivating use of CGNs. It is the depletion of IPV4. When you don't have enough IPs, to serve your customers, you will do any possible technical solutions, like using CGNs. Although I do agree with you that commercial companies are seeing it as you mentioned. Kind Regards, Saeed. -----Original Message----- From: Mikael Abrahamsson Sent: Monday, February 23, 2015 2:21 PM To: Saeed Khademi Cc: address-policy-wg@ripe.net Subject: Re: [address-policy-wg] 2015-01 New Policy Proposal (Alignment ofTransfer Requirements for IPv4 Allocations) On Mon, 23 Feb 2015, Saeed Khademi wrote:
If a company decides to put their customers behind CGN and free some part of their allocations / assignments, they should return free address space to RIRs, so they can fulfill other requests.
If this is the case, then the customers will not be put behind CGN because the business case of putting them behind CGN isn't there anymore. The customers are only put behind CGN because iPv4 addresses have value. You're saying they have no value, thus there is no driver to sell them, thus no reason to put customers behind CGN (prematurely). -- Mikael Abrahamsson email: swmike@swm.pp.se
Hi everyone, I have thinking at what to answer regarding the comments on this proposal. Firstly, the /22 from the last /8 policy proposal aimed to create a method for anyone to receive at least a few (1024) IPv4 addresses by becoming a member of the RIPE NCC. Even then, the proposers had noted that anyone can open multiple LIRs and receive from the RIPE NCC more than 1024 IP addresses and asked the RIPE NCC to be vigilant. [1] What happens now is not in the spirit of that policy proposal as the /22 from the RIPE NCC does not have the two years holding period so a few found a way to make a business using this loophole. This policy proposal is just trying to add the same holding period for a transfer of the /22 as it is already for the rest of the allocations made by the RIPE NCC. While I do agree that if the RIPE NCC free pool would be depleted, the market would takeover and normalize the price, the community has decided to have IPv4 addresses available for anyone that wants to become a member of the RIPE NCC and therefore request & receive a /22. I think that a separate proposal could tackle this issue, there were some discussions last year (if I remember correctly) and some members of this community suggested the increasing the limit from /22 to /21. That may deplete the free pool faster, but it will still slowly bleed out in a few years. If we do not agree that this policy proposal is fair and needed, I predict that we will see more and more companies opening LIRs just to make use of this loophole and make a profit from selling one or more /22s from the last /8. Actually, this policy proposal may have already harmed the free pool because if it does not get approved, more people have found out of the loophole and nothing will stop them from using it, they will have the endorsement of the community to just go ahead and open multiple LIRs. I would not be surprised to see a very large ISP or (content) hosting company setting up 1.000 LIRs to get 1million IP addresses.. and if they setup 1024 LIRs in the same 'day' they may even get a /12 as a contiguous block. In that case, would you find it fair that if someone wants to use a loophole (1024 times) they can get a /12 from the RIPE NCC while others need to use the market? Considering these, Martin (and whoever else does not like this policy proposal), please let me know if you oppose to to this proposal as it is written and if you have any suggestion on what would be acceptable. regards, Elvis [1] https://www.ripe.net/ripe/policies/proposals/2010-02 "Some organisations may set up multiple LIR registrations in an effort to get more address space than proposed. The RIPE NCC must be vigilant regarding these, but the authors accept that it is hard to ensure complete compliance." -- <http://v4escrow.net> Elvis Daniel Velea Chief Executive Officer Email: elvis@V4Escrow.net <mailto:elvis@v4escrow.net> US Phone: +1 (702) 475 5914 EU Phone: +31 (0) 61458 1914 Recognised IPv4 Broker/Facilitator in: This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received this email in error, please notify the sender immediately and delete the original.Any other use of this email is strictly prohibited.
Hi Elvis, I agree with your proposal. I'm interested in the fact: Are there such "loophole" cases right now or is it a theoretical problem, that could be happen if 2015-01 would not be accepted? Regards, Carsten Von: address-policy-wg [mailto:address-policy-wg-bounces@ripe.net] Im Auftrag von Elvis Daniel Velea Gesendet: Montag, 9. März 2015 17:32 An: address-policy-wg@ripe.net Betreff: Re: [address-policy-wg] 2015-01 New Policy Proposal (Alignment ofTransfer Requirements for IPv4 Allocations) Hi everyone, I have thinking at what to answer regarding the comments on this proposal. Firstly, the /22 from the last /8 policy proposal aimed to create a method for anyone to receive at least a few (1024) IPv4 addresses by becoming a member of the RIPE NCC. Even then, the proposers had noted that anyone can open multiple LIRs and receive from the RIPE NCC more than 1024 IP addresses and asked the RIPE NCC to be vigilant. [1] What happens now is not in the spirit of that policy proposal as the /22 from the RIPE NCC does not have the two years holding period so a few found a way to make a business using this loophole. This policy proposal is just trying to add the same holding period for a transfer of the /22 as it is already for the rest of the allocations made by the RIPE NCC. While I do agree that if the RIPE NCC free pool would be depleted, the market would takeover and normalize the price, the community has decided to have IPv4 addresses available for anyone that wants to become a member of the RIPE NCC and therefore request & receive a /22. I think that a separate proposal could tackle this issue, there were some discussions last year (if I remember correctly) and some members of this community suggested the increasing the limit from /22 to /21. That may deplete the free pool faster, but it will still slowly bleed out in a few years. If we do not agree that this policy proposal is fair and needed, I predict that we will see more and more companies opening LIRs just to make use of this loophole and make a profit from selling one or more /22s from the last /8. Actually, this policy proposal may have already harmed the free pool because if it does not get approved, more people have found out of the loophole and nothing will stop them from using it, they will have the endorsement of the community to just go ahead and open multiple LIRs. I would not be surprised to see a very large ISP or (content) hosting company setting up 1.000 LIRs to get 1million IP addresses.. and if they setup 1024 LIRs in the same 'day' they may even get a /12 as a contiguous block. In that case, would you find it fair that if someone wants to use a loophole (1024 times) they can get a /12 from the RIPE NCC while others need to use the market? Considering these, Martin (and whoever else does not like this policy proposal), please let me know if you oppose to to this proposal as it is written and if you have any suggestion on what would be acceptable. regards, Elvis [1] https://www.ripe.net/ripe/policies/proposals/2010-02 "Some organisations may set up multiple LIR registrations in an effort to get more address space than proposed. The RIPE NCC must be vigilant regarding these, but the authors accept that it is hard to ensure complete compliance." -- [cid:image001.png@01D05B11.E2664830]<http://v4escrow.net> Elvis Daniel Velea Chief Executive Officer Email: elvis@V4Escrow.net<mailto:elvis@v4escrow.net> US Phone: +1 (702) 475 5914 EU Phone: +31 (0) 61458 1914 Recognised IPv4 Broker/Facilitator in: [cid:image002.png@01D05B11.E2664830][cid:image003.png@01D05B11.E2664830] This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received this email in error, please notify the sender immediately and delete the original.Any other use of this email is strictly prohibited.
Hi Carsten, not only that the loophole exists, but the RIPE NCC has even pointed it out in an RIPE Labs article (and several previous RIPE Meetings): https://labs.ripe.net/Members/wilhelm/ripe-ncc-membership-statistics-2014 I think that the more we talk about it, the more this loophole will be (ab)used. The part that was just theoretical was estimating how long it will take a company to decide that instead of going to the market, they could actually go to the RIPE NCC and get a /16 or maybe a /12 at €2.3 - €3.4 per IP (depending in which quarter you decide to do it). - this policy proposal will still not fix this issue, will just raise even more awareness.. this policy proposal is just trying to patch the transfer policy. we still need to discuss whether we want to touch the mergers and acquisitions process. regards, elvis On 10/03/15 09:13, DOI (BIT I 5) wrote:
Hi Elvis,
I agree with your proposal. I’m interested in the fact: Are there such “loophole” cases right now or is it a theoretical problem, that could be happen if 2015-01 would not be accepted?
Regards,
Carsten
*Von:*address-policy-wg [mailto:address-policy-wg-bounces@ripe.net] *Im Auftrag von *Elvis Daniel Velea *Gese**ndet:*Montag, 9. März 2015 17:32 *An:* address-policy-wg@ripe.net *Betreff:* Re: [address-policy-wg] 2015-01 New Policy Proposal (Alignment ofTransfer Requirements for IPv4 Allocations)
Hi everyone,
I have thinking at what to answer regarding the comments on this proposal.
Firstly, the /22 from the last /8 policy proposal aimed to create a method for anyone to receive at least a few (1024) IPv4 addresses by becoming a member of the RIPE NCC. Even then, the proposers had noted that anyone can open multiple LIRs and receive from the RIPE NCC more than 1024 IP addresses and asked the RIPE NCC to be vigilant. [1]
What happens now is not in the spirit of that policy proposal as the /22 from the RIPE NCC does not have the two years holding period so a few found a way to make a business using this loophole. This policy proposal is just trying to add the same holding period for a transfer of the /22 as it is already for the rest of the allocations made by the RIPE NCC.
While I do agree that if the RIPE NCC free pool would be depleted, the market would takeover and normalize the price, the community has decided to have IPv4 addresses available for anyone that wants to become a member of the RIPE NCC and therefore request & receive a /22. I think that a separate proposal could tackle this issue, there were some discussions last year (if I remember correctly) and some members of this community suggested the increasing the limit from /22 to /21. That may deplete the free pool faster, but it will still slowly bleed out in a few years.
If we do not agree that this policy proposal is fair and needed, I predict that we will see more and more companies opening LIRs just to make use of this loophole and make a profit from selling one or more /22s from the last /8. Actually, this policy proposal may have already harmed the free pool because if it does not get approved, more people have found out of the loophole and nothing will stop them from using it, they will have the endorsement of the community to just go ahead and open multiple LIRs. I would not be surprised to see a very large ISP or (content) hosting company setting up 1.000 LIRs to get 1million IP addresses.. and if they setup 1024 LIRs in the same 'day' they may even get a /12 as a contiguous block. In that case, would you find it fair that if someone wants to use a loophole (1024 times) they can get a /12 from the RIPE NCC while others need to use the market?
Considering these, Martin (and whoever else does not like this policy proposal), please let me know if you oppose to to this proposal as it is written and if you have any suggestion on what would be acceptable.
regards, Elvis
[1] https://www.ripe.net/ripe/policies/proposals/2010-02 "Some organisations may set up multiple LIR registrations in an effort to get more address space than proposed. The RIPE NCC must be vigilant regarding these, but the authors accept that it is hard to ensure complete compliance."
--
Elvis Daniel Velea
Chief Executive Officer
Email:elvis@V4Escrow.net <mailto:elvis@v4escrow.net> US Phone: +1 (702) 475 5914 EU Phone: +31 (0) 61458 1914
Recognised IPv4 Broker/Facilitator in:
This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received this email in error, please notify the sender immediately and delete the original.Any other use of this email is strictly prohibited.
-- <http://v4escrow.net> Elvis Daniel Velea Chief Executive Officer Email: elvis@V4Escrow.net <mailto:elvis@v4escrow.net> US Phone: +1 (702) 475 5914 EU Phone: +31 (0) 61458 1914 Recognised IPv4 Broker/Facilitator in: This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received this email in error, please notify the sender immediately and delete the original.Any other use of this email is strictly prohibited.
On Fri, 2015-02-20 at 20:43 +0100, Elvis Daniel Velea wrote:
hi Martin,
maybe I should have started my first e-mail to this proposal with the links of the recordings at RIPE69 in London where we have discussed the creation of this policy proposal: https://ripe69.ripe.net/archives/video/200/ https://ripe69.ripe.net/archives/video/10147/
Thanks - will watch later, and yes I and others could have found them myself of course, but the pointers to timestamps are really helpful - thanks for that. I am genuinely interested in understanding well the situation.
On 20/02/15 18:26, Martin Millnert wrote:
<snip>
When the last /22 policy was discussed and approved, the members of this community [...] I see there is enough space for even more than 10k new entrants. I have no argument against that this is what the community has decided. But you would like to change it... Please do start a separate topic if you feel like you would maybe want to come up with a proposal in that direction.
Yes, fair. Nothing more to add in this thread on that.
If you want to ask for the evidence for the 70 cases the RIPE NCC has observed, well you could ask Andrea.
I'll watch the videos first and then we'll see.
some things that I have noticed, and this is public data:
1. see the example of registries ru.ibulavkin* on one side. I think they have opened about 27 registries in a few months. They have 6 opened at this moment and I believe #23 and #25 will be closed to make room for more harvesting. ftp://ftp.ripe.net/ripe/stats/membership/alloclist.txt I think all of their /22s are merged into ru.srv2013 (as they have 24 of those /22s) which is on the same name. I could also bet that the 4 /22s they have in registries #22, #24, #26 and #27 will be merged into the big one and I am not sure that we could ever prevent that. I kinda see it as a legitimate way to getting addresses if they really use them and not stockpile.
However...
2.have a look at the transfer list and filter for QuickSoft LLC. https://www.ripe.net/lir-services/resource-management/ipv4-transfers/table-o...
How can _one_ company transfer (up until now) 12 /22s from the last /8 and 3 of them only in February 2015.
Where's the speculation in that? Seems they are just basically transferring space from RIPE /8 pool to customers of theirs. Obviously, this could be something that the community would want to stop, screwing RIPE NCC over the LIR membership fees. But I can't call it "speculation".
3. If you further verify the list of transfers and the delegated-extended files, filter for /22s from 185/8 you will even find allocations that have been made by the RIPE NCC and transferred within a week from the allocation date.
Again, since the transfers take effect so quickly, there seems to be zero speculation. The transferring party knows with very high precision that they're going to sell the space to a customer.
Buying and selling address space isn't at all necessarily "speculation". It's just reselling, right? Just like your business. I would not compare them, but I'll take this bullet for the sake of the proposal... (Gert, you said tomatoes, not bullets directed to my business :)... heh, should have expected it.
I see how your can interpret my comment as a bullet, but I'm really not against your "industry" at all (if done correctly). And you seem to be behaving well, engaging the policy process / community etc., from what I have seen here. Obviously there is a question of some in your industry sort-of abusing what could be the spirit of the final /8 rule, which in essence is that if you want a /22 from the RIPE NCC free pool, you are supposed to stay a LIR member and feed the NCC with membership fees, lowering the fees for all members since revenue surpasses expenses by too much. And that's what this is really about, right? "Speculation" is to not be certain of the outcome of what you're doing. But if you have a customer waiting list for address space, it isn't speculation, it's merely a pretty useful service optimized within the existing rules.
(I also learned on your website that your organisation is involved with making policies -- transfer policies I assume -- better. I approve of that work!) Well, not only. I/we also volunteered (along with a few other co-authors) to unify the IPv6 policies into one simple document (as also requested by the community at a few RIPE Meetings). However, that policy proposal was withdrawn after RIPE67 because the changes it proposed were too complex. https://ripe67.ripe.net/archives/video/36/
Will check later -- divide and conquer, perhaps? /M
Hi Martin, Martin Millnert wrote: [...]
This means that new entrants will have a method to at least receive a /22 from the RIPE NCC for the foreseeable future.
At the current burn-rate, 8 years.
Does you calculation anticipate the scheduled allocations that will be made to the RIPE NCC under the Global Policy for Post Exhaustion IPv4 Allocation Mechanisms by the IANA? It looks like March's allocation will deliver an extra 512 /22s. Regards, Leo
On Fri, 2015-02-20 at 23:44 +0000, Leo Vegoda wrote:
Hi Martin,
Martin Millnert wrote:
[...]
This means that new entrants will have a method to at least receive a /22 from the RIPE NCC for the foreseeable future.
At the current burn-rate, 8 years.
Does you calculation anticipate the scheduled allocations that will be made to the RIPE NCC under the Global Policy for Post Exhaustion IPv4 Allocation Mechanisms by the IANA? It looks like March's allocation will deliver an extra 512 /22s.
No, simple stupid two point average line based on the numbers Elvis mentioned. But there's been additions during that time, too, I noticed in some graph. I bet Geoff can predict it better, modulo policy and behavioural changes. /M
Hi Andy, I am not sure I understand what you oppose to. Can you please clarify your comment/opposition so that I can address it? Regards, Elvis On 19/02/15 18:53, Andy Davidson wrote:
On 11 Feb 2015, at 13:46, Marco Schmidt <mschmidt@ripe.net> wrote:
A proposed change to RIPE Document "IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region" is now available for discussion. Thanks for your sharing policy proposal idea but I think the deckchairs would look better on the other side of this mighty unsinkable ship. I therefore can’t support this proposal.
Andy
-- <http://v4escrow.net> Elvis Daniel Velea Chief Executive Officer Email: elvis@V4Escrow.net <mailto:elvis@v4escrow.net> US Phone: +1 (702) 475 5914 EU Phone: +31 (0) 61458 1914 Recognised IPv4 Broker/Facilitator in: This message is for the designated recipient only and may contain privileged, proprietary, or otherwise private information. If you have received this email in error, please notify the sender immediately and delete the original.Any other use of this email is strictly prohibited.
Hello, In my opinion - if there is such proven cases of abuse - we should do something to prevent this. At that point I vote for support/ +1 Regards, Vladislav -----Original Message----- From: address-policy-wg [mailto:address-policy-wg-bounces@ripe.net] On Behalf Of Marco Schmidt Sent: Wednesday, February 11, 2015 4:46 PM To: policy-announce@ripe.net Cc: address-policy-wg@ripe.net Subject: [address-policy-wg] 2015-01 New Policy Proposal (Alignment of Transfer Requirements for IPv4 Allocations) Dear colleagues, A proposed change to RIPE Document "IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region" is now available for discussion. You can find the full proposal at: https://www.ripe.net/ripe/policies/proposals/2015-01 We encourage you to review this proposal and send your comments to <address-policy-wg@ripe.net> before 12 March 2015. Regards Marco Schmidt Policy Development Officer RIPE NCC
participants (22)
-
Andy Davidson -
Carlos Friacas -
Dan Lüdtke -
DOI (BIT I 5) -
Elvis Daniel Velea -
Erik Bais -
George Giannousopoulos -
Gert Doering -
James Blessing -
Jim Reid -
Leo Vegoda -
Marco Schmidt -
Martin Millnert -
Mikael Abrahamsson -
Opteamax GmbH -
poty＠iiat.ru -
Radu-Adrian FEURDEAN -
Randy Bush -
Saeed Khademi -
Sander Steffann -
Sascha Luck [ml] -
Tore Anderson