Hi, On Tue, Dec 07, 2021 at 02:29:15PM +0000, Erik Bais wrote:

As WG chairs we would like to see the position of the WG on the topic and what could be seen as a possible solution.

As a member of the WG, I do share the sentiment that the intent of the "IPv4 runout" policies have been "ensure that late comers to the game can have a bit of IPv4 space, to number their IPv6 translators", and not "grab some space for free, and sell it for more money elsewhere". I do not think this can be fixed on the AGM level ("one legal entity can only have one LIR account") - we've been there, in the rush to /22s, and all it does it "make people hide behind shell companies", so in the end, the address space goes out anyway, but registry quality suffers. Trying to make the NCC require even more paperwork isn't going to stop those that want to game the system, but will impact everyone else by making the NCC more annoying to deal with. My suggestion would be along the lines what was proposed on the APWG meeting already - earmark these /24s as non-transferrable, ever. Consequences: - there is no more financial incentive to "get one cheap, sell it expensive" - if you need space to run your business, this is exactly what it is there for - you can still sell your business (with the /24), you just need to keep the LIR account. But that's as with other business assets. - if you want to merge multiple LIR accounts, all having their own /24 - then you need to keep around these accounts, or return some of the /24s. - corrolary: if you use these /24s to number your IPv6 translators, then renumbering this translator into "your other /24" is actually not very hard. - corrolary2: If you use the /24s to directly number your customers, you missed the boat already (wearing my RIPE unicorn t-shirt today). Gert Doering -- NetMaster -- have you enabled IPv6 on something today...? SpaceNet AG Vorstand: Sebastian v. Bomhard, Michael Emmer Joseph-Dollinger-Bogen 14 Aufsichtsratsvors.: A. Grundner-Culemann D-80807 Muenchen HRB: 136055 (AG Muenchen) Tel: +49 (0)89/32356-444 USt-IdNr.: DE813185279

Hi,

...

On 7 Dec 2021, at 14:56, Gert Doering <gert@space.net> wrote:

My suggestion would be along the lines what was proposed on the APWG meeting already - earmark these /24s as non-transferrable, ever.

+1 WFM

+1 from me as well. This would have very little (if any) impact on the newcomers for whom this policy was created. Transfers that have already happened should not be affected of course, but we can make a policy that stops new transfers being made in the future. I would prefer to disallow any new transfers, independent of when the assignment was made, to avoid a rush on the NCC for new memberships. Cheers, Sander

Hi, On Tue, Dec 07, 2021 at 06:25:21PM +0100, denis walker wrote:

Many years ago I questioned why we ever invented a market for address space 'that no one owns' when we had a perfectly good system of allocating address space based on need and when no longer needed was returned to the RIR to be re-allocated...for free. I was told 'don't be silly, people will still sell the address space but not record the transfers in the RIPE Database'. So the quality of the registry diminishes. What is going to stop people selling these 'never to be transferred' allocations and not recording the transfer in the RIPE Database? I am sure some back door dealings can be arranged to keep the LIRs active that have the allocations registered and obfuscate the fee payments to confuse the RIPE NCC. Have companies developed some sense of morality in recent years?

If the LIR fee is still to be paid, this is commercially not very attractive - and as such, should stop the business model "open a LIR, get a /24 for <x> EUR, sell it for <5*x>" nicely. Note that we always acknowledged the need for a block of addresses to "change hands", by mergers & acquisition. Having a formal transfer policy was basically just accepting that people would hide this in a company sale otherwise. My proposal is actually to disallow transfers *including* disallowing M&A transfers on these. It MUST stay in the LIR it was requested by, and if the LIR closes, it MUST be returned. Buying a "company with the LIR" would still be possible, of course (and I do not see a way to disallow this, it's like MS trying to disallow selling used windows licenses), but "... and then transferring, and closing the LIR" would not. Gert Doering -- NetMaster -- have you enabled IPv6 on something today...? SpaceNet AG Vorstand: Sebastian v. Bomhard, Michael Emmer Joseph-Dollinger-Bogen 14 Aufsichtsratsvors.: A. Grundner-Culemann D-80807 Muenchen HRB: 136055 (AG Muenchen) Tel: +49 (0)89/32356-444 USt-IdNr.: DE813185279

Hi, On Tue, Dec 07, 2021 at 08:40:30PM +0300, Alexey Bulgakov wrote:

Hi,<div><br /></div><div>And what is Gert's role in RIPE NCC now?<br /><br />-- <br />Regards, Alex<br /><br /></div>19:31, 7 ?????????????? 2021 ??., Gert Doering <gert@space.net>:<br /><blockquote class="210e7a848e8fcb45wmi-quote"><p>Hi,<br /><br />On Tue, Dec

Somewhat hard to make out your question in this mess of top-quoted HTML ugliness. I never had a role in the NCC, and since I passed on the chairing hat, I no longer have a formal role in any of the working groups of RIPE. I continue to be a user of address resources, operator of routers that do care about routing table size, and advocate of letting IPv4 die and using IPv6 instead of bickering around deck chairs. But people seem to prefer the expensive before the unknown... Gert Doering -- NetMaster -- have you enabled IPv6 on something today...? SpaceNet AG Vorstand: Sebastian v. Bomhard, Michael Emmer 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 Tue, 7 Dec 2021 at 18:44, Sebastian-Wilhelm Graf <ripe-lists@sebastian-graf.at> wrote:

Hello!

This has the advantage of being "fair"

This depends on your definition of fairness. Let's be brutally honest here. Anyone who has set up 10, 20, 30 LIRs in the last couple of years and has received multiple /24s is intentionally circumventing the goal of the policy for financial gain. They are playing games for profit. Let's get the legal advice we need and stop these games. These are policies, not national/international laws. Policies are a set of rules for the RIPE NCC membership. Members have signed contracts agreeing to all policies and agreed changes to those policies. Nothing says a policy change cannot be retroactive. As Gert said, let's apply a policy change back to 1/1/21. If someone wants to challenge it in court...let them name and shame themselves. As a community/membership we should be willing to stand by our principles of fairness and let the RIPE NCC go to court to defend these principles. While IPv4 is still in use and essential for genuine new startup businesses, let's stand up to those who are playing these games for profit...for the good of the internet. I don't know who any of these people are with multiple LIRs. But I am sure they are all subscribed to this mailing list and will do what they can to prevent policy changes that stop them from making profits. To re quote Daniel's famous phrase at the Database BoF, "Let's stop tinkering around the edges" of these policies, jump in at the deep end and fix the problem...to stop the blatant profiteering. I am going to go one step further than Gert's proposal. Let's suspend the current policy pending a review. In other words, freeze the allocation of /24s. I am sure there is nothing in the PDP or anywhere else that allows for this. But there probably is nothing that disallows it either. Again let's have a legal review and take bold action. I am probably going to get hammered for saying all this, but sometimes we need to make bold moves and set new precedences... cheers denis co-chair DB-WG

Hi, On Tue, Dec 07, 2021 at 08:27:07PM +0000, Adrian Bolster wrote:

Whilst I agree with the vast majority of your email it is absurd to retrospectively apply a newly adopted policy. I believe this would be a very unhealthy precedent to set.

Strictly speaking, all transfer policies have been applied retroactively (at some point, transfers were made possible for all resources that had been allocated or assigned before that point). Also, we have done this when increasing the holding period for the /22s to 24 months - which, of course, people that made money of doing fast-LIRs did not like. So this has been done and can be done again. What we cannot do is retroactively disallow a transfer that has already been *done*, but deciding new policies for existing allocations and assignment is fully covered by the RIPE general service agreement. Gert Doering -- NetMaster -- have you enabled IPv6 on something today...? SpaceNet AG Vorstand: Sebastian v. Bomhard, Michael Emmer Joseph-Dollinger-Bogen 14 Aufsichtsratsvors.: A. Grundner-Culemann D-80807 Muenchen HRB: 136055 (AG Muenchen) Tel: +49 (0)89/32356-444 USt-IdNr.: DE813185279

Was the holding time of 24 months applied retrospectively to a LIR opened prior to the policy adoption? There will be no objection to applying a retrospective rule that makes no difference or only affects individuals in a positive way. However to impose post contractual limitations after contracts have been agreed and then apply them retrospectively is in my opinion very questionable. Perhaps a better use of time and efforts is to let IPv4 die it’s inevitable death; that will force other’s hands adopting IPv6 sooner rather than later. Adrian. Sent from my iPhone On 7 Dec 2021, at 21:04, Gert Doering <gert@space.net> wrote: Hi, On Tue, Dec 07, 2021 at 08:27:07PM +0000, Adrian Bolster wrote: Whilst I agree with the vast majority of your email it is absurd to retrospectively apply a newly adopted policy. I believe this would be a very unhealthy precedent to set. Strictly speaking, all transfer policies have been applied retroactively (at some point, transfers were made possible for all resources that had been allocated or assigned before that point). Also, we have done this when increasing the holding period for the /22s to 24 months - which, of course, people that made money of doing fast-LIRs did not like. So this has been done and can be done again. What we cannot do is retroactively disallow a transfer that has already been *done*, but deciding new policies for existing allocations and assignment is fully covered by the RIPE general service agreement. Gert Doering -- NetMaster -- have you enabled IPv6 on something today...? SpaceNet AG Vorstand: Sebastian v. Bomhard, Michael Emmer 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 Dec 7, 2021, at 11:53 AM, denis walker <ripedenis@gmail.com> wrote:

I am going to go one step further than Gert's proposal. Let's suspend the current policy pending a review. In other words, freeze the allocation of /24s. I am sure there is nothing in the PDP or anywhere else that allows for this. But there probably is nothing that disallows it either. Again let's have a legal review and take bold action.

I’m not going to speculate on whether or not this is warranted in this particular case - I won’t claim to have the deep understanding necessary - I will note that there is precedent for this; this course of action is functionally identical to the emergency policy that the ARIN Board Of Trustees put into place in February 2019 that suspended waiting list allocations in the region, as a direct result of the waiting list abuse discovered which seems very similar to the abuse being alleged in this thread. https://www.arin.net/vault/announcements/2019/20190207_waitlist.html <https://www.arin.net/vault/announcements/2019/20190207_waitlist.html> That said, the current RIPE waiting list policy seems very similar to the policy that ARIN put into place when reverting the suspension, except for a shorter transfer suspension window (24 months as opposed to ARIN’s 5 year restriction on waiting list resources). So it’s not clear if further policy restrictions would solve this problem, as opposed to active investigation of request patterns that appear suspicious when held up to scrutiny.

I am probably going to get hammered for saying all this, but sometimes we need to make bold moves and set new precedences...

Ideally, sufficient scrutinization of waiting list requests could result in the exposure of abusive patterns and bad actors, similar to the scrutiny that led to the discovery of the Micfo fraud. But that’s like saying that that we should have zero crime in a city because we have a police department.

cheers denis co-chair DB-WG

Thanks, -Chris

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C) IPv4 waiting list priority follows the size of existing allocations for the LIR. The lower amount of allocations, starting with zero, the higher the priority.

if the purpose of new allocations is to allow entry, why would an LIR with any existing allocation be given more? randy

That would only happen if there are zero new entrants, as an LIR with any existing allocation would have a lower priority on the waiting list.

Such a policy would not fight the initial point of discussion that there are single entities requesting multiple times, or using individual legal entities. After all, Rick's IP hoarding business A BV and Rick's IP hoarding business B BV are separate legal entities, thus in your proposal being put in front of a single entity that has two requests under the same legal entity. Such policy, I think, would only push for incorporating multiple entities for the sole purpose of pushing ahead in the queue. (e.g. just look at "Network Space Provider <no.> LTD" in the British company register). All are/were held by a single UBO. Perhaps it would make sense to record UBOs (ultimate beneficial owners), and categorize the waiting list based on the amount of IPs a UBO has already received, plus limit the amount of memberships unique UBOs can open (albeit: open, with a restriction of being unable to request scarce resources). This should include pre-2012 allocations, given we're at the last stretch. and it would be weird to hand someone holding a /21 a 'final /24' when others are in a more urgent need of holding any IPs. Of course, any new policy should only be put into effect for newly made allocations, without any retrospective effects. Regards, Rick On Wed, Dec 8, 2021 at 2:47 PM Jan Ingvoldstad <frettled@gmail.com> wrote:

On Wed, Dec 8, 2021 at 12:26 PM Randy Bush <randy@psg.com> wrote:

...

...

C) IPv4 waiting list priority follows the size of existing allocations for the LIR. The lower amount of allocations, starting with zero, the higher the priority.

if the purpose of new allocations is to allow entry, why would an LIR with any existing allocation be given more?

That would only happen if there are zero new entrants, as an LIR with any existing allocation would have a lower priority on the waiting list.

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Just register each company with different but bogus identities. CH does not check this information. Which by implication would make it hard for the NCC to check.

They already identify and take note of the director / authorized representative who does the application with the RIPE NCC. It wouldn't seem hard to keep track and put it to measure. Nothing is bullet-proof. That is something we just have to accept, and I believe is mentioned already multiple times in this thread alone. That does not mean trivial options shall simply be disqualified for that sole matter. That it isn't 100% effective, does not mean that it does not filter out at least some of the scum. If we can at least filter the most ruthless, that might just free up enough IPv4 space to keep enough supply to feed new entrants. We should not push at trying to make it as hard as possible for new entrants to join, rather push at enforcing guidelines to make sure it is not abused (at least not to a certain extent). It is unjustifiable to refuse a startup to hold 2x /24 if they can justify a use technically, when more established entities within our association hold more than a trifold of such an allocation. Please: encourage new entrepreneurship, do not crush them 'to the ground'. Also: how to deal with some in the addressing-wg chair being active in 'hoarding' allocations? It seems to me that said (co-)chair would have to recuse himself from any involvement in this matter, as it indirectly is influenced by his business in mind? After all, if said (co-)chair can make it harder for new entrants to obtain IPv4 space, that inherently means his brokering business can thrive from a lack of supply he can (in)directly cause? Regards, Rick On Wed, Dec 8, 2021 at 3:40 PM Jim Reid <jim@rfc1035.com> wrote:

...

On 8 Dec 2021, at 14:12, Rick Bakker <rick@bakker-it.eu> wrote:

(e.g. just look at "Network Space Provider <no.> LTD" in the British company register). All are/were held by a single UBO.

Companies House (the UK register of companies) says all of them were dissolved on Nov 16th - about three weeks ago. This news may have some bearing on whatever address resources were or weren’t obtained by those now dead firms.

BTW if these firms had a single ultimate beneficial owner, it would have been trivial to obscure that fact. Just register each company with different but bogus identities. CH does not check this information. Which by implication would make it hard for the NCC to check.

Colleagues Can I suggest another approach. Instead of having a multitude of policies for IPv4 (Allocation and Assignment, Transfer, Waiting List, etc), why don't we just write a new IPv4 policy? Take the relevant and necessary bits from all other policies and add in new bits and constraints. While we do this all allocations of IPv4 from the RIPE NCC should be immediately suspended. Then we have all the rules about IPv4 in one place. Lets face it, the NCC is never going to have huge amounts of IPv4 addresses to freely hand out again. But we also know IPv6 is not going to become the dominant variant for some time yet. So let's consolidate our position on IPv4. I would suggest that the free pool of IPv4 that the RIPE NCC has from time to time should only be used to allow new startups to enter the business. Transfers on these new startup blocks should not be allowed, ever. If the new startup business is merged or acquired by a company that already hold address space then the new startup block must be returned to the RIPE NCC. If all their addresses are in use a time period can be allowed for the merged company to buy more addresses and renumber before returning the new startup block. If the merging or acquiring company holds no address space then the new company can be allowed to keep the new startup block, but the no transfer rules still apply. This should apply to all blocks allocated in the last 1 (or 2?) years. Once you are in the business, if you need more addresses you go to the market (unfortunate but that is the reality of monetising IP addresses). All efforts should be made to prevent anyone bypassing the new rules. An amnesty should be declared to allow those who have cheated the system for profit in the last couple of years to return those addresses they are currently hoarding. I am interested in the comment by Chris Woodfield about the Micfo fraud https://www.wsj.com/articles/executive-pleads-guilty-in-internet-address-fra... This raises a number of thoughts in my mind. If there are any lawyers or LEA representatives following this thread I would love to hear your views on this. Firstly, if any of these organisations that have set up multiple LIRs to obtain IP addresses for profit are based or headquartered in the USA, can the US Department of Justice bring a similar case against them as the did against Micfo for defrauding the RIPE NCC in a similar way Micfo did with ARIN? Could a similar case be brought against organisations in any part of the RIPE region by the appropriate legal authorities? Obtaining IP addresses in this way for profit prevents new companies starting up in competition with those hoarding the addresses. Certainly in the EU and the UK there are anti competitive laws. Have these laws been broken? Can the appropriate legal authorities take action against these organisations? Maybe here it would be a test case to set a new legal precedence as the Micfo case was in the USA. This is a self regulating industry. That puts constraints on what the industry can do to protect itself and show itself to regulators that it operates in a fair and openly competitive way. I am certainly in favour of pushing boundaries here and taking strong action against organisations that are behaving in a way that damages the image and operation of the industry as a whole. People often say that the RIPE NCC is not the internet police. Maybe we need to call in the real police if laws have been broken... cheers denis co-chair DB-WG On Wed, 8 Dec 2021 at 16:14, Martin Stanislav <ms@uakom.sk> wrote:

On Wed, Dec 08, 2021 at 02:40:24PM +0000, Jim Reid wrote:

...

...

On 8 Dec 2021, at 14:12, Rick Bakker <rick@bakker-it.eu> wrote:

(e.g. just look at "Network Space Provider <no.> LTD" in the British company register). All are/were held by a single UBO.

BTW if these firms had a single ultimate beneficial owner, it would have been trivial to obscure that fact. Just register each company with different but bogus identities. CH does not check this information. Which by implication would make it hard for the NCC to check.

NCC is already spending resouces on "Know Your Customer" (KYC) efforts wrt due diligence for the quality of registration data and the sanctions.

I'm by no means trying to say this is an easy or exhilarating endeavour, or that it's possible to reuse such efforts early enough to save any v4 resources for the new entrants.

Martin

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You have overlooked a couple of points here Nick. On Wed, 8 Dec 2021 at 19:30, Nick Hilliard <nick@foobar.org> wrote:

denis walker wrote on 08/12/2021 17:43:

...

I would suggest that the free pool of IPv4 that the RIPE NCC has from time to time should only be used to allow new startups to enter the business. Transfers on these new startup blocks should not be allowed, ever.

What your suggestion does is acknowledge that ipv4 address space has asset value. Financial value of an asset is measured either in terms of capital value (probably non-depreciable in the case of ipv4), or as an operational cost.

When IPv6 becomes the dominant variant, the capital value of IPv4 depreciates to zero. Until then, address space you have bought on the open market, or were allocated prior to runout, does have a capital asset value. Holding any IPv4 addresses has an operational cost.

If there's no ability to transfer the objects out of the holding company, then a block of ipv4 addresses changes from a non-depreciable fixture to an operational cost for using an asset for as long as the fees are paid, i.e. a rental arrangement. Selling the holding company is straightforward.

This would only apply to these last dregs of address space used to allow fair competition. It does not 'change' to an operating cost. Holding any address space has an operating cost no matter how you received it. It doesn't 'change from' a non depreciable fixture as you did not pay for it.

In other words, what you're effectively proposing is that the RIPE NCC enters the ipv4 address rental market, and competes with existing market operators, with no real protection against address transfers.

Since it's formation the RIPE NCC has been in the address rental market. This is what it always has and continues to do. Before runout, if you wanted address space the RIPE NCC 'rented', or allocated, address space to you. The cost of the rental, or general service, agreement was the LIR fee. If you no longer needed the address space you returned it to the RIPE NCC, or rental company, and terminated your rental agreement. The RIPE NCC will not be competing with existing market operators. They can buy and sell any address space, except this tiny fragment used to allow new startups. The RIPE NCC can only rent out this last tiny fragment. cheers denis co-chair DB-WG

This may not be what you or other people intend to suggest, or want, but it is the practical outcome.

Nick

Hi, On Thu, Dec 09, 2021 at 12:26:35AM +0000, Nick Hilliard wrote:

I sympathise with what you're trying to achieve here: you want to design a policy mechanism which prioritises new entrants who need IPv4 resources so that legitimate new businesses can operate successfullt. Problem is, none of the mechanisms that have been proposed so far on apwg are going to work, or else they are likely to have unexpected and potentially serious downstream consequences.

So, if you were to decide, what would you do? Gert -- have you enabled IPv6 on something today...? SpaceNet AG Vorstand: Sebastian v. Bomhard, Michael Emmer Joseph-Dollinger-Bogen 14 Aufsichtsratsvors.: A. Grundner-Culemann D-80807 Muenchen HRB: 136055 (AG Muenchen) Tel: +49 (0)89/32356-444 USt-IdNr.: DE813185279

Hello, I would just like to chime in on this aswell, not as much as a long standing member with lots of experience of being an LIR or even an RIPE member, but rather on the complete opposite side of the spectrum. We are an VERY small ISP/MSP that have been approached by an fairly (the largest) FTTH provider in the nordics to be bundled as ISP for home consumers and MSP/ISP for companies they install fiber for during the next year or two in central sweden. This means that for us we are now under massive pressure to acquire all the resources required to start delivering this in january/February from the new datacenters in two more locations and all the links as well as the IP ranges we intend to use for CG:nat for our consumer customers. We have an /24 from prior to us becoming an member but that is entirely allocated to our WISP service and our primary hosting datacenter. We started the process of becoming an member and LIR about a week prior to the meetings (Unbeknownst to us) at that point there was zero in line for the /24 allocations and we were feeling confident that "Any day now our application will go through nd we can get an /24 almost immediatly" that is almost a month ago now and in the 5 days from that until when we could actually request an allocation as we finally became an member the queue became 150-200 ish and has only gone up since with the "Longest waiting" application going up with one day every days, and as such the queue is standing still solid. This is worrying from us because even if we are planning to use IPv6 native on everything and all clients there is sadly a massive ammount of IPv4 still needed especially as an ISP. What this means for us is that we are now being forced into becoming one of the buyers for the ranges that was intended for usecases like us but have been grabbed by organizations only intending to sell them. Causing us to pay way more for these IPadresses than we should have to really. I will be quite frank about this and say that it feel very disheartening to essentially miss the 0 day queue allocations by 5 days. end up in a one month long quque that just grows with no more allocations and on top of that it is VERY obvious that these organisations uses the members list as a "To be customers" base because about 4 hours after we became members we got mails and phonecalls from about 5 different companies stating they want to sell us IP adresses. It just feels like this is not what RIPE was intended for but obviously is being used for. I apologize if i am sounding too salty or if my mail is not according to well established RIPE etiquette, and dont get me wrong. we are VERY happy about being a new member with a single LIR and getting our own IPv6 and insight into the future of the internet, just felt that i should give the point of view of exactly one of those "Small new one lir members" that many here reffer to and exactly how our experience with this issue has been.. Regards, Mathias W CEO / Infrastructure Architect - West Digital Management AB. On Fri, Dec 10, 2021 at 4:59 AM Florian Fuessl <flo@degnet.de> wrote:

Personally, I think a mixed approach may help to decrease the pressure on the IPv4 waitlist. Actions should aim to make it unattractive for address brokers to open new LIR accounts to gain capital profit from IPv4 assets.

It should not block reasonable legal actions on mergers, acquisitions, or other changes in the business structure of LIRs.

Therefore instead of locking IPv4 resources from the IPv4 waitlist as non-transferable, it’s probably more effective to set up an inverse fee on these types of changes in the LIR business structure.

For example: - leave the existing policy blocking these actions within the first 24 months. - after 24 months a one-time fee like ( 10 {years} - $years-of-membership ) * $current-annual-LIR-service-fee has to be paid to execute mergers and acquisitions including IPv4 resources.

The gain of the policy change should be: - not to affect long time LIRs and reasonable resource usage - allow changes in the business structure of LIRs

Having to pay a painful one-time service fee after the lock period makes it a risky deal for address brokers to incorporate new LIR startups to gain cheap IPv4 resources for later sale or mergers. But it is not going to block reasonable changes in business structure.

Kind regards Florian Fuessl

...

Am 09.12.2021 um 08:56 schrieb Gert Doering <gert@space.net>:

Signierter PGP-Teil Hi,

On Thu, Dec 09, 2021 at 12:26:35AM +0000, Nick Hilliard wrote:

...

I sympathise with what you're trying to achieve here: you want to design a policy mechanism which prioritises new entrants who need IPv4 resources so that legitimate new businesses can operate successfullt. Problem is, none of the mechanisms that have been proposed so far on apwg are going to work, or else they are likely to have unexpected and potentially serious downstream consequences.

So, if you were to decide, what would you do?

Gert -- have you enabled IPv6 on something today...?

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Hi again and sorry for the delayed reply. I realize it is not an easy thing to solve. I also both feel and understand that something needs to be done due to the situation at hand. The problem is that many of the solutions i would think of may include administration overhead, but i guess i will put forward two maybe three ideas. The first and easiest but that will not satisfy everyone is the most obvious one. Only allow new members to procure from the waiting list and make the addresses nontransferable. This would in my opinion be a stop gap for a bigger solution because we cannot go ahead and block legitimate business needs for larger entities just because of newcomers like myself. However that ties into my second more realistic approach of what might be accepted but also requires some changes on the administration. How about simply having a split queue system? New members with single LIR goes to the front of the line and gets an nontransferable address. Others will according to their number of existing LIRs or ranges go to the back of the line according to their current ownership where an legitimate need for more ranges constitutes an expected revenue across said ranges and as such the bigger expectancy of acquiring larger ranges via an market otherwise said ranges are not being utilized properly (i understand the existence of non profits and edge cases but not everyone can be 100% satisfied, neither can i with this in the future) Make an buffer that is not possible to be allocated to multi LIRs/multi range holders. I am not an old member enough to have good insight to where a good buffer would be but for arguments sake i would say 100. This means that there is supposed to be 100 /24 ranges available (Could be 20 or 30 or anything RIPE agrees on) and as long as there is, the "Multi holder Queue" would be able to request ranges against motivational uses. There could even be a third queue at say 250 ranges available where all the ranges above that goes to open market against the requirement that they become used within x time and if they are to be resold they have to be resold/rented out at fair pricing. This could be 25,50 or whatever, i don't have the insight yet on how often ranges are allocated to give an accurate number and will not pretend as such either. This would guarantee that the original spirit of the /24's for newcomers idea is retained, while adopting to the wishes of the larger members as well to a degree, I fully understand that there are some really really big entities out there with big needs for IPv4 still and i don't want to block them in any way shape or form because i one day hope to be able to make use of our ranges and services to become on of the really big players, with the benefit of being such a new player that i can already today build IPv6 native and just use IPv4 for the still required things and then hopefully phase out IPv4 and return our ranges down the road. We today have as i mentioned earlier an single IPv4 /24 available for our older WISP/MSP datacenter, It was acquired from an entity called Resilans (If mentioning other entities by name is not allowed i apologize) they also helped us with the process of becoming an LIR and ripe member so we are VERY grateful to them as even tho they did charge for their time, it was a fair price and we would not be here today without them. Entities like them are in my opinion fair and could benefit from the third queue where they did price fairly against us and didnt try to gouge us like other entities that have contacted us after we became members (some asked for outrageous prices for a single /24) They also provide the ability for non members that cannot become members for some reason to acquire IPs for their business, such as it was for us back then. We didn't have any multi-homing ability which we now will with Datacenter 2 (Which is our fiber ISP location) and our L2 link between them. So we didn't even qualify until recently and we also didn't feel we could justify for our then VERY small operations being an LIR and the administration around that, there are others like us out there and for them an resell/second hand renting market of IPv4 is very beneficial We all know IPv4 is a sinking ship and we implement stop gaps such as NAT and then CGNAT to try and prolong its inevitable doom, but until that day comes i hope that my understanding of RIPE so far is accurate where you.. Us all try to make the playing field as equal as possible without hindering each others opportunities. Sorry for the mile long message but this is in my opinion one of several potential ways to do this down the road that might help in some way. I would also like to put out there the idea of presenting the number of ranges in store on the LIR waiting list graph, it would serve two purposes. It would allow small entities like us that when there is a 0 waiting line to have an understanding of how soon there might be a queue again so we can plan our potential entry as an LIR. I actually held off on us being an LIR because we had so much else to prepare and get in place for our new venture, if i would have seen the graph rapidly declining i would have tried to become one sooner and perhaps been able to grab one prior to the member days rather than come in 5 days after the waiting list shot up. The second benefit would also be to drive home the acute situation to everyone and perhaps open up for more understanding for the smaller entities out there that have to rely on this service to get IPv4 other than turning to in some cases heavily overpriced addresses. One last thing before i end this already too long rant. Thank you all so far for not only actually listening to a newcomers rant about our opinion, but also truly showing to us that you really care about our opinion and input. We cant wait to be able to bring back and contribute to this community and hopefully prove our self worthy of the time and consideration shown so far. Very warm regards, Mathias W CEO and Infrastructure Architect - West digital Management AB. On Fri, Dec 10, 2021 at 10:58 AM Sander Steffann <sander@steffann.nl> wrote:

Hi Mathias,

...

I will be quite frank about this and say that it feel very disheartening to essentially miss the 0 day queue allocations by 5 days. end up in a one month long quque that just grows with no more allocations and on top of that it is VERY obvious that these organisations uses the members list as a "To be customers" base because about 4 hours after we became members we got mails and phonecalls from about 5 different companies stating they want to sell us IP adresses.

It just feels like this is not what RIPE was intended for but obviously is being used for.

I apologize if i am sounding too salty or if my mail is not according to well established RIPE etiquette, and dont get me wrong. we are VERY happy about being a new member with a single LIR and getting our own IPv6 and insight into the future of the internet, just felt that i should give the point of view of exactly one of those "Small new one lir members" that many here reffer to and exactly how our experience with this issue has been..

Don't worry, you talk about your frustration quite politely :) And it is totally justified. This is why I think something needs to be done now. Yes, it's rearranging deckchairs on the Titanic, but some people are still trying to survive.

As a new member, what do you think about these ideas? Would it be good to make addresses untransferable? Or keep them transferable but ask the NCC to impose a one-time merger&acquisition fee? Or any other way? What would be ok for your real internet business but not for address sellers?

Cheers, Sander

Hi Guys I am doing some analysis on recent allocations using a variety of public data. I have some questions some of you may be able to help me with. -What was the policy in 2019 regarding /22 allocations? Was it a free for all? -When was the waiting list implemented? -when was the allocation size dropped to /24? -The companies/LIRs I have been looking at, I see lots of /22 allocations in 2019 and lots of /24 allocations in 2021, but nothing allocated to them in 2020. What happened last year? Maybe it is a coincidence that these random companies made no applications last year. But given the extent to which they were grabbing address space in 2019 and 2021, it seems odd they did nothing last year. cheers denis co-chair DB-WG On Mon, 13 Dec 2021 at 01:32, Nick Hilliard <nick@foobar.org> wrote:

Mathias Westerlund wrote on 12/12/2021 07:50:

...

I realize it is not an easy thing to solve. I also both feel and understand that something needs to be done due to the situation at hand.

this situation can't be solved: it can only be managed. There's a unresolvable high demand for number resources, and an unresolvable shortage of supply.

The challenge is to work out what categories of problems we can live with, and then devise policies to implement that. This is how the current policies came into existence.

In regard to creating new policies or updating current ones:

- the ultimate aim is accurate registration of resources

- there is reluctance on the part of RIRs to deregister previously allocated number resources except in cases of contractual default

- due to the high perceived value of ipv4 address resources, reclaiming addresses due to contractual default is likely to slow down in future

- the greater the difference between supply and demand, the higher the price on the open market, and the more this will hurt organisations who need ip addresses, and the more demand there will be to change the rules to something else.

- "new entrant" companies can be created simply and quickly (i.e. prioritising "new entrants" will create more avenues to abuse the registration system).

- increasing the price of registration of addresses solves some problems but creates others

- the RIR cannot make a value judgement about whose legitimate need for IP addresses is more important

- some people will try hard to cheat the system, and some will succeed

- whatever policy is implemented, it needs to be applied fairly and rigorously

- the policies and implementations need to be compliant with local and regional laws / regulations

The intersection of these constraints rules out many options for creating new policies.

Nick

...

The problem is that many of the solutions i would think of may include administration overhead, but i guess i will put forward two maybe three ideas.

The first and easiest but that will not satisfy everyone is the most obvious one. Only allow new members to procure from the waiting list and make the addresses nontransferable.

This would in my opinion be a stop gap for a bigger solution because we cannot go ahead and block legitimate business needs for larger entities just because of newcomers like myself. However that ties into my second more realistic approach of what might be accepted but also requires some changes on the administration.

How about simply having a split queue system? New members with single LIR goes to the front of the line and gets an nontransferable address. Others will according to their number of existing LIRs or ranges go to the back of the line according to their current ownership where an legitimate need for more ranges constitutes an expected revenue across said ranges and as such the bigger expectancy of acquiring larger ranges via an market otherwise said ranges are not being utilized properly (i understand the existence of non profits and edge cases but not everyone can be 100% satisfied, neither can i with this in the future) Make an buffer that is not possible to be allocated to multi LIRs/multi range holders. I am not an old member enough to have good insight to where a good buffer would be but for arguments sake i would say 100.

This means that there is supposed to be 100 /24 ranges available (Could be 20 or 30 or anything RIPE agrees on) and as long as there is, the "Multi holder Queue" would be able to request ranges against motivational uses.

There could even be a third queue at say 250 ranges available where all the ranges above that goes to open market against the requirement that they become used within x time and if they are to be resold they have to be resold/rented out at fair pricing. This could be 25,50 or whatever, i don't have the insight yet on how often ranges are allocated to give an accurate number and will not pretend as such either.

This would guarantee that the original spirit of the /24's for newcomers idea is retained, while adopting to the wishes of the larger members as well to a degree, I fully understand that there are some really really big entities out there with big needs for IPv4 still and i don't want to block them in any way shape or form because i one day hope to be able to make use of our ranges and services to become on of the really big players, with the benefit of being such a new player that i can already today build IPv6 native and just use IPv4 for the still required things and then hopefully phase out IPv4 and return our ranges down the road.

We today have as i mentioned earlier an single IPv4 /24 available for our older WISP/MSP datacenter, It was acquired from an entity called Resilans (If mentioning other entities by name is not allowed i apologize) they also helped us with the process of becoming an LIR and ripe member so we are VERY grateful to them as even tho they did charge for their time, it was a fair price and we would not be here today without them.

Entities like them are in my opinion fair and could benefit from the third queue where they did price fairly against us and didnt try to gouge us like other entities that have contacted us after we became members (some asked for outrageous prices for a single /24) They also provide the ability for non members that cannot become members for some reason to acquire IPs for their business, such as it was for us back then. We didn't have any multi-homing ability which we now will with Datacenter 2 (Which is our fiber ISP location) and our L2 link between them. So we didn't even qualify until recently and we also didn't feel we could justify for our then VERY small operations being an LIR and the administration around that, there are others like us out there and for them an resell/second hand renting market of IPv4 is very beneficial

We all know IPv4 is a sinking ship and we implement stop gaps such as NAT and then CGNAT to try and prolong its inevitable doom, but until that day comes i hope that my understanding of RIPE so far is accurate where you.. Us all try to make the playing field as equal as possible without hindering each others opportunities.

Sorry for the mile long message but this is in my opinion one of several potential ways to do this down the road that might help in some way.

I would also like to put out there the idea of presenting the number of ranges in store on the LIR waiting list graph, it would serve two purposes.

It would allow small entities like us that when there is a 0 waiting line to have an understanding of how soon there might be a queue again so we can plan our potential entry as an LIR. I actually held off on us being an LIR because we had so much else to prepare and get in place for our new venture, if i would have seen the graph rapidly declining i would have tried to become one sooner and perhaps been able to grab one prior to the member days rather than come in 5 days after the waiting list shot up.

The second benefit would also be to drive home the acute situation to everyone and perhaps open up for more understanding for the smaller entities out there that have to rely on this service to get IPv4 other than turning to in some cases heavily overpriced addresses.

One last thing before i end this already too long rant. Thank you all so far for not only actually listening to a newcomers rant about our opinion, but also truly showing to us that you really care about our opinion and input. We cant wait to be able to bring back and contribute to this community and hopefully prove our self worthy of the time and consideration shown so far.

Very warm regards, Mathias W CEO and Infrastructure Architect - West digital Management AB.

On Fri, Dec 10, 2021 at 10:58 AM Sander Steffann <sander@steffann.nl <mailto:sander@steffann.nl>> wrote:

Hi Mathias,

> I will be quite frank about this and say that it feel very disheartening to essentially miss the 0 day queue allocations by 5 days. end up in a one month long quque that just grows with no more allocations and on top of that it is VERY obvious that these organisations uses the members list as a "To be customers" base because about 4 hours after we became members we got mails and phonecalls from about 5 different companies stating they want to sell us IP adresses. > > It just feels like this is not what RIPE was intended for but obviously is being used for. > > I apologize if i am sounding too salty or if my mail is not according to well established RIPE etiquette, and dont get me wrong. we are VERY happy about being a new member with a single LIR and getting our own IPv6 and insight into the future of the internet, just felt that i should give the point of view of exactly one of those "Small new one lir members" that many here reffer to and exactly how our experience with this issue has been..

Don't worry, you talk about your frustration quite politely :) And it is totally justified. This is why I think something needs to be done now. Yes, it's rearranging deckchairs on the Titanic, but some people are still trying to survive.

As a new member, what do you think about these ideas? Would it be good to make addresses untransferable? Or keep them transferable but ask the NCC to impose a one-time merger&acquisition fee? Or any other way? What would be ok for your real internet business but not for address sellers?

Cheers, Sander

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Dear colleagues, When reading my answer from yesterday I see I could have been more precise, please see my clarification inline below. On 14/12/2021 17:47, Angela Dall'Ara wrote:

Hi Denis,

I hope the following answers your questions:

Q. What was the policy in 2019 regarding /22 allocations? Was it a free for all?

A. From 14 September 2012 to 18 September 2019, the first IPv4 allocation size was limited to a maximum of a single /22 or the equivalent for each LIR, as per ripe-509 which was implemented in January 2011: https://www.ripe.net/publications/docs/ripe-509#----use-of-last----for-pa-al...

Through this policy, only LIRs without an IPv4 allocation from the RIPE NCC could request a /22 and they had to provide their intention of making assignments from the allocation.

Clarification: Through this policy, only LIRs that did not receive an IPv4 allocation from the RIPE NCC after 14/09/2012 could request a /22 and they had to provide their intention of making assignments from the allocation.

As a side note, the requirement to hold an IPv6 allocation before requesting a /22 IPv4 allocation was removed in March 2015, as per ripe-632: https://www.ripe.net/publications/docs/ripe-632#51

Q. When was the waiting list implemented? Q. When was the allocation size dropped to /24?

A. The waiting list was introduced and the IPv4 allocation size reduced from a /22 to /24 on 19 September 2019, as per ripe-725: https://www.ripe.net/publications/docs/ripe-725#51bis

Ripe-725 was activated the moment the RIPE NCC could no longer allocate a /22 IPv4 allocation (single range or equivalent) from its IPv4 free pool. Through this policy, the requirement to make assignments from an allocation was removed and only LIRs without an IPv4 allocation could request a /24 IPv4 allocation via the waiting list.

Clarification: Through this policy, the LIR's confirmation of the intention to make assignments from an allocation was removed and only LIRs without an IPv4 allocation could request a /24 IPv4 allocation via the waiting list.

Kind regards, Angela

-- Angela Dall'Ara RIPE NCC Policy Officer

Hi Denis, ripe-725 has been published on 30 July 2019, following up on the acceptance of policy proposal 2019-02, "IPv4 Waiting List Implementation”, https://www.ripe.net/ripe/mail/archives/address-policy-wg/2019-July/012987.h... and it has been implemented on 19 September 2019. https://www.ripe.net/ripe/mail/archives/address-policy-wg/2019-September/013... This version stated - in section "5.1 Allocations made by the RIPE NCC to LIRs": "Once an equivalent of a /22 can no longer be allocated, the RIPE NCC will start allocating IPv4 resources based on a first-come-first-serve waiting list. At that point in time the contents of section 5.1 of this policy document will be automatically replaced with the contents of section 5.1bis and section 5.1bis will be deleted from this policy document." - in section "5.2 Unforeseen circumstances": "A /16 will be held in reserve for some future uses, as yet unforeseen. . . . In the event that this /16 remains unused at the time the remaining addresses covered by this policy have been distributed, it returns to the pool to be distributed as per section 5.1, and this section is to be automatically deleted from the policy document." ripe-730 has been published on 10 October 2019, following up on the acceptance of policy proposal 2019-05, "Revised IPv4 assignment policy for IXPs". https://www.ripe.net/ripe/mail/archives/address-policy-wg/2019-October/01306... ripe-733 has been published on 25 November 2019, following up on the automatic updates stated in ripe-725 (see above), as a result of the depletion of the RIPE NCC free IPv4 pool. https://www.ripe.net/ripe/mail/archives/address-policy-wg/2019-November/0131... Kind regards, Angela -- Angela Dall'Ara RIPE NCC Policy Officer On 15/12/2021 20:00, denis walker wrote:

Hi Angela

I have a question about policy ripe-725.

...

...

Q. When was the waiting list implemented? Q. When was the allocation size dropped to /24?

A. The waiting list was introduced and the IPv4 allocation size reduced from a /22 to /24 on 19 September 2019, as per ripe-725: https://www.ripe.net/publications/docs/ripe-725#51bis Are you saying section 5.1bis of ripe-725 became active as section 5.1 on 19 Sept 2019? This textual change in the policy did not take place in ripe-730, published on 20191010. But waited until ripe-733

On Wed, 15 Dec 2021 at 13:22, Angela Dall'Ara <adallara@ripe.net> wrote: published on 20191125.

cheers denis

Gert Doering wrote on 09/12/2021 07:56:

So, if you were to decide, what would you do?

the ipv4 address market is now the largest global supplier of ipv4 addresses. To put some figures on it, 11433920 addresses were transferred via the ripe ncc in 2021 so far (ripencc-transfers_latest.json), and 9696896 in 2020. alloclist.txt shows 2981 /24 allocations so far in 2021, i.e. 763136 addresses, and 1166 /24 allocations in 2020, i.e. 298496 addresses I.e. the RIPE NCC allocated only 6.25% of the total address space which changed hands in the ripe region in 2021, and ~3% in 2020. In a market situation like this, there are two ways of making an impact: 1. by being a large enough market player that decisions you make will make a significant difference to the ecosystem and 2. by changing the rules - which RIPE / the RIPE NCC has some ability to do. The RIPE NCC has historically been reluctant to interfere with past assignments, and it's unlikely that this will change. It doesn't have the market power to change the market substantially, and any rule change it makes will only affect new allocations. In other words, a policy change from APWG, if implemented by the RIPE NCC, would only potentially affect a tiny percentage of address holdership changes, and would be unlikely to make much of a difference in the overall scheme of things. In addition to this, Marco's email mentioned:

In the last 24 months, we provided 4,178 LIRs with a /24 allocation: - 2,019 allocations (48%) went to members with a single LIR account

Allocations to members with a single LIR account are unlikely to be wholesale abusers. Some of the LIRs with multiple accounts and /24s look like genuine ip address users (e.g. telcos / vpn hosting outfits / etc). But a number of them look unusual, e.g. where the first entry on a web search for their company name is their RIPE LIR ID.

So, if you were to decide, what would you do?

So, that. If I were supreme ruler of the universe, I'd get more information about these peculiar-looking allocations, then make a decision about whether it was worth either changing policy or operational practice to block or restrict allocations of this form, then model some potential options in terms of risk / outcome, and then after thinking about it for a while, I might make a decision to change policy, or executive practice, or not, depending on the overall likely outcome. Right now we don't have enough data to work with. Also, unless a fix actually fixes something, it's just busywork. Sander was right though: we're talking about rearranging the deck chairs on the Titanic, and any discussion needs to be framed in this context. Nick

On Wed, 8 Dec 2021 at 14:47, Jan Ingvoldstad <frettled@gmail.com> wrote:

On Wed, Dec 8, 2021 at 12:26 PM Randy Bush <randy@psg.com> wrote:

...

...

C) IPv4 waiting list priority follows the size of existing allocations for the LIR. The lower amount of allocations, starting with zero, the higher the priority.

if the purpose of new allocations is to allow entry, why would an LIR with any existing allocation be given more?

That would only happen if there are zero new entrants, as an LIR with any existing allocation would have a lower priority on the waiting list.

If there are no new entrants on the waiting list, the RIPE NCC should just hold on to any address space it has until there is another new entrant. I agree with Randy. The RIPE NCC should not give freely any address space to any organisation that already holds address space in ANY of it's many LIRs. If a company that already holds address space wants more they can buy it on the open market. To avoid new startup shell companies cheating the system, maybe we should go back to the needs based assessment for new startups. cheers denis

-- Jan --

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On Wed, Dec 8, 2021 at 7:41 PM Randy Bush <randy@psg.com> wrote:

...

...

...

C) IPv4 waiting list priority follows the size of existing allocations for the LIR. The lower amount of allocations, starting with zero, the higher the priority.

if the purpose of new allocations is to allow entry, why would an LIR with any existing allocation be given more?

That would only happen if there are zero new entrants, as an LIR with any existing allocation would have a lower priority on the waiting list.

i asked why, not how. imiho, the list should be for *new* entrants, period.

If there are no new entrants, why should any available netblocks be kept unavailable for entrants who request additional netblocks? Not that I think it will ever happen ... -- Jan

Hi Denis,

What is going to stop people selling these 'never to be transferred' allocations and not recording the transfer in the RIPE Database?

The fact that the LIR can’t be closed. Having to remain a member and pay the membership fee for as long as you want to use the allocation is business as usual for people who actually want to run a network, but not for people who want to sell the space and then close the LIR. Cheers, Sander

Hello, it seems to be a good idea to earmark new /24 IPv4 allocations as non-transferrable. It's simple from administrative point of view and clear policy for newcommers. - Daniel On 12/7/21 15:56, Gert Doering wrote:

Hi,

On Tue, Dec 07, 2021 at 02:29:15PM +0000, Erik Bais wrote:

...

As WG chairs we would like to see the position of the WG on the topic and what could be seen as a possible solution.

As a member of the WG, I do share the sentiment that the intent of the "IPv4 runout" policies have been "ensure that late comers to the game can have a bit of IPv4 space, to number their IPv6 translators", and not "grab some space for free, and sell it for more money elsewhere".

I do not think this can be fixed on the AGM level ("one legal entity can only have one LIR account") - we've been there, in the rush to /22s, and all it does it "make people hide behind shell companies", so in the end, the address space goes out anyway, but registry quality suffers.

Trying to make the NCC require even more paperwork isn't going to stop those that want to game the system, but will impact everyone else by making the NCC more annoying to deal with.

My suggestion would be along the lines what was proposed on the APWG meeting already - earmark these /24s as non-transferrable, ever.

Consequences:

- there is no more financial incentive to "get one cheap, sell it expensive"

- if you need space to run your business, this is exactly what it is there for - you can still sell your business (with the /24), you just need to keep the LIR account. But that's as with other business assets.

- if you want to merge multiple LIR accounts, all having their own /24 - then you need to keep around these accounts, or return some of the /24s. - corrolary: if you use these /24s to number your IPv6 translators, then renumbering this translator into "your other /24" is actually not very hard. - corrolary2: If you use the /24s to directly number your customers, you missed the boat already (wearing my RIPE unicorn t-shirt today).

Gert Doering -- NetMaster

My suggestion would be along the lines what was proposed on the APWG meeting already - earmark these /24s as non-transferrable, ever.

I don't think it is a good idea to split the IPv4 addresses into different types, transferable and non-transferrable. it puts those newcomers in a disadvantageous position compared to the older members, it is not fair and doesn't fix anything in long term. Regards, Arash On Wed, Dec 8, 2021 at 1:56 AM Gert Doering <gert@space.net> wrote:

Hi,

On Tue, Dec 07, 2021 at 02:29:15PM +0000, Erik Bais wrote:

...

As WG chairs we would like to see the position of the WG on the topic and what could be seen as a possible solution.

As a member of the WG, I do share the sentiment that the intent of the "IPv4 runout" policies have been "ensure that late comers to the game can have a bit of IPv4 space, to number their IPv6 translators", and not "grab some space for free, and sell it for more money elsewhere".

I do not think this can be fixed on the AGM level ("one legal entity can only have one LIR account") - we've been there, in the rush to /22s, and all it does it "make people hide behind shell companies", so in the end, the address space goes out anyway, but registry quality suffers.

Trying to make the NCC require even more paperwork isn't going to stop those that want to game the system, but will impact everyone else by making the NCC more annoying to deal with.

My suggestion would be along the lines what was proposed on the APWG meeting already - earmark these /24s as non-transferrable, ever.

Consequences:

- there is no more financial incentive to "get one cheap, sell it expensive"

- if you need space to run your business, this is exactly what it is there for - you can still sell your business (with the /24), you just need to keep the LIR account. But that's as with other business assets.

- if you want to merge multiple LIR accounts, all having their own /24 - then you need to keep around these accounts, or return some of the /24s. - corrolary: if you use these /24s to number your IPv6 translators, then renumbering this translator into "your other /24" is actually not very hard. - corrolary2: If you use the /24s to directly number your customers, you missed the boat already (wearing my RIPE unicorn t-shirt today).

Gert Doering -- NetMaster -- have you enabled IPv6 on something today...?

SpaceNet AG Vorstand: Sebastian v. Bomhard, Michael Emmer Joseph-Dollinger-Bogen 14 Aufsichtsratsvors.: A. Grundner-Culemann D-80807 Muenchen HRB: 136055 (AG Muenchen) Tel: +49 (0)89/32356-444 USt-IdNr.: DE813185279 --

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Hi, On Wed, Dec 08, 2021 at 06:03:53PM +1100, Arash Naderpour wrote:

...

My suggestion would be along the lines what was proposed on the APWG meeting already - earmark these /24s as non-transferrable, ever.

I don't think it is a good idea to split the IPv4 addresses into different types, transferable and non-transferrable. it puts those newcomers in a disadvantageous position compared to the older members, it is not fair and doesn't fix anything in long term.

Actually, the point is to have something to offer to the newcomers. If we do not stop the hoarding *now*, there won't be any IPv4 left - would that be "more fair" to the newcomers? I wouldn't mind a policy that says "The RIPE NCC does no longer deal in IPv4 resources at all. Everything coming back into the RIPE NCC free pool is returned to IANA." - that would be maximally *fair* (the same amount of nothing for everybody), but I assume you wouldn't like that either. Gert Doering -- NetMaster -- have you enabled IPv6 on something today...? SpaceNet AG Vorstand: Sebastian v. Bomhard, Michael Emmer Joseph-Dollinger-Bogen 14 Aufsichtsratsvors.: A. Grundner-Culemann D-80807 Muenchen HRB: 136055 (AG Muenchen) Tel: +49 (0)89/32356-444 USt-IdNr.: DE813185279

+1 Let’s try and stop the elite formed by said old members… Also: how objective can it be said this working group is, when a prominent member himself, is part of companies that do exactly what is said to try and prevent here? Cough cough cough… Looking back at 2019, forming shell companies to obtain /22s, to merge the companies and the LIRs, only to “broker” (hint) this exact space… This smells like actively trying to put competition into disadvantage. If you wish to fight these companies, make it hard for everyone. E.g. delay every single transfer, of any prefix. Or prevent every single transfer, no matter when the prefix was first allocated. Fair it wouldn’t be, but with an elite thinking they know best, will it ever be? Op wo 8 dec. 2021 om 08:03 schreef Arash Naderpour <arash_mpc@parsun.com>

...

My suggestion would be along the lines what was proposed on the APWG meeting already - earmark these /24s as non-transferrable, ever.

I don't think it is a good idea to split the IPv4 addresses into different types, transferable and non-transferrable. it puts those newcomers in a disadvantageous position compared to the older members, it is not fair and doesn't fix anything in long term.

Regards,

Arash

On Wed, Dec 8, 2021 at 1:56 AM Gert Doering <gert@space.net> wrote:

...

Hi,

On Tue, Dec 07, 2021 at 02:29:15PM +0000, Erik Bais wrote:

...

As WG chairs we would like to see the position of the WG on the topic and what could be seen as a possible solution.

As a member of the WG, I do share the sentiment that the intent of the "IPv4 runout" policies have been "ensure that late comers to the game can have a bit of IPv4 space, to number their IPv6 translators", and not "grab some space for free, and sell it for more money elsewhere".

I do not think this can be fixed on the AGM level ("one legal entity can only have one LIR account") - we've been there, in the rush to /22s, and all it does it "make people hide behind shell companies", so in the end, the address space goes out anyway, but registry quality suffers.

Trying to make the NCC require even more paperwork isn't going to stop those that want to game the system, but will impact everyone else by making the NCC more annoying to deal with.

My suggestion would be along the lines what was proposed on the APWG meeting already - earmark these /24s as non-transferrable, ever.

Consequences:

- there is no more financial incentive to "get one cheap, sell it expensive"

- if you need space to run your business, this is exactly what it is there for - you can still sell your business (with the /24), you just need to keep the LIR account. But that's as with other business assets.

- if you want to merge multiple LIR accounts, all having their own /24 - then you need to keep around these accounts, or return some of the /24s. - corrolary: if you use these /24s to number your IPv6 translators, then renumbering this translator into "your other /24" is actually not very hard. - corrolary2: If you use the /24s to directly number your customers, you missed the boat already (wearing my RIPE unicorn t-shirt today).

Gert Doering -- NetMaster

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On Tue, Dec 7, 2021 at 3:56 PM Gert Doering <gert@space.net> wrote:

Hi,

On Tue, Dec 07, 2021 at 02:29:15PM +0000, Erik Bais wrote:

...

As WG chairs we would like to see the position of the WG on the topic and what could be seen as a possible solution.

As a member of the WG, I do share the sentiment that the intent of the "IPv4 runout" policies have been "ensure that late comers to the game can have a bit of IPv4 space, to number their IPv6 translators", and not "grab some space for free, and sell it for more money elsewhere".

I do not think this can be fixed on the AGM level ("one legal entity can only have one LIR account") - we've been there, in the rush to /22s, and all it does it "make people hide behind shell companies", so in the end, the address space goes out anyway, but registry quality suffers.

Trying to make the NCC require even more paperwork isn't going to stop those that want to game the system, but will impact everyone else by making the NCC more annoying to deal with.

My suggestion would be along the lines what was proposed on the APWG meeting already - earmark these /24s as non-transferrable, ever.

I would definitely support that, but...

Consequences:

- there is no more financial incentive to "get one cheap, sell it expensive"

- if you need space to run your business, this is exactly what it is there for - you can still sell your business (with the /24), you just need to keep the LIR account. But that's as with other business assets.

- if you want to merge multiple LIR accounts, all having their own /24 - then you need to keep around these accounts, or return some of the /24s. - corrolary: if you use these /24s to number your IPv6 translators, then renumbering this translator into "your other /24" is actually not very hard. - corrolary2: If you use the /24s to directly number your customers, you missed the boat already (wearing my RIPE unicorn t-shirt today).

If the goal of the WG is to stop some small number of LIRs abusing the system, make it non-transferrable, but really never, return to the pool. Any "if" will just change the game for those who abuse the system. Hardline only works if we make an assumption that being an LIR is more expensive than "renting" 256 v4 addresses on the market. I don't know how long this will hold on. As it was mentioned already at APWG, I think ARIN approach is more elegant, 5 years is a reasonable number these days. This could be revised to further extend the hold time if needed, rather than the membership fee. Yes, abuse will go on, but less interesting short term and at least with the prospect of proper registration. v6 stats are depressing, v4 is not going away, we are just inflating the prices and further skewing the DB accuracy. AJ Wolski

Hi,

I think that I speak for the WG, that the intent for the final /8 policy and the waitinglist policy, is to provide IPv4 (at least a small bit) to newcomers .. meaning that how it currently works and how it was >intended .. that this might not align with what the WG initially wanted.

A newcomer can still apply to get an /24 with the current policy, being in a waiting list means you need to wait (it aligns with the current policy). there was no intention to have a fast track or a definite waiting period to get the /24. If a newcomer needs IPv4 urgently they can request an existing member to transfer IP address to them, looking at transfer statistics we can see that there are many v4 transfers happening every month. Maybe better to find a way to push old members to return their free IPv4 blocks to have more free IP in the pool? This can be done by a change to the current billing method but that needs to be decided by NCC members, not the WG. Regards, Arash On Wed, Dec 8, 2021 at 1:29 AM Erik Bais <erik@bais.name> wrote:

Hi Marco,

Thank you for the detailed information of the dispersion about the current and past of the waitinglist.

To the WG:

The current workings of the IPv4 Waitinglist is specified in the IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region

https://www.ripe.net/publications/docs/ripe-733#5

Currently there is a First Come First Serve procedure for the waitinglist .. and there are no limitation to allocating v4 space to members that have been already allocated v4 space since the waitinglist started.

I think that I speak for the WG, that the intent for the final /8 policy and the waitinglist policy, is to provide IPv4 (at least a small bit) to newcomers .. meaning that how it currently works and how it was intended .. that this might not align with what the WG initially wanted.

If a change would be desired by the WG, it should go through the PDP, meaning that a policy change would be required.

As WG chairs we would like to see the position of the WG on the topic and what could be seen as a possible solution.

Regards, Erik Bais On behalf of the AP-WG Co-Chair collective.

On 07/12/2021, 10:23, "address-policy-wg on behalf of Marco Schmidt" < address-policy-wg-bounces@ripe.net on behalf of mschmidt@ripe.net> wrote:

Dear colleagues,

In the Address Policy Working Group sessions at RIPE 83, I shared our observations regarding the IPv4 waiting list policy. [1]

The intent of this policy was to provide newcomers with a minimal amount of IPv4 space for as long as possible. However, about half of these allocations went to members that received several /24 allocations via multiple LIR accounts.

As there was interest in reviewing the policy at the RIPE Meeting, I would like to provide more detail on the provision of IPv4 allocations over the last two years and the current situation with the waiting list.

In the last 24 months, we provided 4,178 LIRs with a /24 allocation: - 2,019 allocations (48%) went to members with a single LIR account - 452 allocations (11%) went to members with 2-4 LIR accounts - 298 allocations (7%) went to members with 5-9 LIR accounts and - 1,409 allocations (34%) went to members with 10 or more LIR accounts (up to 33 /24 allocations to a single member)

This trend towards allocations to multiple LIR accounts has accelerated in the past six months. Between June and November 2021, only 24% of allocations went to members with a single LIR account, while 54% went to members with 10 or more accounts.

We see the same trend with the current waiting list. At the time of writing, we can see 327 requests for a /24 allocation: - 83 (25%) are from members with a single LIR account - 42 (13%) are from members with 2-4 LIRs accounts - 45 (14%) are from members with 5-9 LIR accounts - 157 (48%) are from members with 10 or more LIR accounts

Consequently, there is a significantly longer wait time for members with a single LIR account.

Looking at the current market prices for IPv4 in comparison to our membership fees, even a wait time of several months is acceptable for organisations that plan to transfer their allocation after the end of the holding period. Conversely, the long wait time will create uncertainty for real newcomers, especially if they can’t rely on IPv6-only networks.

I hope the WG finds this information useful for further discussion. If there is consensus to change the current situation, there are several approaches available – including a review of the waiting list policy and changing ‘per LIR’ to something else. Other approaches, such as a different charging scheme or changing the concept of multiple LIRs would need to be approved by the RIPE NCC membership.

Kind regards, Marco Schmidt Assistant Manager Registry Services RIPE NCC

[1] https://ripe83.ripe.net/archives/video/642/

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Hi all, I read here long enough but usually, I do not write. Let me say just a few words. My letter is not an answer to any particular letter. It is the impression from the whole thread. I think we need to be honest with ourselves. We try to give cheaply the expensive resource. We don't have enough control to check that resource is not transferred to another recipient for money. Did you ever see that everybody follows the rules in such cases? We say that we want to give resources to newcomers almost for free but we also don't do this because of limited resources. Can you imagine a startup that just seats on the chair and wait a half of a year for the /24? (And during all this time it pays for membership without defined perspectives.) I can't. So I think there are two ways. First is selling IP addresses for their market price. I heard many times all reasons why we cannot do this. Ok. I do not try to persuade anybody to do it. I just try to be honest. The second is just to accept the [black] market of IPv4 addresses and at least try to make rules that will not cause disturbance of information in the RIPE DB (if you restrict IP transfer you just will not see this transfer in the RIPE DB but IPs will be used by another owner). BTW when we try to give IPv4 to all we slow down the IPv6 deployment. Please, do not explain to me evident things. Just be honest to yourselves. -- Taras Heichenko tasic@academ.kiev.ua

Hi Marco I have a few more questions for you so have a clearer picture of what is going on here. -How many of these 98 members have operated the first LIR account for a number of years and held a significant amount of IPv4 address space with that account? (What I am trying to understand is if any of these members were not operating at all as an LIR before setting up this series of LIR accounts simply to obtain address space they have no intention of using but is only to sell.) -Are any of these 98 organisations transfer brokers? (I am sure it does not break any confidentiality rules to identify the type of business a group of unnamed members operate.) -Are any of these 98 organisations based in the USA? -Over what time period were their other 9 or more accounts created? -How many of these 1254 /24s have been assigned or are detectably in use? -What is the most LIRs any one member holds and how many /24s has that member obtained? -How many members have 5-9 LIRs? -How many /24s have been allocated under the waiting list policy and transferred within 6 months of the end of the 2 year holding period? This should keep your analysts busy for a while :) cheers denis co-chair DB-WG btw your document https://www.ripe.net/manage-ips-and-asns/ipv4/how-waiting-list-works references an outdated version of the IPv4 policy On Thu, 9 Dec 2021 at 17:13, Marco Schmidt <mschmidt@ripe.net> wrote:

Dear Arash,

Thank you for your question.

At the moment, we see 98 members with 10 or more LIR accounts. These members have received a total of 1254 /24s under the current IPv4 waiting list policy.

I would like to note that these numbers are constantly changing. On the one hand, some members continue to open additional LIR accounts, while other members consolidate or close many LIR accounts as soon as the 24-month holding period expires. This also explains the slight difference from the previously published numbers. Several members that held 10 or more accounts when they received /24s have since reduced their number of LIRs.

I hope this answers your question.

Kind regards, Marco Schmidt Assistant Manager Registry Services RIPE NCC

On 08/12/2021 12:39, Arash Naderpour wrote:

Hi Marco,

Could you please let me know how many organizations have 10 or more LIR accounts?

Thanks,

Arash Naderpour

On Tue, Dec 7, 2021 at 8:22 PM Marco Schmidt <mschmidt@ripe.net> wrote:

...

Dear colleagues,

In the Address Policy Working Group sessions at RIPE 83, I shared our observations regarding the IPv4 waiting list policy. [1]

The intent of this policy was to provide newcomers with a minimal amount of IPv4 space for as long as possible. However, about half of these allocations went to members that received several /24 allocations via multiple LIR accounts.

As there was interest in reviewing the policy at the RIPE Meeting, I would like to provide more detail on the provision of IPv4 allocations over the last two years and the current situation with the waiting list.

In the last 24 months, we provided 4,178 LIRs with a /24 allocation: - 2,019 allocations (48%) went to members with a single LIR account - 452 allocations (11%) went to members with 2-4 LIR accounts - 298 allocations (7%) went to members with 5-9 LIR accounts and - 1,409 allocations (34%) went to members with 10 or more LIR accounts (up to 33 /24 allocations to a single member)

This trend towards allocations to multiple LIR accounts has accelerated in the past six months. Between June and November 2021, only 24% of allocations went to members with a single LIR account, while 54% went to members with 10 or more accounts.

We see the same trend with the current waiting list. At the time of writing, we can see 327 requests for a /24 allocation: - 83 (25%) are from members with a single LIR account - 42 (13%) are from members with 2-4 LIRs accounts - 45 (14%) are from members with 5-9 LIR accounts - 157 (48%) are from members with 10 or more LIR accounts

Consequently, there is a significantly longer wait time for members with a single LIR account.

Looking at the current market prices for IPv4 in comparison to our membership fees, even a wait time of several months is acceptable for organisations that plan to transfer their allocation after the end of the holding period. Conversely, the long wait time will create uncertainty for real newcomers, especially if they can’t rely on IPv6-only networks.

I hope the WG finds this information useful for further discussion. If there is consensus to change the current situation, there are several approaches available – including a review of the waiting list policy and changing ‘per LIR’ to something else. Other approaches, such as a different charging scheme or changing the concept of multiple LIRs would need to be approved by the RIPE NCC membership.

Kind regards, Marco Schmidt Assistant Manager Registry Services RIPE NCC

[1] https://ripe83.ripe.net/archives/video/642/

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On Thu, 9 Dec 2021 at 20:36, James Kennedy <jameskennedy001@gmail.com> wrote:

...

This should keep your analysts busy for a while :)

A slightly more respectful tone for the hard work performed by the RIPE NCC analysts to answer not-so-easy questions would be appreciated, Denis.

As a former RIPE NCC analyst, who has answered many such requests in the past and is well aware of the amount of work involved, speaking to other analysts, that was not in any way intended to be disrespectful James. cheers denis co-chair DB-WG

Regards, James co-chair apwg

On Thu, Dec 9, 2021 at 7:30 PM denis walker <ripedenis@gmail.com> wrote:

...

Hi Marco

I have a few more questions for you so have a clearer picture of what is going on here.

-How many of these 98 members have operated the first LIR account for a number of years and held a significant amount of IPv4 address space with that account? (What I am trying to understand is if any of these members were not operating at all as an LIR before setting up this series of LIR accounts simply to obtain address space they have no intention of using but is only to sell.)

-Are any of these 98 organisations transfer brokers? (I am sure it does not break any confidentiality rules to identify the type of business a group of unnamed members operate.)

-Are any of these 98 organisations based in the USA?

-Over what time period were their other 9 or more accounts created?

-How many of these 1254 /24s have been assigned or are detectably in use?

-What is the most LIRs any one member holds and how many /24s has that member obtained?

-How many members have 5-9 LIRs?

-How many /24s have been allocated under the waiting list policy and transferred within 6 months of the end of the 2 year holding period?

This should keep your analysts busy for a while :)

cheers denis co-chair DB-WG

btw your document https://www.ripe.net/manage-ips-and-asns/ipv4/how-waiting-list-works references an outdated version of the IPv4 policy

On Thu, 9 Dec 2021 at 17:13, Marco Schmidt <mschmidt@ripe.net> wrote:

...

Dear Arash,

Thank you for your question.

At the moment, we see 98 members with 10 or more LIR accounts. These members have received a total of 1254 /24s under the current IPv4 waiting list policy.

I would like to note that these numbers are constantly changing. On the one hand, some members continue to open additional LIR accounts, while other members consolidate or close many LIR accounts as soon as the 24-month holding period expires. This also explains the slight difference from the previously published numbers. Several members that held 10 or more accounts when they received /24s have since reduced their number of LIRs.

I hope this answers your question.

Kind regards, Marco Schmidt Assistant Manager Registry Services RIPE NCC

On 08/12/2021 12:39, Arash Naderpour wrote:

Hi Marco,

Could you please let me know how many organizations have 10 or more LIR accounts?

Thanks,

Arash Naderpour

On Tue, Dec 7, 2021 at 8:22 PM Marco Schmidt <mschmidt@ripe.net> wrote:

...

Dear colleagues,

In the Address Policy Working Group sessions at RIPE 83, I shared our observations regarding the IPv4 waiting list policy. [1]

The intent of this policy was to provide newcomers with a minimal amount of IPv4 space for as long as possible. However, about half of these allocations went to members that received several /24 allocations via multiple LIR accounts.

As there was interest in reviewing the policy at the RIPE Meeting, I would like to provide more detail on the provision of IPv4 allocations over the last two years and the current situation with the waiting list.

In the last 24 months, we provided 4,178 LIRs with a /24 allocation: - 2,019 allocations (48%) went to members with a single LIR account - 452 allocations (11%) went to members with 2-4 LIR accounts - 298 allocations (7%) went to members with 5-9 LIR accounts and - 1,409 allocations (34%) went to members with 10 or more LIR accounts (up to 33 /24 allocations to a single member)

This trend towards allocations to multiple LIR accounts has accelerated in the past six months. Between June and November 2021, only 24% of allocations went to members with a single LIR account, while 54% went to members with 10 or more accounts.

We see the same trend with the current waiting list. At the time of writing, we can see 327 requests for a /24 allocation: - 83 (25%) are from members with a single LIR account - 42 (13%) are from members with 2-4 LIRs accounts - 45 (14%) are from members with 5-9 LIR accounts - 157 (48%) are from members with 10 or more LIR accounts

Consequently, there is a significantly longer wait time for members with a single LIR account.

Looking at the current market prices for IPv4 in comparison to our membership fees, even a wait time of several months is acceptable for organisations that plan to transfer their allocation after the end of the holding period. Conversely, the long wait time will create uncertainty for real newcomers, especially if they can’t rely on IPv6-only networks.

I hope the WG finds this information useful for further discussion. If there is consensus to change the current situation, there are several approaches available – including a review of the waiting list policy and changing ‘per LIR’ to something else. Other approaches, such as a different charging scheme or changing the concept of multiple LIRs would need to be approved by the RIPE NCC membership.

Kind regards, Marco Schmidt Assistant Manager Registry Services RIPE NCC

[1] https://ripe83.ripe.net/archives/video/642/

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