[arin-ppml] IP leasing policy (was: Waiting List IPv4 blocks transferred after issuance)

[Jimmy Hess]

On Wed, May 29, 2019 at 5:26 PM Scott Leibrand <scottleibrand at gmail.com> wrote:
> (New subject line for a new topic.)
> You just described a lease policy: one where leasing is not allowed.  Such a policy would
> have to exist to be enforced.  Right now there is no policy, so leasing is allowed because
> it's not prohibited.

Actually not.   ARIN's Policy does not have to contain a specific
prohibition for every form of abuse --- The PDP describes when
IP addresses can be allocated,  and any intended Usage for IP
resources that is not provided by an allocation policy should not
get past ARIN's required reviews.

An organization attempting to misrepresent to ARIN the nature of
that organization and their business, the need for IP addresses,  or
the intended use for IP addresses and then after receiving an allocation
proceeding to "leasing"  IP addresses without services would be fraud.

"We have no allocations but want a /22 of IP addresses,  b/c we intend
to open up shop and lease /24s to qualified applicants..."  should Not
and even pass muster under the current policies and required reviews
---  ISPs  should in fact be able to show through sufficient connectivity
contracts, etc, that they have procured an ISP network;   If they cannot,  then
they are not providing Internet Services,  then they are not an ISP.

> ISPs lease space to their customers all the time, bundled with IP connectivity.   [...]

No....    ISPs  provide services related to global IP connectivity and allocate
in the amount of IP addresses required for use with that ISP's services;
the IPs are not a separate thing that an ISP may offer to
others who are not current customers of their ISP business.

> Hosting companies do the same.  So do VPN providers.

Hosting companies and VPN providers with a working network and
customers to serve are ISPs;  they are in the business of providing
internet connectivity to "devices" that are owned or rented by
external customers.

>  The challenge with a "no leasing allowed" policy is differentiating ....

There is no need to differentiate.   A  re-assignment or allocation
is something that ISPs do to allow a customer use of IP addresses
necessary in order to have internet connectivity
through that ISP's services OR to allocate a range of IP addresses to
another ISP who is their customer,  After the allocating ISP
reviews and verifies their customer's  network design and
IP address justification documentation accordingly.


You can tell if an organization is an ISP,  and not "Leasing" IP addresses,
because an ISP will only allocate or assign according to justified need
respecting ARIN's required Policies and terms

regarding customers required to return IP addresses and requiring and
confirming that downstream customers adhere to required ARIN policies.
4.2.3.3 and  4.2.3.4 through 7*

"The original ISP should allow sufficient time for the renumbering process
to be completed before requiring the address space to be returned."
"ISPs must require their downstream customers to adhere to the
following criteria: ...".

A  "leasing of IPs" is a fraudulent action not authorized by the ARIN RSA which
involves a holder of number resources purporting to Rent "ownership"
to property they do not have ---

that is, a block of IP resources as if those were a piece of property that
may be retained or procured by an end user organization for speculative
purposes or "in case of possible future need some down the road"
without ever actually using or having a valid justification to receive/hold
the IP resources.


--
-JH