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

[Mike Burns]

Hi Jimmy,

A few things are conflated with leasing in your comments below, including
fraud, speculation and justifications.
Let's forget about fraud. Fraud to obtain resources remains a transgression
with any lease policy.

Justification issues are fair game, I think they merit further discussion in
the context of a more specified policy.

For the rest of it, in the actual world the boundary between a legitimate
ISP "customer" and a lessor is blurry.
If I give you a 64kbit VPN "circuit" for router management, can I let you
advertise and route my IPv4 block under your ASN?

Regards,
Mike



-----Original Message-----
From: ARIN-PPML <arin-ppml-bounces at arin.net> On Behalf Of Jimmy Hess
Sent: Thursday, May 30, 2019 11:26 AM
To: Scott Leibrand <scottleibrand at gmail.com>
Cc: arin-ppml <arin-ppml at arin.net>
Subject: Re: [arin-ppml] IP leasing policy (was: Waiting List IPv4 blocks
transferred after issuance)

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
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