[arin-ppml] Draft Policy ARIN-2019-18: LIR/ISP Re-Assignment to Non-Connected Networks - Clarifying Language

[Owen DeLong]

The more I think about this proposal, the more disturbed I am by the following concept…

I do not think we should be building policy to facilitate the creation or expansion of “IPv4 landlords”. If an organization wishes to monetize its existing space through leasing rather than sale, I think this is a valid and perhaps even necessary service as mentioned in today’s meeting.

However, I do not want to see ARIN accepting “We’re acquiring more space in order to lease it out later” as a valid reason for approving a transfer into an organization. I think that legitimizing such transactions only creates additional incentives to distort the market.

As far as organizations which cannot afford IPv4 are concerned, I think that the general solution is a combination of IPv6 and NRPM 4.10.

Owen


> On Nov 1, 2019, at 7:28 AM, Owen DeLong <owen at delong.com> wrote:
> 
> I have trouble with both phrases.
> 
> Even if the resources are to be re-assigned to organizations or entities which do not receive connectivity from the original registrant, I see no reason to issue addresses to anyone who will not be using them on an operational network.
> 
> Owen
> 
> 
>> On Oct 31, 2019, at 3:10 PM, Scott Leibrand <scottleibrand at gmail.com <mailto:scottleibrand at gmail.com>> wrote:
>> 
>> On Thu, Oct 31, 2019 at 3:03 PM Kiran Malancharuvil <k at openiadvisors.com <mailto:k at openiadvisors.com>> wrote:
>> Dear All,
>> 
>> Prior to tomorrow's community discussion of Draft Policy ARIN-2019-18, I wanted to offer some clarification and propose some language for consideration to address questions posed on the PPML.
>> 
>> Regarding the question over the intended meaning of "non-connected networks", I will clarify that I mean this policy to refer to re-assignment to organizations and entities which do not receive connectivity from the original registrant.  
>> 
>> As such, I wanted to offer the following alternative edit to 8.5.2: 
>> 
>> 8.5.2 Operational Use
>> ARIN allocates or assigns number resources to organizations via transfer primarily for the purpose of use on an operational network, but may allocate or assign number resources to organizations for other purposes, including re-assignment to organizations and entities which do not receive connectivity from the original registrant.
>> 
>> 
>> I believe this is consistent with the intent of 2019-18, and I would support this language.
>>  
>> 
>> 
>> Alternatively, and more simply, since the sentence referencing "non-connected networks" starts with "including" and is therefore not meant to be an exclusive "other purpose", but rather illustrative, we can remove it entirely.  That option would read: 
>> 
>> 8.5.2 Operational Use
>> ARIN allocates or assigns number resources to organizations via transfer primarily for the purpose of use on an operational network, but may allocate or assign number resources to organizations for other purposes.  
>> 
>> I believe this is materially different than the text above, in that it would give ARIN permission to approve transfers for any reason whatsoever. ARIN in the past has interpreted such ambiguity in favor of allowing whatever is not expressly prohibited. As such, I don't think this language accomplishes the original intent, and would oppose it.
>> 
>> -Scott
>>  
>> *please note that the online version of the policy proposal reads "solely primarily" instead of "primarily".  This is a typo due to originally proposing the language with the word "solely" in strike-through text (solely), which did not translate.  
>> 
>> Further, I want to clarify, as the original author of the proposal, that the key intent of the policy is to acknowledge that small and medium-sized businesses have a need for IPv4 space, but often cannot afford to buy space in the current market.  Legitimizing a subleasing market increases accessibility to IPv4 space, and opens the market to business solutions to facilitate safe, trusted subleasing practices, including keeping the correct registry updated.  
>> 
>> Thanks all for the continued discussion.  
>> 
>> Best,
>> 
>> Kiran
>> -- 
>> Kiran Malancharuvil
>> Open-i Advisors      
>> p:  415 419 9138
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