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

Fernando Frediani fhfrediani at gmail.com
Fri Nov 1 12:00:25 EDT 2019


Exactly, and the main justification for this proposal to allow 
subleasing  is a total misuse of IP addressing and a try to privilege 
specific companies in detriment to all others.

I do not agree that legitimizing leasing as such increases accessibility 
to IPv4 space. Organization already have access to it by transfers. By 
allowing leasing as such prices of both leasing and transfer has the 
potential to rise significantly as organizations will prefer much more 
to sublease than to transfer which is logic to think that will increase 
pricing in general for both and which is only interesting to those who 
are involved in the transaction and not to those who are seeking for 
IPv4 space and have already access via transfers.
The point about keeping the correct registry updated is not a 
justification either because this is already a obligation. If someone is 
not doing that or is doing things in a different way is going against 
the current policies. Any organization who signed a contract when they 
became a member accepted to follow these rules and they must bound to 
them, not the other way round.
As said there is not reasons to issue addresses to anyone who will not 
be using them on a operational network other than legitimate speculation 
of IP space.

I consider the current text in NRPM as appropriate and therefore I 
oppose this proposal in full.

Regards
Fernando

On 01/11/2019 11:28, Owen DeLong 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
>>     http://openiadvisors.com <http://openiadvisors.com/>
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