[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 14:18:26 EDT 2019

I don't think the problem is only the language but the main point which 
it implicates in the whole ecosystem.

I agree with Owen's point that the solution to those who cannot transfer 
is a combination of IPv6 and NRPM 4.10.
In other RIRs there are, in my view, very successful and fair policies 
for IPv4 exhaustion that only assigns a maximum of a /22 to newcomers 
and which would address this issue. Unfortunately this has not been the 
same here.
I also see the same way as Albert that in most cases leases will be 
required for abusers and those seeking for long term may just transfer 
which is available and works.

Regarding the analogy the car is a private property, while the IP space 
by contract is not (Section 7 of the RSA)

Fernando Frediani

On 01/11/2019 14:41, Scott Leibrand wrote:
> In my opinion, it makes sense to allow leasing if we require that 
> addresses only be (re-)assigned to organizations who'll be using them 
> on an operational network. I think we're looking for language 
> something like:
> *ARIN allocates or assigns number resources to organizations via 
> transfer for the purpose of use on an operational network. 
> Organizations receiving number resources via transfer may reallocate 
> or reassign number resources to organizations that do not receive 
> connectivity from the registrant for use on another operational network.
> *
> Further arguments inline below.
> On Fri, Nov 1, 2019 at 9:19 AM <hostmaster at uneedus.com 
> <mailto:hostmaster at uneedus.com>> wrote:
>     I also agree with what has been said, and am also opposed to the
>     proposal.
>     Some of the justification seems to be in the form of "I cannot
>     afford to
>     buy a car, so I demand that someone permit me to lease one". 
>     Noone is
>     going to get into the car leasing business unless they can make
>     money.
>     Generally the only money making segment is going to be the short
>     term,
>     since the lessors profit is going to make buying cheaper than
>     leasing in
>     the longer term.  I think the same applies to IP leasing.
>     In the case of IP address leasing, the only major users of short term
>     leases are abusers.  The advancers of this proposal talk of longer
>     term
>     leases to get discussion away from those abusers.  However, most
>     of the
>     time, someone wanting a long term lease would be better off to
>     buy, as
>     they can always sell them on again at the end of the need and often
>     recover nearly all of their original investment, effectively having a
>     short term use of the address space nearly free.
> Nope, transferring purchased addresses and then re-transferring them 
> after < 12 months is disallowed by current rules (with the goal of 
> preventing speculation).
> To extend your analogy, we currently disallow anyone from selling a 
> car they've owned for less than a year. Some people would really like 
> to rent a car for a shorter duration, so they do so. But the DMV has 
> rules requiring you to make regular use of your current cars before 
> you can buy an additional one, and doesn't consider short-term rental 
> to be a legitimate use, so they won't issue license plates for 
> companies that rent out most of their cars and want to obtain more 
> cars to also rent out.
> -Scott
>       I think the long term
>     IP leasing business model will not work.
>     The only valid leasing I can see is an entity that has excess address
>     space that they expect to use in the future, and I think that case is
>     already addressed in the current rules. They would also be
>     unlikely to
>     lease to someone that is an abuser, since they will have to live
>     with the
>     block reputation after the lease ends.
>     Albert Erdmann
>     Network Administrator
>     Paradise On Line Inc.
>     On Fri, 1 Nov 2019, Fernando Frediani wrote:
>     >
>     > 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
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