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

[Scott Leibrand]

On Thu, Oct 31, 2019 at 3:03 PM Kiran Malancharuvil <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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