[arin-ppml] Draft Policy ARIN-2021-6: Remove Circuit Requirement

[Owen DeLong]

> On Sep 21, 2021, at 10:31 , Jon Lewis <jlewis at lewis.org> wrote:
> 
> On Tue, 21 Sep 2021, William Herrin wrote:
> 
>> On Tue, Sep 21, 2021 at 8:07 AM ARIN <info at arin.net> wrote:
>>> Current ARIN policy prevents the use of leased-out addresses as evidence of utilization.
>> 
>> OPPOSE.
>> 
>> Independent use of LIR-assigned addresses in BGP should be
>> discouraged. It pollutes the BGP table by requiring disaggregation of
>> neighboring addresses which might otherwise be efficiently routable.
>> 
>> Also unclear why we should pretend that LIRs do a better job enforcing
>> ARIN policy on address registrants than ARIN itself does. A LIR
>> leasing arrangement delegates that responsibility from ARIN without,
>> to my view, any good cause.
> 
> Also apposed [and very confused].  Is this some kind of mistake or did ARIN-prop-302 [to which I am apposed], which suggested a small edit to NRPM 2.4, removing the language that suggested some connection between LIR->end user IP assignment and network services provided by the LIR, somehow morph into changes to 8.x affecting the transfer of number resources?

Section 2 defines terms.

If you change the definition of a term that section 8 depends on, it likely has policy implications for the application of section 8.

This change to section 2 would have implications for (at least) sections 4, possibly 5, 6, and 8 as currently written.

> ARIN-prop-302 seems to be an attempt to legitimize the practice of leasing IP space, which seems to me has been a grey area, at least not supported by the current definition of LIR in 2.4.

That’s exactly what it is. An attempt to recognize that leasing occurs, is normal every day practice, and treat it accordingly.

If you are opposed to this, then I suggest that someone should probably draft language that tightens up ARIN’s current tolerance of leasing as a secondary use for address after they have been used
for some primary purpose that involves connectivity.

I’ll also point out that current policy does allow for one to:
	1.	Obtain an aggregate (e.g. X.Y.0.0/16)
	2.	Announce aggregate
	3.	Lease chunks of aggregate to customers over GRE tunnels.

100% legitimate.

	4.	Allow customer to announce more specific chunk to other providers over actual circuits.
	5.	Prepend the heck out of the aggregate announcement just in case.

100% legitimate under current policy.

100% valid to justify the need for additional addresses once all addresses are used in this fashion.

When you decide your business is large enough, you are free to turn off the tunnels if you wish, the fig leaf is no longer required under current policy.

This proposal eliminates the need for the fig leaf in the first place.

> Does anyone else find it odd that "2. Definitions" defines end-user and LIR, but not ISP?  2.4 does say that LIRs are generally ISPs.  When are they not ISPs, and when they're not ISPs, what are they?

A variety of other things:
	Cloud service providers
	Datacenter providers
	Web Hosting providers
	VPS providers
	VPN Services

The term ISP is ambiguous and does not cover all cases where an organization needs to be able to issue addresses to customers and register those
reallocations and reassignments, so the term LIR came into existence.

LIR is a specific term meaning an organization that issues addresses to customers for use in their networks. Admittedly, in most cases, LIR is somewhat
synonymous with ISP in that the relationship between an LIR and its customers usually also involves the LIR providing connectivity to the customer in
some form or other. This is not always the case and current policy does not preclude the use of addresses without connectivity, but it does not allow
ARIN to count that utilization as “utilized” when considering a new application.

Again, I have no dog in this fight, personally. I don’t care whether 302 is adopted or not. It will not impact me in any way.

As such, I attempt to clarify the existing situation for people to make an informed judgment on the proposal as written.

I will say that either this policy, or one which actually prohibits leasing should move forward because the current policy situation is simply absurd,
as demonstrated above.

Owen